We have 5 facilities that are on the same block. However, they have different street addresses due to their location. My question is this. When each facility generates a universal waste, can the waste be transported to "one" facility that is considered the main pick up location for universal wastes without violating DOT or  EPA regulations?

Parker,

Yes, it is possible to do it but the pain may not be worth it. I'm going to assume you are small quantity handler of universal waste. The first thing you'll need to determine is if the universal waste is a hazardous material. In my opinion, most batteries, mercury equipment, and some pesticides are hazardous materials. You'll need to determine that for your specific waste streams. If the products are hazmat, then taking the products out of building A and transporting them on a public road to building B would be violation of the transportation rules.

A few things to look at: 1) Are there non-public roads which connect the buildings? If so, then its not transportation.

2) You can ship between buildings on public roads but you'll need to become a hazardous materials transporter, designate one facility as a destination facility. The shipments will require a bill of lading or manifest. The cost of compliance will probably overwhelm what your paying in stop fees.

3) Items which are not hazardous materials can be transported between buildings.

MikeCJ

Mike

We are a Small Quantity Handler of Universal Wastes. The materials you mentioned above are hazardous but these are managed under the Universal Waste Rule. The Hazardous Waste requirements are relaxed if you are managing under Universal Waste Rules (intent to recycle). If the Hazardous Waste Rules are relaxed then there are no DOT rules to comply with. With that said, I was thinking we could transport between facilities on public roads.

If your wastes are classified as hazardous then I agree with your #2 statement above. For example, I am classifying bulbs as a hazardous wastes once one is broken by mistake. At that point, it must be managed under the hazardous wastes rule and therefore will not be transported on public roads. We do not want to become a hazardous material transporter so our waste vender will have to make a pickup from that facility.

Am I on the right page here? Does this make sense? I want to make sure I'm understanding what I have read in the requirements.

Parker,

Forgive me if I'm wrong but I think you may be confusing hazardous waste (EPA) with hazardous material (DOT). I agree that the universal waste rules are a relaxed version hazardous waste rules but I do not agree that a relaxtion of the hazardous waste rules in any way impact the hazardous material rules. I googled "DOT Shipping of Universal Waste" and came up with the following "

What are the requirements for universal waste transporters? UW transporters are subject to the requirements of subpart D of part 273. Transporters must also comply with all applicable DOT regulations and ensure that any UW transported goes to a UW handler or destination facility. Because DOT regulations do not require a manifest to accompany the shipment, DOT does not consider UW to be a “hazardous waste”. However, transporters must decide if the waste falls under any other  DOT hazard classes. If so, transporters are required to comply with the DOT requirements for “hazardous material” under 49 CFR parts 171 through 180. Transporters may store UW at a transfer facility for 10 days or less. They must also contain any accidental UW releases.

If you find an exception, please post it. I'll be glad to say I was wrong.

MikeCJ