Universal waste disposal is certainly a formidable word and for your small company, it may seem daunting to even think of the rules and regulations behind disposing of this type of hazardous waste; especially if you have one employee who is juggling this aspect of your company along with numerous other tasks. Let's see if we can help!
First, let's discuss what exactly the state of California deems universal waste, or rather common hazardous waste which is hazardous waste that is frequently produced by households and businesses.
The following can be considered universal waste:
- Electronic devices
- Electric lamps
- Mercury-containing equipment
- CRTs and CRT glass
- Non-empty aerosol cans
These items range from televisions, portable DVD players, fluorescent light bulbs, picture tubes from computer monitors or glass from these monitors that has been broken up for recycling. None of these items are allowed to just be placed in the trash.
The Department of Toxic Substance Control for the state of California has regulatory standards set for universal waste. There are three types of regulated entities: Universal Waste Handlers, Universal Waste Transporters, and Destination Facilities.
Let's delve into each of these categories briefly and discuss where your business fits!
Universal Waste Handler
Is normally a generator of hazardous waste, usually a owner or operator of a facility that accumulates universal waste, receives universal waste from another facility, or accumulates and sends this waste to another facility. Including but not limited to:
- A household or business that generates universal waste but does not accept it from other people or businesses.
- A person or business that accepts universal waste and accumulates it at his or her own facility.
- A person or business who performs treatment and recycling of hazardous waste allowed by the universal waste handler regulations.
A universal waste handler must:
- Obtain an EPA identification number or contact DTSC.
- Determine which material being recycled/treated is hazardous material and use proper containment after segregating hazard waste in distinct areas of their facility.
- If needed, comply with zoning requirements when storing hazardous waste.
- Use proper labeling and markings.
- Avoid storing hazardous waste for longer than one (1) year.
- Provide training to personnel who manage and/or supervise those who handle universal waste and keep all records of training.
- Must keep record of deliveries and shipments of universal waste for up to three (3) years.
Universal Waste Transporter
Are companies or persons engaged in transportation off-site of universal waste by airway, railway, highway or water. This may be a person transporting universal waste via personal vehicle, a shipping service such as FedEx, UPS, or USPS.
Transporters are also hauling companies who specialize in hauling only universal waste with a destination facility that offers a special hazardous waste pick-up and general trucking companies.
It's important to note that if your company does not store but only transports universal waste your business is still considered a universal waste transporter.As a transporter there is no need to notify DTSC or submit annual reports for transport activity.
Your company, being a transporter, is only allowed to hold universal waste for up to ten (10) days at a zoned facility before you will fall into the category of "handler".
Are fully-regulated hazardous waste facilities that treat, dispose of, and/or recycles a specific type of universal waste. These will include recycling facilities and hazardous landfills. Facilities must manage the universal waste strictly related to the California Code of Regulations unless they are otherwise authorized.
Destination facilities are required to follow specific rules for shipping off-site including rejected shipments. As a facility you are required to keep records of all shipments received for three (3) years. If your company only accepts and accumulates hazardous waste, you are considered a handler.
So now that we've discussed the different types of businesses or persons involved in universal waste, let's discuss exemptions. There are two types of universal waste handlers that are not bound to regulatory laws regarding log keeping of waste, labeling or obtaining an identification number from the EPA.
- Households defined as single residences, apartments or condominiums who do not dispose of or conduct treatment of hazardous waste material, but dispose of them properly according to the regulations of the U.S. Environmental Protection Agency. These wastes include but are not limited to: motor oil and paint substances.
- Conditionally Exempt Small Quantity Universal Waste Generator (CESQUWG) defined as a producer of <100kg (220lbs) of hazardous waste. CESQUWG's also can not conduct treatments or recycling, rather they must ship off the universal waste to a facility for disposal.
Managing universal waste can appear intimidating, but hopefully we have outlined some basics for you so that you will feel more confident in the way your business handles such responsibilities and relieve some of the stress of your employees who supervise this area of your company.