University of Notre Dame Risk Management and Safety Department Universal Waste Training

Universal Waste Definition Universal waste is a subgroup of hazardous waste. The EPA termed it universal waste because it is “universal” to all work environments. Universal waste is: generated in a wide variety of settings, not solely industrial generated by a vast community present in significant volumes in nonhazardous management systems There are four types of universal waste

Types of Universal Waste Lamps Ex: fluorescent, high intensity discharge, neon, mercury vapor, high pressure sodium, metal halide lamps, etc. Batteries Ex: sealed lead acid, nickel‐cadmium, lithium ion, mercuric oxide, silver oxide, and other alkaline batteries Mercury Containing Equipment Ex: thermometers, manometers, barometers, relay switches, mercury reg. meters, pressure gauges, sprinkler system contacts Pesticides Unused/cancelled pesticides subject to voluntary recall under section 19(b) of FIFRA (Federal Insecticide, Fungicide, and Rodenticide Act).

Regulations Universal waste is regulated both federally and by the state. Federal Regulation: 40 CFR part 273 Indiana Regulation: 329 IAC 3.1-16

Regulated Groups Small Quantity Handler of Universal Waste* Large Quantity Handler of Universal Waste Transporters of Universal Waste Destination Facilities *Notre Dame is a Small Quantity Handler of Waste

Accumulating Universal Waste Any place where universal waste is collected is considered to be an accumulation site, regardless of the quantity of waste, while the universal waste is held there.

Accumulation Time Limit A small quantity handler of universal waste may accumulate universal waste for no longer than one year from the date the universal waste is generated, or received from another handler You must be able to demonstrate the length of time that the universal waste has been accumulated from the date it becomes a waste or is received. This can be done by: Labeling the universal waste container with the date universal waste was put in the container Marking or labeling each individual item of universal waste Making an on-site inventory system

Small Quantity vs. Large Quantity Handler Small Quantity Handler of Universal Waste < 5000 kg or 11, 000 lbs accumulated at any time Store and label universal waste in containers or packages that are structurally sound, compatible and adequate to prevent breakage Store waste for no more than 1 year from start of accumulation Inform employees about universal waste Large Quantity Handler of Universal Waste >5000 kg or 11, 000 lbs accumulated at any time Store and label universal waste in containers or packages that are structurally sound, compatible and adequate to prevent breakage Store waste for no more than 1 year from start of accumulation Train employees about universal waste & emergencies Keep shipping records for 3 years (required) Register as LQHUW and obtain EPA ID #

Universal Waste: Lamps Lamps must be placed in containers or packages that are structurally sound, adequate to prevent breakage, and compatible with the contents of the lamps. Containers must be labeled with a universal waste label and the accumulation start date Containers and packages must remain closed unless adding or removing lamps and must lack evidence of leakage or damage that could cause leakage under reasonably foreseeable conditions If a lamp breaks, it is now considered hazardous waste rather than universal waste and must be dealt with accordingly It is recommended that you do not tear the flaps off of the lamp containers and tape the flaps closed when lamps are not being added to the container When container is full, contact Maintenance to pick it up for recycling

Lamps at Notre Dame At Notre Dame, when lamps are changed by Maintenance they are taken to the storage area in Maintenance (100 Maintenance Center) and kept until the current lamp disposal contractor is contacted for pickup. If lamps are accumulated elsewhere on campus, these can be moved to Maintenance. Athletics will collect and store their own universal waste lamps

Universal Waste: Batteries It is recommended that universal waste batteries be stored in an approved plastic container with the proper universal waste label affixed and filled-out with the date of the start of accumulation Batteries may be stored individually, but each individual battery must have a universal waste label Cover positive and negative terminals (electricians tape or a similar material works well) prior to placing in the container If a battery shows evidence of damage or leakage, it is considered a hazardous waste and must be dealt with accordingly When container is full, contact Recycling to pick it up

Batteries at Notre Dame Battery containers must be closed as stated in the following EPA regulations: “A small quantity of handler of universal waste must contain any universal waste battery that shows evidence of leakage, spillage, or damage that could cause leakage under reasonably foreseeable conditions in a container. The container must be closed, structurally sound, compatible with the contents of the battery, and must lack evidence of leakage, spillage, or damage that could cause leakage under reasonable foreseeable conditions.” At Notre Dame, batteries are collected by Recycling. This includes batteries that are collected in the battery buckets. They are stored in the Mason Services Building (100 Mason Services Building). Recycling properly stores the batteries until they are picked up by the current battery disposal contractor. Car batteries are stored by Transportation where they are kept until they are exchanged or properly disposed of.

Universal Waste: Pesticides Must be stored in a container that remains closed, structurally sound, compatible with the pesticide, and that lacks evidence of leakage, spillage, or damage that could cause leakage under reasonably foreseeable conditions The container must be labeled with a universal waste label, the name of the pesticide product, and the date of the start of accumulation.

Pesticides at Notre Dame Currently all pesticides at Notre Dame are used completely, and are therefore not disposed of via universal waste methods.

Mercury containing equipment Universal Waste: Mercury containing equipment Mercury containing equipment must be managed in a way that prevents releases of any universal waste or component of a universal waste Mercury containing equipment should be properly labeled with a universal waste label and dated with the accumulation start date Risk Management and Safety should be contacted to pick up any mercury containing equipment

Mercury Containing Equipment at Notre Dame If mercury containing equipment is to be collected or mercury is spilled, Risk Management and Safety should be called.

Waste Labeling Requirements Label must identify the type of universal waste (Ex: Universal waste-lamps or waste-lamps) The container that holds the universal waste must be labeled/marked with: The label that was on or accompanied the product as sold or distributed The words “Universal Waste-(type)(s)” or “Waste-(type)(s) The date the waste was first accumulated in the container

Label Example

Response to Release A small quantity handler of universal waste must immediately contain all releases of universal wastes and other residues from universal wastes. A small quantity handler of universal waste must determine whether any material resulting from the release is hazardous waste, and if so, must manage the hazardous waste in compliance with all applicable requirements of 40 CFR parts 260 through 272. The handler is considered the generator of the material resulting from the release, and must manage it in compliance with 40 CFR part 262.

Cleaning Up Broken Fluorescent Bulb 1. Open a window and leave the room for 15 minutes or more. 2. Carefully scoop up the fragments and powder with stiff paper or cardboard and place them in a sealed plastic bag. Use disposable rubber gloves, if available (i.e., do not use bare hands). Wipe the area clean with damp paper towels or disposable wet wipes and place them in the plastic bag. Do not use a vacuum or broom to clean up the broken bulb on hard surfaces. 3. Place bag in a box to prevent leakage or puncturing of the bag 4.Transfer plastic bag to a broken lamp storage box 5. Wash your hands after disposing of the bag. 6. Contact Risk Management for hazardous waste removal

Fluorescent Bulbs (Continued) If a fluorescent bulb breaks on a rug or carpet: 1. Use procedure above to scoop up fragments and power, use duct tape to pick up small fragments. 2. If vacuuming is needed after all visible materials are removed, vacuum the area where the bulb was broken, remove the vacuum bag (or empty and wipe the canister) and put the bag or vacuum debris into a sealed plastic bag. 3. Place bag in a box to prevent leakage or puncturing of the bag 4.Transfer plastic bag to a broken lamp storage box 5. Wash your hands after disposing of the bag. 6. Contact Risk Management for hazardous waste removal

Shipping Must use a qualified Universal Waste Transporter for transportation of Universal Wastes A small quantity handler of universal waste is prohibited from sending or taking universal waste to a place other than another universal waste handler, a destination facility, or a foreign destination.  If a universal waste being offered for off-site transportation meets the definition of hazardous materials under 49 CFR parts 171 through 180, a small quantity handler of universal waste must package, label, mark and placard the shipment, and prepare the proper shipping papers in accordance with the applicable Department of Transportation regulations under 49 CFR parts 172 through 180

Training § 273.16: A small quantity handler of universal waste must train all employees who handle or have responsibility for managing universal waste. The training must describe proper handling and emergency procedures appropriate to the type(s) of universal waste handled at the facility. § 273.36: A large quantity handler of universal waste must ensure that all employees are thoroughly familiar with proper waste handling and emergency procedures, relative to their responsibilities during normal facility operations and emergencies.

Contact Information Contact Maintenance for lamp pickup Phone: 574-631-7701 Email: ndmaint@nd.edu Contact Recycling for battery pickup Phone: 574-631-7026 Fax: 574-631-0630 E-mail: ihogan1@nd.edu Contact Risk Management and Safety for mercury containing equipment and pesticide pickup. Contact for florescent bulb breaks and mercury spills Phone (574) 631-5037