This article identifies some of the most common reasons that documentation for feature X09.1 - Implement a Waste Management Plan - is marked as pending in preliminary documentation review (WELL Certification) or round 1 (WELL at scale) reviews. This guidance does not include all possible reasons for a pending status, but provides information and context based on common review issues. 

Ensure plan coverage is complete

To meet the requirements of X09.1, your Waste Management Plan must include all six components detailed in the feature:

1. Identification of roles, responsibilities and vendors for implementing the plan.
2. Identification of the sources of waste, estimation of rates of generation and strategies to minimize waste generation.
   • You must demonstrate how you calculated the sources as well as the estimated rate of waste generation; for example, if your project has a set schedule for replacing batteries or electronic devices, use this schedule to estimate how much waste will be produced. In that case, a strategy to minimize waste generation might include using rechargeable batteries.
3. Strategies for waste collection. Each of the categorized wastes is separately contained in clearly labeled receptacles and removed from the building within one year.
4. Protocols for cleaning spills of mercury (including broken fluorescent lamp tubes), pesticides and battery electrolyte fluid, including sealed containment of residues, as applicable.
   • For requirements c and d, your policy must clearly state that these residues are separated from normal waste and explain how they are stored. For example, your policy might include the types of containers that these wastes are stored in. You should also clearly state who is responsible for cleaning these spills.
5. Protocols to track, measure and report waste stream flows.
   • For this requirement, you should provide an operations schedule detailing periodic pickups and explain how you monitor and measure this waste.
6. Protocols for off-site shipment of wastes.
   • For this requirement, your document could simply state that X company comes to your location to remove waste.

It may be helpful to format specific sections of your project’s Waste Management Plan after parts a-f in the feature, ensuring no required aspect is left out. Additionally, ensure that each component is explained in full (e.g. for part d, describe the end-to-end protocol for cleaning spills, including who is responsible, what procedures they should follow, and where/how spills will ultimately be disposed).

Parts c-f of feature X09.1 all involve the timely removal of waste from a building or project. Submissions commonly marked as pending may not fully detail what policies or schedules are in place to ensure timely removal. To prevent this, your plan should include the specific schedule for waste removal.

Provide comprehensive coverage of all waste types

The Waste Management Plan outlined in Feature X09.1 covers “all batteries, pesticides, lamps that may contain mercury, other mercury-containing equipment (including thermostats and thermometers), and electrical and electronic equipment present or expected to be present within the project during the building operations…”

When designing your Waste Management Plan, it is important to conduct a thorough review of any and all materials that may fit the above criteria. If you determine that one or more of the waste types above is not, or will not be present in your project, this must be stated in either the plan itself, or a separate narrative document. This will ensure that reviewers know your Waste Management Plan covers all specified waste types. The reviewers cannot assume that materials are or are not present unless specifically stated.

Provide project specific content

Submissions commonly marked as pending may contain policies that repeat feature language without project-specific details. To avoid this, ensure your Waste Management Plan describes specific policies and procedures that apply to the entire location of a single asset project, or all locations in a portfolio project. 

Additionally, plans should be customized, and show actual implemented strategies.