Universal Waste Management Training

1. Universal Waste Management Training The Texas A&M University System Environmental, Health & Safety

2. 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

3. Pesticide 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

4. 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 Rules for “Universal Waste Handlers” (Differ from RCRA Hazardous Waste Generator Rules)

5. 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-lampings Building demolitions Challenges Tracking wastes scattered among many locations Keeping track of the 1 yr time limit Rules for “Universal Waste Handlers”

6. What is a Universal Waste- Batteries - • Many types must be managed 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

7. Look for the Recycling Seal

8. Look for the seal Recycle Rechargeable Batteries and Cell Phones CAUTION Bag all batteries, one per bag, and place in box. FIRE DANGER if battery terminals touch!

9. Rechargeable Battery Recycling

10. How to Recycle Rechargeable Batteries & Cell Phones Step 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

11. Example Battery Recycling Poster from Tarleton State University

12. 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

13. What is a Universal Waste- Lamp(s) - • Fluorescent (Hg) • Halogen (Hg) • Metal Halide (Hg) • High/Low Pressure Sodium (Hg) • Mercury Vapor (Hg) • Incandescent (Pb)

14. 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

15. What is Universal Waste -Mercury-Containing Equipment- • Thermostats may be handled and labeled separately as Universal Waste – Mercury Thermostats

16. What is a Universal Waste- Pesticide(s) - • The Universal Waste Regulations for pesticides are limitedto • Recalled pesticides subject to FIFRA procedures, and • 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.

17. May include: Used or unused paint Spent solvents used in painting PPE from painting Paint removal wastes Paint filters Only 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 What is a Universal Waste - Paint & Paint Related Waste - (Texas Only) 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

18. 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

19. - Lamps 07/14/08 Universal Waste - Lamps Universal Waste - Lamps Container Start Date: 12/05/08 Container Start Date: 10/17/08 - Lamps 04/23/08 UW Requirements - Accumulation- Universal Waste - Lamps - • 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 be • out-of-the-way so as to prevent breakage or damage of Universal Waste(s)

20. 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

21. Universal Waste - Batteries 12/05/00 - Lamps 07/14/08 Universal Waste - Lamps Universal Waste - Lamps Container Start Date: 12/05/08 Container Start Date: 10/17/08 - Lamps 04/23/08 UW Requirements - Containers - • Containers Must Be: • Labeled • Dated • Compatible • Kept closed • Able to reasonably prevent releases if internal contents are broken or leaking Universal Waste - Lamps -

22. 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) UNIVERSAL WASTE BATTERIES LAMPS MERCURY-CONTAINING EQUIPMENT PESTICIDES PAINT & PAINT-RELATED WASTES Container Start Date: ____________ TEXAS & FEDERAL LAW PROHIBIT IMPROPER DISPOSAL THESE 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! UW Requirements - Labels - Example Label

23. UNIVERSAL WASTE CONTENTS ________________________ NUMBER PER CONTAINER __________ CONTAINER START DATE ___________ SHIPPER ____________________ ____________________ ____________________ Alternate Universal Waste Label

24. 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

25. 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)

26. Responding to a Spill or Breakage • If conditions are deemed safe, immediately contain the release and overpack 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

27. For Further UW Guidance • Universal Waste Management Plan • Compliance Manager • Gordon Evans, A&M System Environmental Manager, or • Jay Abbt & Daron White, PVAMU Environmental Health & Safety Dept • Texas Universal Waste Regulations • 30 TAC §335.261 - Universal Waste Rule • 30 TAC §335.262 - Standards for Management of Paint and Paint-Related Waste