WELCOME CUSTOMIZED ENVIRONMENTAL TRAINING UNIVERSAL WASTE RULE

UNIVERSAL WASTE RULE

CUSTOMIZED ENVIRONMENTAL

TRAINING

WELCOME

UNIVERSAL WASTE 1/ 60 ©

Copyright Training 4 Today 2001 Published by EnviroWin Software LLC

INSTRUCTOR

Insert Instructor Name Here



OBJECTIVES

 Explain Why the Universal Waste Rule Was Written.

 Define Universal Waste.

 Discuss How the Universal Waste Rule Affects Business.

 Discuss Management of Waste Batteries.

 Discuss Management of Waste Pesticides.

 Discuss Management of Waste Thermostats.

 Discuss Management of Waste Lamps.

 Discuss Use of Contractors.



GOALS

 Understand Why the Universal Waste Rule Was Written.

 Understand What Are the Universal Wastes.

 Be Familiar How the Universal Waste Rule Affects Business.

 Be Familiar With the Management of Waste Batteries.

 Be Familiar With the Management of Waste Pesticides.

 Be Familiar With the Management of Waste Thermostats.

 Be Familiar With the Management of Waste Lamps.



BACKGROUND

 More than 600 Million Lamps Discarded Each Year as

Hazardous Waste or are Sent to Landfills.

 Ni-Cd Rechargeable Batteries are Estimated to

Represent Approximately 75 percent of the Cadmium

Found in Municipal Solid Waste in 1995.

 EPA Projected that Lead-Acid Rechargeable Batteries, of which Small Sealed Lead-Acid Batteries are a Small

Percentage, Would Represent Approximately 65

Percent of the Lead Found in Municipal Solid Waste in

1995.

©

Copyright Training 4 Today 2001 Published by EnviroWin Software LLC UNIVERSAL WASTE 5/ 60

LEARNERS

 Supervisors

 Facility Engineers

 Maintenance Personnel

 Department Managers

 Building Occupants

 Process Specialists

 Environmental and Safety Committees



OVERVIEW

The goal of this course is to provide supervisors with the tools needed to management universal wastes. It recommends practical, actions that can be carried out by facility management, maintenance personnel and building occupants. The course will help you to integrate good universal waste management activities into your existing organization and identify which of your staff have the necessary skills to carry out those activities.



WHAT THIS COURSE DOES NOT DO

The course is not intended to provide information to treat or recycle universal wastes. These specialties required training beyond the intended scope of this course.

Where this expertise is needed, outside assistance should be solicited.



RESOURCE CONSERVATION AND

RECOVERY ACT (RCRA)

 RCRA addresses both hazardous waste and solid waste.



FEDERAL REGULATIONS

Pertinent Regulations:

 40 CFR 273 – Universal Waste Regulations



STATES’ ROLE

 RCRA encourages states to develop and run their own hazardous waste programs as an alternative to direct EPA management.

 States that are authorized to implement the RCRA program must adopt the universal waste rule in a separate state rulemaking for it to be effective.

 The rule is in effect in states and territories that are not RCRA-authorized including Iowa, Alaska, Hawaii, and

Puerto Rico.



WHY THE UNIVERSAL WASTE

RULE

 Eases regulatory burdens on businesses.

 Promotes proper recycling or disposal of hazardous waste batteries, pesticides, thermostats, and lamps which will reduce the amount of hazardous waste items in the municipal solid waste stream.

 Provides for collection opportunities for communities and businesses.



CHARACTERISTICS OF

UNIVERSAL WASTES

These wastes share several characteristics:

 They are frequently generated in a wide variety of settings other than the industrial settings usually associated with hazardous wastes

 They are generated by a vast community, the size of which poses implementation difficulties for both those who are regulated and the regulatory agencies charged with implementing the hazardous waste program; and

 They may be present in significant volumes in nonhazardous waste management systems.



