management of universal waste in iowa & illinois

IDENTIFICATION AND MANAGEMENT OF UNIVERSAL WASTEThe applicable regulatory requirements of the US DOT, US EPA, Iowa DNR, and Illinois EPA.

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The 2013 Iowa-Illinois Safety Council Expo

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Daniels Training Services815.821.1550www.DanielsTraining.comInfo@DanielsTraining.com

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It’s important to first understand which State and Federal agencies have authority over these regulations and how they impact compliance.

The regulatory agencies

@DanielsTrainingID & Management of Universal Waste

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Universal Waste RegulationsIowa:

US EPA Region VII

Illinois:

IEPA

ID & Management of Universal Waste

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Transportation of Universal Waste

• USDOT/PHMSA regulates the transportation of hazardous materials (HazMat).

• Not all UW are HazMat.


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In order to understand the universal waste regulations, you must know the basis for and the purpose of the hazardous waste regulations.

An introduction to the hazardous waste regulations


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The Hazardous Waste Determination

• The generator of a waste, any waste, must determine what, if any, hazards it contains.

• This process must be documented and records retained.


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What is a USEPA Hazardous Waste?

D001

F-CodesK-Codes

P & U Codes

D004-D043D003

D002


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What is Cradle to Grave?

• If you generate a hazardous waste, regulations are applicable throughout its lifecycle.

FOREVER!!!


@DanielsTraining 11ID & Management of Universal Waste

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The universal waste regulations were created to provide generators of hazardous waste with an option for management of certain hazardous waste. This section will address the purpose of universal waste and its place within the RCRA regulations. Later we will discuss specific universal waste management requirements.

An introduction to the universal waste regulations


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The Four (4) USEPA Universal Waste

1. Batteries

2. Lamps

3. Mercury-containing devices

4. Recalled or canceled pesticides


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Any more USEPA Universal Waste?

• US EPA may add to this list.

• States may create their own Universal Waste.


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Any More UW in Illinois or Iowa?

Illinois has not expanded the USEPA list of Universal Waste

Iowa follows USEPA regulations


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Conditions for use of theUniversal Waste Option1. Must be a waste.

• Used, spent, to be discarded, no longer acceptable for its intended use, etc.

2. Must be a hazardous waste.

3. Additional considerations for Pesticides.


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If you choose the universal waste option for the management of your hazardous waste, you must ensure you are in compliance with the applicable State and Federal regulations

On-site management of universal waste


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Universal Waste – Handler StatusSmall Quantity Handler

• Generate or receive for consolidation.

• Accumulate <5,000 kg of Universal Waste.

Large Quantity Handler

• Generate or receive for consolidation.

• Accumulate ≥5,000 kg of Universal Waste.

Transporter

• Transport and store at Transfer Facility for ≤10 days.

Destination Facility

• Recycle, treat, or dispose.


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Notification to State or USEPA

Small Quantity Handler

• USEPA ID # not required.


• USEPA ID # required.


Use the 8700-12 Form

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Employee Training


• Inform employees of proper handling and emergency procedures.


• Ensure all employees are “thoroughly familiar” with proper waste handling & emergency procedures.


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Tracking Off-Site Shipments


• Not required to track off-site shipments.


• Must track off-site shipments.• Name & address of destination.

• Quantity & type of each UW.

• Date shipment left.


Retain records for 3 years

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Universal Waste Handler Prohibitions

• May not dispose, treat, recycle, or dilute Universal Waste.• Some on-site management allowed.

• Must manage to prevent a release to the environment.


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Requirements in the Event of a Spill

• Immediately contain all releases of UW.

• Spilled UW may no longer be subject to management as universal waste.• May be a hazardous waste.


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Universal Waste On-Site Accumulation Time Limit• One year of on-site accumulation.• “Longer if solely to facilitate disposal.”

Translation: You may wait until you have enough UW to justify a shipment


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You Must Label Universal Waste

• “Universal Waste

“• “Waste “

• “Used “

• Variations allowed for:• HG-Thermostats• Pesticides


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Off-Site Shipments of Universal Waste• Uniform Hazardous

Waste Manifest not required.

