The handling and disposal of Hazardous Waste (waste that is potentially dangerous or harmful to human health or the environment) is governed by the Federal Resource Conservation and Recovery Act (RCRA). Universal Waste is Hazardous Waste that is widely and commonly used and produced by households and businesses. Universal Waste handling and management
regulations are more relaxed than those that apply to Hazardous Waste. The Federal Universal Waste regulations are codified in Title 40 of the Code of Federal Regulations § 273 and, up until recently, regulate four types of universal waste:
- Batteries
- Pesticides
- Mercury-containing equipment
- Lamps
The Environmental Protection Agency (EPA) has recently added hazardous waste aerosol cans as a category of Universal Waste material (30 CFR § 273.6) under this regulation. With an effective date of February 7, 2020, the addition of aerosol cans as a category of Universal Waste is intended to provide a solid system for managing discarded aerosol cans and promote the
collections and recycling of hazardous waste aerosol cans.
The rule will affect large quantity generators who generate, transport, treat, recycle, or dispose of hazardous waste aerosol cans (it does not affect households or very small quantity generators). Due to their characteristic for ignitability, aerosol cans have traditionally qualified as Hazardous Waste (40 CFR 261.21). The inclusion of aerosol cans as Universal Waste means that handlers can now have to apply the Universal Waste management standards which include more relaxed requirements for labeling, accumulation time, employee training, responses to release, export requirements, and tracking.
In some states, aerosol cans have already been added as a category of Universal Waste. For example, in California, Universal Waste includes, among other things, aerosol cans as well as Electronic Devices, CRTs, and CRT Glass. Regulations vary state-by-state, as such, to ensure compliance, review and understand the guidelines applicable to your state.
Business Management Systems such as ISO 14001 Environmental Management System (EMS), ISO 45001 Occupational Health and Safety Management System and R2 Standard require organizations to review and keep updated their list of legal and regulatory requirements, including RCRA requirements. If you need guidance on the standards of Hazardous Waste and
Universal Waste management and reviewing your legal and regulatory compliance contact GlenView Group at info@glenviewgroup.com.
