Universal Waste Management Training

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2. 2  Objectives: Implement proper UW Management at all Postal Facilities Understand how to manage certain hazardous wastes as universal wastes. Facilitate compliance with Federal Universal Waste Regulations. Provide guidance for State specific regulations

3. 3 Universal Waste Overview Universal Waste Regulations were created by the US EPA and State Environmental Agencies to streamline and simplify hazardous waste management and encourage recycling for specific common and widely generated hazardous wastes. This training is based on current FEDERAL REGULATIONS as of January 2009 and may change over time. **Please note that additional regulations and requirements may vary from State to State, therefore it is necessary to review your State’s requirements when managing specific Universal Waste Materials.

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5. 5 Mercury-Containing Lamps

6. 6 Batteries

7. 7 Mercury Containing EquipmentMercury containing equipment is a device or part of a device that contains elemental Mercury which is necessary to its function. 

8. 8  Pesticides Waste Pesticides are Universal Wastes It is POSTAL POLICY that regulated pesticide use be conducted entirely by external contractors (i.e. for bringing regulated pesticides on-site for any use). Pesticides available through retail outlets (e.g., wasp spray, etc) are only to be used in accordance USPS hazard communication and personal protective equipment policies Non-empty cans of bug spray must be disposed of as a Universal Waste Facilities with waste pesticides should contact their Environmental Specialist for assistance.

9. 9 Why must we recycle Universal Wastes? 40 CFR 273.11   Prohibitions. A small quantity handler of universal waste is: (a) Prohibited from disposing of universal waste; and (b) Prohibited from diluting or treating universal waste, except by responding to releases as provided in 40 CFR 273.17; or by managing specific wastes as provided in 40 CFR 273.13.

10. 10  Other Regulated WastesThat Must Be Recycled PCB Ballasts (Toxic Substances Control Act) Lead Acid Batteries (Resource Conservation Recovery Act) Electronics (if they contain lead, cadmium, or other regulated hazardous wastes)

11. 11 Universal Waste Generator Status Small Quantity Handler (SQH) Generates less than 5000 kg (11,000 lbs) of Universal Waste in one year Most Postal Facilities will fall into this category Large Quantity Handler (LQH) Generates 5000 kg (11,000 lbs) or more of Universal Waste in one year

12. 12 Requirements for the Management of Universal Waste  The Federal Universal Waste Regulations are found in 40 CFR Part 273. States can modify the universal waste rule and add additional universal waste(s) and/or establish more restrictive requirements (but they can’t reduce EPA requirements) in individual State Regulations, so check with your State for the exact regulations that apply. Go to the web-site listed below. http://www.epa.gov/waste/hazard/wastetypes/universal/statespf.htm

13. 13 Different Universal Wastes in States(Note: This List is Not Comprehensive) These Materials Are Classified as "Universal Waste" . . . In These States: Aerosol Cans: California, Colorado Antifreeze: Louisiana, New Hampshire PCB Ballasts: Maine, Maryland, Vermont Barometers: New Hampshire, Rhode Island Cathode Ray Tubes (CRTs): Maine, New Hampshire, Rhode Island Electronics: Arkansas, California, Colorado, Connecticut, Louisiana, Michigan, Nebraska, New Jersey Oil-Based Finishes: New Jersey Paint and Paint-Related Wastes: Texas Hazardous Waste Pharmaceuticals: Michigan

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16. 16 General Procedures for Management and Recycling of Universal Wastes at USPS Facilities

17. 17  Accumulation Areas EPA Requirements Separate area designated for Universal Waste storage Clearly labeled with sign Appropriate containers for each type of Universal Waste Accumulation Limit (check state regulations) Time Limit on Storage = 1 year Closed Containers for all UW waste types Labeling “Universal Waste – Accumulation Area” - Specify UW Types Stored in Area

18. 18 Accumulation Areas(Example of signage)

19. 19 Approved Storage Containers Fluorescent Bulbs - Fiber drums with lids or boxes that can be closed to contain and protect the bulbs from breakage Batteries - Store in closed, impermeable containers Separate containers for each battery type Tape contacts with electrical tape

20. 20 Inspections Accumulation areas should be inspected for open containers, leaking containers, misplaced wastes, and general cleanliness. Broken lamps or other Universal Waste debris must be packaged and handled as hazardous waste. Follow USPS approved work practices - contact your Environmental Specialists. Verify that the accumulation limit has not been exceeded. Containers should be properly labeled, inspected for leaks and dates verified that wastes are not kept on site for more than1 year. Deficiencies should be corrected immediately.