• Must determine if it’s a DOT HazMat.

• Must ship to another UW Handler or Destination Facility.

• If you self-transport UW, must comply with Transporter regulations.


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Though very similar, each type of universal waste has its own regulations which may differ in how you may manage the waste on-site.

Specific requirements for the management of universal waste


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What is a Universal Waste Battery?

• Includes:• NiCad, lead acid, lithium, mercury, silver, etc.


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What isn’t a Universal Waste Battery?

• Doesn’t include:• Non-hazardous (alkaline) batteries.

• Lead acid batteries being reclaimed.


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Lead Acid Batteries for Reclamation

• Manage according to the lead acid battery exemption for recyclable materials @ 40 CFR 266.80.


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Management of Universal Waste Batteries• Containers needed only if evidence of leakage.

• Bag batteries or tape terminals for shipment to meet USDOT/PHMSA requirements.


UniversalWaste

Batteries

4.12.13

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Why Tape Battery Terminals?

• If terminals contact during shipment, the heat from a residual charge is enough to cause vehicle fires.


Batteries = HazMat

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More Management Options for UW Batteries (1.0)• Handler (Large or Small) may conduct any of the following (next slide), as long as:• The casing of each battery cell is not breached, remains intact, and closed, except…

• Cells may be opened to remove electrolyte but shall be immediately closed after removal.

Next slide


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More Management Options for UW Batteries (2.0)• Allowable on-site management (see previous slide):• Sort batteries by type.• Mix battery types in one container.• Discharge electric charge from batteries.• Regenerate used batteries.• Disassemble batteries or battery packs.• Remove batteries from consumer products.• Remove electrolyte from batteries.


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What is a Universal Waste Mercury Containing Device?• Device or part of a device with elemental mercury integral to its function

• Includes:• Thermometers, thermostats, switches, gauges, more...


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What isn’t a Universal Waste Mercury Containing Device?

• Doesn’t include:• Liquid metallic mercury.

• Spill clean-up.• Batteries.• Lamps.


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Management of Universal WasteMercury-Containing Devices

• Containers needed only if evidence of leakage.

• Non-metallic container with tight-fitting lid recommended.

• Spill kit recommended.


UniversalWaste

MercuryContaining

Devices

4.12.13Hg Devices may be HazMat

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Alternate Labeling for UW Thermostats

• “Universal Waste – Mercury Thermostats”

• “Waste Mercury Thermostats”

• “Used Mercury Thermostats”


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More Management of UWMercury-Containing Devices

• Handler may remove Hg-containing ampules, if:• Remove in a manner designed to prevent breakage.• Remove only over or in a containment device.• Hg clean up system readily available.• Transfer spilled Hg to approved container.• Area is well ventilated and monitored.• Employees “thoroughly familiar” with Hg handling and spill response.

• Removed ampules stored in closed, non-leaking containers in good condition with packing materials to prevent breakage.


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What is a Universal Waste Lamp?

• Bulb or tube of electric lighting device.

• Includes:• Fluorescent, HID, high pressure sodium, neon, mercury vapor, metal halide, etc.


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What isn’t a Universal Waste Lamp?

• Doesn’t include:• Incandescent.• “Green Cap” fluorescents.


“Green Caps” still contain Mercury

Management of UW Lamps

• Container with lid required.

• Incidental breakage (~<5%) OK if contained properly.

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Intact Lamps ≠ HazMat

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The use of this option will vary by state. This presentation will look at the requirements for use of this option in Illinois and Iowa.

Crushing of universal waste lamps


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Crushing of UW Lamps

Iowa

• Not allowed under UW regulations.

• Deliberate crushing must be managed as a hazardous waste.

Illinois

• OK, with conditions.


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Illinois: Mercury Emissions

• Must be crushed in a closed system designed and operated so that any emission of mercury ≤0.1 mg/m3 TWA over 8 hours.

