1. Hazardous Waste Section
Universal Waste

2. Management Standards For
Universal Waste

3. Universal Waste Waste Batteries Waste Pesticides
Waste Mercury - Containing Devices
Waste Lamps
Waste Pharmaceuticals

4. 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

5. Universal Waste
Note: If managed as UW, waste does not count towards HW generator status
Four unbroken lamps = 1Kg (per FAC)
DEP Notification Requirements
only required for LQHs

6. 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.

7. 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.

8. Universal Waste SQHs – 40 CFR 273.15 (a - c)
LQHs – 40 CFR (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

9. Universal Waste SQHs – 40 CFR 273.17 (a and b)
LQHs – 40 CFR (a and b)
Response to releases:
Immediately contain releases
Perform a hazardous waste determination on residues from releases and properly manage residues

10. Universal Waste SQHs – 40 CFR 273.18 (a - h)
LQHs – 40 CFR (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

11. Universal Waste SQHs – 40 CFR 273.18 (a - h)
LQHs - 40 CFR (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

12. 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.

13. 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

14. Universal Waste Batteries

15. 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 (a)(2))

16. Universal Waste Batteries SQH/LQH Requirements

17. Universal Waste Batteries
SQHs – 40 CFR (a)
LQHs – 40 CFR (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

18. Universal Waste Batteries
SQHs – 40 CFR (a)
LQHs – 40 CFR (a)
Clearly labeled:
“Universal Waste – Battery(ies)”
“Waste Battery(ies)”
“Used Battery(ies)”

19. DOT Transport Concerns
All Batteries are subject to requirements in HMR (49 CFR )
Chemical or other materials contained in battery
Electrical potential of the battery

20. 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

22. Universal Waste Batteries SQH Improper Management

23. Universal Waste Batteries SQH Proper Management

24. UW pesticides

25. Universal Waste Mercury – Containing Equipment

26. Universal Waste Mercury – Containing Equipment

27. 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

28. Universal Waste Mercury – Containing Equipment
SQHs – 40 CFR (c)
LQHs – 40 CFR (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

29. 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

30. 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

31. Universal Waste Mercury – Containing Equipment
SQH Improper Management

32. Universal Waste Mercury – Containing Equipment
SQHs – 40 CFR (d)(1)
LQHS – 40 CFR (d)(1)
Clearly labeled:
“Universal Waste – Mercury - Containing Equipment”
“Waste Mercury - Containing Equipment”
“Used Mercury - Containing Equipment”
SQHs – 40 CFR (d)(2)
LQHs – 40 CFR (d)(2)
“Universal Waste – Mercury Thermostat(s)”
“Waste Mercury Thermostat(s)”
“Used Mercury Thermostat(s)”

33. Universal Waste Lamps

34. Universal Waste Lamps Requirements
SQHs – 40 CFR (d)
LQHs – 40 CFR (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

35. 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)”

36. Universal Waste Lamps – Improper Management

37. Universal Waste Lamps – Improper Management

38. Universal Waste Lamps – Proper Management

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

40. Universal Waste Lamps
Improper Response
Broken bulbs in trash

41. Universal Waste Lamps
Improper Response
Broken glass on floor

42. Universal Waste Lamps Bulb Crushers

43. 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)

44. Universal Waste Lamps Bulb Crushers

45. Universal Waste Lamps – Improper Management

46. Universal Waste Lamps – Improper Management

47. Universal Waste Pharmaceuticals

48. UPW
SQH of Universal Pharmaceutical Waste no longer need to notify

49. Questions?