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Hazardous Waste Section. Universal Waste. Management Standards For . Universal Waste . Universal Waste . Waste Batteries Waste Pesticides Waste Mercury - Containing Devices Waste Lamps Waste Pharmaceuticals. Universal Waste (UW) Handlers. Small Quantity Handler (SQHs)

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Hazardous Waste Section


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Management Standards

For

Universal Waste

universal waste
Universal Waste
  • Waste Batteries
  • Waste Pesticides
  • Waste Mercury - Containing Devices
  • Waste Lamps
  • Waste Pharmaceuticals
universal waste uw handlers
Universal Waste (UW) Handlers
  • Small Quantity Handler (SQHs)
    • Does not accumulate 5,000 kilograms or more of universal waste (batteries, pesticides, mercury-containing equipment or lamps, or pharmaceuticals) at any time
  • Large Quantity Handlers (LQHs)
    • Accumulates 5,000 kilograms or more of total universal waste (batteries, pesticides, mercury-containing equipment or lamps, or pharmaceuticals) at any time
    • Accumulates UPW consisting of > 1 Kg total of pharmaceuticals listed as acute hazardous waste (P-listed)
    • This designation is retained through the end of the calendar year
universal waste1
Universal Waste
  • Note: If managed as UW, waste does not count towards HW generator status
  • Four unbroken lamps = 1Kg (per 62-737 FAC)
  • DEP Notification Requirements
    • only required for LQHs
universal waste2
Universal Waste
  • SQHs – 40 CFR 273.16
    • Personnel Training:
      • A SQH must inform all employees who handle or have responsibility for managing UW. The information must describe proper handling and emergency procedures.
universal waste3
Universal Waste
  • LQHs – 40 CFR 273.36

Personnel Training:

A LQH must ensure all employees are thoroughly familiar with proper handling and emergency procedures, relative to their responsibilities during normal facility operations.

universal waste4
Universal Waste
  • SQHs – 40 CFR 273.15 (a - c)
  • LQHs – 40 CFR 273.35 (a - c)

Accumulation Time Limits:

      • One Year
      • Longer than one year (if solely for purpose of accumulation and other requirements are met)
      • Accumulation Start Date, Inventory system or other method
universal waste5
Universal Waste
  • SQHs – 40 CFR 273.17 (a and b)
  • LQHs – 40 CFR 273.37 (a and b)

Response to releases:

      • Immediately contain releases
      • Perform a hazardous waste determination on residues from releases and properly manage residues
universal waste6
Universal Waste
  • SQHs – 40 CFR 273.18 (a - h)
  • LQHs – 40 CFR 273.38 (a - h)
    • Off-Site Shipments:
      • Send UW only to a UW handler, destination facility, or foreign destination
      • May self-transport if complying with transporter requirements in subpart D
      • Comply with DOT requirements if UW is a hazmat
      • Before shipment, ensure that it will be received
universal waste7
Universal Waste
  • SQHs – 40 CFR 273.18 (a - h)
  • LQHs - 40 CFR 273.38 (a - h)
    • Off-Site Shipments (continued):
      • If shipment is rejected, receive it back or ship to another destination facility
      • If rejecting a shipment, contact originating handler, ship to originating handler or to another destination facility
      • If shipment received is hazardous waste and not UW, notify EPA/DEP
      • If shipment received is non-hazardous, but not UW, the waste may be managed appropriately
universal waste8
Universal Waste
  • SQHs – 40 CFR 273.19 – Tracking UW Shipments:
    • A SQH is not required to keep records of shipments, however you should be able to demonstrate proper recycling during an inspection.
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Universal Waste
  • LQHs – 40 CFR 273.39 – Tracking UW Shipments:
    • UW Shipped:
      • Keep records – logs, invoices, manifests, bills of lading or other shipping documents
        • Name and address where UW shipped
        • Quantity of each type shipped
        • Date of shipment
    • Records retained for three years
universal waste batteries1
Universal Waste Batteries
  • Spent lead acid not managed under 40 CFR 266 subpart G
  • Hazardous waste batteries (those that exhibit a characteristic)
  • Becomes waste on the date the handler decides to discard it (see definition of discarded material 261.2(a)(2))
universal waste batteries2
Universal Waste Batteries
  • SQHs – 40 CFR 273.13 (a)
  • LQHs – 40 CFR 273.33(a)
  • Managed in a way to prevent releases
    • Must contain leaking batteries
    • Container must be closed, structurally sound, and compatible
    • Container must lack evidence of leakage, spillage or damage
universal waste batteries3
Universal Waste Batteries
  • SQHs – 40 CFR 273.14(a)
  • LQHs – 40 CFR 273.33(a)
    • Clearly labeled:
      • “Universal Waste – Battery(ies)”
      • “Waste Battery(ies)”
      • “Used Battery(ies)”
dot transport concerns
DOT Transport Concerns
  • All Batteries are subject to requirements in HMR (49 CFR 171-180)
    • Chemical or other materials contained in battery
    • Electrical potential of the battery
dot transport concerns1
DOT Transport Concerns
  • Common violations & safety concerns
    • Used batteries collected in large containers that do not adequately prevent damage or releases during transport
    • Outer packages/shipping documents not marked and/or labeled as required
    • No action is being taken to prevent a short circuit, such as separating the batteries or taping
universal waste mercury containing equipment2
Universal Waste Mercury – Containing Equipment
  • Device or part of a device that contains elemental mercury integral to its function
  • Excludes waste that is non-hazardous
  • Excludes equipment or devices where mercury-containing components have been removed
  • Becomes waste on the date the handler decides to discard it
universal waste mercury containing equipment3
Universal Waste Mercury – Containing Equipment
  • SQHs – 40 CFR 273.13 (c)
  • LQHs – 40 CFR 273.33 (c)
    • Managed in a way to prevent releases
      • Contain leaking equipment in containers that are:
        • Closed
        • Structurally sound
        • Compatible with contents
        • Lack evidence of leakage
        • Designed to prevent escape of mercury
universal waste mercury containing equipment4
Universal Waste Mercury – Containing Equipment
  • Ampules may be removed from equipment, provided that:
    • They are removed and managed in a proper manner
    • They are removed over or in a container
    • There is a mercury clean-up system in place
    • Spills are managed properly
    • It is ensured the area is well ventilated and monitored
universal waste mercury containing equipment5
Universal Waste Mercury – Containing Equipment
  • Ampules may be removed from equipment, provided that:
    • Proper employee training is ensured
    • Removed ampules are stored in proper containers with adequate packing material
    • A hazardous waste determination will be performed on clean-up waste or equipment and then properly managed based upon the determination
universal waste mercury containing equipment7
Universal Waste Mercury – Containing Equipment
  • SQHs – 40 CFR 273.14 (d)(1)
  • LQHS – 40 CFR 273. 34(d)(1)
    • Clearly labeled:
      • “Universal Waste – Mercury - Containing Equipment”
      • “Waste Mercury - Containing Equipment”
      • “Used Mercury - Containing Equipment”
  • SQHs – 40 CFR 273.14 (d)(2)
  • LQHs – 40 CFR 273.34(d)(2)
    • Clearly labeled:
      • “Universal Waste – Mercury Thermostat(s)”
      • “Waste Mercury Thermostat(s)”
      • “Used Mercury Thermostat(s)”
universal waste lamps requirements
Universal Waste Lamps Requirements
  • SQHs – 40 CFR 273.13 (d)
  • LQHs – 40 CFR 273.33 (d)
    • Managed in a way to prevent releases
      • Contain lamps in containers
        • Closed
        • Not leaking
        • Structurally sound
      • Immediately clean up broken lamps and place in containers
universal waste lamps1
Universal Waste Lamps
  • SQHs – 40 CFR 273.14 (e)
  • LQHs – 40 CFR 273.34(e)
    • Clearly labeled:
      • “Universal Waste – Lamp(s)”
      • “Waste Lamp(s)”
      • “Used Lamp(s)”
universal waste lamps2
Universal Waste Lamps

Improper Response to Releases

universal waste lamps3
Universal Waste Lamps

Improper Response

universal waste lamps4
Universal Waste Lamps

Improper Response

bulb crushers
Bulb Crushers
  • 62-737.400(6)(b) FAC

A generator of universal waste lamps may use crushing equipment on site to reduce the volume of stored lamps provided:

    • The lamps are crushed in a controlled manner that prevents the release of mercury vapor
    • The crushing operations and maintenance of the unit are performed in accordance with manufacturer’s instructions (filter change outs and operator training)
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UPW
  • SQH of Universal Pharmaceutical Waste no longer need to notify