A hazardous waste is a waste with properties that make it dangerous or capable of having a harmful effect on human health or the environment. Hazardous waste is generated from many sources and come in the forms of liquids, solids gases, and sludges.  EPA developed a regulatory definition and process for identify specific substances known to be hazardous and created regulations specific to these wastes.

For a material to be classified as a hazardous waste, it must first be a solid waste. The first step in the hazardous waste identification process is determining if a material is a solid waste. Next the determination process examines whether or not the waste is specifically excluded from regulation as a solid or hazardous waste.  If determined to be solid waste, the waste is further evaluated to establish whether the waste is a listed or characteristic hazardous waste.

At EAFB, hazardous waste is managed at specific locations only.  These areas are Central Accumulation Areas (CAA) or Satellite Accumulation Points (SAP).  Only authorized and trained personnel can manage hazardous waste. Improperly managed hazardous waste has the potential to release harmful substances to the environmental and cause harmful exposure to humans or other living things. Mismanaging hazardous waste also exposes EAFB to potential fines from the EPA.

Quick guides in the form of posters and fact sheets are provided in the links to the right. These posters include the steps you need to take for proper management of UW and are available for you to print and post in your unit, shop, and work areas.  More information about Universal Waste, EAFB waste management, and training is provided below.

REGULATORY AGENCIES

Alaska Administrative Code (AAC) adopts by reference federal regulations for hazardous (HW) and UW.  In Alaska, UW rules are administered by Environmental Protection Agency (EPA) Region 10. EPA’s UW regulations streamline the HW management standards for certain categories of HW that are commonly generated.  EAFB is a Small Quantity Handler of Universal Waste (SQHUW), one of four types of regulated participants in the UW system. The EPA is the federal regulatory agency that is charged with auditing and inspecting EAFB to ensure compliance with all federal HW/UW regulations.

UNIVERSAL WASTE TYPES

A waste must first be determined as hazardous before it can be considered a UW. UW is a specific category of HW. Put simply, UW is HW! Federal regulations identify five specific categories of materials that can be managed as UW:

• Lamps
• Batteries
• Mercury-Containing Equipment
• Pesticides

Title 40 of the Code of Federal Regulations (CFR) Part 273 defines the type of materials that fall under the UW categories and specify in what situations that material can be considered a UW.  Regulations for UW are tailored to each type of UW and require that the materials be managed in a way that prevents releases to the environment. Regulation standards include labeling, containerization and storage, release response requirements, and transport to a facility that is permitted or designated to receive hazardous waste, such as a recycler.

Lamps

40 CFR part 273.9 defines a lamp as the bulb or tube portion of an electric lighting device. A lamp is specifically designed to produce radiant energy. Common UW lamps include fluorescent, high intensity discharge, neon, mercury vapor, high pressure sodium, and metal halide lamps. Lamps are not considered a UW if they have not been discarded as a waste or don’t meet the definition of a HW.

Batteries

40 CFR section 273.9 defines a battery as a device consisting of one or more electrically connected electrochemical cells which is designed to receive, store, and deliver electric energy. The term battery also includes an intact, unbroken battery from which the electrolyte has been removed. Some batteries meet this definition but are not UW. These include spent lead-acid batteries that are being managed under the requirements of 40 CFR part 266 subpart G, batteries that are not waste because they have not been discarded, and batteries that don’t meet the definition of a HW.  Lead-acid batteries are managed under Subpart G at EAFB are not handled as UW. Common alkaline batteries (AA, C, D, etc) are also not UW.

Mercury-Containing Equipment

40 CFR part 273.9 defines mercury-containing equipment as a device or part of a device (including thermostats but excluding batteries and lamps) that contains elemental mercury integral to its function.  Some mercury-containing equipment meets this definition but is not UW, such as: equipment or devices from which the mercury-containing components have been removed; mercury-containing equipment that is not waste because it has not been discarded; and mercury-containing equipment doesn’t meet the definition of HW.

Pesticides

40 CFR part 273.9 defines a pesticide as any substance or mixture of substances intended for preventing, destroying, repelling, or mitigating any pest, or intended for use as a plant regulator, defoliant, or desiccant, with exceptions for animal drugs and animal feeds. While regulated as UW, EAFB does not generate or manage pesticides.

EAFB TRAINING

A four-hour training course is offered by Environmental Compliance Consultants (ECC), the installation HW/UW contractor. Handlers of UW must attend the training.  Your Unit Environmental Coordinator (UEC) or Hazardous Waste Manager will identify the need for you to take the training or you can make a request to your UEC.  Once identified with a training need, a Command Letter authorizing the training must be obtained, which your UEC will request.    Once the Command Letter has been received, you must schedule and attend the ECC training.  The training allows you to handle UW, receive empty prelabeled containers, and turn in UW containers at the Hazardous Waste Facility (Building 4388) every Wednesday, from 0800-1100. It also helps to ensure your unit complies with EAFB, Alaska, and federal regulations.

1)  What is Universal Waste?

Universal Waste (UW) is a category of hazardous waste.  Waste cannot be UW if it isn’t a hazardous waste.  UW includes lamps, batteries, aerosol cans, pesticides, and mercury-containing equipment.

2)  Why is it important to manage UW correctly?

Improperly managed UW has the potential to release harmful substances to the environmental and cause harmful exposure to humans or other living things. Units who mismanage UW also face potential fines from the EPA which could reduce funding needed to maintain mission readiness!

3)  What kind of container can I use?

Your installation has specific containers for UW; however, the regulations are broad enough to allow many types of containers.  If you don’t have an ECC provided container, then you may use something different.  However, your container must meet the following requirements:  It must be able to be closed, structurally sound, compatible with the contents of the UW, and must lack evidence of leakage, spillage, or damage that could cause leakage under reasonably foreseeable conditions. Additionally, for aerosol cans the container must be protected from sources of heat.  Avoid having to improvise a container and obtain a prelabeled container from ECC.

4)  How long can I keep UW?

At the unit level UW waste must be turned in when your container is full or 8 months after the first UW item was placed in the container, whichever occurs first. Turn in day is every Wednesday from 0800-1100 at the Hazardous Waste Building #4388.

5)  I put my used lamps and bulbs in a trash can like container, is that okay? 

Maybe.  If the container is structurally sound, compatible with the lamp contents, and lack evidence of leakage, spillage, or damage that could cause leakage AND can be sealed closed, then your container is compliant.  If it does not meet ALL these criteria it cannot be used and could result in violations and fines.  Note, there are also labeling requirements.

6)  Can I go get a box with a lid and manage my lamps and batteries until I get the training?

Leaving burned out bulbs or lamps in their original fixtures until you receive a container from ECC for their proper management and storage, may be the best choice for your unit and ot ensure full environmental compliance. Contact ECC or the Environmental Department if you find yourself in this situation. With their guidance, they may allow you to take steps to immediately to achieve compliance. This a short-term solution for an immediate correction. Your EUC should coordinate authorization of the ECC training, and upon authorization, you should attend the training as soon as possible. Once you have the required training ECC will provide you with pre-labeled waste containers. 

7)  What if there is no time to overlap training with my replacement when I leave? How will the UW get managed?

EAFB assigns 2 personnel to each SAA/accumulation point, a primary and an alternate.  If you believe trained personnel will not be available to support UW management at your departure contact your EUC or the Environmental Department prior to leaving your work area.

8)  If go over the accumulation date can I relabel?

No, this would be a violation of the regulations and could result in violations and fines.

At the unit level, EAFB requires that you turn-in your UW at the Hazardous Waste Building (#4388) no later than 8 months after the first item was placed in the container. The EPA allows EAFB to accumulate UW up to 12 months. Conducting your weekly inspections as required by your Hazardous Waste Management Plan will ensure that you don’t find yourself in this situation.

9)  If they issue me 4 ft lamp containers and I have 8 ft lamps is it okay to break the lamps to get them to fit?

No, UW handlers can’t break lamps! Purposely breaking lamps changes the method and management requirements for you and your unit and exposes EAFB to potentially significant fines. Contact ECC for the appropriate containers or to arrange for a pickup.

10)  What do I do if the label is missing or weathered and cannot be easily read?

Replace the label with a new legible label.  Complete the label with the existing information, leaving the date listed as when the first waste item was placed in the container. Retain the original weathered label, if possible, within your HW management folder or files.

11)  If I go through the training offered by base environmental and ECC, can I then train my coworkers to remove lamps and manage them as UW?

Currently, no. Only personnel who have received the ECC training are authorized to manage UW.  The Environmental Department is working to develop modified training to account for personnel who only handle UW.

12)  If my UW batteries are leaking or the cases are bulging what do I do with them?

Damaged or leaking batteries (or suspected) must by overpacked and containerized.  Inner overpack and outer containers must be sealed and closed.  The outer container must meet normal UW container requirements and be labeled appropriately with the accumulation date and the words “Universal Waste Batteries.”  If you are unsure what do with these batteries or how to properly package them, call ECC for additional guidance.

13) What do I do if I keep calling or emailing to get training and no one responds? Can I manage the lamps and batteries without training if I know what to do?

No, Until you receive the ECC training you are not authorized to manage UW. Continue to reach out to your EUC, ECC, or the Environmental Department. See FAQ #6 for more information.

All primary and alternates must attend initial HW training from ECC. HW Refresher training is available on the TEACH website as an on-demand course. Course title: WESS 010 Hazardous Waste Accumulation Seminar (USAF Annual RCRA Refresher)

Website: https://usaf.learningbuilder.com/account/login/?ReturnUrl=%2f

14)  I know universal waste is not the same as hazardous waste and I have been trained for hazardous waste at my last job. Why do I need to take 4 hours of training if the office I work in only has UW?

EAFB has specific environmental requirements that identify HW managers and the training that they must obtain. This ensures HW managers are familiar with the most current regulations and properly manage their waste streams. Improved training is currently being developed for HW managers who only handle UW. This training is intended to be available via a desktop program and can be completed at the HW manager’s convenience.  

15)  Why can’t I take universal waste and hazardous waste off site to manage at the local waste management facility?

While this might seem like an easy solution to managing your wastes, this is strictly prohibited by EAFB and federal requirements! Only a properly licensed and permitted Hazardous Waste Transporter may transport and remove hazardous wastes from an installation. Installations in Alaska have received significant fines for the improper transportation and disposal of installation generated hazardous wastes off site.