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UNIVERSAL WASTE- SMALL QUANTITY HANDLER REQUIREMENTS
FEDERAL SMALL QUANTITY HANDLER REQUIREMENTS

“Small Quantity Handler” of Universal Waste means a universal waste handler who does not accumulate 5,000 kilograms or more total of universal waste calculated collectively at any time.

Prohibitions: A Small Quantity Handler of Universal Waste is prohibited from disposing of universal waste; and prohibited from diluting or treating universal waste, except by responding to releases as provided in 40 C.F.R. 273.17, or by managing specific wastes as provided in 40 C.F.R. 273.13.

Did SQH comply with universal waste prohibitions? [40 CFR 273.11]

BATTERIES

“Battery” means a device consisting of one or more electrically connected electrochemical cell which is designed to receive, store, and deliver electric energy. An electrochemical cell is a system consisting of an anode, cathode, and an electrolyte, plus such connections (electrical and mechanical) as may be needed to allow the cell to deliver or receive electrical energy. The term battery also includes an intact, unbroken battery from which the electrolyte has been removed.

Did SQH place universal waste batteries that showed evidence of leakage, spillage or damage that could cause leakage into a container that was closed, structurally sound, compatible with the contents of the batteries, and showing no evidence of leakage, spillage, or damage that could cause leakage? [40 CFR 273.13(a)(1)]

Activities: A Small Quantity Handler of Universal Waste may conduct the following activities: sorting batteries by type, mixing battery types in one container, discharging batteries so as to remove the electric charge, regenerating used batteries, disassembling batteries or battery packs into individual batteries or cells, removing batteries from consumer products, or removing electrolyte from batteries.

Did SQH, which conducted activities on batteries, ensure that the casing of individual battery cell was not breached and remained intact and closed? [40 CFR 273.13(a)(2)]

Did SQH determine if electrolyte removed from batteries, or solid waste generated as the result of performing activities on batteries, was hazardous? [40 CFR 273.13(a)(3)]

Did SQH clearly label or mark individual universal waste batteries or containers of universal waste batteries with the words “Universal Waste—Battery(ies)”, or “Waste Battery(ies)”, or “Used Battery(ies)”? [40 CFR 273.14(a)]

PESTICIDES

“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.

Did SQH place universal waste pesticides in a container that was closed, structurally sound, compatible with the pesticide, and showing no evidence of leakage, spillage, or damage that could cause leakage? [40 CFR 273.13(b)(1)]

Did SQH overpack containers of universal waste pesticides which did not meet the requirements of 40 C.F.R. 273.13(b)1? [40 CFR 273.13(b)(2)]

Did the SQH ensure that tanks, used to accumulate universal waste pesticides, meet the requirements of 40 C.F.R. 265 Subpart J , except for 40 C.F.R. ? [40 CFR 273.13(b)(3)]

Did SQH ensure that transport vehicles or vessels containing universal waste pesticides were closed, structurally sound, compatible with the pesticide, and showing no evidence of leakage, spillage, or damage that could cause leakage? [40 CFR 273.13(b)(4)]

Did SQH clearly label or mark containers, tanks, transport vehicles or vessels of recalled universal waste pesticides with the label that was on or accompanied the product as sold or distributed, and the words “Universal Waste-Pesticide(s)” or “Waste-Pesticide(s)”? . [40 CFR 273.14(b)]

Did SQH clearly label or mark containers, tanks, transport vehicles or vessels of unused universal waste pesticides with the words “Universal Waste-Pesticide(s)” or “Waste-Pesticide(s)”, and with the label that was on the product when purchased, or the appropriate label as required under the Department of Transportation regulation 49 C.F.R. part 172, or another label prescribed or designated by the waste pesticide collection program administered or recognized by the state? [40 CFR 273.14(c)]

MERCURY-CONTAINING EQUIPMENT

“Mercury-Containing Equipment” means a device or part of a device (including thermostats, but excluding batteries and lamps) that contains elemental mercury integral to its function.