WASTES COVERED

There are 4 wastes that are considered Universal Wastes:

1. Hazardous waste batteries

2. Hazardous waste pesticides that are either recalled or collected in waste pesticide collection programs.

3. Hazardous waste thermostats

4. Hazardous waste lamps was added in 1999.



HOW IT AFFECTS BUSINESS

The Universal Waste Rule eases the regulatory burden on businesses that generate these wastes by streamlining the requirements related to:

 Notification

 Labeling and marking

 Prohibitions

 Accumulation time limits

 Employee training

 Response to releases

 Off-Site Shipments

 Tracking

 Exports



HOW IT AFFECTS BUSINESS

 Many industries strongly support this rule because they have identified easy collection of universal wastes as a priority to ensure sound environmental management. This rule makes it easier for companies to establish collection programs and participate in manufacturer take-back programs required by a number of states. Many large manufacturers and trade associations have established national and regional collection programs for their products.

 The rule does not apply to businesses that generate less than 100 kilograms of universal wastes per month

Conditionally Exempt Small Quantity Generators.



HANDLERS AND GENERATORS

1. A handler is a person who generates, or creates, universal waste. This is a person who uses batteries, lamps, pesticides, or thermostats and who eventually decides that they are no longer usable and thus are waste. or

2. A handler is a person who receives universal waste from generators or other handlers, consolidates the waste, and then sends it on to other handlers, recyclers, or treatment/disposal facilities.

Universal waste handlers accumulate universal waste, but do not treat, recycle, or dispose of the waste.



SMALL QUANTITY HANDLERS

 Small Quantity Handlers of Universal Waste (handles less than 5,000 kg or 11,000 lbs of total universal wastes (hazardous batteries, certain hazardous pesticides, hazardous thermostats, or hazardous lamps, calculated collectively) on site at any time)

 Requirements include packaging in a way to minimize breakage; immediately cleaning up any leaks or spills; and properly labeling containers.



LARGE QUANTITY HANDLERS

 Large Quantity Handlers of Universal Waste (handles

5,000 kg or 11,000 lbs or more of total universal wastes on site at any time)

 Requirements include EPA notification; packaging in a way to minimize breakage; immediately cleaning up any leaks or spills; properly labeling containers; and complying with recordkeeping and reporting requirements.



NOTIFICATION

 Small quantity generators DO NOT have to notify EPA of their universal waste activities. They also are not required to obtain an EPA identification number.

 Large quantity generators ARE

REQUIRED to notify EPA of their universal waste activities and to obtain an EPA identification number.

 Non-contiguous property is viewed as a separate site. DO NOT add quantities from separate sites.



LABELING

For Batteries, they are to be marked:

 Universal waste batteries (i.e., each battery), or

 A container in which the batteries are contained, must be labeled or marked clearly with any one of the following phrases:

“Universal Waste--Battery(ies)”, or

“Waste Battery(ies)” or “Used

Battery(ies)”.



LABELING

Pesticides are to be marked:

 The label that was on or accompanied the product as sold or distributed; and

 The words “Universal

WastePesticide(s)” or “Waste

Pesticide(s)”.



LABELING

Thermostats are to be marked:

Each thermostat or a container in which the thermostats are contained, must be labeled or marked clearly with any one of the following phrases: “Universal

Waste-Mercury Thermostat(s)” or

“Waste Mercury Thermostat(s)” or

“Used Mercury Thermostat(s)”.



LABELING

Individual waste lamps or containers must clearly state one of the following:

“Universal Waste Lamps” or

“Waste Lamps” or

“Used Lamps”.



PROHIBITIONS

1. Disposal - handlers are prohibited from diluting or disposing of universal waste, except for a provision allowing farmers to dispose of waste pesticides for their own use on their own farms.

2. Treatment – handlers are prohibited from treating waste, except by removing electrolytes from batteries, volume reduction for lamps, or responding to releases.

3. Shipment - handlers were prohibited from sending or taking universal waste to a place other than a consolidation point, destination facility, or foreign destination.



