Universal Waste Rule

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Universal Waste Rule
Pesticides
Hazardous Waste Lamps
Batteries
Thermostats

• 40 CFR Part 273
• Promulgated May 11, 1995 (60 FR 25492)

http//www.epa.gov/epaoswer/hazwaste/id/univwast.h
tm
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Types of Waste Covered

• Four types of Federal universal wastes
• Batteries (e.g., nickel cadmium) (does not
  include lead acid)
• Certain pesticides that are either recalled or
  collected in waste pesticides collection programs
• Mercury-containing thermostats
• Lamps
• Universal waste categories must be
  hazardous waste before they can be designated as
  universal wastes
• CRTs and mercury-containing devices are planned
  to be proposed this summer as Federal universal
  wastes

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Goals of the Universal Waste Rule

• Encourage environmentally sound collection and
  recycling or treatment of universal waste
• Improve implementation of the hazardous waste
  system
• Ease regulatory burden
• Reduce the wastes going to municipal landfills or
  combustors

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Questions

• Generator status
• What is the difference from a small quantity
  generator of hazardous waste and a universal
  waste handler?
• The most notable difference is that for universal
  waste there are longer storage times, no manifest
  requirements. See table on pages 15 and 16 for a
  more complete comparison.
• How does handing universal waste affect the
  generator calculations to determine if you are
  a large or small quantity generator of hazardous
  waste?
• You must include all hazardous wastes in your
  generator calculations. If you are using
  universal waste standards for universal wastes,
  then those wastes do not count in the hazardous
  waste calculations.
• Can SQG dispose of UW in the municipal landfill
  for regular trash
• No

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Questions

• Recycling, treatment and disposal
• Can small quantity generators of hazardous waste
  dispose of universal waste in the municipal
  landfill for regular trash?
• No, it has to be recycled or go to a hazardous
  waste treatment or disposal facility
• Does all universal waste have to be recycled?
• No, it is just easier to do so, although there
  may not be any treatment option for mercury other
  than being recycled (retorted)
• How is universal waste different when it gets to
  the recycling, treatment, or disposal facilities?
• The universal waste no longer has different
  standards when it get to the destination
  facility. It is then handles as regular
  hazardous wastes

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Universal Waste Rule Status
You can use universal waste rule provisions
before final authorization (during the adoption
process) as long as you comply with the federal
regulations.
Universal wastes are hazardous wastes with
streamlined handling standards. If you are not
using universal waste regulations, then you must
use hazardous waste regulations for those waste.
(The hazardous waste regulations have some
exclusions that may apply.)
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States with Universal Waste that are Different
than Federal
This list may not be complete since it is
collected from public information on the Internet.
Types of state-only Universal Wastes Aerosol
Cans (CO) Antifreeze (LA, NH) Ballasts
(MD, ME, VT) Cathode Ray Tubes / CRT (ME, MI,
NH, RI) Electronic Devices and Electronic
Components (CO) Mercury Related Universal
Wastes - Mercury-Containing Devices (CO, MA, MI,
ND, NH, PA, RI)- Barometers (NH, RI)- Gas Flow
Regulators (NH)- Intact Mercury-Containing
Ampules (NH)- Manometers (NH, RI)- Mercury
Switches (MI) and Relays (NH, RI)- Mercury
Thermometers (MI)- Sphygmomanometers (NH, RI)-
Thermocouples (NH, RI)- Thermometers (NH, RI) -
Water meters (NH) (last updated February 2002)
Note California has proposed to add Cathode ray
tube materials, Consumer electronic devices,
Aerosol cans, Mercury-containing motor vehicle
light switches (public hearing September 30, 2002)
http//www.epa.gov/epaoswer/hazwaste/id/univwast/u
wsum.htm
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Regulated Community

• Groups that manage universal waste
• 1. Small Quantity Handlers of Universal Waste
  (SQHUW)
• accumulate less than 5,000 Kg or 11,000 lbs of
  universal waste
• 2. Large Quantity Handlers of Universal Waste
  (LQHUW)
• accumulate 5,000 Kg or more of universal waste
• 3. Universal Waste Transporters

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Management Requirements Lamps
A Universal Waste Handler must

• Manage ALL universal waste lamps in a way that
  prevents releases
• Must contain ALL universe waste lamps in
  appropriate containers (like the box the new ones
  come in)
• Immediately clean up and place in an appropriate
  container any lamp that is broken

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A Universal Waste Handler must

• SPILLS AND CLEAN-UP
• Determine if mercury cleanup residues and/or
  solid waste exhibit a characteristic of hazardous
  waste
• If hazardous, manage in compliance with
  applicable Subtitle C requirements OR
• If not hazardous, manage in compliance with
  applicable federal state and local regulations

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Management Requirements Batteries
Are all batteries hazardous, therefor qualify as
universal waste?