“Thermostat” means a temperature control device that contains metallic mercury in an ampule attached to a bimetal sensing element, and mercury-containing ampules that have been removed from these temperature control devices in compliance with the requirements of 40 C.F.R. 273.13(c)(2) or 273.33(c)(2).

Did SQH place universal waste mercury-containing equipment with non-contained elemental mercury or that shows evidence of leakage, spillage or damage in a container that was that was closed, structurally sound, compatible with the contents of the device, designed to prevent the escape of mercury into the environment, and showing no evidence of leakage, spillage, or damage that could cause leakage? [40 CFR 273.13(c)(1)]

Did SQH remove mercury-containing ampules in a manner designed to prevent breakage of the ampules? [40 CFR 273.13(c)(2)(i)]

Did SQH remove mercury-containing ampules only over or in a containment device? [40 CFR 273.13(c)(2)(ii)]

Did SQH ensure that a mercury clean-up system was available to immediately transfer any mercury, resulting from spills or leaks from broken ampules, from the containment device to a container that meets the requirements of 40 C.F.R. part 260 through 272? [40 CFR 273.13(c)(2)(iii)]

Did SQH immediately transfer any mercury, resulting from spills or leaks from broken ampules, from the containment device to a container that meets the requirements of 40 C.F.R. part 260 through 272? [40 CFR 273.13(c)(2)(iv)]

Did SQH ensure that the area in which mercury-containing ampules are removed is well ventilated and monitored to ensure compliance with applicable OSHA exposure levels for mercury? [40 CFR 273.13(c)(2)(v)]

Did SQH ensure that employees removing mercury-containing ampules are thoroughly familiar with proper waste mercury handling and emergency procedures? [40 CFR 273.13(c)(2)(vi)]

Did SQH store mercury-containing ampules in closed, non-leaking containers that were in good condition? [40 CFR 273.13(c)(2)(vii)]

Did SQH pack mercury-containing ampules in containers with packing materials adequate to prevent breakage during storage, handling, and transportation? [40 CFR 273.13(c)(2)(viii)]

Did SQH who removed the opened original housing holding mercury not contained in an ampule immediately seal the housing with an air-tight seal, and follow the requirements under 40 C.F.R.273.13(c)2 for removing and managing ampules? [40 CFR 273.13(c)(3)]

Did SQH, who removes mercury-containing ampules or seals mercury in its original housing determine if any waste generated exhibited a characteristic of hazardous waste, and manage the waste in compliance with all appropriate regulations? [40 CFR 273.13(c)(4)]

Did SQH properly label or mark universal waste mercury-containing equipment or containers of universal waste mercury-containing equipment? [40 CFR 273.14(d)]

LAMPS

“Lamp”, also referred to as universal waste lamp is defined as the bulb or tube portion of an electric lighting device. A lamp is specifically designed to produce radiant energy, most often in the ultraviolet, visible, and infrared regions of the electromagnetic spectrum. Examples of common universal waste electric lamps include, but are not limited to, fluorescent, high intensity discharge, neon, mercury vapor, high pressure sodium, and metal halide lamps.

Did SQH place universal waste lamps in a container that was structurally sound, adequate to prevent breakage, compatible with the contents of the lamps, closed, and showing no evidence of leakage, spillage or damage that could cause leakage? [40 CFR 273.13(d)(1)]

Did SQH clean up and place any universal waste lamp that was broken or that showed evidence of breakage, leakage, or damage that could cause the release of hazardous constituents in a container that was closed, structurally sound, compatible with the lamp, and showing no evidence of leakage, spillage or damage that could cause leakage or releases of mercury or other hazardous constituents to the environment? [40 CFR 273.13(d)(2)]

Did SQH ensure that each lamp or a container or package in which lamps are contained is labeled or marked clearly with one of the following phrases: “Universal Waste—Lamp(s)”, or “Waste Lamp(s)”, or “Used Lamp(s)”? [40 CFR 273.14(e)]

