Universal Waste Management Training

The Texas A&M University SystemEnvironmental, Health & Safety

Special Thanks to Koch Industries, Wichita, KS

Training Objectives

In this training, you will learn:

• What is a Universal Waste• Universal Waste management requirements• Steps for responding to a spill or breakage• Where to go for more information

What is a Universal Waste?

A special subset of hazardous waste, including:

– Batteries– Lamps– Pesticides– Mercury-Containing Equipment– Paint & Paint-Related Wastes (Texas)

Termed “universal wastes” by EPA because these hazardous wastes are generated in a wide variety of settings by a vast community

PesticidePesticidePesticidePesticide

Rules for “Universal Waste Handlers”

Small Quantity Handler of Universal Waste (SQHUW)

< 5000 kg or 11, 000 lbs accumulated at any one time

– One year accumulation limit– Inform employees about universal

waste

– Send universal waste to handler, or designated TSD

– Containers labeled, dated, closed and compatible

– Clean up spills– Keep shipping records for 3 years

(recommended)

Large Quantity Handler of Universal Waste (LQHUW)

> 5000 kg or 11, 000 lbs accumulated at any one time

– One year accumulation limit– Train employees about univer. waste

& emergencies– Send universal waste to handler, or

designated TSD– Containers labeled, dated, closed and

compatible– Clean up spills– Keep shipping records for 3 years

(required)– Notify as LQHUW and obtain EPA

ID number

(Differ from RCRA Hazardous Waste Generator Rules)

Rules for “Universal Waste Handlers”

Small Quantity Handler of Universal Waste (SQHUW)

< 5000 kg or 11, 000 lbs accumulated at any one time

– One year accumulation limit– Inform employees about universal

waste

– Send universal waste to handler, or designated TSD

– Containers labeled, dated, closed and compatible

– Clean up spills– Keep shipping records for 3 years

(recommended)

• Universities and agencies should easily stay below the 11,000 lb limit

• Possible exceptions:– Major re-lamping– Building demolitions

• Challenges– Tracking wastes scattered

among many locations– Keeping track of the 1 yr

time limit

What is a Universal Waste- Batteries -

• Many types must bemanaged as Universal Wastes, including those that contain:

• Lead Acid Batteries (e.g. car batteries) may be taken or shipped to a facility for regeneration or managed as UW

• Common consumer batteries, including alkaline (AA, AAA, C, D, 9 volt), lithium batteries, and nickel-metal hydride batteries(These types are non-hazardous and may be discarded with solid waste (trash) without special requirements.)

�Nickel & Cadmium (e.g. NiCad)�Mercury (e.g. Hg or Ag Oxide)(i.e., most rechargeable batteries)Exceptions

Look for the Recycling Seal

Recycle Rechargeable Batteries and Cell Phones

Look for the seal

CAUTIONBag all batteries, one per bag,

and place in box.

FIRE DANGERif battery terminals touch!

Rechargeable Battery Recycling

How to Recycle Rechargeable Batteries &

Cell PhonesStep 1 – Place battery or cell

phone in its own plastic bag (to prevent fire) and put it in the box

Step 2 – Periodically police box for foreign objects

Step 3 – When box is full, fold down and seal flap

Step 4 – Ship box (UPS prepaid) to RBRC, who will replenish your boxes

Example Battery Recycling Poster from Tarleton State University

What is a Universal Waste- Lamp(s) -

• Contain leachable amounts of toxic components (e.g. mercury or lead) that fail the EPA’s TCLP test.

• Examples: Fluorescent, Halogen, Metal Halide, High or Low Pressure Sodium, Mercury Vapor, Incandescent

• Not “green” lamps (e.g., Phillips AltoTM, GE EcoluxTM, or OSRAM SYLVANIA ECOLOGICTM) passing TCLP

• Fluorescent (Hg)

• Halogen (Hg)

• Metal Halide (Hg)

• High/Low Pressure Sodium (Hg)

• Mercury Vapor (Hg)

• Incandescent (Pb)

What is a Universal Waste- Lamp(s) -

What is Universal Waste -Mercury-Containing

Equipment-• Contain the toxic component (Mercury)• Commonly recognized mercury-containing devices

– Thermostats– Thermometers– Barometers – Manometers / sphygmomanometers– Flow meters– Mercury light switches– Mercury regulators– Pressure relief gauges– Water treatment gauges, and – Gas safety relays

What is Universal Waste -Mercury-Containing

Equipment-• Thermostats may be handled and labeled

separately as Universal Waste – Mercury Thermostats

What is a Universal Waste- Pesticide(s) -

• The Universal Waste Regulations for pesticides are limited to

1. Recalled pesticides subject to FIFRA procedures, and

2. Unused pesticide products collected and managed as part of a waste pesticide collection program (e.g., for farmers).

• Consult your Compliance Manager if you have pesticides which have been recalled or are no longer needed at your facility.