ACCUMULATION TIME LIMITS

 A 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,

 The exception to the above is unless such activity is solely for the purpose of accumulation of such quantities of universal waste as necessary to facilitate proper recovery, treatment, or disposal.

 However, the handler bears the burden of proving that such activity is solely for the purpose of accumulation of such quantities of universal waste as necessary to facilitate proper recovery, treatment, or disposal.



ACCUMULATION TIME LIMITS

 Placing the universal waste in a container and marking or labeling the container with the earliest date.

 Marking or labeling each individual item

 Maintaining an inventory system on-site that identifies the date each universal waste became a waste

 Maintaining an inventory system on-site that identifies the earliest date that any universal waste in a group of universal waste items or a group of containers of universal waste became a waste or was received

 Placing the universal waste in a specific accumulation area and identifying the earliest date that any universal waste in the area became a waste or was received; or

 Any other method which clearly demonstrates the length of time of accumulation .



EMPLOYEE TRAINING

Both large and small quantity handlers of universal waste must inform all employees who handle or have responsibility for managing universal waste. The information must describe proper handling and emergency procedures appropriate to the type(s) of universal waste handled at the facility.



RESPONSE TO RELEASES

 A handler of universal waste must immediately contain all releases of universal wastes and other residues from universal wastes.

 A handler of universal waste must determine whether any material resulting from the release is hazardous waste, and if so, must manage it as a 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 is subject to 40 CFR part 262.



OFF-SITE SHIPMENTS

 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 handler of universal waste self-transports universal waste off-site, the handler becomes a universal waste transporter.

 If a universal waste meets the definition of hazardous materials, a handler of universal waste must package, label, mark and placard the shipment, and prepare the proper shipping papers.

 Prior to sending a shipment of universal waste, the originating handler must ensure that the receiving handler agrees to receive the shipment.




 If a universal waste shipment is rejected by the destination facility, the originating handler must either:

(1) Receive the waste back after the shipment has been rejected, or

(2) Agree with the receiving handler on a destination facility to which the shipment will be sent.

 If a shipment containing universal waste, or a portion of a shipment containing universal waste is rejected, the receiving handler must:

(1) Send the shipment back to the originating handler, or

(2) If agreed to by both the originating and receiving handler, send the shipment to a destination facility.




 If a handler of universal waste receives a shipment containing hazardous waste that is not a universal waste, the handler must immediately notify the appropriate regional EPA office of the illegal shipment, and provide the name, address, and phone number of the originating shipper. The EPA regional office will provide instructions for managing the hazardous waste.

 If a handler of universal waste receives a shipment of non-hazardous, non-universal waste, the handler may manage the waste in any way that is in compliance with applicable federal, state or local solid waste regulations.



TRACKING

 A small quantity handler of universal waste is not required to keep records of shipments of universal waste.

 Large quantity handlers of universal waste must keep a receipt of shipments received. The record may take the form of a log, invoice, manifest, bill of lading, or other shipping document.



TRACKING

Shipments off-site.

 Large quantity handlers of universal waste must keep a record of each shipment of universal waste sent from the handler to other facilities. The record may take the form of a log, invoice, manifest, bill of lading or other shipping document.

Record retention.

 A large quantity handler of universal waste must retain the records for at least three years from the date of receipt of a shipment of universal waste.

(2) A large quantity handler of universal waste must retain the records for at least three years from the date a shipment of universal waste left the facility.



EXPORTS

A handler of universal waste who sends universal waste to a foreign destination must:

(a) Comply with the requirements applicable to a primary exporter

(b) Export such universal waste only upon consent of the receiving country and in conformance with the EPA

Acknowledgement of Consent; and

(c) Provide a copy of the EPA Acknowledgement of

Consent for the shipment to the transporter transporting the shipment for export.



RECYCLING VS. DISPOSAL

 Under the Universal Waste Rule, all universal wastes must go to a destination facility for any treatment, recycling, or disposal. Land disposal restrictions, including the treatment standards, are fully applicable to destination facilities.