• No, but most are
• There is interest to share battery-specific
  determinations (tests to see if they are
  hazardous)

Universal waste handler must

• Contain batteries that show evidence of leakage,
  spillage, or damage
• Store and transport batteries in containers
  appropriate for battery type to ensure contents
  dont spark and ignite.

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Regulatory Summary

• The Universal Waste Rule was published in the
  Federal Register May 11, 1995 (60 FR 25492) and
  codified at 40 CFR 273
• The Mercury-Containing and Rechargeable Battery
  Management Act was signed on May 13, 1996 (PL
  104-142)
• A technical correction was published in the
  Federal Register December 24, 1998 (63 FR 71225)
• Lamps were added as a new Federal universal waste
  July 6, 1999 (64 FR 36466) Information on
  universal waste http//www.epa.gov/epaoswer/hazwa
  ste/id/univwast.htm

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Management Requirements ELECTRONICS
Why Electronics

• Does the equipment contain heavy metals (lead,
  cadmium, copper, zinc, mercury)?
• We know that CRTs often contain a lot of lead,
  easily enough to fail the toxicity test (TCLP).
  We don't have a lot of info about the other
  metals - we have been going on the assumption
  that they don't have enough of any to fail the
  TCLP. EPA Regions 4 and 5 are doing a study with
  the U. of Fla to measure lead in different kinds
  of electronics, including CPUs, cell phones, and
  printers. They will also be looking at other
  metals. The results could be final by the end of
  this year.
• Can they be landfilled legally?
• Waste CRTs generated by businesses would often
  not be able to be legally disposed of in a
  municipal landfill. No hard data yet on other
  electronics - people should always check with
  their States, with respect to CRTs and other
  electronics.
• Reuse programs?
• Reuse is always the best option for usable
  equipment. There are many programs and you
  should check with your state for available ones.

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Tables for Reference
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Comparison to Hazardous Waste Generators Table
located at http//www.epa.gov/epaoswer/hazwaste/
id/univwast/table.htm
16
...Continued Comparison to Hazardous Waste
Generators Table located at http//www.epa.gov/e
paoswer/hazwaste/id/univwast/table.htm
Note regulations can vary by state
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Universal Waste Handler Requirements
Differences SQHUW (273 Subpart B) LQHUW
(273 Subpart C)
A universal waste handler who accumulates up
to, but not including, 5,000 Kg on-site at any
one time 273.6 Not Required 273.12 Less than
5,000 Kg 273.6 Not Required 273.19 Proper
handling and emergency procedures 273.16
A universal waste handler who accumulates 5,000
Kg or more on-site at any one time 273.6 Required
273.32 No limit Not required, but must keep
basic shipping records 273.39 training geared
towards employee responsibilities 273.36
Classification EPA Identification
Number On-Site Accumulation Limit Manifest Empl
oyee Training
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Universal Waste Handler Requirements
Similarities
SQHUW and LQHUW (273 Subpart B and
C) Disposing of, diluting, or treating
universal waste (some exceptions apply) 273.11
or 273.31 Must manage universal waste in a way
that prevent releases into the environment
(specific standards apply to each type) 273.13
or 273.33 Must label or mark universal waste or
containers of universal waste to identify
universal waste type 273.14 or 273.34 One year
unless for proper recovery treatment or disposal
273.15 or 273.35 Must immediately contain
releases and handle residues appropriately make
hazardous waste determination on material
resulting from release 273.17 or 273.37 Must
send universal waste only to other handlers,
destination facilities, or foreign destination
273.18 or 273.38
Prohibitions Waste Management Labeling/ Markin
g Accumulation Time Limit Response to
Releases Shipments
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Universal Waste Transporter Requirements
Transporters 273 Subpart D A person
engaged in the off-site transportation of
universal waste by highway, rail, air, or water
273.6 Disposing of, diluting, or treating
universal waste 273.51 Must comply with
applicable DOT regulations (49 CFR 171)
273.52 Ten days at a transfer facility
273.53 Must immediately contain releases and
handle residues appropriately make hazardous
waste determination on material resulting from
release 273.54 Must transport universal waste
only to other handlers, destination facilities,
or foreign destination 273.55
Definition Prohibitions Waste Management Stora
ge Time Limit Response to Releases Shipments