UW Audit Checklist
Large Quantity Handler
(>5,000 of waste in one year)
yes no n/a
comments
Documentation
1 Has large quantity handler notified the
Department of its universal waste activity using
DHEC form 2701?
Batteries
1 Are batteries handled in a manner that will
prevent 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 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 closed?
USC EHS Office of Environmental Management
EHS-F-189
Page 1 of 4
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 to prevent
breakage
 Remove ampoules over containment device
(e.g., tray or pan)
 Ensure that mercury clean-up system is
available & that spills and releases are
transferred to a container the meets subpart I
requirements?
 Ensure the area where ampules are removed
is well ventilated and meets OSHA
exposure limits for mercury.
 Ensure that employees removing ampules
are thoroughly familiar with proper waste
handling and emergency procedures. Stores
removed ampules in closed, non-leaking
containers in good condition.
 Packs removed ampules in container with
adequate packing material to prevent
breakage.
 Has the handler determined that material
generated from separating ampules from
thermostats exhibits the characteristics of
hazardous waste?
Lamps
1 Has handler managed lamps in such a way 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 the contents?
3 Are broken lamps immediately cleaned up and
placed in containers that are closed, structurally
sound, adequate to prevent breakage, and
compatible with the contents?
USC EHS Office of Environmental Management
EHS-F-189
Page 2 of 4
Destroy Previous Revisions
Issue Date: 6/18/07
Reviewed: ______
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 manufacturers
product label, or “universal wastepesticide(s)”, or “waste pesticide(s).”
 For thermostats; “universal waste-mercury
thermostat(s)”, or “waste mercury
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 wastes
for longer 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 in used:
 Waste is placed in containers that are
marked with the earliest date
 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 a group of
universal waste items or a group of
containers became a waste
 waste is placed in a specific accumulation
area identifying the earliest date that 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 handler sent universal waste to only
another universal waste handler, destination
facility, or a foreign destination?
USC EHS Office of Environmental Management
EHS-F-189
Page 3 of 4
Destroy Previous Revisions
Issue Date: 6/18/07
Reviewed: ______
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?
3 Receipt of shipments: Does handler track each
shipment of Universal waste showing the
name/address of the originator, quantity of
waste received, and the date of receipt?
4 Off-site shipments: Does handler keep a record
of each shipment sent which includes
name/address of handler, destination facility:
the quantity and type of each universal waste
sent: the date the shipment was sent?
5 Does handler retain these records for at least
three years?
6 Has transporter complied with all applicable
USDOT regulations in 49 CFR part 171-180?
USC EHS Office of Environmental Management
EHS-F-189
Page 4 of 4
Destroy Previous Revisions
Issue Date: 6/18/07
Reviewed: ______