Comparison of Requirements for Universal Waste

Comparison of Requirements for Universal Waste & Hazardous Waste in WV

The following tables have a comparison of requirements for

Handlers of Universal Waste and Generators of Hazardous Waste
Transporters of Universal Waste and Hazardous Waste
Destination Facilities for Universal Waste and Hazardous Waste

These tables are a guide, please see the regulations for the entire requirements. These tables are not intended to modify or affect in any way existing statutory or regulatory requirements; they are intended to briefly summarize existing requirements. In addition, states can have more stringent requirements. In many cases a state has lowered the amounts allowed for the conditionally exempt small quantity generators (lower than 220 lb.).

1. General Comparison of Universal Waste Handler Requirements to Hazardous Waste Generator Requirements.

	Universal Waste Handler Requirements		Hazardous Waste Generator Requirements
	Small Quantity Handler of Universal Waste (SQHUW)	Large Quantity Handler of Universal Waste (LQHUW)	Conditionally Exempt Small Quantity Generator (CESQG)	Small Quantity Generator (SQG)	Large Quantity Generator (LQG)
Quantity Handled by Category	Accumulate < 5,000 kg (11,000 lb) on site at any one time §273.9	Accumulate 5,000 kg (11,000 lb) or more on site at any one time §273.9	Generate: ˜100 kg (220 lb.) per month ˜1 kg acute* per month §261.5(a) and (e)	Generate < 1,000 kg (2,200 lb.) per month §260.10	Generate: š1,000 kg per month > 1 kg acute* per month Part 262 and §261.5 (e)
EPA Identification Number	Not required §273.12	Required §273.32	Required §261.5	Required §262.12	Required §262.12
On-Site Accumulation Limit	< 5,000 kg §273.9	No quantity limit	1,000 kg 1 kg acute* 100 kg spill residue from acute §§261.5(f)(2) & (g)(2)	< 6,000 kg §262.34(d)(1)	No quantity limit
Storage Time Limit (without a storage permit)	1 year, unless for proper recovery, treatment, or disposal §273.15	1 year, unless for proper recovery, treatment, or disposal §273.35	None §261.5	˜180 days or ˜270 days if >200 miles from TSD §262.34(d) & (e)	˜90 days §262.34(a)
Manifest	Not required §273.19	Not required, but must keep basic shipping records §273.39	Not required §261.5	Required §262.20	Required §262.20
Personnel Training	Basic training §273.16	Basic training geared toward employee responsibilities §273.36	Not required §261.5	Basic training §262.34(d)	Full training §262.34(a)

The universal waste citations listed can be found at 40 CFR 273.

The conditionally exempt small quantity generator citations listed can be found at 40 CFR 261.5.

The generator citations listed can be found at 40 CFR 262

General definitions of terms applicable to these regulations are found in 40 CFR 260.10.

Note: "§" is used in this page to refer to a section in title 40 of the Code of Federal Regulations (For example "§273.15" is also referred to as "40 CFR 273.15" or "title 40, part 273, section 15.")

"Acute" refers to acute hazardous waste as identified in 40 CFR 261.

2. General Comparison of Universal Waste Transporter to Hazardous Waste Transporter Requirements.

	Universal Waste Transporters 40 CFR part 273 subpart D	Hazardous Waste Transporters 40 CFR part 263
Compliance with Department of Transportation (DOT)	Yes §273.52(a) cites DOT Requirements 49 CFR parts 171-180	Yes §263.10 And DOT Requirements 49 CFR parts 171-179
EPA ID Number (Notification Requirements)	none	yes §263.11
Allowance to Store up to 10 days at a Transfer Facility	yes §273.53	yes §263.12
Manifest Requirements	none	yes §263.20-22
Response to Releases	yes §273.54	yes, with more complex requirements §263.30-31

3. Comparison of Universal Waste "Destination Facility " Requirements to Hazardous Waste Recycling, Treatment, Storage, & Disposal Facility Requirements

"Destination facilities" are facilities that treat, dispose of, or recycle a particular category of universal waste and are subject all applicable requirements that apply to any hazardous waste treatment, storage and disposal facilities. 40 CFR 273.9, 273.60.

Facilities that are just accumulating a universal waste, but not recycling, treating, or disposing of that waste category can use the less stringent universal waste requirements for handling that universal waste category.

The universal waste rule does not change the requirement for recycling facilities to get a storage permit if they store waste before they recycle it. Also if a recycling facility does not store, they still have to comply with the requirements of 40 CFR 261.6(c)(2) according to 40 CFR 273.60(b)

Please see the regulations for the full requirements, also state regulations can be different.