Listen up: If your facility generates waste, you might qualify for hazardous waste exemptions.
Under the Resource Conservation Recovery Act (RCRA), the Environmental Protection Agency (EPA) regulates facilities that generate hazardous wastes. These regulations provide the framework for how hazardous wastes need to be stored and handled while they are onsite, transported and treated or disposed.
Among these regulations are special exemptions or streamlined requirements for some types of wastes that don’t present high levels of hazards when they are properly managed, including wastes that:
- Are often generated by facilities other than industry and manufacturing
- Are generated by members of the community, making it difficult for regulatory agencies to govern them
- May be present in high volumes in non-hazardous waste management systems [60 FR 25493]
Universal wastes are one category of these special wastes. In many cases, the hazardous components of universal wastes are also highly recyclable, which fits into EPA’s waste management hierarchy and encourage environmental stewardship.
Currently, four types of wastes can be managed under the EPA’s Universal Waste Management Rules [40 CFR 273]:
- Intact, unbroken batteries, except spent lead acid batteries and other batteries specifically managed under other regulations
- Bulbs (lamps)
- Bulbs that contain mercury and are designed to produce light. Examples are fluorescent, high intensity discharge (HID), neon, mercury vapor, high pressure sodium and metal halide lamps.
- Mercury-containing equipment
- Any device or part of a device that contains elemental mercury, such as thermometers and thermostats.
- Products used to prevent, destroy, repel or mitigate pests; or any product that regulates, defoliates or desiccates plants and is not an animal drug.
The Universal Waste Rules provide management standards for both small and large quantity generators, including container management, labeling and training requirements. These rules are less stringent than full hazardous waste management regulations, providing generators with more flexibility to manage these waste streams.
As always, your state and local regulations might be more stringent than federal regulations. Make sure you check with your state and local entities to ensure you’re always in compliance.