Universal Waste Management Program Compliance Checklist

Universal waste regulations simplify management of common hazardous waste streams like batteries and fluorescent lamps. This checklist ensures your facility meets small or large quantity handler requirements under EPA 40 CFR Part 273.

  • Industry: Waste Management
  • Frequency: Monthly
  • Estimated Time: 25-30 minutes
  • Role: EHS Coordinator / Facilities Manager
  • Total Items: 36

Universal Waste Handler Category

Verify correct handler category determination.

  • Handler category determined (Small: less than 5,000 kg on site vs Large: 5,000+ kg)?
  • Large quantity handlers notified EPA and obtained EPA ID?
  • Current on-site quantity tracked and not exceeding handler category limits?
  • State-specific universal waste additions checked?
  • Universal waste inventory tracked by type and quantity?
  • No universal waste stored more than 1 year from generation date?

Battery Management

Verify batteries are properly managed.

  • All battery containers labeled 'Universal Waste - Batteries' or 'Used Batteries'?
  • Batteries stored in closed containers in good condition?
  • No leaking batteries in storage?
  • Leaking battery response procedure: manage as hazardous waste?
  • Accumulation start date marked on all battery containers?
  • Batteries sent to certified universal waste handler or recycler only?

Fluorescent Lamp and Mercury Lamp Management

Verify lamps are properly managed.

  • Lamp containers labeled 'Universal Waste - Lamps' or 'Used Lamps'?
  • Lamps stored in closed containers preventing breakage?
  • Broken lamp cleanup protocol posted: mercury vapor precautions, ventilate?
  • Lamps not crushed before recycling?
  • Accumulation start date on lamp containers?
  • Lamps sent to certified lamp recycler only?

Mercury-Containing Equipment

Verify mercury equipment is properly managed.

  • Mercury-containing equipment (thermostats, switches) labeled 'Universal Waste - Mercury Equipment'?
  • Mercury-containing equipment stored to prevent breakage?
  • Mercury spill kit available where mercury equipment is stored?
  • Thermostat recycling program utilized (Thermostat Recycling Corporation)?
  • Mercury equipment sent to certified recycler only?
  • Mercury equipment inventory tracked?

Employee Training

Verify employee training requirements.

  • Small quantity handlers: employees trained to identify universal waste and understand requirements?
  • Large quantity handlers: formal training program on universal waste regulations?
  • Employees trained on emergency response for releases (battery acid, mercury)?
  • Training records documenting employee training on file?
  • New employees trained before handling universal waste?
  • Annual refresher training on universal waste requirements?

Recordkeeping

Verify required documentation.

  • Shipping records to recyclers retained 3 years?
  • Receipts from recyclers confirming proper disposal on file?
  • Monthly universal waste quantity tracking records maintained?
  • State-required universal waste reporting current?
  • Any releases or spills documented?
  • All records accessible for regulatory inspection?

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Why Use This Universal Waste Management Program Compliance Checklist?

This universal waste management program compliance checklist helps waste management teams maintain compliance and operational excellence. Designed for ehs coordinator / facilities manager professionals, this checklist covers 36 critical inspection points across 6 sections. Recommended frequency: monthly.

Frequently Asked Questions

What does the Universal Waste Management Program Compliance Checklist cover?

This checklist covers 36 inspection items across 6 sections: Universal Waste Handler Category, Battery Management, Fluorescent Lamp and Mercury Lamp Management, Mercury-Containing Equipment, Employee Training, Recordkeeping. It is designed for waste management operations and compliance.

How often should this checklist be completed?

This checklist should be completed monthly. Each completion takes approximately 25-30 minutes.

Who should use this Universal Waste Management Program Compliance Checklist?

This checklist is designed for EHS Coordinator / Facilities Manager professionals in the waste management industry. It can be used for self-assessments, team audits, and regulatory compliance documentation.

Can I download this checklist as a PDF?

Yes, this checklist is available as a free PDF download. You can also use it digitally in the POPProbe mobile app for real-time data capture, photo documentation, and automatic reporting.

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