January 26, 2012
Recent EH&S Trends Based on 2011 Data
February 2, 2012
The EH&S Compliance Cycle: Audits, Development, Implementation, and Maintenance
February 9, 2012
Supplemental Environmental Project (SEP) & August Mack’s eCAP Programe
February 16, 2012
Background Contaminants
February 21, 2012
IDEM Rule 6 Storm Water Permits
February 23, 2012
Environmental Due Diligence for Commercial Property Transaction
March 2, 2012
How Do You Manage Your Safety Risk in Environmental Remediation Projects?
March 8, 2012
Changes to Indiana Closure Guidance
March 15, 2012
Environmental Considerations with Land Use Redevelopment
March 22, 2012
Updated Toxic Substances Control Act (TSCA) Chemical Data Reporting (CDR) Standards
The U.S. Environmental Protection Agency’s (EPA) universal waste rules are set forth in 40 CFR Part 273. These regulations streamline hazardous waste management standards for federally designated “universal wastes.” Although other wastes have been mentioned for inclusion into the universal waste rules at the federal level, the current universal wastes include batteries, pesticides, mercury-containing equipment and bulbs (lamps). States can modify the universal waste rule and add additional universal waste(s) to individual state regulations.
For the majority of facilities, the applicable standards are for those that apply to the small quantity handlers of universal waste. By definition, this means a universal waste handler who does not accumulate 5,000 kilograms or more of universal waste (batteries, pesticides, mercury-containing equipment or lamps, calculated collectively) at any time. At the federal level, a small quantity handler is not required to notify the EPA of universal waste handling activities. A small quantity handler of universal waste must manage universal waste in a way that prevents releases of any universal waste or component of a universal waste to the environment.
Additional requirements for small quantity handlers of universal waste include issues such as labeling/marking, accumulation time limits, employee training and response to releases. All of these requirements are outlined in the federal standard cited above. Again, individual states can require additional requirements.
What are the benefits of handling waste as a universal waste? If properly handled under these regulations, this waste does not count as hazardous waste and does not require following the more stringent hazardous waste regulations. If these waste materials are not handled as universal waste, then the EPA expects that you will manage them as hazardous wastes unless you can prove otherwise. When an environmental regulatory inspector walks into your facility and asks what you do with old batteries or fluorescent lamps, what would be your answer? If you do not know the answer or the facility just throws them in the normal trash, you may be potentially looking at a notice of violation!
If you want to learn more details about the universal waste rules, please register here for August Mack’s July 29th webinar on this subject.Tom Anderson is the corporate manager for August Mack Environmental, Inc. He has more than 25 years industrial experience with extensive knowledge in EH&S facility audits, air regulations, RCRA hazardous waste management, Spill Prevention Control and Countermeasure (SPCC) Plans, storm water permits and Storm Water Pollution Prevention Plans (SWPPPs), wastewater issues and emergency planning and community right-to-know reporting (EPCRA). More recently, Tom has been active in sustainability initiatives and working with various businesses in developing an approach that benefits both the environment and the bottom line. Tom can be reached at 317.916.3105 or via e-mail at tanderson@augustmack.com.