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) 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 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 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 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 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 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 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 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 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.

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 Batteries

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 Batteries SQH/LQH Requirements

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 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 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 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 Batteries SQH Improper Management

Universal Waste Batteries SQH Proper Management

UW pesticides

Universal Waste Mercury – Containing Equipment

Universal Waste Mercury – Containing Equipment

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 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 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 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 Equipment SQH Improper Management

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) “Universal Waste – Mercury Thermostat(s)” “Waste Mercury Thermostat(s)” “Used Mercury Thermostat(s)”

Universal Waste Lamps

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 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 Lamps – Improper Management

Universal Waste Lamps – Improper Management

Universal Waste Lamps – Proper Management

Universal Waste Lamps Improper Response to Releases Don’t throw away! Intact and broken bulbs in the trash

Universal Waste Lamps Improper Response Broken bulbs in trash

Universal Waste Lamps Improper Response Broken glass on floor

Universal Waste Lamps 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)

Universal Waste Lamps Bulb Crushers

Universal Waste Lamps – Improper Management

Universal Waste Lamps – Improper Management

Universal Waste Pharmaceuticals

UPW SQH of Universal Pharmaceutical Waste no longer need to notify

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