Managing Universal Waste 40 CFR 273 & 22 CCR 66273

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Philip Thomas Jenkins
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1 TABLE OF CONTENTS 1. GOAL PURPOSE SCOPE RESPONSIBLE PERSONS (22 CCR 66273) SPILLS (22 CCR 66273) UNIVERSAL WASTE DISPOSAL POLICY (22 CCR 66273) TRAINING (22 CCR 66273) PROCEDURE FOR STORING WASTES (22 CCR 66273)... 4 Page 1 of 7 Version 2 (January 2014)

2 1. Goal The University of the Pacific (Pacific) strives to provide its employees with a safe and healthful workplace. In order to achieve this goal, all levels of management and supervision are required to ensure that the guidelines of this Managing Universal Waste Plan are followed. 2. Purpose 2.1. This document has been designed to: Implement a system that provides employees access to environmental health and safety information (training, bulletins, etc.) necessary for the safe completion of their job responsibilities, Ensure that safety inspections are routinely conducted, and Ensure that the Three Fundamental Objectives of the Pacific Safety Program are effectively pursued The Three Fundamental Objectives are: Striving for an Injury and Illness free workplace. Identifying and eliminating operational deficiencies that can lead to injuries, illnesses, and/or fatalities. Maintaining a proactive and effective Safety Program (e.g., open communication between employee and supervisor, employee health and safety training, regularly scheduled inspections, accident and injury investigation). 3. Scope 3.1. This document applies to all personnel under the direct supervision of a Pacific employee (i.e., Temporary Employees, Temporary Agency Employees, Part time Employees, Full time Employees, Student Assistants, Federal Work Study, Graduate Assistants, etc.). All personnel shall comply with the provisions outlined in this document. 4. Responsible Persons (22 CCR 66273) 4.1 Department Heads and Chairs Be familiar with this Plan and its contents and objectives Support the Plan and oversee its implementation. Page 2 of 7 Version 2 (January 2014)

3 Ensure that proper administrative and engineering controls are provided in the work area. 4.2 Managers, Supervisors and Lead Personnel Must be familiar with this Plan and its contents and objectives Ensures workers understand and follow universal waste rules Ensures Personal Protective Equipment or PPE is available and in working order and is used correctly by employees Conducts documented monthly safety inspections that include inspection of emergency equipment, (e.g., eyewashes, safety showers and fire extinguishers) Identify and develop safety procedures when employees or students are working with potentially dangerous materials. Specific procedures for spills, waste disposal, decontamination, and accident response procedures must be developed by the department Monitor work sites and correct deficiencies. 4.3 Employees Shall be familiar with this Plan and its contents and objectives Conduct each task in accordance with the applicable training, exposure risk information, or department Standard Operating Procedure (SOP) Participate in required training sessions Use PPE and other protective devices when required. 5. Spills (22 CCR 66273) 5.1 Incidental spills: All incidental spills may be cleaned up by employees or students provided they have appropriate training and understanding of the chemicals being used at the time. These are generally small quantity spills of 1 gallon or less. 5.2 Larger spills: All larger spills will be cleaned up by either the local fire department or a contracted service. A contract exists between Pacific and Universal Environmental, Inc. for these situations. Page 3 of 7 Version 2 (January 2014)

4 6. Universal Waste Disposal Policy (22 CCR 66273) 6.1. The Universal Waste Disposal Policy ensures minimal harm will result to people, organisms and the environment from the disposal of universal waste The policy is based on the definition that Pacific is a small quantity generator based on the requirements of 40 CFR 273 and 22 CCR The University does not accumulate 5,000 kg or more total of universal waste (batteries, pesticides not in California, thermostats, or lamps, calculated collectively) at any one time. 7. Training (22 CCR 66273) 7.1 Employee training applicability and requirements Training applies to all personnel who work with materials as defined by universal waste regulations Training will include how to handle, store, package and label universal waste containers Written instructions, such as this plan, are adequate to meet training requirements. 8. Procedure for Storing Universal Wastes (22 CCR 66273) 8.1 Various methods can be used to demonstrate the length of time the waste has been accumulated: a) Label container with the date of the first waste placed in the container b) Mark or label each waste (i.e. battery) when it becomes a waste c) Maintain an inventory of when each material becomes a waste d) Place waste in an accumulation area and identify the date the first waste is placed in the accumulation area. e) Universal waste can be stored for one year after generating or receiving the waste. f) Universal waste cannot be treated except when cleaning up a release or managing specific wastes as stated in , for example, removing mercury ampoules from thermostats or electrolyte from batteries. 8.2 Additional Storage Requirements Batteries: Applies to Alkaline, nickel-cadmium, silver button, mercury, small sealed lead acid batteries (burglar alarm and emergency light batteries), and carbon-zinc No storage requirement if battery is in good condition Batteries must be segregated based on type. Zinc batteries must never be stored in the same container as alkaline batteries. Page 4 of 7 Version 2 (January 2014)

