Both small and large quantity handlers of universal waste must comply with an accumulation time limit of 1 year for storing universal wastes. A permit is not required.
The accumulation period is measured from the time the waste is either generated (the date it becomes a waste) or received from another universal waste handler. Universal wastes may be stored longer if you can demonstrate to EPA that more time is necessary to properly recycle the waste.
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Documenting Accumulation Time
The regulations require you to be able to document the length of time that universal wastes have been accumulating on-site. The rule suggests various methods to meet this requirement, including:
- Placing the universal waste in a container that is marked or labeled with the earliest date that any universal waste in the container became a waste or was received
- Marking or labeling each individual item of universal waste with the date it became a waste or was received
- Maintaining an inventory system
- Placing the universal waste in a specific accumulation area
Transporters
Universal waste transporters may only store the waste at a transfer facility for 10 days or less, or be subject to the same waste management rules applicable to small or large quantity handlers.
A transfer facility is defined as any transportation-related facility, including loading docks, parking areas, storage areas, and other similar areas where shipments of universal waste are held during the normal course of transportation.
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Tracking Requirements
Large quantity handlers and destination facilities must keep a record of each shipment of universal waste received at the facility. The record may be a log, invoice, manifest, bill of lading, or other shipping document. The record must include:
- Name and address of the originating universal waste handler or foreign shipper who sent the universal waste
- Quantity of each type of universal waste received
- Date of receipt of the shipment of universal waste
These records must be kept for at least 3 years from the date of receipt of the universal waste shipment.
Large quantity handlers must keep a record of each shipment of universal waste sent to another facility. The record must include:
- Name and address of the universal waste handler, destination facility, or foreign destination to whom the universal waste was sent
- Quantity of each type of universal waste sent
- Date the shipment of universal waste left the facility
These records must be kept for at least 3 years from the date the universal waste shipment left the facility.