Environmental Universal Waste Control Program

Batteries - Any battery which is considered a hazardous waste must be managed as a universal waste. This includes discarded primary (non-rechargeable) and secondary (rechargeable) batteries that contain elements such as cadmium, lead, or mercury, which would render them federally or state-hazardous. Examples are nickel-cadmium (Ni-Cad), sealed lead-acid, mercury-oxide (button cell), or older alkaline (manufactured prior to 1993) batteries. However, waste lead-acid batteries (such as automotive batteries) not managed, or eligible for management are subject to the Universal Waste Rule requirements. Lead-acid batteries that are stored at facilities that reclaim them are subject to federal and state regulations. Many commonly generated waste batteries, such as dry cell zinc-carbon, silver oxide, and post-1993 alkaline (long-life) batteries, typically do not contain appreciable amounts of the hazardous elements of concern, and hence would not be required to be managed as universal waste. Consumer products such as those that contain difficult-to-remove rechargeable batteries may also be managed along with universal waste batteries. In the interest of diverting these items from less desirable disposal destinies such as incineration or disposal in solid waste landfills, the state encourages the disposal of all batteries as universal waste.

Pesticides that have been recalled or banned from use, are obsolete, have become damaged, or are no longer needed (due to changes in cropping patterns or other factors) are considered universal wastes. These have often been stored for long periods of time in sheds or barns.

Thermostats, which can contain as much as three grams of liquid mercury and are found in homes and commercial, industrial, and community buildings must be managed as universal waste.

Cathode Ray Tubes commonly known as "picture tubes" in televisions, computer monitors, oscilloscopes, and radar-receiving equipment are universal wastes. The tube itself and the entire display device containing the cathode ray tubes, are universal waste.

Mercury-Containing Devices include any electrical product or component which contains elemental mercury that is necessary for its operation and is housed within an outer metal, glass, or plastic casing. These devices include, but are not limited to, thermometers, barometers, electric switches, electric relays, thermocouples, manometers, and sphygmomanometers.

Mercury-Containing Lamps are lamps in which mercury is purposely introduced by the manufacturer for the operation of the lamp. They include, but are not limited to, fluorescent lamps, neon lamps, high intensity discharge (HID) lamps (including mercury vapor, metal halide and high pressure sodium lamps).

Generators and handlers of universal waste:

• must not dispose of a universal waste in the regular solid waste stream,

• must not dilute or treat universal waste,

• must not intentionally break or crush universal waste,

• must take steps to prevent releases to the environment,

• must label each universal waste item or each container of universal waste items with the words "Universal Waste" and the identity of the waste, e.g. "Waste Thermostats." (Note that with pesticides, affix the old product label to the container, or if not available, affix the appropriate US DOT Label found in 49 CFR 172.)

• must identify the accumulation start date on the container or the item itself,

• must train employees on proper waste handling and emergency procedures,

• must respond to spills/breakage and manage the released material as hazardous waste if it has hazardous waste characteristics,

• must manage unintentional breakage of significant numbers of universal waste items as hazardous waste,

• must satisfy US DOT packaging, labeling, marking, placarding, and shipping paper requirements per 40 CFR 273.18 or 40 CFR 273.38 for any universal waste that is a US DOT hazardous material prior to off-site shipment,

• may accumulate universal wastes on-site for up to one year,

• may accumulate universal waste for more than one year for the sole purpose of facilitating proper recovery, treatment, or disposal,

• may self-transport universal wastes to other universal waste handlers or to an authorized destination facility provided that handler complies with universal waste transporter requirements.

The handler may conduct the following activities with regard to the following waste items:

Batteries: A handler of universal waste must manage universal waste batteries in a way that prevents release of any universal waste or component of a universal waste to the environment. A handler must contain any waste battery that shows evidence of leakage, spillage or damage. However, a handler of universal waste may conduct the following activities as long as the casing of each individual battery cell is not breached and remains intact and closed (except that cells may be opened to remove electrolyte but must be immediately closed after removal):

• A container that remains closed, structurally sound, compatible with the pesticide, and that lacks evidence of leakage, spillage, or damage that could cause leakage under reasonably foreseeable conditions; or

• A leaking or damaged container in an overpack container; or

• A tank which meets the requirements for a hazardous waste tank; or

• A transport vehicle or vessel that is closed, structurally sound, compatible with the pesticide, and that lacks evidence of leakage, spillage, or damage that could cause leakage under reasonably foreseeable conditions.

Thermostats: A handler of universal waste must manage universal waste thermostats in a way that prevents releases of universal waste or component of universal waste to the environment. A handler of universal waste must contain any universal waste thermostat that shows evidence of leakage, spillage, or damage that could cause leakage under reasonably foreseeable conditions in a container. The container must be closed, structurally sound, compatible with the contents of the thermostat, and must lack evidence of leakage, spillage, or damage that could cause leakage under reasonably foreseeable conditions. A handler of universal waste may remove mercury-containing ampoules from universal waste thermostats provided the handler:

• Removes the ampoules in a manner designed to prevent breakage of the ampoules;

• Removes ampoules only over or in a containment device (e.g., tray or pan sufficient to collect and contain any mercury released from an ampoule in case of breakage);

• Ensures that a mercury clean-up system is readily available to immediately transfer any mercury resulting from spills or leaks from broken ampoules from the containment device to a container that meets the requirements of 40 CFR 262.34;

• Immediately transfers any mercury resulting from spills or leaks from broken ampoules from the containment device to a container that meets the requirements of 40 CFR 262.34;

• Ensures that the area in which ampoules are removed is well ventilated and monitored to ensure compliance with applicable OSHA exposure levels for mercury;

• Ensures that employees removing ampoules are thoroughly familiar with proper waste mercury handling and emergency procedures, including transfer of mercury from containment devices to appropriate containers;

• Stores removed ampoules in closed, non-leaking containers that are in good condition;

• Packs removed ampoules in the container with packing materials adequate to prevent breakage during storage, handling, and transportation. Note that if the ampoule is removed, the handler must determine whether or not any spilled mercury, clean-up residues, or remaining solid waste exhibit a characteristic of hazardous waste and must manage it as such if it does.