Universal wastes are items that are generated by a large number of businesses in relatively small quantities. Five hazardous wastes are identified as universal wastes under Section 273 of Delaware’s Regulations Governing Hazardous Waste. They are batteries, mercury-containing equipment, obsolete agricultural pesticides, lamps and aerosol cans.

Under the regulations, Universal Wastes may have alternative management standards, depending on the amount of wastes managed. The following are questions and answers regarding universal wastes.

Disclaimer: The information below is intended to serve as a guide to responsible waste management and does not supersede Delaware’s Regulations Governing Hazardous Waste (7 DE Admin. Code 1302). Regulations specific to Universal Wastes can be found in Part 273 of the regulations.

How is the Universal Waste Rule Less Stringent than the Regulatory Requirements for Hazardous Waste Management?

As the stringency of the Regulations Governing Hazardous Waste differs between generator categories, so does the Universal Waste Rule. The Universal Waste Rule has two categories of universal waste handlers — small quantity and large quantity.

Universal waste handlers can generate larger quantities of universal waste and accumulate these wastes onsite for longer periods of time than they can other hazardous waste.

For example, a small quantity generator of hazardous waste cannot generate greater than 2,200 pounds (1,000 kg) of hazardous waste in a calendar month and may not accumulate the hazardous waste onsite for more than 180 days. However, a small quantity handler of universal waste may accumulate less than 11,000 pounds (5,000 kg) of universal waste for periods up to one year.

What are the Differences Between the Small Quantity and Large Quantity Handlers of Universal Waste?

A small quantity handler of universal waste may accumulate less than 11,000 pounds (5,000 kg) of total universal waste, (e.g. aerosol cans, batteries, pesticides, mercury thermostats or mercury-containing lamps) for periods up to one year.

A large quantity handler of universal waste is one who accumulates 11,000 pounds (5,000 kg) or more of total universal waste for periods up to one year. Large quantity handlers of universal waste are also required to complete an EPA Site Identification form and obtain an EPA ID number.

What are the Requirements for a Small Quantity Handler of Universal Waste?

Small quantity handlers must ensure that any universal wastes they are accumulating are managed in a closed container that prevents the release of the universal waste or waste components. Each container must be labeled with the type of universal waste it contains.

The small quantity handler may accumulate its universal waste no longer than one year from the date the waste was generated and must maintain records demonstrating the actual generation date. Additionally, the small quantity handler must ensure all employees handling a universal waste have been provided information on proper handling and emergency procedures appropriate to the types of wastes managed.

A small quantity handler must send its universal waste to another universal waste handler, a permitted facility or a foreign destination (export requirements apply). Small quantity handlers are required to maintain records of universal waste shipments (manifest, bill of lading, or other shipping document) for a minimum of three (3) years.

Universal waste shipments may be transported by a contracted transporter or by the small quantity handler of universal waste. In either case, a Delaware Hazardous Waste Transporter Permit is not required.

What are the Requirements for a Large Quantity Handler of Universal Waste?

In general, the requirements for large quantity handlers are more stringent than those of small quantity handlers of universal waste. First, the large quantity handler must notify the Compliance and Permitting Section and receive an EPA Identification Number. Much like the small quantity handler, the universal waste must be accumulated in a closed container labeled with what it contains.

Large quantity handlers may not accumulate universal wastes for more than one year and must maintain records demonstrating the date of the universal waste generation.

Employees managing universal waste must be trained as to proper waste handling and emergency procedures.

Shipments of universal waste from a large quantity handler must be tracked on a manifest, bill of lading, or similar type of document which must be maintained for at least three (3) years.

What Are the Requirements for Universal Waste Transporters?

While a Delaware Hazardous Waste Transporter permit is not required, there are certain regulatory requirements for universal waste transporters.

Universal waste transporters may not dispose of, dilute, or treat universal waste, nor can transporters store universal waste shipments more than ten (10) days without becoming subject to more stringent handler requirements.

Universal waste transporters must deliver the universal waste to either another universal waste transporter, or a permitted facility or a foreign destination (export requirements apply).

Transporters must ensure compliance with all applicable federal Department of Transportation regulations found in 49 CFR 171 through 180.

What Are the Requirements for Universal Waste Destination Facilities?

Universal waste destination facilities are, in actuality, permitted hazardous waste treatment, storage and disposal facilities (TSDs). Therefore, these facilities must comply with the requirements for TSDs found in the Regulations Governing Hazardous Waste.

Related Topics:  hazardous, Health and Safety, permitting and regulation, universal, waste, waste and hazardous substances, waste management