The handling of Universal Waste (UW) is a part of the SkyVine ITAD recycling program that requires additional handling to comply with State and Federal requirements for the handling and storage of UW items. This procedure is to help identify specific types of UW as well as procedures that must be followed in order to ensure the safe, effective and compliant management of Universal Wastes.

1. Universal Waste – Regulatory Overview

Two regulatory agencies oversee universal waste compliance in Texas:

State – Texas Commission on Environmental Quality (TCEQ)

Federal – United States Environmental Protection Agency (USEPA)

Both can proceed with civil or criminal prosecution for hazardous waste violations

The regulation encourages the collection and recycling of certain categories of hazardous Effective November 1, 2002, MDE finalized amendments to COMAR 26.13 implementing EPA's Universal Waste Rule

Waste that has been identified as "Universal Wastes"

The regulation also provides alternative management standards for these wastes so that they are not subject to the full range of the hazardous waste regulations

2. Identifying Universal Waste

Universal Wastes are certain hazardous wastes that are universally generated in a wide variety of settings, not solely industrial, and present a limited hazard.

Although not subject to the full range of hazardous waste regulations, Universal Wastes MUST still be managed separately from general trash.

The categories of universal waste include:

• lamps

• batteries (all types)

• PCB ballasts

• mercury containing devices

3. Universal waste lamps consist of:

• fluorescent lamps compact fluorescent lamps

• high intensity discharge lamps neon lamps

• mercury vapor lamps

• high pressure sodium lamps; and metal halide lamps

Note: Incandescent bulbs are non-hazardous and may be thrown in regular trash.

4. Universal Waste Batteries consist of:

• Nickel-Cadmium batteries

• Metal hydride batteries Lead-acid batteries

• Silver oxide

• Mercury

• Lithium Zinc carbon

These batteries are commonly used in pagers, cell phones, cameras, and computers.

5. Universal Waste PCB Ballasts consist of:

• PCB light ballasts are electrical devices used for starting and regulating fluorescent and discharge lamps

• In 1978 the US EPA banned the use of PCBs which were used in the processing of light ballasts.

• Ballasts produced after 1978 that do not contain PCBs are labeled by the manufacturer as “No PCBs”.

• If ballast does not contain the label or markings stating, “No PCBs”, assume that it contains PCBs and manage as universal waste.

6. Universal Waste Mercury consist of:

• Mercury thermostats are temperature control devices that contain metallic mercury in an ampule attached to a bi-metal sensing element.

• Mercury thermometers are devices that measure temperature or temperature gradient.

• Mercury manometers are devices to measure pressure.

Proper UW Management and Handling Procedures

• Containers and Packaging

• Labeling and Marking

• Storage

Universal Waste Lamps –

Proper Handling Procedures

• DO NOT MIX LAMPS. Each type of Lamp must be placed in a separate container.

• Containers must remain closed unless adding or removing lamps. Container must lack evidence of leakage, spillage or damage. (40 CFR 273)

• As soon as the lamp or first lamp (if multiple lamps are being stored in a single container) is placed in the container then the container must be labeled with the words Universal Waste-Lamp(s) and must be dated.

• Universal wastes may be stored at the point of generation or in a maintenance shop provided they:

1. Are stored in a secure location where they will not be accidentally broken or considered disposal trash.

2. Location identified as a UW storage area.

3. Each container is properly labeled as indicated.

Lamps must be placed in containers or packages that are structurally sound, adequate to prevent breakage, and compatible with the contents of the lamps. (40 CFR 273)

Handlers shall collect lamps and place in containers provided for the purpose of collecting lamps

Typical types of Containers: (Others may be suitable as long as sufficient to prevent breakage and/or to contain breakage if any)

40 gallon fiber drum used for straight tubes

30 gallon fiber drum used for U-Tubes

30 gallon fiber drum used for HID Lamps

Universal Waste Batteries –

Proper Handling Procedures

Universal waste batteries that are in good condition and do not show evidence of leakage spillage or damage are not required to be stored in a container.

It is recommended that smaller batteries be stored in a larger container or packaging for labeling purposes.

If you choose to label each battery individually, then you must label each with the words Universal Waste-Batteries and with the date it became a waste.

If you choose to place each battery in a larger container, then as soon as the first battery is placed in the container the container must be labeled with the words Universal Waste- Batteries and must be dated.

Universal wastes batteries may be stored at the point of generation or in a maintenance shop provided they:

1. Are stored in secure locations where they will not be accidentally broken or considered disposal trash.

2. Location identified as a UW storage area.

3. Each container is properly labeled as indicated.

• Batteries must be sorted by battery chemistry into different containers:

  • Alkaline

  • Nickel Metal Hydride

  • Nickel Cadmium

  • Lithium Ion

  • Lithium Primary

  • Lithium Polymer

  • Lead Acid

• Battery terminal must be taped to protect from short circuiting if:

  • Terminals are exposed and:

    • All batteries more than 9 volts

    • All lithium batteries

Lithium Metal and Lithium-Ion Batteries

For highway or rail transport only of small to medium batteries such as those found in cell phones, cameras, laptops, equipment used by audiovisual professionals

Lithium batteries have caused fires while in storage and transportation. Lithium batteries must have the terminals taped or be placed in individually sealed plastic bags before putting the batteries into storage containers.

Select any sturdy container (box, drum, or pail) that will:

• Contain the batteries placed in it

• Be capable of being dropped from 4 feet without damaging or spilling the contents

Special shipping document statements

As of March 30, 2017, small or medium lithium batteries shipped for recycling or disposal under this procedure no longer require special statements on the shipping documents.

Universal Waste PCB Ballasts –

Proper Handling Procedures

DO NOT MIX PCB Ballasts with non-PCB Ballasts. Each type of ballast must be placed in a separate container.

Containers must remain closed unless adding or removing ballast. Container must lack evidence of leakage, spillage or damage. (40 CFR 273)

As soon as the PCB ballast or first PCB ballast (if multiple ballasts are being stored in a single container) is placed in the container then the container must be labeled with the words Universal Waste-PCB Ballast(s) and must be dated.

Universal wastes may be stored at the point of generation or in a maintenance shop provided they:

1. Are stored in secure locations where they will not be accidentally broken or considered disposal trash.

2. Location identified as a UW storage area.

3. Each container is properly labeled as indicated.

55 gallon metal drum used for PCB Ballasts

Universal Waste Mercury Thermostats –

Proper Handling Procedures

Mercury thermostats must be managed in a way that prevents releases of any mercury to the environment.

The mercury thermostats must be labeled with the words “Universal Waste – Mercury Thermostat” and must also be labeled with the date they became a waste.

Universal wastes may be stored at the point of generation or in a maintenance shop provided they:

1. Are stored in secure locations where they will not be accidentally broken or considered disposal trash.

2. Location identified as a UW storage area.

3. Each container is properly labeled as indicated.

Document Revision History

Rev. Description of Change Approved Date Approved By

0 New 01/04/2022 C. Vo

8.0.9-P Universal Waste Handling Procedure - Rev.0

This document is uncontrolled when printed

Universal Waste Handling Procedure Test