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

2. 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

3. 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).

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

5. 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

6. 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.

7. 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

8. 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 #

9. 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

10. 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

11. 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

12. 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.

13. 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.

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

15. 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

16. 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.

17. 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

18. Label Example

19. 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

20. 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

21. 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

22. 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

23. Training
§ : 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.
§ : 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.

24. Contact Information
Contact Maintenance for lamp pickup
Phone:
Contact Recycling for battery pickup
Phone:
Fax:
Contact Risk Management and Safety for mercury containing equipment and pesticide pickup. Contact for florescent bulb breaks and mercury spills
Phone (574)