• Crushing area well-ventilated and monitored to comply with OSHA exposure levels for mercury.


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Illinois: Quarterly Notification

• Use form provided by IEPA, must include:• Name & address of handler.• Estimated amount of lamps crushed/month.• Technology of crushing, including:

• Certification or testing data from manufacturer that emission controls of IL regulations are met.


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Illinois: Containers for Crushed Lamps

• Closed.• Non-leaking.• Suitable to prevent release during storage, handling, and transportation.

• Good condition.• Not acceptable:

• Severe rusting.• Apparent structural defects or deterioration.


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Illinois: Spills or Leaks

• Immediately transfer spills or leaks to container meeting requirements of 35 IAC 722.134 (IL hazardous waste regulations).

• Must have equipment necessary for this transfer available.


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Illinois: Employee Training

• Ensure employees crushing lamps “thoroughly familiar with proper waste mercury handling and emergency procedures, including transfer of mercury from containment devices to appropriate containers.”


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Though a “Universal Waste”, it is of little use to those outside of the pesticide manufacturing industry. A summary of the regulatory requirements follows.

Recalled or canceled pesticides


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Definition of Pesticide

• “Pesticide” means any substance or mixture of substances intended for preventing, destroying, repelling, or mitigating any pest or intended for use as a plant regulator, defoliant, or desiccant, other than any article that:• Is a new animal drug per FFDCA sec. 201(w).• Is an animal drug determined by Sec. of Health and Human Services to be a new animal drug.

• Is an animal feed per FFDCA sec. 201(x) and subject to cancel or recall.


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Pesticides Subject to UW Regulations (1.0)

• Recalled pesticides:• Stocks of a suspended and canceled pesticide that is part of a voluntary or mandatory recall per FIFRA sec. 19(b).

• Stocks of a suspended or canceled pesticide or a pesticide not in compliance with FIFRA that is part of a voluntary recall by the registrant.

There must be a decision to discard


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Pesticides Subject to UW Regulations (2.0)

• Stocks of other unused pesticide products collected and managed as part of a waste pesticide collection program.


There must be a decision to discard

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Pesticides not Subject to UW Regulations

• Recalled and unused pesticides managed by farmers per 40 CFR 262.70.

• Those cans of bug spray or unused weed & feed you have in storage.


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Management ofUniversal Waste Pesticides• Contained in one of the following:

• Closed container in good condition, compatible, no leakage, etc..

• May overpack if original container in poor condition.

• Tank per 40 CFR 265, Subpart J (w/ exclusions).

• Transport vehicle or vessel if closed, good condition, compatible, no leakage, etc.


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Labeling of UW Pesticides

Recalled Pesticide

• Original label.

And…• “Universal Waste – Pesticide(s)”

Or…• “Waste-Pesticide(s)”

Unused Pesticide

• Original label, if legible.• If no good, label per DOT regulations.

• If still no good, other label prescribed by State.

And…


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I provide:Annual RCRA Training for Hazardous Waste Personnel.AndTriennial HazMat Employee Training.

Public Seminars, Onsite, Webinars…

Daniels Training Services815.821.1550Info@DanielsTraining.comwww.DanielsTraining.com


Got Question?

mailto:[email protected]

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For More Information• IEPA Guidance for UW Lamps:

http://www.epa.state.il.us/land/fluorescent-lamps/• IDNR Fluorescent Lamp Handling:

http://www.iowadnr.gov/Portals/idnr/uploads/waste/fluorescentlamphandling.pdf

http://www.iowadnr.gov/Portals/idnr/uploads/waste/sw%20bulbs.pdf• 40 CFR 273:

http://www.ecfr.gov/cgi-bin/text-idx?c=ecfr&tpl=/ecfrbrowse/Title40/40cfr273_main_02.tpl


http://www.epa.state.il.us/land/fluorescent-lamps/






http://www.iowadnr.gov/Portals/idnr/uploads/waste/sw%20bulbs.pdf





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