Managing Universal Waste

Universal Waste Handlers
EPA ID Number and Notification
Proper Management
Labeling
Accumulation Time Limits
Training
Emergency Response
Treatment
Proper Disposal
Recordkeeping
Managing Common Universal Wastes at Veterinary Facilities

Batteries
Fluorescent Light Bulbs
Electronics
Mercury-Containing Equipment

Introduction

EPA finalized the universal waste rule on May 11, 1995 as a way of streamlining the recycling efforts of commercial and industrial groups. Under this rule, a hazardous waste generator has the option of designating certain hazardous waste as universal waste, making them subject to less stringent environmental regulations. These wastes are hazardous waste batteries, hazardous waste thermostats (such as mercury-containing thermostats), certain hazardous waste lamps, and certain hazardous waste pesticides.

States do have autonomy when it comes to the universal waste rule. They do not have to accept it, they can add or remove wastes, or they can have more stringent requirements. Thus, before you designate any hazardous waste as a universal waste, you will need to check with your state agency to see if they will allow it. Most states follow the federal rule. 

EPA has added all mercury-containing equipment, including mercury thermometers to the federal list of universal waste effective in July, 2005.

This section has been created to help healthcare facilities comply with the federal universal waste regulations found in 40 CFR 273. 

Universal Waste Handlers

The federal universal waste rule establishes two types of universal waste handlers. The small quantity handler of universal waste (SQHUW) who accumulates less than 5,000 kg of universal waste on site at any one time and the large quantity handler of universal waste (LQHUW) who accumulates 5,000 kg or more of universal waste. Veterinary facilities typically fall within the small quantity handler category. The vast majority, if not all veterinary clinics, fall into the SQHUW category. Veterinary facilities associated with large universities or research facilities may be classified as LQHUW.

Please note that once you have accumulated 5,000 kg of universal waste on site, you will remain a LQHUW for the rest of the calendar year. So if you find yourself with 5,000 kg of fluorescent light bulbs in January, even if you got rid of all of them in February and never accumulated that much again, you would still be considered a LQHUW until next January. Also keep in mind that what type of universal waste handler you are is not calculated on a month by month basis like we do for hazardous waste generation but on the total amount of universal waste accumulated at your facility at one time.

EPA ID Number and Notification

Only large quantity handlers of universal waste (LQHUW) need to obtain an EPA ID number and send a written notification to EPA that includes: 

• A statement indicating that you are now a LQHUW

• The name of your facility
• Your street and mailing addresses

• The name and phone number of the person at your facility responsible for managing your universal waste

• The types and quantities of universal waste managed at your facility

Proper Management

All handlers of universal waste, whether one fluorescent light bulb or a million fluorescent light bulbs, need to manage their universal waste  in such a way as to prevent releases of the universal waste or component of the universal waste to the environment. For example, lamps, because they can easily break, must always be kept in containers or packages that are closed, structurally sound, adequate to prevent breakage, and compatible with the contents of the lamp.

Labeling

All handlers of universal waste need to mark or label the universal waste or a container of the universal waste for the purposes of identifying the type of universal waste and to let inspectors know that you have chosen to handle these hazardous wastes as universal wastes.  An inspector will assume these wastes are hazardous wastes unless you clearly designate otherwise.  The regulations give you the following labeling options:

• Universal Waste ' Battery(ies); or Waste Battery(ies); or Used Battery(ies)
• Universal Waste-Pesticides; or Waste Pesticides
• Universal Waste- Mercury Thermostat(s); or Waste Mercury Thermostat(s), or Used Mercury Thermostat(s)
• Universal Waste-Lamp(s); or Waste lamp(s); or Used lamp(s)

Please note that you can not put a label on the wall. It must be either on the individual piece of universal waste or on the container in which the universal waste is stored.

Accumulation Time Limits

The federal universal waste regulations allow universal waste handlers to keep universal waste on site for a year. Although handlers can extend that period if they need more time to facilitate proper recovery, treatment, or disposal. For example, if your recycler will not pick up your universal waste until you reach a certain quantity, the law will allow you more than a year to accumulate that amount. You just need to show documentation to the inspector that you needed that longer period.

Given that there is a time limit on the storage of universal waste, all universal waste handlers need to be able to demonstrate the length of time the universal waste has been on-site. The regulation gives the following suggestions on how to do this but you can choose any method that works even ones not on the suggested list.

• Labeling a container of universal waste with the earliest date that any universal waste in the container became a waste
• Labeling each individual waste with the date it became a waste
• Maintaining an inventory system on-site that identifies the date each universal waste became a waste
• Maintaining an inventory on-site that identifies the earliest date that any universal waste items or a group of containers of universal waste became a waste
• Placing the universal waste in a specific accumulation area and identifying the earliest date that any universal waste in the area became a waste

Training

It should go without saying that all handlers of universal waste need to train their employees on the proper handling and emergency procedures associated with the universal waste managed at their facility. For instance, if you are storing fluorescent light bulbs, your employees should know what to do if one breaks.

Emergency Response

If there is a release of universal waste or a component of universal waste to the environment, one must immediately contain the release and then determine if any material resulting from the release (e.g. contaminated carpet, soil, personal protective equipment) is a hazardous waste and properly handle it as such.

Treatment

All universal waste handlers are prohibited from treating or diluting universal waste on site. There are some exceptions made for batteries and thermostats. For example, you are allowed to remove electrolyte from batteries and mercury containing ampules from thermostats and still handle the batteries and thermostats as universal wastes. However, there are no exceptions made for lamps. So if you have a bulb crusher on site, you cannot manage your lamps as universal waste, you must handle them as hazardous waste and comply with all applicable treatment requirements under RCRA.

Furthermore, bulb crushers need to be operated in a manner that minimizes the potential for releases.  For example, the bulb crushing operation shown in the photo 1 will not be acceptable to EPA since the ground glass from the bulbs will be strewn throughout the area and all over the equipment. On the other hand, the bulb crushing operation in photo 2 will be allowed because it contains all of the crushed glass and ensures that none of the materials from the bulb escapes into the atmosphere.

Photo 1:	Photo 2:

Proper Disposal

In regards to disposal, all universal waste handlers can send their universal waste to either another universal waste handler, a destination facility which is defined by the regulations to be one who treats, recycles or disposes of universal waste, or a foreign destination. One, of course, must comply with all applicable Department of Transportation shipping requirements.

Please note that unlike hazardous waste, you can transport your universal waste from one handler to another so if you have several hospitals in an area, you can send your waste to one of the hospitals who would then send it on to the destination facility. By doing this you may be able to reduce your shipment costs if there is a discount for bulk deliveries.

Recordkeeping

As for recordkeeping, only large quantity handlers of universal waste (LQHUW) are required to keep records of where they are sending their universal waste and if applicable, any universal waste they are receiving from others. There is no specified form for these records. Use whatever works for you (i.e., logs, invoices, manifests, bill of ladings etc.).

The only requirement is that when a LQHUW is shipping universal waste off site, the records must show the name and address of the facility to whom the wastes are being sent; the quantities and types of waste they are sending that facility; and the date of shipment.

Similarly, if they are receiving wastes from other handlers, they must keep records of the names and addresses of the facilities sending them waste; the types and quantities of universal waste they are receiving from each facility; and when they received the waste.

These records must be kept for three years.

Managing Common Universal Wastes at Veterinary Facilities