 Except for pesticides that are disposed of by incineration, recycling of the other three types of universal wastes is actually mandatory because of land disposal restrictions.

 Disposal sites must use the best demonstrated available technology (BDAT).



TRANSPORTERS

The following are requirements of transporters:

 must not dispose of universal waste

 must not dilute or treat except to respond to spills

 must comply with Department of Transportation regulations

 are not required to use manifests

 may keep universal waste at transfer facilities up to

10 days

 must respond to releases

 must only transport universal waste to a universal waste handler, destination facility or foreign destination

 must comply with export requirements for foreign shipments



DESTINATION FACILITIES

A destination facility means a facility that treats, disposes of, or recycles a particular category of universal waste.

The following are requirements for destination facilities:

 must comply with hazardous waste storage, treatment or disposal facility permitting

 must comply with recycling facility requirements only if no storage occurs

 must send waste off-site only to another destination facility or a foreign destination

 must keep records



BATTERIES

 EPA has defined battery to mean a device consisting of one or more electrically connected electrochemical cells which is designed to receive, store, and deliver electric energy. An electrochemical cell is a system consisting of an anode, cathode, and an electrolyte, plus such connections as may be needed to allow the cell to deliver or receive electrical energy.

The term battery also includes an intact, unbroken battery from which the electrolyte has been removed.

 Batteries such as nickel-cadmium (Ni-Cd) and small, sealed lead-acid batteries found in electronic equipment, mobile telephones, portable computers and emergency backup lighting.

 Large lead-acid car batteries are NOT considered Universal

Wastes.



BATTERIES

A handler of universal waste must manage universal waste batteries in a way that prevents releases of any universal waste or component of a universal waste to the environment, as follows:

1. A 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 reasonably foreseeable conditions.



BATTERIES

2. A handler of universal waste may conduct the following activities as long as the casing of each individual battery cell is not breached and remains intact and closed:

(i) Sorting batteries by type

(ii) Mixing battery types in one container

(iii) Discharging batteries so as to remove the electric charge

(iv) Regenerating used batteries

(v) Disassembling batteries or battery packs into individual batteries or cells

(vi) Removing batteries from consumer products

(vii) Removing electrolyte from batteries



BATTERIES

3. A small quantity handler of universal waste who removes electrolyte from batteries, or who generates other solid waste, must determine whether the electrolyte and/or other solid waste exhibit a characteristic of hazardous waste.

 If the electrolyte and/or other solid waste exhibit a characteristic of hazardous waste, it is subject to all applicable requirements of hazardous waste handling.

 If the electrolyte or other solid waste is not hazardous, the handler may manage the waste in any way that is in compliance with applicable federal, state or local solid waste regulations.



PESTICIDES

EPA has defined pesticide to mean any substance or mixture of substances intended for preventing, destroying, repelling, or mitigating any pest, or intended for use as a plant regulator, defoliant, or desiccant, other than any article that:

(a) Is a new animal drug under FFDCA section 201(w)

(b) Is an animal drug that has been determined by regulation of the Secretary of Health and Human

Services not to be a new animal drug

(c) Is an animal feed under FFDCA section 201(x) that bears or contains any substances described by paragraph (a) or (b) of this section



PESTICIDES

A handler of universal waste must manage universal waste pesticides in a way that prevent releases of any universal waste or component of a universal waste to the environment. The universal waste pesticides must be contained in one or more of the following:

(1) 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;



PESTICIDES

(2) A container that does not meet the closed and structurally sound requirements, provided that the unacceptable container is overpacked in a container that does meet the closed and structurally sound requirements; or



PESTICIDES

(3) A tank that meets the requirements of 40 CFR part 265 subpart J, except for 40 CFR

265.197(c), 265.200, and

265.201; or

(4) A transport vehicle or vessel that is closed, structurally sound, compatible with the pesticide, and that lacks evidence of leakage, spillage, or damage that could cause leakage under reasonably foreseeable conditions.



