Title: Universal Waste Rule
1Universal 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
2Types 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
3Goals 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
4Questions
- 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
5Questions
- 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
6Universal 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.)
7States 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
8Regulated 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
9Management 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
10A 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
11Management 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.
12Regulatory 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
13Management 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.
14Tables for Reference
15Comparison 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
17Universal 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
18Universal 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
19Universal 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