Universal Waste Training

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1 Universal Waste Training

2 Universal Waste Training Requirement Universal waste generators must inform/train all their employees who handle or have responsibility for managing universal waste. The training must describe proper handling and emergency procedures appropriate to the type(s) of universal waste generated and handled at the facility

3 2010 Training What are Universal Wastes? Universal Wastes are certain hazardous wastes that are universally generated in large quantities by industrial facilities but present a limited hazard. As long as you follow Universal Waste regulations, they are exempt from the hazardous waste regulations However, they must still be managed separately from general trash.

4 What are Universal Wastes? There are four (4) categories of universal waste, which include: lamps; batteries; pesticides; and mercury-containing equipment.

5 Universal Waste Lamps Universal waste lamps consist of: fluorescent lamps; high intensity lamps; neon lamps; mercury vapor lamps; high pressure sodium lamps; and metal halide lamps.

6 Universal Waste Lamps Proper Handling Procedures Lamps must be placed in containers or packages that are structurally sound, adequate to prevent breakage, and compatible with the contents of the lamps. It is common practice that the original box which the lamp was purchased in be used to store the waste lamp. Containers and packages must remain closed unless adding or removing lamps and must lack evidence of leakage, spillage or damage that could cause leakage under reasonably foreseeable conditions. This is where most companies get dinged during an inspection!

7 Universal Waste Lamps Proper Handling Procedures As soon as the first lamp is placed in the container, that container must be labeled with the words Universal Waste- Lamps and must be dated. Dependent on how your Facility is set up, you may either bring the universal waste to a designated storage area (i.e. the hazardous waste storage area) or create a designated storage area. Universal Waste (Lamps) can only be stored up to 180 days in order to maintain the station as a CE-SQG. That s why you must date the box when you place the first lamp in it!

8 Universal Waste Lamps Emergency Procedures If a lamp breaks or shows evidence of leakage, spillage, or damage you must: Immediately clean up the broken lamp and place the pieces or damaged lamp in a container; The container holding the broken lamp must be closed, structurally sound, compatible with the contents of the lamps; The containers must not show any evidence of leakage, spillage or damage that could cause leakage or releases of mercury or other hazardous constituents to the environment under reasonably foreseeable conditions Wear personal protective equipment while cleaning up the broken lamp

9 Universal Waste Lamps Emergency Procedures The container and contents would now be classified as a hazardous waste and must be managed accordingly. This includes properly labeling the container and ensuring that it is immediately brought to a hazardous waste storage area. The date that the containers is brought to the storage area should be filled in on the label.

10 Universal Waste Batteries Universal Waste Batteries consist of: Nickel-Cadmium batteries; Metal hydride batteries; Lead-acid batteries; Silver oxide Mercury oxide; Lithium; Alkaline (i.e. AA, AAA, C, D) Zinc air; and Zinc carbon. These batteries are commonly used in pagers, cell phones, cameras, and computers.

11 Universal Waste Batteries Proper Handling Procedures Large 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. However, they should be on a secondary containment pellet. It is recommended that the smaller batteries be stored in a larger container for labeling purposes.

12 Universal Waste Batteries Proper Handling Procedures 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. Remember, for smaller batteries being collected in a larger drum, it is very important that you tape the ends of the batteries to prevent completing an electrical circuit. You may either bring the universal waste to a designated storage area (i.e. hazardous waste storage area) or create a designated storage area. There is a one year limit that universal waste batteries can be stored

13 Universal Waste Batteries Emergency Procedures If the casing of a battery is breached or shows evidence leakage, spillage, or damage, the battery and any associated spilled material must be placed in a container. The container must be closed, structurally sound, compatible with the contents of the battery, and must lack evidence of leakage, spillage, or damage that could cause leakage under reasonably foreseeable conditions. The container would now be classified as a hazardous waste and must be managed accordingly. This includes properly labeling the container and ensuring that it is immediately brought to the hazardous waste storage area. The date that the containers is brought to the vault should be filled in on the label.

14 Universal Waste Pesticides Pesticides are defined as 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. Typically, Piedmont employees do not use or store any pesticides at our facilities.

15 Universal Waste Pesticides Proper Handling Procedures In the event that Piedmont needs to dispose of a pesticide: The waste pesticides must be contained in a container that remains closed, structurally sound, compatible with the pesticide, and that lacks evidence of leakage, spillage, or damage that could cause leakage under reasonably foreseeable conditions. If the original manufacturers container does not meet this requirement (or the container that the pesticide is in) then the unacceptable container must be over-packed in a container that does meet this requirement. Do not pour out the pesticide into a different container! Wear proper personal protection equipment while handling any container with pesticides.

16 Universal Waste Pesticides Proper Handling Procedures Each universal waste pesticide container must be labeled or marked clearly with either: the label that was on or accompanied the product as sold or distributed and the words Universal Waste Pesticides, or if the container is over-packed, the universal waste sticker and the words Universal Waste Pesticides AND The date the pesticide was classified as a waste. There is a one year limit that universal waste pesticides can be stored on-site. Dependent on how your Facility is set up, you may either bring the universal waste to a designated storage area (i.e. hazardous waste storage area) or create a designated storage area.

