Category: Large vs. Small Handler

The Thin Green Line

January 06, 2012   nlrgreen   No comments

Green Line

Programs like office paper, glass and can recycling are often implemented by a business’s  ”green team’ or as part of a corporate sustainability program. These programs help not only the environment but also provide a tangible aspect to a businesses green image and environmental responsibility. A corporate officer or employee can easily see the recycling bins and see what they have accomplished. However a company may not be subject to EPA fines if  the program is improperly managed or liable for incorrect storage of these items.* Would a EPA auditor say “Hey those aluminum cans and paper for shredding have no accumulation date.” or “What is your procedure to guard against environmental breach of those Snapple bottles?”. Most likely not. So when does environmental responsibility become a environmental requirement? Answer: When a company generates used lamps, batteries, ewaste, ballasts or mercury devices.

While used fluorescent lamps are taken away to the proper storage containers in the back of a  facility may not be in your face “look at us we recycle” it is still environmentally friendly and most importantly is the LAW.  Simple things such as having a universal waste recycling program, trained staff or properly stored containers with accumulation dates can help companies be compliant and reduce their liability. All of these things can be accomplished without a environmental health and safety officer or being a draw on budgets. The below are a few simple steps to successful universal waste recycling:

1) Learn & Educate-Understand your state’s regulations and specifics on universal waste
• What is Universal Waste? • RCRA Requirements • My State’s Regs
2) Assess Your Company- Take a general look at what universal waste your company produces and how often. See if you are a small or large generator3) Plan the Program- Based on the amount of waste generated see if a national mail-back program or bulk pick-up service is needed. Also look at factors beyond quantities such as ease of management, your facilities locations, or specific needs of your industry.

4) Implement & Monitor- Once you have selected the proper program be sure to implement it company-wide, educate employees, monitor progress, keep recycling records/certificates and evaluate the program yearly.

5) Have Questions or Need Assistance? Get Help-Call 877.822.4733 to discuss your company’s specific needs, implement a new program or to enhance a current one.
*depending on what state your company is in this may not be true. Check your local laws and regulations.

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Lamp Recycling Handler Size: Small vs. Large

April 05, 2011   nlrgreen   No comments

 

A handler accumulates universal waste (in this case lamps) but do not treat, recycle, or dispose of the waste. Knowing your size under the Universal Waste Rule allows you to know exactly what your requierments are. The EPA cites them as:

The universal waste regulations include requirements for two groups of handlers based on the amount of universal waste accumulated on site at any one time:

-A small quantity handler of universal waste may accumulate less than 11,000 pounds (5,000 kg) of total universal waste, (i.e., 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.

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. Small quantity handlers are not required to use a uniform hazardous waste manifest or keep records of universal waste shipments.  However, it is highly recommended such records be maintained. Universal waste shipments may be transported by a contracted transporter or by the small 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 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.

Get the EPA Guide: Introduction to universal waste

Need more information? Contact NLR

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