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Printers'
National Environmental Assistance Center |
Fact Sheet |
www.pneac.org 1-888-US-PNEAC |
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Universal Waste Rules and How They Affect a Printer
By Debra F. Jacobson
Introduction
The Universal Waste
Rules (UWR's) were promulgated by U.S. EPA on May 11, 1995. The UWR's regulate
and encourage recycling of hazardous waste nickel-cadmium and other batteries,
certain types of waste pesticides, mercury containing thermostats and HID lamps
(mercury vapor, metal halide, and high pressure-sodium).
The goal of the UWR's
is to encourage resource conservation while adequately protecting human health
and the environment; improving the EPA's current hazardous waste regulatory
program and provide individuals and organizations incentives to collect
unregulated portions of these waste streams and manage them the same way the
regulated wastes are, thereby removing these wastes from the municipal waste
stream (keep them out of the landfills). The Universal Waste classification can
help reduce the amount of reportable hazardous waste a printer generates.
There are two types
of universal waste handlers – large quantity handlers and small quantity
handlers of universal waste. These classifications are similar to the hazardous
waste generator classifications. A small quantity handler of universal waste
(SQHUW) is one that stores less than 5,000 Kg or about 11,000 lbs of universal
waste (all types combined) on any given day during the calendar year; a large
quantity handler of universal waste is one that stores greater than 5,000 Kg of
universal waste on site. For the purpose of this fact sheet the focus will be
on requirements applicable to Small Quantity Handlers of Universal Waste
(SQHUW) rules because it is unlikely that any printer in the United States
would be classified as a LQHUW.
SQHUW means a person
who uses batteries, pesticides, thermostats, and HID lamps, and who
eventually decides they are no longer usable and thus are waste. Contractors or
repair people who decide that these items are no longer usable and remove them
from service are also considered handlers of universal waste.
SQHUW's are not
required to notify EPA of their universal waste activities (no initial, annual,
or biannual report required) and they are not required to obtain an EPA waste
generator identification number as long as they do not store 5,000 Kg (~11,000
lbs) of universal waste on site at any given time. (40 CFR 273.32) Note, if a
facility is generating other types of hazardous wastes they are still required
to notify EPA and obtain an I.D. #.
SQHUW's are required
to provide basic handling and emergency action information/training to
employees who handle universal wastes. In the case of a release, handlers are
required to immediately contain (prevent spread or additional spillage) and
handle/neutralize residues appropriately. They are also required to comply with
all OSHA employee handling and exposure regulations. These requirements are
analogous to those currently required for small quantity generators of
hazardous waste. Any training provided under other programs that meets any or
all of the training requirements of Part 273 of RCRA regulations may be used to
fulfill this requirement. You need only add a reference to 40 CFR Part 273 to
the training documentation.
The amount of
universal waste a printing facility generates does not count towards their
monthly quantity of RCRA hazardous waste determination. In other words the
amount of universal waste generated should not be counted towards the total
amount of hazardous waste generated monthly. Universal waste does not impact
your hazardous waste generator status.