17 Universal Waste Pesticides Emergency Procedures If the container storing universal waste pesticides is breached or shows evidence leakage, spillage, or damage, the pesticide and any associated spilled material must be immediately placed in a container. The container must be closed, structurally sound, compatible with the contents of the battery, and must lack evidence of leakage, spillage, or damage that could cause leakage under reasonably foreseeable conditions. The container would now be classified as a hazardous waste and must be managed accordingly. This includes properly labeling the container and ensuring that it is immediately brought to a hazardous waste storage area. The date that the containers is brought to the storage area should be filled in on the label.

18 Universal Waste Mercury-Containing Equipment Mercury-Containing Equipment (MCE) is defined a device or part of a device that contains elemental mercury integral to its function. Various types of MCE waste include instruments that are used in industry, hospitals and households. Some commonly recognized items include, but are not limited to, thermometers, thermostats, barometers, manometers, temperature and pressure gauges, and mercury switches.

19 Universal Waste Mercury Thermostats Proper Handling Procedures Universal waste MCE must be managed in a way that prevents releases of any universal waste or component of a universal waste to the environment. The MCE must be labeled with the words Universal Waste Mercury-Containing Equipment and must also be date labeled with the date they became a waste. There is a one year limit that universal waste MCE can be stored on-site. Dependent on how your Facility is set up, you may either bring the universal waste to a designated storage area (i.e. hazardous waste storage area) or create a designated storage area.

20 Universal Waste Mercury Thermostats Emergency Procedures Any universal waste MCE that shows evidence of leakage, spillage, or damage that could cause leakage under reasonably foreseeable conditions must be placed in a container. The container must be closed, structurally sound, compatible with the contents of the MCE and must lack evidence of leakage, spillage, or damage that could cause leakage under reasonably foreseeable conditions. The container would now be classified as a hazardous waste and must be managed accordingly. This includes properly labeling the container and ensuring that it is immediately brought to a hazardous waste storage area. The date that the containers is brought to the storage area should be filled in on the label.

21 General Rule Keep in mind that materials you use at home for your personal use and dispose of in your household trash may be considered hazardous when used and disposed of at US Airways Always think before you throw something in the trash!

22 Enforcement, Fines & Penalties There are two regulatory agencies that oversee universal waste compliance: State Your State s Dept. of Environmental Protection Federal United States Environmental Protection Agency (USEPA) *Both agencies can proceed with civil or criminal prosecution for hazardous waste violations

23 Enforcement, Fines & Penalties Individuals may be criminally prosecuted for knowingly and willfully: Transporting waste to non-permitted facility Improper disposal of hazardous wastes/universal waste (including down drain, in general trash, etc.) Making false statements on any label, record, report or other form used for compliance purposes Individual criminal penalties may consist of: $50,000 fine for each day of violation, and/or Prison sentence of 2-5 years

24 Questions? If at any time you are in doubt about what to do with a waste, contact your Supervisor or the Piedmont Safety Department at:

25 Quiz 1. Universal Wastes are considered to? a. Pose limited hazard but are still a form of hazardous waste. b. Be extremely hazardous and pose a serious threat. c. Pose no hazard and can be thrown in the trash. d. Not be found anywhere at our facilities. 2. All of the following are classified as Universal Waste except? a. Lamps. b. Mercury Manometer. c. Pesticides. d. Computer monitor.

26 Quiz 3. Universal waste must be? a. In a structurally sound container to prevent spillage. b. Labeled as universal waste. c. Stored on-site for up to 1 year. d. All of the above. 4. If a lamp breaks or shows evidence of leakage, spillage or damage it now must be labeled as? a. Stays universal waste. b. Hazardous waste and placed in a Hazardous waste storage area. c. Broken. d. Not labeled and thrown away immediately to get rid of evidence.

27 Quiz 5. Universal Wastes are considered to? a. Pose limited hazard but are still a form of hazardous waste. b. Be extremely hazardous and pose a serious threat. c. Pose no hazard and can be thrown in the trash. d. Not be found anywhere at our facilities. 6. All of the following are classified as Universal Waste except? a. Lamps. b. Mercury Manometer. c. Pesticides. d. Computer monitor.

28 Quiz 7. Which of the following would be considered Mercury- Containing Equipment? a. Barometer. b. Thermostat. c. Thermometer. d. All of the above. 8. True/False. You must tape the ends of your batteries before throwing them in a disposal container.

29 Quiz 9. Which of the following lamps/bulbs are not classified a universal waste? a. fluorescent lamps. b. high intensity lamps. c. neon lamps. d. lava lamps. 10. True/false. Those things that you use at home and dispose of in your trash could be considered hazardous waste here at Piedmont.

30 Quiz 11. The two regulatory agencies that oversee universal waste compliance are? a. US EPA and FAA b. Applicable State and the US EPA c. FAA and DOT d. OSHA and US EPA 12. Which is the proper way to manage Universal Waste Batteries? a. Place each battery in a container and label the container. b. Label each battery separately. c. Do not label either the individual battery or the container. d. Either a or b.