What is a Universal Waste- Paint & Paint Related Waste - (Texas Only)

May include:• Used or unused paint• Spent solvents used in painting• PPE from painting• Paint removal wastes• Paint filtersOnly if the material is a characteristic hazardous

waste (ignitable or toxic)

Does Not Include• Aqueous-based paint & paint-related wastes or otherwise

non-hazardous wastes

If shipped out of Texas - must be manifested as hazardous waste

For more information: http://www.tceq.state.tx.us/comm_exec/forms_pubs/pubs/rg/rg-370.html

Minimizing Universal Waste -Paint & Paint-Related Wastes

• Choose the Right Paint– Minimize use of ignitable oil / petroleum-based

paints.– Avoid using oil-based aerosol paints

• Use Paint Wisely– Use it all, leaving little to waste– Use aerosol cans until empty, puncture and drain– For leftover paint, use it or give it away, don’t

throw it away• Conserve Thinners

– Reuse thinner until it becomes thick with paint residues

– Consider disposable brushes to reduce thinner usage

UW Requirements- Accumulation-

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• Must have designated accumulation area(s) for each Universal Waste Subset accumulated at your facility.– May designate with a sign or the

guidance sheet from Universal Waste Management Plan

• Designated area must beout-of-the-way so as to prevent breakage or damage of Universal Waste(s)

Universal Waste- Lamps -

Common Universal Waste Accumulation Areas

• Satellite Locations– Custodial / housekeeping closets– Shops– Basements– Mechanical rooms– Near building manager offices

• Central Accumulation– Adjacent to hazardous waste central accumulation

area– Physical Plant Storage Building

UW Requirements- Containers -

• Containers Must Be:– Labeled– Dated– Compatible– Kept closed– Able to reasonably

prevent releases if internal contents are broken or leaking

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Universal Waste- Lamps -

UW Requirements - Labels -

• Label must state:Universal Waste – ********Container Start Date: ____

• Pesticides require the original manufacturers or other state approved label in addition to the Universal Waste Label (Consult your Compliance Manager)

Example Label

UNIVERSAL WASTEBATTERIES

LAMPS

MERCURY-CONTAINING EQUIPMENT

PESTICIDES

PAINT & PAINT-RELATED WASTES

Container Start Date: ____________TEXAS & FEDERAL LAW PROHIBIT IMPROPER

DISPOSALTHESE MATERIALS ARE REGULATED BY 40 CFR §273

AND 30 TAC §335.261 & 262

SHIPMENTS MUST COMPLY WITH APPLICABLE U.S. DOT REGULATIONS (49 CFR Parts 172 – 180)

HANDLE WITH CARE!

Alternate Universal Waste Label

UNIVERSAL

WASTE

CONTENTS ________________________

NUMBER PER CONTAINER __________

CONTAINER START DATE ___________

SHIPPER ____________________________________________________________

UW Requirements- Shipping of UW -

• Must package, label, mark and placard the shipment in accordance with DOT regulations

• Must use a qualified Universal Waste Transporter for transportation of Universal Wastes

• Must ship to:– A Universal Waste Handler– A Universal Waste Destination Facility

UW Requirements- Recordkeeping and Notification -

• Must keep shipping papers for three years

• Must be able to prove annual accumulation quantities. – May use a tracking form (preferred), or – Maintain shipping papers

• Prior to accumulating 11,000 lbs of Universal Waste at any time, you need to notify the EPA using EPA Form 8700-12.(Consult your Compliance Manager for further information)

Responding to a Spill or Breakage

• If conditions are deemed safe, immediately contain the release and over pack any leaking containers

• Clean up released material

• You may not place released material or broken, leaking items back into the container with Universal Waste -– A hazardous waste determination must be conducted on the

released material. – If it is found to be hazardous it must be handled as a hazardous

waste rather than as a universal waste.

Always use proper safety precautions

For Further UW Guidance

• Universal Waste Management Plan

• Compliance Manager– Gordon Evans, A&M System Environmental

Manager, or– Your EH&S Manager / Safety Officer

• Texas Universal Waste Regulations– 30 TAC §335.261 - Universal Waste Rule– 30 TAC §335.262 - Standards for Management

of Paint and Paint-Related Waste