Ask the Expert: Record Keeping for Universal Waste Shipments

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In our latest episode of Ask the Expert, brought to you by the team of industry experts at EHS Hero®, we are reviewing a recent subscriber question regarding record keeping requirements for universal waste shipments. See what the experts had to say.

Q: What are the record keeping requirements for universal waste shipments?

There are Universal Federal Waste Record Keeping Requirements for Universal Bulk Waste Handlers (LQHUW) and Universal Waste Destination Facilities. (The Universal Regulation defines a LQHUW as a Universal Waste Handler that accumulates 5,000 kg or more in total of Universal Waste, collectively calculated, at any time. A Universal Waste Destination Facility is defined as a facility that treats, disposes or recycles a special category of universal waste, except for management activities carried out by LQHUWs and handlers of small quantities of universal waste.)

Register of universal waste received. LQHUWs and receiving facilities must maintain a record of each universal waste shipment received at the facility. The record can be a ledger, invoice, manifest, bill of lading, movement document, or other shipping document. The file must include:

  • Name and address of the original universal waste handler or foreign shipper who sent the universal waste
  • Quantity of each type of universal waste received
  • Date universal waste shipment received

These records must be kept for at least three years from the date of receipt of the universal shipment of waste.

Registration of Universal Waste Shipping. An LQHUW must maintain a record of each universal waste shipment sent to another facility in the form that applies to universal waste records received. The file must include:

  • Name and address of universal waste handler, destination facility or foreign destination to which universal waste was sent
  • Quantity of each type of universal waste sent
  • Date the universal waste shipment left the facility

These records must be retained for at least three years from the date the universal waste shipment left the facility.

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