4Universal 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 timeLarge Quantity Handlers (LQHs)Accumulates 5,000 kilograms or more of total universal waste (batteries, pesticides, mercury-containing equipment or lamps, or pharmaceuticals) at any timeAccumulates 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
5Universal WasteNote: If managed as UW, waste does not count towards HW generator statusFour unbroken lamps = 1Kg (per FAC)DEP Notification Requirementsonly required for LQHs
6Universal 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.
7Universal 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.
8Universal Waste SQHs – 40 CFR 273.15 (a - c) LQHs – 40 CFR (a - c)Accumulation Time Limits:One YearLonger than one year (if solely for purpose of accumulation and other requirements are met)Accumulation Start Date, Inventory system or other method
9Universal Waste SQHs – 40 CFR 273.17 (a and b) LQHs – 40 CFR (a and b)Response to releases:Immediately contain releasesPerform a hazardous waste determination on residues from releases and properly manage residues
10Universal 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 destinationMay self-transport if complying with transporter requirements in subpart DComply with DOT requirements if UW is a hazmatBefore shipment, ensure that it will be received
11Universal 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 facilityIf rejecting a shipment, contact originating handler, ship to originating handler or to another destination facilityIf shipment received is hazardous waste and not UW, notify EPA/DEPIf shipment received is non-hazardous, but not UW, the waste may be managed appropriately
12Universal 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.
13Universal Waste LQHs – 40 CFR 273.39 – Tracking UW Shipments: UW Shipped:Keep records – logs, invoices, manifests, bills of lading or other shipping documentsName and address where UW shippedQuantity of each type shippedDate of shipmentRecords retained for three years
15Universal Waste Batteries Spent lead acid not managed under 40 CFR 266 subpart GHazardous 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))
17Universal Waste Batteries SQHs – 40 CFR (a)LQHs – 40 CFR (a)Managed in a way to prevent releasesMust contain leaking batteriesContainer must be closed, structurally sound, and compatibleContainer must lack evidence of leakage, spillage or damage
19DOT Transport Concerns All Batteries are subject to requirements in HMR (49 CFR )Chemical or other materials contained in batteryElectrical potential of the battery
20DOT Transport Concerns Common violations & safety concernsUsed batteries collected in large containers that do not adequately prevent damage or releases during transportOuter packages/shipping documents not marked and/or labeled as requiredNo action is being taken to prevent a short circuit, such as separating the batteries or taping
27Universal Waste Mercury – Containing Equipment Device or part of a device that contains elemental mercury integral to its functionExcludes waste that is non-hazardousExcludes equipment or devices where mercury- containing components have been removedBecomes waste on the date the handler decides to discard it
28Universal Waste Mercury – Containing Equipment SQHs – 40 CFR (c)LQHs – 40 CFR (c)Managed in a way to prevent releasesContain leaking equipment in containers that are:ClosedStructurally soundCompatible with contentsLack evidence of leakageDesigned to prevent escape of mercury
29Universal Waste Mercury – Containing Equipment Ampules may be removed from equipment, provided that:They are removed and managed in a proper mannerThey are removed over or in a containerThere is a mercury clean-up system in placeSpills are managed properlyIt is ensured the area is well ventilated and monitored
30Universal Waste Mercury – Containing Equipment Ampules may be removed from equipment, provided that:Proper employee training is ensuredRemoved ampules are stored in proper containers with adequate packing materialA hazardous waste determination will be performed on clean-up waste or equipment and then properly managed based upon the determination
34Universal Waste Lamps Requirements SQHs – 40 CFR (d)LQHs – 40 CFR (d)Managed in a way to prevent releasesContain lamps in containersClosedNot leakingStructurally soundImmediately clean up broken lamps and place in containers
43Bulb 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 vaporThe crushing operations and maintenance of the unit are performed in accordance with manufacturer’s instructions (filter change outs and operator training)