THERMOSTATS

EPA has defined thermostat to mean a temperature control device that contains metallic mercury in an ampule attached to a bimetal sensing element, and mercury-containing ampules that have been removed from these temperature control devices.



THERMOSTATS

A handler of universal waste must manage universal waste thermostats in a way that prevents releases of any universal waste or component of a universal waste to the environment, as follows:

(1) A small quantity handler of universal waste must contain any universal waste thermostat 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 thermostat, and must lack evidence of leakage, spillage, or damage that could cause leakage under reasonably foreseeable conditions.



THERMOSTATS

(2) A handler of universal waste may remove mercury containing ampules from universal waste thermostats provided the handler:

(i) Removes the ampules in a manner designed to prevent breakage of the ampules;

(ii) Removes ampules only over or in a containment device;

(iii) Ensures that a mercury clean-up system is readily available to immediately transfer any mercury resulting from spills or leaks from broken ampules, from the containment device to a container;

(iv) Immediately transfers any mercury resulting from spills or leaks from broken ampules from the containment device to a container;

Continued 



THERMOSTATS

(2) Continued

(v) Ensures that the area in which ampules are removed is well ventilated and monitored to ensure compliance with applicable

OSHA exposure levels for mercury;

(vi) Ensures that employees removing ampules are thoroughly familiar with proper waste mercury handling and emergency procedures, including transfer of mercury from containment devices to appropriate containers;

(vii) Stores removed ampules in closed, non-leaking containers that are in good condition;

(viii) Packs removed ampules in the container with packing materials adequate to prevent breakage during storage, handling, and transportation;



THERMOSTATS

(3)(i) A small quantity handler of universal waste who removes mercury-containing ampules from thermostats must determine whether the following exhibit a characteristic of hazardous waste:

(A) Mercury or clean-up residues resulting from spills or leaks; and/or

(B) Other solid waste generated as a result of the removal of mercury-containing ampules.

(ii) If the mercury, residues, and/or other solid waste exhibit a characteristic of hazardous waste, it must be managed in compliance with all applicable requirements (iii) If the mercury, residues, and/or other solid waste is not hazardous, the handler may manage the waste in any way that is in compliance with applicable federal, state or local solid waste regulations.



LAMPS

 EPA has defined lamp or “universal waste lamp” as the bulb or tube portion of an electric lighting device. A lamp is specifically designed to produce radiant energy, most often in the ultraviolet, visible, and infra-red regions of the electromagnetic spectrum.

 Examples of common universal waste electric lamps include, but are not limited to, fluorescent, high intensity discharge, neon, mercury vapor, high pressure sodium, and metal halide lamps.



LAMPS

A lamp is a hazardous waste if it exhibits one or more of the characteristics of a hazardous waste, as defined in 40 CFR

261. It becomes a waste lamp:

(1) A used lamp becomes a waste on the date it is discarded.

(2) An unused lamp becomes a waste on the date the handler decides to discard it.



LAMPS

A handler of universal waste must manage lamps in a way that prevents releases of any universal waste or component of a universal waste to the environment, as follows:

(1) A handler of universal waste must contain any lamp in containers or packages that are structurally sound, adequate to prevent breakage, and compatible with the contents of the lamps. Such containers and packages must remain closed and must lack evidence of leakage, spillage or damage that could cause leakage under reasonably foreseeable conditions.



LAMPS

(2) A handler of universal waste must immediately clean up and place in a container any lamp that is broken and must place in a container any lamp that shows evidence of breakage, leakage, or damage that could cause the release of mercury or other hazardous constituents to the environment. Containers must be closed, structurally sound, compatible with the contents of the lamps and must lack evidence of leakage, spillage or damage that could cause leakage or releases of mercury or other hazardous constituents to the environment under reasonably foreseeable conditions.



LAMPS

Handlers of universal waste may treat mercury-containing lamps at the site they were generated for the purpose of volume reduction.