Labeling Requirements
Universal waste is
subject to DOT packaging and shipping label requirements, however when the
waste does not require a hazardous waste manifest many of the DOT labeling
requirements do not apply. Universal waste and/or containers of universal waste
must be labeled at all times. The waste must be labeled as follows depending on
the type of universal waste:
Generators can
accumulate waste on site for up to one year. Beyond one year the generator must
prove to the EPA that the reason for storing the waste longer is for the sole
purpose of facilitating proper recovery, treatment, or disposal of the waste
(see 40CFR 273.15(b) & 273.35(b)). Generators (SQHUW's)
can take/send their universal waste only to a consolidation point, destination
facility, or foreign destination. The generator (SQHUW) also must receive confirmation/approval
from the receiving facility prior to sending the universal waste to their
facility. (See 40CFR 237.18(a) and 273.38(a)). The facility the
universal waste is sent to (destination facility) whether it be for recycling
or treatment and disposal, must be in compliance with 40CFR parts 264, 270, and
261.6(c)(2). In other words the destination facility must be properly permitted
to accept the specific universal waste you are sending for treatment or
recycling. If a shipment of
hazardous waste, which is not considered universal waste, is shipped to another
handler or destination facility, the receiving facility is required to notify
the regional EPA office immediately. The receiver is required to provide the
name, address, & phone number of the shipper. The EPA will provide
instructions for managing the hazardous waste should this occur. SQHUW's offsite
shipments of universal waste do not require a hazardous waste manifest or other
record keeping. Record keeping is required for LQHUW's. (See 40CFR 273.39 &
273.62) In general, it is recommended that simple documentation of quantities
of universal waste shipped off site be maintained by SQHUW's in order to
track/document your generator status. Under the universal waste regulations
generators of universal waste still must comply with all of the land disposal
restriction regulations found in 40CFR 268. Facilities who
generate 220 lbs/month (<100 Kg) or less of universal waste have the option
to manage their waste under the Conditionally Exempt Small Quantity Generator
provisions of 40 CFR 261.5 rather than the universal waste regulations (or the
full Subtitle C regulations). The majority of
Universal Waste generated by a printing facility will be mercury-containing
lamps/bulbs. However other universal wastes such as lead/acid batteries from
industrial lift trucks, etc. may also be generated. Below is a table that
references some of the common sources of Universal Waste at a printing
facility. Waste Description Source Mercury Containing
Bulbs Ambient Light
Fixtures Mercury Containing
Bulbs UV Curing Equipment Lead/Acid Batteries Lift
trucks/equipment Nickel/Cadmium
Batteries Phones, Radios,
etc. Lithium Batteries Phones, Radios,
etc. Thermostats -
Ambient Temp Controls (contain mercury) Facility
Maintenance Thermostats
(contain mercury) Pre-press equipment If you are unsure
whether the bulbs you are using contain mercury and are regulated by the
Universal Waste rules the manufacturer or supplier can advise you. Many bulb
manufacturers are now supplying environmentally preferable bulbs which are not
considered hazardous, meaning they are not considered Universal Waste. Most bulb recycling
facilities specify preferred packaging for the bulbs. The most common request
is to store and ship the bulbs in their original packaging. In fact some bulb
recyclers offer discounts on handling and recycling fees if the bulbs are
provided in their original package. Alternative, commonly high density plastic,
bulb storage containers can be purchased as well. Additionally, if possible, it
is best to keep the bulbs intact (unbroken) so that the recycling facility can
recover a greater percentage of the materials. Broken bulbs also create an
increased environmental hazard because the mercury could easily leak out of the
packaging the broken bulbs are stored in. For more information
about Universal Waste see the EPA's web site at www.epa.gov/epaoswer/hazwaste/id/univwast.htm
or contact your state environmental regulatory agency (http://www.pneac.org/contacts/stateregcont.html)
for information about state-specific rules and guidelines regarding Universal
Waste. Author: Debra
Jacobson Waste Management and Research Center 630.472.5019 For
additional information about compliance issues or pollution prevention
opportunities in the printing industry visit the PNEAC web site at www.pneac.org. Specific questions about technology, equipment, vendors can
be posted on the PrinTech listserv. To subscribe, simply follow the
instructions on the PNEAC web site at www.pneac.org. For more information or to contact someone from PNEAC please
visit www.pneac.org and post your request
using “Ask PNEAC”. PNEAC Contacts: Gary Miller Waste Management and Research Center 217.333.8940 Debra
Jacobson Waste Management and Research Center 630.472.5019 Wayne
Pferdehirt Solid
& Hazardous Waste Education Center 608.265.2361 Gary A. Jones Manager, Environmental, Health, and Safety Affairs Graphic Arts Technical Foundation Written: November 16, 1999 Revised: September 8, 2005 Reformatted: January 31, 2006 Note: Reasonable effort has been made to review and verify
information in this document. Neither PNEAC and its partners, nor the technical
reviewers and their agencies, assume responsibility for completeness and
accuracy of the information, or its interpretation. The reader is responsible
for making the appropriate decisions with respect to their operation, specific
materials employed, work practices, equipment and regulatory obligations. It is
imperative to verify current applicable regulatory requirements with state
and/or local regulatory agencies. © 2006
PNEAC
Storage & Accumulation
Off-site shipments
Record-keeping & Tracking
CESQG's & Universal Waste
Universal Waste Commonly Generated at a Printing Facility
Determining & Handling Your Universal Waste Bulbs