Universal Waste: Bulbs, Batteries, Bugs and Barometers
by Mike King
For many years, most hazardous waste generators tossed burned out fluorescent bulbs, scrap rechargeable batteries and unneeded mercury-containing devices like mercury switches into the dumpster along with other plant trash.
Most did not realize that these wastes are often hazardous wastes and, as such, must be treated or disposed in a specially permitted RCRA (Resource Conservation and Recovery Act) facility.
Also for many years, regulatory agencies tacitly allowed this practice to continue. Many had formal polices that it was OK to toss spent fluorescent bulbs into the dumpster as long as the number of bulbs was kept small.
In the 1990s, EPA decided to get control of these hazardous wastes. EPA acknowledged that the nature of these wastes was unique. These wastes are generated by a wide variety of businesses (many of which generate no other hazardous wastes), and these wastes are often generated in relatively small quantities. EPA decided it needed to get creative in order to encourage generators to handle these wastes responsibly.
So in 1995, the EPA carved out a special class of hazardous waste and adopted a streamlined set of management standards to encourage compliance. EPA called these wastes "universal wastes" and the relaxed management standards: the Universal Waste Rule.
Initially, EPA only included three types of hazardous wastes in the universal waste category, but later the list was expanded and now includes:
* Burned-out light bulbs ("lamps"), such as fluorescent, mercury vapor, sodium vapor, neon, metal halide and "high intensity discharge" lamps.
* Batteries such as nickel cadmium, silver oxide, nickel metal hydride, sealed lead acid and lithium.
* Mercury-containing devices such as thermostats, barometers, thermometers and mercury switches.
* Expired, collected or recalled pesticides.
EPA allows facilities that generate these types of wastes in small quantities (called small quantity handlers or "SQHs") to accumulate them onsite for up to one year: far longer than the maximum time limits for conventional hazardous wastes. Further, SQHs have increased flexibility in shipping these wastes offsite. These wastes do not have to be sent directly to a permitted RCRA facility. They can be sent to another SQH or an LQH for bulking into large volumes. This often results in reduced shipping, treatment and recycling costs. Additionally, these wastes can be self-transported or transported by any commercial carrier. The SQH does not need to hire a specially permitted hazardous waste transporter.
EPA also allows individual states that administer the Universal Waste Rule to add their own wastes to this list. Several states have taken advantage of this opportunity and added wastes such as cathode ray tubes (computer monitors), scrap electronics and waste pharmaceuticals.
A facility the produces these types of wastes may manage them as universal wastes if they elect to do so. In brief, the facility must comply with the following primary requirements:
1. Accumulate the wastes onsite in secure, designated area(s).
2. Place breakable or damaged wastes in sturdy, leak-tight containers.
3. Label the wastes or the containers to identify the type of waste.
4. Track onsite accumulation times.
5. Clean up spills or leaks quickly and properly manage the cleanup wastes.
6. Train the employees who manage these wastes.
7. Ship the wastes offsite to an appropriate receiving facility
There are other requirements that may apply and any facility should check its state regulations. However, facilities ranging from manufacturers to retailers to government operations to hospitals and schools are increasingly adopting universal waste programs. Universal waste programs take advantage of streamlined management standards and are often useful in complying with landfill bans that affect some of these wastes.
This trend toward universal waste programs is expected to continue to expand in popularity and scope.
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