5 All battery containers must be labeled: 1) Used batteries for recycling, 2) Type of battery and 3) Start date that batteries were first added to container Containers 5 gallons or less may be kept on the floor, or shelf. Larger than 5 gallon containers must be kept on a pallet If battery shows signs of leakage or damage, it must be placed into a separate container and treated as hazardous waste. The container must be structurally sound and kept closed Non-leaking batteries may be shipped as Universal Waste on a Bill of Lading Mercury: Thermostats, Switches, Metallic Mercury If thermostat or any mercury containing device shows signs of damage and/or leakage, it must be placed into a container. The container must be structurally sound and kept closed If Mercury ampoules are removed from thermostats, they must be kept in closed leak proof containers Elemental Mercury (Metallic Mercury) must be kept in a closed and leak proof container All Mercury containers should be labeled as to contents Mercury for Recycling or Recycled Mercury along with the start date Mercury was first added to the container Lamps Lamps must be stored in structurally sound containers. Container must be kept closed at all times Lamp container must be labeled as Recycled lamps, Used lamps or Lamps for recycling plus the date lamps were first placed into the container Consumer electronics are considered universal waste Electronic waste will be stored off-site, and when shipped, must be palletized and wrapped in plastic or palletized and placed in a rigid container Call either Purchasing or Risk Management as to the removal of electronic waste to the off-site facility Ballasts, both PCB and non-pcb Both PCB and Non-PCB ballasts can be recycled. Both should be stored in a rigid container such as a drum, fiber box, or poly drum. Page 5 of 7 Version 2 (January 2014)

6 The drums for PCB or Non-PCB should be labeled as to their contents Recycled Ballasts with either PCB or Non-PCB written on label, along with the start date ballasts were first added to the container Lead Lead can be recycled. Due to the weight of Lead, place all Lead into a closed metal container. Remember, lead is a very heavy material, do not overload any single container Label container Lead for Recycling or Recycled lead and with the date Lead was first added to the container Dental amalgam can be recycled; the container must be labeled with the contents and the date the first materials were added to the container. The container should be closed and can be kept in a common area or shared area. 8.3 Labeling, transport and disposal Batteries: Universal waste-battery or Waste Battery or Used Battery. (Exception is the larger (automotive type Lead-Acid Batteries which are always hazardous waste.) Please contact Risk Management for clarification on the type of batteries in your possession Thermostats: Universal waste-mercury Thermostats or Waste Mercury or Used Mercury thermostat(s) Lamps: Universal waste-lamps, or Waste Lamps or Used lamps As long as the materials are not leaking or damaged in any way, transport can use a Bill of Lading (BOL) and a hazardous waste manifest is not required Separate departments do not need to keep copies of tracking documents; Risk Management will keep this information Federal Universal waste can be disposed of or recycled California - Lamps must be recycled. (Lamps may include fluorescent, high intensity discharge lamps, sodium vapor, neon, mercury vapor, metal halide and any lamp which exhibit a characteristic of a hazardous waste.) Page 6 of 7 Version 2 (January 2014)

7 9.0. References and Definitions (22 CCR 66273) References CFR part Section of the Code of Federal Regulations: Standards for Universal Waste Management CCR Sections of the California Code of Regulations covering: Universal Waste Management sections to , Title 22, CCR, Division 4.5 & Chapter The Department of Toxic Substance Control (DTSC) in Sacramento oversees the Universal Waste Programs in California. Information on this and related programs may be obtained through their web site at: Universal Wastes are defined as: Wastes that are more common and pose a lower risk to people and the environment than other hazardous wastes. All Universal Wastes are Hazardous Wastes except that their labeling, storage and disposal requirements are lower than regulated hazardous wastes. Page 7 of 7 Version 2 (January 2014)

Essentially they are hazardous wastes with low hazards and high volumes in commerce and so are designated as a lower level of waste

Essentially they are hazardous wastes with low hazards and high volumes in commerce and so are designated as a lower level of waste Any waste stream listed and defined in Section 66261.9 Requirements for Universal Waste Are exempt from the management requirements of chapter 6.5 of division 20 of the Health and Safety Code and its implementing