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   A universal waste handler is either the generator of the waste or a collector / consolidator.  There are two categories of universal waste handlers - Small Quantity Handlers of Universal Waste (SQHUW) and Large Quantity Handlers of Universal Waste (LQHUW).  SQHUW may accumulate up to 11,000 pounds of all universal waste categories combined.  When a handler exceeds 11,000 pounds, they become a LQHUW and are subject to a few extra requirements.

   Both SQHUW and LQHUW must:

  • Label or mark wastes.  For example, "universal waste-batteries" or "waste mercury thermostats."
  • Limit accumulation to one year from the date first generated, or received from another handler.
  • Manage wastes to prevent releases to the environment.
  • Immediately contain releases and handle residues appropriately (as solid, or as hazardous waste).  If residues are hazardous, manage them in accordance with all applicable requirements of the Dangerous Waste Regulations.
  • Follow procedures for handling batteries and removing mercury-containing ampules from thermostats.
  • Send or take universal waste to another handler who is acting as a collection center (with their prior agreement), a destination facility (TSD or recycler), or a foreign destination.
  • Ensure that the receiving facility (collection center or destination facility) will accept the load before it is sent.  If rejected, the original handler must accept the waste back, or both parties may agree on a new destination.
  • Follow the export notification procedures for foreign destinations.
  • Provide employee training.  LQHUW must ensure that employees are familiar with waste handling and emergency procedures.  SQHUW must distribute basic handling and emergency information.

   Additional Large Quantity Handler (LQHUW) requirements

  • Maintain basic records to track waste shipments.  Records may be in the form of a log, invoice, manifest, bill of lading, or other shipping document.  They must be maintained for three years and must include names, addresses, quantity and types of wastes, and shipment dates.
  • Notify Ecology and obtain a RCRA ID number.  Handlers who anticipate accumulating 11,000 pounds or more of universal waste at any one time must submit a one-time written notification and receive a RCRA ID number before exceeding the 11,000 pound limit.

   Note: LQHUW status is maintained through the end of the calendar year in which 11,000 pounds or more of universal waste is accumulated.

Prohibitions for All Handlers

   Handlers may not dilute, dispose, or treat universal wastes.  There are two exceptions:

   Routine Battery management activities.  The following routine battery management activities are not considered treatment: sorting batteries by type, mixing battery types in one container, discharging batteries, regenerating used batteries, disassembling battery packs, removing batteries from discarded consumer products, and removing electrolyte.  These are acceptable battery management practices provided the casing of each battery cell is not breached and remains intact and closed.  Cells may be opened to remove electrolyte, but must be closed immediately after removal.

   Removing mercury-containing ampules from thermostats.  The handler of the waste can remove mercury-containing ampules.  Detailed directions for removing mercury ampules may be found in the rule itself.

   Collection Centers/Consolidation Points

   A collection center receives universal waste from other universal waste handlers (generators), consolidates it, and sends it to a treatment, storage, disposal or recycling facility (destination facility).  The collection center must comply with the appropriate set of LQHUW or SQHUW requirements based on the amount of universal waste that is collected on site.

   A permitted treatment, storage or disposal (TSD) facility may be a collection center for universal wastes that it consolidates and sends on to a destination facility.  The TSD must comply with the appropriate LQHUW or SQHUW requirements.  A TSD may not collect universal wastes as a universal waste handler if it is the destination facility.  It is considered the destination facility if it treats, disposes of, or recycles that particular category of universal waste.

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Universal Waste Rule for Batteries and Mercury Containing Thermostats, #98-40

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