Universal Waste Regulations and Electronic Waste Issues

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1 Universal Waste Regulations and Electronic Waste Issues C D P H E H a z a r d o u s M a t e r i a l s W a s t e M a n a g e m e n t D i v i s i o n - H a z a r d o u s W a s t e P r o g r a m w w w. c o l o r a d o. g o v / c d p h e / h a z w a s t e K a t h r y n S t e w a r t ( ) k a t h r y n. s t e w a r s t a t e. c o. u s

2 Universal Waste Regulations Solid Waste-Non Hazardous Waste Landfills Hazardous Waste Universal Waste

3 Universal Wastes in Colorado Waste batteries Aerosol cans that contain hazardous waste when discarded Certain pesticides Mercury-containing devices/lamps Electronic devices and components (E-Wastes)

4 Hazardous Waste or Universal Waste Facilities have the option of choosing to manage certain wastes as traditional Hazardous Wastes (HW) or as Universal Wastes (UW). Colorado encourages recycling of some specific, but widely generated, hazardous wastes by offering reduced regulatory requirements under the Universal Waste Regulations.

5 Benefits of Universal Waste Rules Recycling Protect our environment Avoid hazardous wastes in municipal landfills Reduced Regulatory Requirements Longer on-site storage allowances Reduced tracking requirements Volume does not count towards hazardous waste generator status

6 Two Types of Universal Waste Handlers Handlers Any facility that generates or manages UW is a handler Generators and recycling facilities Small Quantity Handlers (SQH) <5000 kg of universal waste on site at any one time Large Quantity Handlers (LQH) >5000 kg of universal waste on site at any one time Must notify Division as a LQH

7 Universal Waste Handlers Same requirements for both handler categories, except LQH must notify the Division

8 Requirements for All Handlers Manage in a way that prevents releases Label containers One year accumulation Staff trained in waste handling and emergency response relative to jobs Contain and clean up releases Limited treatment, only as specifically allowed in regulations

9 Prevent Releases Accumulate in a manner that minimizes potential for releases or exposures

10 No Disposal to the Ground or Trash

11 Containers Must contain wastes, devices or components No leakage or spillage Immediately clean up spills, containerize Must be closed, except for computers and electronic devices

12 Containers Labels Used ( ), Waste ( ) or Universal Waste ( ) Label individual waste containers/devices or accumulation container

13 Containers Appropriate container based on type of waste

14 Destination Facility Must ship to another universal waste handler or to a destination facility Destination facility = treatment, disposal or recycling facility May be subject to hazardous waste permitting requirements Recycles waste into products with value Treatment beyond that allowed for handlers Disposes of waste in hazardous waste landfill Recyclers may be subject to Solid Waste recycling regulations

15 Limited Treatment Allowed Crushing waste mercury-containing lamps Puncturing waste aerosol cans Disassembly of electronic devices

16 6 Universal Wastes in Colorado Waste batteries Aerosol cans Certain pesticides Mercury-containing devices Mercury Lamps Electronic devices and components (E-Wastes)

17 Batteries Ni-cad, silver-oxide, mercury-oxide, lithium, zinc-air, and some alkaline and zinc-carbon May contain mercury and other metals, may also be reactive Send to battery recycler or use mail-back program

18 Safe Storage Container

19 Aerosol Cans Cans that still contain contents that are hazardous Send to hazardous waste disposal facility or Manage as a Universal Waste

20 Contents drained from cans must be managed as hazardous waste and are no longer universal waste Puncturing Cans

21 Pesticides Most pesticides are regulated under FIFRA instead of the Colorado Hazardous Waste Regulations. Universal Waste Recalled, suspended or banned pesticides Unused pesticides collected as part of a waste pesticide collection program Send to hazardous waste disposal facility or use CHEMSWEEP

22 Mercury-containing Lamps Lighting devices that contain mercury Fluorescent, compact fluorescent, high intensity discharge (HID), neon, mercury vapor, high pressure sodium, metal halide lamps, etc. Ballast not usually UW see TSCA

23 Storage Containers Appropriate container based on type of waste

24 Green-Tipped Fluorescent Lamps Green-tipped fluorescent lamps can be disposed of in the trash, but recycling is strongly encouraged Lamps still contain mercury Stabilizers are often added to get lamp to pass TCLP test, but no data to show long term stability in the landfill

25 Mercury-containing Devices Devices containing elemental mercury that acts as conductor of temperature, pressure, electricity Barometers, switches Not dental or other amalgams Send to hazardous waste disposal facility, out-of-state recycler, or use mail-back program

26 E-Waste Can Be A Resource Cathode Ray Tubes (CRTs) lead, Circuit boards and old electronic equipment lead, chromium, and silver Older electronic equipment Mercury from mercury switches Batteries nickel cadmium, lithium, or sealed lead acid

27 Electronic Devices and Components Devices that contain circuit boards or other parts that exhibit toxicity characteristics for heavy metals like lead, chromium, mercury, cadmium or silver CPUs Computer peripherals Cell phones Monitors TVs Laptops

28 Products Or Wastes? Must manage in a manner consistent with a product having value if you want to claim that it is not a waste This is not how products are managed

29 Managed as Products?

30 E-Waste Containers Structurally sound, adequate to prevent breakage, and compatible

31 Reduced Market for Leaded Glass People quit making CRT glass monitors Instead are making LCD flat screens Only one place left for CRT glass recycling Must send it to India via Mexico Or pay to send it to HW landfill

32 E-Waste Illegal Disposal CASE STUDY

33 CASE STUDY

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41 Unilateral Order

42 Requirements of Order VIOLATION Failure to make a hazardous waste determination resulting in illegal disposal Fine $15000 Dispose of all waste at a HW disposal facility Submit site characterization plan Clean up site per plan

43 Universal Waste Guidance Hazardous Materials & Waste Management Division Hazardous waste guidance Customer Technical Assistance Line

Universal Waste Program FACILITIES MANAGEMENT DIVISION 1180 East Broad Street Athens, Georgia 30602

Universal Waste Program FACILITIES MANAGEMENT DIVISION 1180 East Broad Street Athens, Georgia 30602 Universal Waste Program 2018 FACILITIES MANAGEMENT DIVISION 1180 East Broad Street Athens, Georgia 30602 Universal Waste The Universal Waste Program is part of the Resource Conservation and Recovery Act