SOP 4.18:Universal Waste Management

Contents

1.Introduction...... 1

2.Regulatory and contractual requirements...... 1

3.Health and safety precautions...... 1

4.Standard procedures for managing Universal Waste...... 2

Attachment A: Example Shipping Paper...... 5

1.Introduction

Collection of Universal Waste (UW) facilitates environmentally sound disposal and proper recycling. “Universal” is a term used to describe specific wastes that may be managed in accordance with reduced RCRA regulations. Collection of UWby this Program is optional and if accepted, may be commingled with HHW.Most HHW facilities will fall into the category of “small quantity handler” of UW. A small quantity handler stores no more than 5,000 kg (11,000 pounds) of UW on-site at one time.

UW includes dry cell batteries, pesticides, fluorescent lamps, and mercury-containing equipment (e.g., liquid mercury, thermostats, switches, thermometers, relays, manometers, barometers, thermocouples, dental amalgams, gauges).In this SOP, the term “shipping paper” includes other waste shipment tracking documents which may be referred to as a “waste-tracking invoice” or “DOT shipping paper.”

2.Regulatory and contractual requirements

UW management is allowed at HHW facilities in accordance with theOperational Contract Between a HHW Program and the State;Minn. Rules pt. 7045.0575 through 7045.0585, and the Federal and Minnesota UW Rule 7045.1400.§§273.14, 273.34, §273.15(c)(1), §273.35(c)(1),§273.15(c)(2), §273.35(c)(2), §273.15(c)(3), §273.35(c)(3), §273.15(c)(4), §273.35(c)(4)), §273.15(c)(5),§273.35(c)(5), §273.15(c)(6), and §273.35(c)(6). See U. S. EPAfact sheet on Universal Waste: hazwaste/id/univwast/basic.htm and MPCA fact sheet

3.Health and safety precautions

3.1Requirements

3.1.1This Program is responsible for proper UW recycling or disposal. Staff shall be trained on proper acceptance and management ofUW.

3.1.2Staff shall ensure proper ergonomic techniques are being followed while processing UWto avoid injury; see SOP 2.11 Ergonomics.

4.Standard procedures for managing UW

4.1Reduced hazardous waste (HW)management requirements

UWis allowed to be managed following these reduced requirements:

  • Small quantity handlers are not required to report to EPA for accepting UW if accumulation limits are below 5,000 kilograms of any one UW type.
  • businesses are not required to obtain anHW generator license if accumulation limits are below 5,000 kilograms of any one UW type.
  • a shipping papermay be used in lieu of a HW manifest for shipments containing only UW.
  • a business may transport UWto this Facility usinga business or personal vehicle.

4.2Recordkeeping

4.2.1An HW manifest is not required for shipments of UW. If a shipping paper is provided, it shall contain the following information:

  • name and address of the originating UW from whom the waste was sent.
  • description of the materials shipped.
  • the quantity of each type of UW shipped.
  • shipment receiving date; see Attachment A of this SOP.

4.2.2If this Facility partners with a recycling network (e.g.,Rechargeable Battery Recycling Corporation-RBRC), shipping papers for shipments of UW within those consolidation networks are not required. These networks may require their own paperwork to accompany shipments.

4.2.3A Facility receipt shall be provided if participants are charged a UW disposal fee.

4.2.4Keep copies of UW-tracking documents for at least 3 years from the date of issuance.

4.2.5A tally shall be retained for household and non-household UW received to ensure storage limits for small quantity handlers are not exceeded.

4.2.6Report annual collection of UW as required by the State.

4.3Processing UW

4.3.1Waste packaging. UWshall be packaged following the state-contracted HW disposal company or specific recycling company guidelines. All containers shall be packaged to sufficiently contain the waste at all times during transport. Some UW (e.g., batteries and thermostats) may only find a sturdy cardboard box or poly pail is sufficient to meet this standard, while other waste types may require a metal or poly container. See SOP 4.4 Waste Packaging.

4.3.2Container storage. UWshall be stored in designated Facility areas sufficient to contain the waste and components of the waste at all times; see SOP 4.11 Waste Storage.

4.3.2.1Marking containers in storage. UW containers shall containapplicable DOT shipping labels and/or marked to identify the type of waste. Markings shall be provided on the waste itself or the container in which the waste is contained.Label or mark the UW to identify the type of waste or a short description of the waste, followed by the words “for Recycling”. For example:

  • Battery containers destined for recycling shall be marked with the words “Batteries for Recycling”or“UW—Batteries” or “Waste Batteries.”
  • Pesticides containers accepted for HW disposal shall be marked with the words“UW-Pesticides” or “Waste Pesticides.”
  • Thermostatscontainers destined for recycling shall be marked with the words“UW–Mercury Thermostats” or “Waste Mercury Thermostats” or “Used Mercury Thermostats.”

4.3.2.3Accumulation time limit.The Facility shall be able to demonstrate the length of time that UW has been accumulated since it became a waste or was received. Examples include:

  • Mark or label aUW in a container with the earliest date that any UW in the container became a waste or was received.
  • Marking or labeling the individual item of UW with the date it became a waste orwas received.
  • Maintaining an inventory system on-site that identifies the earliest date any UW in a group of UW items or a group of containers of UW became a waste or was received.
  • PlaceUW in a specific accumulation area and identify the earliest date that any UW in the area became a waste or was received.
  • Approve in advance any other method by the Regional Administrator or the State Director.

4.3.3Product exchange or reuse. Pesticides shall not be placed on product exchange or reuse shelves if they are prohibited, banned, or restricted for use. Restricted-use pesticides may only be given to people certified by MDA to apply restricted use products. See SOP 4.18 Ag-Generated Pesticides. All other usable UW materials received may be placed in the product reuse area.

4.3.4Treatment of UW.This Facility is prohibited from disassembling items defined as UW or from treating the waste; the following activities are not considered treatment:

  • responding to a release
  • activities associated with accumulating or bulking wastes
  • separating batteries by chemistry
  • discharging batteries
  • removing batteries from products or battery packs
  • clipping the mercury ampule out of mercury-containing devices

4.3.5Transporting and off-site management ofUW

4.3.5.1Highway shipments of UWshall be secure.

4.3.5.2Statecontracts and UW recycling networks (e.g., RBRC, TRC) are available for UW management.

4.3.5.3If shipping via the United States Postal Service, this Facility shall ship in compliance with all United States Postal Service requirements.

4.3.5.4The Facility shall comply with DOT transportation requirements.

4.3.5.5If shipping to a foreign destination, this Facilityshall comply with all requirements applicable to HW exports.

Attachment A

HHW Program Shipping Paper

This paper and any attached papers must accompany your shipment.

Only those wastes listed may be transported.

Generator name: / Collection program name and site address:
Address:
HW ID #:
Emergency contact information
Name:
Phone number:
Shipping description / Packing type & count / Total quantity
(List units of measure)

Certification:I hereby declare that the contents of this consignment are fully and accurately described above by proper shipping name and are classified, packed, marked, labeled and are in all respects in proper condition for transportation by highway according to applicable national and international government regulations.

Company rep name: (print) ______(sign) ______Date ______

Driver name: (print) ______(sign) ______Date ______

Date of acceptance by carrier: ______

Certification: I certify I have received the waste listed on this shipping paper.

Program rep: (print) ______(sign) ______Date ______

4.18 Universal Waste ManagementEffective date 10/14/20081