21. 21 Required Container Labels Each Waste Label must state one of the following: “Universal Waste – Lamps” or “Used Lamps” “Universal Waste – Batteries” or “Used Batteries” “Universal Waste – Pesticides” or “Waste Pesticides” “Universal Waste - Mercury Containing Equipment” Label must be dated with the date that the first item was placed in the container Check your State’s specific labeling requirements

22. 22  Documentation Volumes of Universal Waste generated must be tracked Shipping Records: Shipping records may be a log, invoice, manifest, bill of lading, or other shipping documents Records for each shipment are to include: Postal facility name & address, Name & address of recycler, Quantity of each type of universal waste sent, Date the shipment left the postal facility Training All documentation should be retained for at least three years.

23. 23  Training A Small Quantity Handler of universal waste must inform all employees who handle or have responsibility for managing universal waste. The information must describe proper handling and emergency procedures appropriate to the type(s) of universal waste handled at the facility. A Large Quantity Handler of universal waste must ensure that all employees are thoroughly familiar with proper waste handling and emergency procedures, relative to their responsibilities during normal facility operations and emergencies. Use the Universal Waste Service Talk to conduct the annual required training and maintain documentation of this training

24. 24 Contacts For additional information regarding Universal Waste Management, contact an Environmental Policy and Programs Team Leader or Environmental Specialist. A list of the Team Leaders can be found under Safety & Environmental Resources on the USPS Blue Page. Click Environmental POCs for a list.

25. 25 Approved National Universal Waste Recyclers: Veolia Environmental Services: 218 Canton Street Stoughton, MA 02072-2219 Contact: Mr. Barry Jordan at 781-341-6080 or email: barry.jordan@veoliaes.com CRT Processing: 2535 Beloit Ave. Janesville, WI 53546-3046 Contact: Mr. Jeff DeGarmo at 608-754-3400 or email: Jdegarmo@crtprocessing.com Global Investment Recovery: 5806 N 53 RD ST Tampa, FL 33610-4817 Contact: Mr. Doug Buffengarger at 813-620-1507 or email: dbuffenbarger@girm.com Safety Kleen Systems: 5400 Legacy Drive, Cluster II, Building #3 Plano, TX 75024-3105 Contact: Ms. Karla Grissom at 972-265-2482 or email: karla.grissom@safety-kleen.com

26. 26 Universal Waste Management & Recycling Resources:

27. 27 “Where You Live”State Specific Universal Waste Regulations:(Go to web-site listed below and click on your State)

28. 28 QUIZ: If a spent fluorescent lamp is removed from its fixture, how should it be handled? It should be placed in a closed container with a proper label designating the date the first lamp was placed in the container. The lamp may be thrown in the trash The lamp should be placed in a container with other universal wastes including batteries and thermostats Which of the following wastes are considered universal wastes? Household batteries, floppy disks, and Styrofoam cups Fluorescent lamps, mercury thermostats and Nickel Cadmium batteries Chlorinated solvents, waste oil and Cardboard Do containers used to store Universal Wastes require a label? Yes No

29. 29 QUIZ: How long should universal wastes be stored on site before they are sent to an authorized universal waste recycling company? No longer than 365 days Up to 180 days No longer than 2 years There is no time limit on storage of universal wastes According to Postal Service Policy should household batteries (.e.g., AA, AAA, C or D batteries) be thrown in the trash? Yes No

30. 30 QUIZ: 6. If a contractor is retained to complete a re-lamping project for your facility, what documentation should be provided to you at the completion of the project? A copy of the Bill of Lading documenting that the fluorescent lamps were taken to an authorized recycler A copy of the contractor safety checklist showing that the work was completed safely A list of authorized contract employees who can sign the Bill of Lading Should universal waste storage areas be inspected? Yes No What type of documentation is required to prove your Universal Waste generator status? Records of monthly and/or annual universal waste generation volumes (shipping volumes, storage area logs, vendor counts, etc.) Record of Universal Waste Management training A copy of the ebuy requisition for waste recycling services