Ask the Expert, Hazardous and Solid Waste

Ask the Expert: Recordkeeping for Universal Waste Shipments

In our latest installment of Ask the Expert, brought to you by the team of industry experts at EHS Hero®, we look at a recent question from a subscriber asking about the recordkeeping requirements for universal waste shipments. See what the experts had to say. 

Q: What record keeping requirements are there for Universal Waste shipments?

There are federal universal waste recordkeeping requirements for large quantity handlers of universal waste (LQHUW) and universal waste destination facilities. (The universal regulations define an LQHUW as a universal waste handler that accumulates 5,000 kg or more total of universal wastes, calculated collectively, at any time. A universal waste destination facility is defined a facility that treats, disposes of, or recycles a particular category of universal waste, except those management activities performed by LQHUWs and small quantity handlers of universal waste.)

Record of universal waste received. LQHUWs 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, movement document, 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 three years from the date of receipt of the universal waste shipment.

Record of universal waste shipment. An LQHUW must keep a record of each shipment of universal waste sent to another facility in the form that applies to records of universal waste received. 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 three years from the date the universal waste shipment left the facility.