I consider universal waste management a win-win.  It protects the environmental without the more involved requirements associated with other hazardous wastes and promotes recycling.  Subsequently, the relative simplicity of these wastes usually makes them a secondary concern for most environmental compliance programs. 

 

However, this leaves it as low-hanging fruit when thinking about compliance.  In this article we’ll cover a short refresher on this topic and some straightforward tips to help keep your site’s program in compliance.

 

Universal Waste Identification

 

As with any environmental regulation, you must assess whether the rules apply to your site operations.  Only certain hazardous wastes can be managed as universal wastes.  The current federal program covers, the following items:

• Batteries, such as nickel-cadmium;
• Pesticides;
• Mercury-containing Equipment; and,
• Lamps, like fluorescent and neon. 

 

There is currently a proposal to add aerosol cans to the federal program.  You can read more about the proposal here.

 

Depending on your state, other wastes may be eligible for management as under the universal program, such as:

• Aerosol Cans;
• Antifreeze;
• Ballasts;
• Barometers;
• Cathode Ray Tubes (CRTs);
• Electronics;
• Oil-based Finishes;
• Paint and Paint-related Wastes; and,
• Hazardous Waste Pharmaceuticals.

 

LQHUW vs. SQHUW

 

Regulations name two categories of handlers, Small Quantity Handlers of Universal Waste (SQHUW) and Large Quantity Handlers of Universal Waste (LQHUW).  SQHUW have less than 11,000 pounds (5,000 kg) stored on site at any time.  Also, handlers in this category are not required to obtain an EPA identification number. 

 

Alternately, LQHUW have 11,000 pounds (5,000 kg) or greater of universal waste stored at their facility at any given time and must acquire an EPA identification number.  Under this category there is no maximum quantity limit on the amount of universal waste accumulation.  However, LQHUW must keep shipment records of these wastes sent to offsite facilities.

 

The Basics – Universal Waste Management 101

 

The general requirements for universal waste management are similar for both SQHUW and LQHUW.  The storage time limit is one (1) year for both handler categories.  In addition, storage conditions must meet the following requirements:

• Accumulation containers must be sturdy, compatible with the waste they hold, and remain closed during storage, except when actively adding wastes to the container.

 

• The containers must be labelled to show the type of universal waste being stored, i.e. Waste – Batteries or Universal Waste – Lamps.

 

• A practice must be in place to document the length of accumulation time for the universal waste.

 

Furthermore, employee training is required for those workers handling and managing this type of waste at your site.  Basic safe handling, storage requirements, and any other job-specific responsibilities should be included in the training program.

 

Practical Tips to Maintain Compliance

 

• Accumulate the waste based on calendar years. Start new accumulation containers on January 1^st and dispose of any containers holding waste on or before December 31^st of each year.

 

• Mark each accumulation container with the date universal waste was first placed in the container to document accumulation time.

 

• Incorporate required employee training into other required environmental training, such as stormwater or spill prevention.

 

• Include the program in regular site inspections/spot checks.

 

• Keep any required shipping records in an organized manner and designated location.

 

Additional Related Articles for You to Enjoy

 

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Waste and Hazardous Waste Management Tips for Tackling Risk in Your Small Business

 

Parting Words

 

Universal waste is quite easy to manage but still needs attention in order to avoid noncompliance.  Using the information contained in this post, you’ll have a good blueprint to ensure proper management at your facility.  For more information, visit the EPA’s Universal Waste page.  Moreover, you will find the standards governing the program at 40 CFR 273.

 

Prorsa Consulting is available to assist you with your EHS compliance, analysis, and management system needs.  Check out our Services page for more information.

 

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