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What’s Wrong With This Picture? Errors Made by Generators of Universal Waste

What’s Wrong With This Picture? Errors Made by Generators of Universal Waste

The universal waste regulations of the USEPA provide an option for generators of certain hazardous waste to manage them according to a lower regulatory standard:  The Universal Waste Regulations.  To take advantage of this “de-regulation” of a hazardous waste, generators need only comply with some basic regulations pertaining to its onsite management and off-site disposal.  You can learn more about the management of Universal Waste from my article:  The Universal Waste Option for the Management of Hazardous Waste.

The USEPA hazardous waste currently eligible for the Universal Waste option are:

  • Lamps
  • Batteries
  • Mercury-Containing Devices
  • Recalled or Canceled Pesticides

While states may differ in what they identify as a Universal Waste and in some of the on-site management requirements, they all agree that Universal Waste must be sent for disposal or recycling to a Universal Waste Destination Facility.  A business can not simply throw Universal Waste in the trash with its regular garbage.

Improper disposal of universal waste lamps

Does this look like proper management of a Universal Waste?

 

**NOTE:  It may be possible for a Conditionally Exempt Small Quantity Generator of hazardous waste or a homeowner to send its Universal Waste to a Municipal Solid Waste Landfill for disposal with its regular trash or garbage.  However, this is not recommended and some states out-right ban the landfill disposal of fluorescent lamps.

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Whatever your hazardous waste generator status or your status as a handler of universal waste, you and your employees will benefit from some form of my training services.  Please contact me to discuss the best training option for you: