RCRA - Storage/Disposal Details 

All facilities that accumulate certain wastes, including batteries, mercury-containing equipment or lamps (e.g., fluorescent light bulbs) are subject to the universal waste management requirements in 40 CFR 273, which include:

• Following procedures for managing waste batteries in such a way that batteries showing evidence of leakage, spillage, or damage are stored in appropriate containers; the integrity of each battery cell is preserved during the following activities including, but not limited to: sorting, regenerating, and disassembly, and wastes resulting from regeneration/disassembly are properly characterized.
  
• Following procedures for storing waste lamps (whether they are intact or broken) in such a way that they are properly contained. The container(s) must be structurally sound, adequate to prevent breakage or, in the case of broken waste lamps, leakage; and compatible with the contents of the container.
  
• Labeling, as appropriate, the wastes: “Waste Batteries,” “Universal Waste- Batteries,” “Used Batteries,” ”Universal Waste-Mercury Thermostat(s),” “Waste Mercury Thermostat(s),” “Used Mercury Thermostat(s),” “Universal Waste- Lamp(s),” “Used Lamp(s),” “Universal Waste-Mercury-Containing Equipment,” “Waste Mercury-Containing Equipment,” or “Used Mercury-Containing Equipment.”
  
• Tracking the length of time universal waste accumulates, to ensure that the waste does not accumulate for more than one year (unless the facility can demonstrate that accumulating universal wastes for more than one year is necessary to facilitate proper recovery, treatment or disposal).
  
• Providing universal waste training to employees that covers responsibilities for universal waste handling and emergency procedures.
  
• Containing all universal waste releases and determining whether any released material is hazardous waste.

In addition, large quantity handlers of universal waste--those who accumulate 5,000 kg or more of universal waste at any given time--are required to notify the EPA of its universal waste management and retain records of all universal wastes shipped from and received by the facility. (Other wastes considered to be universal wastes include pesticides and mercury thermostats.) Some states (e.g., Massachusetts) also have their own, sometimes more stringent, universal waste regulations. If spent batteries and mercury-containing devices (e.g., thermostats), fluorescent lamps and waste pesticides are not managed as universal wastes, then these wastes must be managed according to applicable RCRA hazardous waste requirements.

For the complete text of the regulations (40 CFR 261, 262, 265, 273, 302 and 355; and 49 CFR 172), click here: