Frequent Questions

How is a handler required to mark the accumulation start date for universal waste?

Small and large quantity handlers of universal waste who accumulate universal waste must be able to demonstrate the length of time that the universal waste has been accumulated from the date it becomes a waste or is received. The handler may make this demonstration by:
 
(1) Placing the universal waste in a container and marking or labeling the container with the earliest date that any universal waste in the container became a waste or was received; 

(2) Marking or labeling each individual item of universal waste (e.g.., each battery or thermostat) with the date it became a waste or was received; 

(3) Maintaining an inventory system on-site that identifies the date each universal waste became a waste or was received; 

(4) Maintaining an inventory system on-site that identifies the earliest date that any universal waste in a group of universal waste items became a waste or was received; 

(5) Placing the universal waste in a specific accumulation area and identifying the earliest date that any universal waste in the area became a waste or was received; or 

(6) Any other method which clearly demonstrates the length of time that the universal waste has been accumulated from the date it becomes a waste or is received (40 CFR §§273.15(c) and 273.35(c) ).

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