ACCUMULATION TIME LIMITS

Did SQH prove that universal waste accumulated for greater than one year was done solely for the purpose of facilitating proper recovery, treatment or disposal? [40 CFR 273.15(a-b)]

Did SQH demonstrate the length of time that universal waste was accumulated? [40 CFR 273.15(c)]

TRAINING

Did SQH ensure that all employees who handle or have responsibility for managing universal waste are informed on the proper handling and emergency procedures appropriate to the type(s) of universal waste handled at the facility? [40 CFR 273.16]

RESPONSE TO RELEASES

Did SQH immediately contain any releases or residues of universal waste? [40 CFR 273.17(a)]

Did SQH determine if any material resulting from the release of universal waste was hazardous, and to manage the waste in compliance with all applicable regulations? [40 CFR 273.17(b)]

OFF-SITE SHIPMENTS

Did SQH send or take universal waste only to another universal waste handler, a destination facility, or a foreign destination? [40 CFR 273.18(a)]

Did SQH, who self-transports, comply with the requirements at 40 C.F.R. 273 Subpart D and N.J.A.C. 7:26A-7.6? [40 CFR 273.18(b)]

Did SQH package, label, mark, placard or complete shipping papers in accordance with the applicable Department of Transportation regulations under 49 C.F.R. parts 172 through 180 for shipments of universal waste which were hazardous materials? [40 CFR 273.18(c)]

Did originating handler of universal waste ensure that the receiving handler agreed to accept the universal waste prior to shipment? [40 CFR 273.18(d)]

Did SQH receive back or agree on an alternate facility for rejected shipments of universal waste? [40 CFR 273.18(e)]

Load Rejection. A Small Quantity Handler of Universal Waste may reject a shipment containing universal waste, or a portion of a shipment containing universal waste that he has received from another handler. If a handler rejects a shipment or a portion of a shipment, he must contact the originating handler to notify him of the rejection and to discuss reshipment of the load. The handler must send the shipment back to the originating handler, or, if agreed to by both the originating and receiving handler, send the shipment to a destination facility.

Did SQH properly reject shipments of universal waste? [40 CFR 273.18(f)]

Did SQH immediately notify the Department upon receipt of an illegal shipment of hazardous waste that was shipped as universal waste? [40 CFR 273.18(g)]

Did SQH that received non-hazardous, non-universal waste, manage the waste in accordance with applicable federal, state or local solid waste regulations? [40 CFR 273.18(h)]

Were all universal waste consumer electronic devices clearly marked, or accumulated in a closed container that was clearly marked, with the words “Universal Waste-Consumer Electronics”?

CONSUMER ELECTRONICS

“Consumer Electronics” means any appliance used in the home or business that includes circuitry. Consumer electronics includes the components and sub-assemblies that collectively make up the electronic products and may, when individually broken down, include batteries, mercury switches, capacitors containing PCBs, cadmium plated parts and lead or cadmium containing plastics. Examples of consumer electronics include, but are not limited to, computers, printers, copiers, tele facsimiles, VCRs, stereos, televisions, and telecommunication devices.

Did SQH place a consumer electronic that shows evidence of leakage, spillage, or damage that could cause leakage, in a container that was closed, structurally sound, compatible with the consumer electronic, and non-leaking? [N.J.A.C. 7:26A- 7.4(b)1]

Did SQH apply for a Class D Approval prior to conducting processing or treatment of consumer electronics? [N.J.A.C. 7:26A- 7.4(b)2]

Did SQH who generates a solid waste as the result of performing activities listed N.J.A.C. 7:26A-7.4(b) determine if the waste was hazardous? . [N.J.A.C. 7:26A- 7.4(b)3]

Were all universal waste consumer electronic devices clearly marked, or accumulated in a closed container that was clearly marked, with the words “Universal Waste-Consumer Electronics”? [N.J.A.C. 7:26A- 7.7(a)]

OIL-BASED FINISHES

“Oil-based finishes” means any paint or other finish which may exhibit, or is known to exhibit, a hazardous waste characteristic, or which contains a listed hazardous waste, and is in its original packaging, or otherwise appropriately contained and clearly labeled. Examples of oil-based finishes include, but are not limited to, oil-based paints, lacquers, stains, and aerosol paint cans.

Did SQH manage oil-based finishes in the original or otherwise appropriate, labeled packaging? [N.J.A.C. 7:26A- 7.4(c)]

Did SQH place a universal waste oil-based finish that showed evidence of leakage, spillage, or damage that could cause leakage, into a container that was closed, structurally sound, compatible with the contents of the oil-based finish, and non-leaking? . [N.J.A.C. 7:26A- 7.4(c)1]

“Processing” means the treatment or transformation of source separated recyclable materials so as to conform to end-market specifications, including, but not limited to, separating material by type, grade or color, crushing, grinding, shredding or bailing or removing contaminants.

Did SQH apply for a Class D Approval prior to processing universal waste oil-based finishes? . [N.J.A.C. 7:26A- 7.4(c)2]

Did SQH manage containers or packages containing oil-based finishes in an area equipped with a secondary containment system meeting the requirements N.J.A.C. 7:26A-7.4(c)3? [N.J.A.C. 7:26A- 7.4(c)3]

Were all containers (or multiple container package units), tanks, transport vehicles or other vessels in which oil-based waste finishes were contained, clearly marked with the words “Universal Waste – Oil-Based Finish”? [N.J.A.C. 7:26A- 7.7(b)]

AEROSOL CANS

Did SQH place Universal Waste Aerosol Cans in containers that were structurally sound, compatible with the contents of the aerosol cans, lacking evidence of leakage, spillage, or damage that could cause leakage under reasonably foreseeable conditions, and protected from sources of heat? [40 CFR 273.13(e)(1)]

Did SQH package Universal Waste Aerosol Cans that showed evidence of leakage in a separate closed container, overpack with absorbents, or immediately puncture it or drain it in accordance with the requirements of 40 C.F.R. 273.13(e)? [40 CFR 273.13(e)(2)]

Did SQH ensure that individual aerosol cans were not breached when conducting activities on Universal Waste Aerosol Cans? [40 CFR 273.13(e)(3)]

Did SQH recycle their empty punctured aerosol cans? [40 CFR 273.13(e)(4)]

Did SQH recycle empty punctured Universal Waste Aerosol Cans and conduct puncturing and draining activities using a device specifically designed to safely puncture the cans and effectively contain the residual contents and any emissions? [40 CFR 273.13(e)(4)(i)]

Did SQH recycle empty punctured Universal Waste Aerosol Cans and establish and follow a written procedure detailing how to safely puncture and drain the cans; maintain a copy of the manufacturer’s specification and instruction on site; and ensure employees operating the device are trained in the proper procedures? [40 CFR 273.13(e)(4)(ii)]

Did SQH recycle empty punctured Universal Waste Aerosol Cans and ensure that puncturing the can is done in a manner designed to prevent fires and to prevent the release of any component of universal waste to the environment? [40 CFR 273.13(e)(4)(iii)]

Did SQH recycle empty punctured Universal Waste Aerosol Cans and immediately transfer the contents from the can or puncturing device to a container or tank that meets the applicable requirements of 40 C.F.R. 262.14, 15, 16, or 17? [40 CFR 273.13(e)(4)(iv)]

Did SQH recycle empty punctured Universal Waste Aerosol Cans and conduct a hazardous waste determination on the contents of the emptied aerosol can per 40 CFR 262.11? [40 CFR 273.13(e)(4)(v)]

Did SQH recycle empty punctured Universal Waste Aerosol Cans, have a written procedure in place in the event of a spill or leak, keep a spill clean-up kit, or ensure that all spills or leaks are cleaned up promptly? [40 CFR 273.13(e)(4)(viii)]

Did SQH label or clearly mark individual aerosol cans, or a container in which cans were contained with the phrase: “Universal Waste—Aerosol Can(s)”, “Waste Aerosol Can(s)”, or “Used Aerosol Can(s)”? [40 CFR 273.14(f)]
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