“One year” is the operative time frame for managing universal wastes under the RCRA regulations at 40 CFR 273. All handlers of universal waste have one year to keep universal waste onsite. To prove that it meets this time limitation, the handler must be able to demonstrate the number of days the universal waste has been accumulating at the facility. Similarly, any handler of universal waste that wants to accumulate universal wastes for over one year must be able to demonstrate that more than 365 days is needed to accumulate enough universal waste to make offsite shipments easier.
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Both small quantity handlers of universal waste (SQHUWs) and large quantity handlers of universal waste (LQHUWs) must comply with an accumulation-time limit of one year for storing universal wastes (a permit is not needed). The year time period is measured from the time the waste is either generated (the date it becomes a waste) or the date it is received from another universal waste handler. A SQHUW or LQHUW must be able to demonstrate the length of time that the universal waste has been accumulated.