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Comparison to Other Requirements


Kinds of Universal Waste

Batteries Lamps Pesticides Mercury-Containing Equipment

The following tables have a comparison of requirements for:

  1. Generators
  2. Transporters
  3. Destination Facilities

These tables are a guide, please see the complete universal waste 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 generator requirements
to universal waste requirements.

  Universal Waste Requirements 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
5,000 kg (11,000) or more on site at any one time
< 100 kg (220 lb) per month
< 1 kg acute* per month 261.5 (a) and (e)
< 1,000 kg (2,200 lb) per month 260.10
> 1,000 kg per month
> 1 kg acute* per month
Part 262 and §261.5 (e)
EPA Identification Number Not required
Not required
On-Site Accumulation Limit
< 5,000 kg
No quantity limit < 1,000 kg
< 1 kg acute*
< 100 kg spill residue from acute
§261.5(f)(2) & (g)(2)
< 6,000 kg
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
< 180 days or
< 270 days
§262.34(d) & (e)
< 90 days
Manifest Not required
Not required, but must keep basic shipping records
Not required
Personnel Training Basic training
Basic training geared toward employee responsibilities
Not required
Basic training
Full training

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.

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2. General comparison of hazardous waste transporter requirements to universal waste transporter requirements.

  Universal Waste Transporters40 CFR part 273 subpart D Hazardous Waste Transporters
40 CFR part 263
Compliance with Department of Transportation (DOT)

§273.52(a) cites DOT Requirements
49 CFR parts 171-180
§263.10 DOT Requirements
49 CFR parts 171-179
EPA ID Number (Notification Requirements) none yes
Allowance to Store up to 10 days at a Transfer Facility yes
Manifest Requirements none yes
Response to Releases yes
yes, with more complex requirements

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3. Comparison of hazardous waste recycling, treatment storage, and disposal facility requirements and universal waste "destination 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)

Universal Waste Destination Facilities - part 273 subpart E

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

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