Universal Waste Audit Checklist
Small Quantity Generator (<5,000 lbs of waste in one year)
Campus:
Audit Date:
Auditor:
yes
no
n/a
comments
Batteries
1
Are batteries handled in a manner that prevents
releases to the environment?
2 Have any batteries that show evidence of leakage
or damage been contained in a compatible and
closed container?
3
Has the handler conducted any of the following
activities:
 Sorting by type?
 Mixing different types in one container?
 Discharging energy?
 Regenerating used batteries?
 Disassembling batteries or packs into
different cells?
 Removing batteries from consumer
products?
 Removing electrolytes?
4 If any of the above activities were performed,
was an accurate hazardous waste determination
made to determine whether resulting materials
are a hazardous waste?
5
Are hazardous wastes handled according to the
hazardous waste management regulations?
Pesticides
1 Are universal waste pesticides being handled in a
manner that will prevent releases to the
environment?
2 Are universal waste pesticides being managed in
containers that are compatible with the contents
and being kept closed?
3 Are damaged containers over-packed?
Thermostats
1 Are universal waste thermostats being handled in
a manner that will prevent releases to the
environment?
2 Are universal waste thermostats being managed
in containers that are compatible with the
contents and being kept closed?
USC EHS Office of Environmental Management
EHS-F-184
Page 1 of 3
Destroy Previous Revisions
Issue Date: 6/18/07
Reviewed: ______
3
Has the handler removed Mercury containing
ampoules from universal waste thermostats in
one of the following ways:
 Remove ampoules in such a way as to
prevent breakage?
 Remove ampoules over containment
device (tray or pam)?
 Ensure that Mercury clean-up system is
available & that spill and releases are
transferred to a container that meets
Subpart 1 Requirements?
 Ensure the area where ampoules are
removed is well ventilated and meets
OSHA exposure limits for Mercury?
 Ensure that employees removing
ampoules are thoroughly familiar with
proper waste handling and emergency
procedures?
 Stores removed ampoules in closed nonleaking containers in good condition?
 Packs removed ampoules in containers
with adequate packing material to
prevent breakage?
 Has handler determined that material
generated from separating ampoules
from thermostats exhibits the
characteristics of hazardous waste?
Lamps
1 Has handler managed lamps in such a way as to
prevent releases of any universal waste to the
environment?
2 Are universal waste lamps managed in containers
that are closed, structurally sound, adequate to
prevent breakage, and compatible with contents?
3 Are broken lamps:
 Immediately cleaned up and placed in
containers that are closed, structurally
sound, adequate to prevent breakage, and
compatible with contents?
 Is cleanup handled as hazardous waste?
Labeling
1 Has the handler ensured that universal wastes are
labeled/marked with one of the following:
 For batteries: “universal waste–
battery(ies)” or “waste battery(ies)” or
“used battery(ies)?”
 For pesticides: The original
USC EHS Office of Environmental Management
EHS-F-184
Page 2 of 3
Destroy Previous Revisions
Issue Date: 6/18/07
Reviewed: ______
manufacturers product label, or
“universal waste–pesticide(s)” or “waste
pesticide(s)?”
 For thermostats: “universal wastemercury thermostat(s)” or “used mercury
thermostat(s)?”
 For lamps: “universal waste-lamp(s)” or
“waste lamp(s)” or “used lamp(s)?”
Accumulation Time Limits
1 Has the handler accumulated universal waste for
less than one year?
2 If wastes were accumulated longer than one year,
was it for the purpose of accumulating sufficient
quantities to facilitate proper recovery, treatment,
or disposal?
3 Is the handler able to demonstrate the length of
time universal wastes have been accumulated?
Which of the following methods is used?
 Waste is placed in containers that are
marked with the earliest date universal
waste was placed in the container?
 Each individual item labeled with a date?
 An inventory system that ID’s the date
of each universal waste?
 An inventory system that ID’s the
earliest date any universal waste in the
area became a waste?
 Any other method that clearly
demonstrates the length of time that
universal wastes have been
accumulated?
Employee Training
1 Has the handler informed all employees who
handle universal waste of proper handling and
emergency procedures?
Off Site Shipments
1 Has the handler sent universal waste to only
another universal waste handler, destination
facility, or a foreign destination?
2 Has handler transported his own universal waste?
If so:
 Does he comply with USDOT shipping
requirements?
 Does handler ensure that receiving
facility agrees to accept shipment?
USC EHS Office of Environmental Management
EHS-F-184
Page 3 of 3
Destroy Previous Revisions
Issue Date: 6/18/07
Reviewed: ______