Crushing is allowed provided that the handler:

 Ensures that mercury clean-up material is available

 Immediately transfer broken tubes to a closed container;

 Crushes lamps in a well-ventilated area

 Ensures that employees crushing lamps are thoroughly familiar with proper waste mercury handling and emergency procedures; and

 Stores crushed tubes in closed, non-leaking containers.



LAMPS

Suggested Storage Practices

Companies currently storing universal waste fluorescent and

HID lamps for recycling have found that the following practices work well:

 Spent lamps are replaced by a maintenance worker or electrical contractor, and are placed into waste storage boxes.

 Waste lamps can be stored in the same boxes that new lamps were shipped in or in boxes of similar size. Storage boxes are available from your lamp recycler or can be purchased from carton distributors.

 Boxes are kept in a designated storage area. Each box should be labeled and dated when the first tube was added to the box.



TIPS FOR USING CONTRACTORS

 Remember, You Control Your Facility or Area!

 Review Procedures With Them Before Starting the Job!

 Ensure They Are Properly Trained!

 Determine Their Environmental Compliance Record!

 Determine Who Is in Charge of Their People!

 Determine How They Will Affect Your Facility’s

Environmental Compliance!



ELEMENTS OF A SUCCESSFUL

UNIVERSAL WASTE PROGRAM

1. DETAILED WRITTEN UNIVERSAL WASTE INSPECTION

GUIDELINES.

2. DETAILED WRITTEN UNIVERSAL BEST MANAGEMENT

PRACTICES.

3. EXTENSIVE EMPLOYEE TRAINING PROGRAMS

4. PERIODIC REINFORCEMENT OF TRAINING

5. SUFFICIENT DISCIPLINE REGARDING IMPLEMENTATION

6. PERIODIC FOLLOW-UP



THE IMPORTANCE OF A

CLEAN ENVIRONMENT

“I would ask all of us to remember that protecting our environment is about protecting where we live and how we live. Let us join together to protect our health, our economy, and our communities -- so all of us and our children and our grandchildren can enjoy a healthy and a prosperous life.”

Carol Browner

Former EPA

Administrator



WELCOME CUSTOMIZED ENVIRONMENTAL TRAINING UNIVERSAL WASTE RULE

UNIVERSAL WASTE RULE

CUSTOMIZED ENVIRONMENTAL

TRAINING

WELCOME

INSTRUCTOR

Insert Instructor Name Here

OBJECTIVES

GOALS

BACKGROUND

LEARNERS

OVERVIEW

WHAT THIS COURSE DOES NOT DO

RESOURCE CONSERVATION AND

RECOVERY ACT (RCRA)

FEDERAL REGULATIONS

STATES’ ROLE

WHY THE UNIVERSAL WASTE

RULE

CHARACTERISTICS OF

UNIVERSAL WASTES

WASTES COVERED

HOW IT AFFECTS BUSINESS

HOW IT AFFECTS BUSINESS

HANDLERS AND GENERATORS

SMALL QUANTITY HANDLERS

LARGE QUANTITY HANDLERS

NOTIFICATION

LABELING

LABELING

LABELING

LABELING

PROHIBITIONS

ACCUMULATION TIME LIMITS

ACCUMULATION TIME LIMITS

EMPLOYEE TRAINING

RESPONSE TO RELEASES

OFF-SITE SHIPMENTS

OFF-SITE SHIPMENTS

OFF-SITE SHIPMENTS

TRACKING

TRACKING

EXPORTS

RECYCLING VS. DISPOSAL

TRANSPORTERS

DESTINATION FACILITIES

BATTERIES

BATTERIES

BATTERIES

BATTERIES

PESTICIDES

PESTICIDES

PESTICIDES

PESTICIDES

THERMOSTATS

THERMOSTATS

THERMOSTATS

THERMOSTATS

THERMOSTATS

LAMPS

LAMPS

LAMPS

LAMPS

LAMPS

LAMPS

TIPS FOR USING CONTRACTORS

ELEMENTS OF A SUCCESSFUL

UNIVERSAL WASTE PROGRAM

THE IMPORTANCE OF A

CLEAN ENVIRONMENT

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