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Universal Waste Management

Happy Monday!
Just wanted to share an observation with you all that I put together while I was on the plane heading to Boston from Chicago last Friday.

Based on my nationwide EMS, OHSAS, electronic waste and EHS regulatory compliance audit experience and trips, it appears that many companies struggle with universal waste management, specifically the storage requirements. Comparing to other more complex environmental regulations, universal waste is actually pretty simple.

Take a look below and let’s prevent potential regulatory violations and management systems nonconformities.

Universal waste regulations have been promulgated by the EPA to ease the management burden and promote the collection and recycling of some commonly generated wastes.

Federal universal waste regulations are listed under 40 CFR 273.

Universal waste streams are:
Batteries
Lamps
Pesticides
Mercury-containing equipment

Don’t forget, each state may have their additional waste streams in addition to the federal program.

Here are some of UW requirements:
Storage requirements:
– Covered, structurally sound containers
– Can store only for a year

Labeling requirements:
– Follow the regulatory verbiage, there are three options:
1- Universal waste lamps (or batteries or other)
2- Waste lamps or
3- Used lamps
– Accumulation begin date: Mark the date when a universal waste item has been discarded on the container.
( If you have other ways of demonstrating that such as inventory, log sheet etc. that’s ok too)

Handler status:
1- Identify whether your facility is a small or large quantity handler:
2- If you accumulate 5000 kg or more universal waste, you are a LQHUW.
3- Train your employees
4- Ship off the universal waste within one year

These were UW management requirements in a nutshell. There are more details of course. Please refer to the actual most current regulations for details on each item listed here. Always, always, always check your state specific requirements!

This link might help with the state requirements:
http://www.epa.gov/osw/hazard/wastetypes/universal/statespf.htm

Folks, remember this post is not meant for legal advice. This is my interpretation of the above mentioned regulations. Always refer to the most current version of the actual regulations and/or consult with your attorney for legal advice.

Shoot me an email if you have any questions.

Have a positive and productive week!

Mel
meldegregorio@greenupconsultants.com

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