Hazardous Waste Section
Universal
Waste
Management Standards
For
Universal Waste
Universal Waste
• Waste Batteries
• Waste Pesticides
• Waste Mercury - Containing Devices
• Waste Lamps
• Waste Pharmaceuticals
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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
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Universal Waste
• Note: If managed as UW, waste does not count
towards HW generator status
• Four unbroken lamps = 1Kg (per 62-737 FAC)
• DEP Notification Requirements
 only required for LQHs
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Universal Waste
• SQHs – 40 CFR 273.16
 Personnel Training:
o A SQH must inform all employees who handle or
have responsibility for managing UW. The
information must describe proper handling and
emergency procedures.
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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.
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Universal Waste
• SQHs – 40 CFR 273.15 (a - c)
• LQHs – 40 CFR 273.35 (a - c)
Accumulation Time Limits:
o One Year
o Longer than one year (if solely for purpose of
accumulation and other requirements are met)
o Accumulation Start Date, Inventory system or other
method
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Universal Waste
• SQHs – 40 CFR 273.17 (a and b)
• LQHs – 40 CFR 273.37 (a and b)
Response to releases:
o Immediately contain releases
o Perform a hazardous waste determination on
residues from releases and properly manage
residues
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Universal Waste
• SQHs – 40 CFR 273.18 (a - h)
• LQHs – 40 CFR 273.38 (a - h)

Off-Site Shipments:
o Send UW only to a UW handler, destination facility,
or foreign destination
o May self-transport if complying with transporter
requirements in subpart D
o Comply with DOT requirements if UW is a hazmat
o Before shipment, ensure that it will be received
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Universal Waste
• SQHs – 40 CFR 273.18 (a - h)
• LQHs - 40 CFR 273.38 (a - h)
 Off-Site Shipments (continued):
o If shipment is rejected, receive it back or ship to another
destination facility
o If rejecting a shipment, contact originating handler, ship to
originating handler or to another destination facility
o If shipment received is hazardous waste and not UW, notify
EPA/DEP
o If shipment received is non-hazardous, but not UW, the waste
may be managed appropriately
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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.
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Universal Waste
• LQHs – 40 CFR 273.39 – Tracking UW
Shipments:
 UW Shipped:
o 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
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Universal Waste Batteries
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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
261.2(a)(2))
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Universal Waste Batteries SQH/LQH
Requirements
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Universal Waste Batteries
• SQHs – 40 CFR 273.13 (a)
• LQHs – 40 CFR 273.33(a)
 Managed in a way to prevent releases
o Must contain leaking batteries
o Container must be closed, structurally sound, and
compatible
o Container must lack evidence of leakage, spillage or
damage
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Universal Waste Batteries
• SQHs – 40 CFR 273.14(a)
• LQHs – 40 CFR 273.33(a)
 Clearly labeled:
o“Universal Waste – Battery(ies)”
o“Waste Battery(ies)”
o“Used Battery(ies)”
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DOT Transport Concerns
• All Batteries are subject to requirements in HMR
(49 CFR 171-180)
 Chemical or other materials contained in battery
 Electrical potential of the battery
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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
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21
Universal Waste Batteries
SQH Improper Management
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Universal Waste Batteries
SQH Proper Management
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UW pesticides
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Universal Waste Mercury –
Containing Equipment
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Universal Waste Mercury –
Containing Equipment
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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 mercurycontaining components have been removed
• Becomes waste on the date the handler decides
to discard it
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Universal Waste Mercury –
Containing Equipment
• SQHs – 40 CFR 273.13 (c)
• LQHs – 40 CFR 273.33 (c)
 Managed in a way to prevent releases
o Contain leaking equipment in containers that are:
– Closed
– Structurally sound
– Compatible with contents
– Lack evidence of leakage
– Designed to prevent escape of mercury
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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
29
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
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Universal Waste Mercury –
Containing Equipment
SQH Improper Management
31
Universal Waste Mercury –
Containing Equipment
• SQHs – 40 CFR 273.14 (d)(1)
• LQHS – 40 CFR 273. 34(d)(1)
 Clearly labeled:
o “Universal Waste – Mercury - Containing Equipment”
o “Waste Mercury - Containing Equipment”
o “Used Mercury - Containing Equipment”
• SQHs – 40 CFR 273.14 (d)(2)
• LQHs – 40 CFR 273.34(d)(2)
 Clearly labeled:
o “Universal Waste – Mercury Thermostat(s)”
o “Waste Mercury Thermostat(s)”
o “Used Mercury Thermostat(s)”
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Universal Waste Lamps
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Universal Waste Lamps
Requirements
• SQHs – 40 CFR 273.13 (d)
• LQHs – 40 CFR 273.33 (d)
 Managed in a way to prevent
releases
o Contain lamps in containers
– Closed
– Not leaking
– Structurally sound
o Immediately clean up broken
lamps and place in containers
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Universal Waste Lamps
• SQHs – 40 CFR 273.14 (e)
• LQHs – 40 CFR 273.34(e)
 Clearly labeled:
o “Universal Waste – Lamp(s)”
o “Waste Lamp(s)”
o “Used Lamp(s)”
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Universal Waste Lamps –
Improper Management
36
Universal Waste Lamps –
Improper Management
37
Universal Waste Lamps –
Proper Management
38
Universal Waste Lamps
Improper Response to Releases
39
Universal Waste Lamps
Improper Response
40
Universal Waste Lamps
Improper Response
41
Universal Waste Lamps
Bulb Crushers
42
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)
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Universal Waste Lamps
Bulb Crushers
44
Universal Waste Lamps –
Improper Management
45
Universal Waste Lamps –
Improper Management
46
Universal Waste Pharmaceuticals
47
UPW
• SQH of Universal Pharmaceutical Waste
no longer need to notify
48
Questions?
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