UW Audit Checklist
Large Quantity Handler
(>5,000 of waste in one year)
yes / no / n/a / comments
Documentation
1 / Has large quantity handler notified the Department of its universal waste activity using DHEC form 2701?
Batteries
1 / Are batteries handled in a manner that will prevent releases to the environment?
2 / Have any batteries that show evidence of leakage or damage been contained in a compatible and closed container?
3 / Has the handler conducted any of the following activities:
  • Sorting by type
  • Mixing different types in one container
  • Discharging energy
  • Regenerating used batteries
  • Disassembling batteries or packs into different cells
  • Removing batteries from consumer products
  • Removing electrolytes

4 / If any of the above activities were performed, was an accurate hazardous wastedetermination made to determine whether resulting materials are a hazardous waste?
5 / Are hazardous wastes handled according to the hazardous waste management regulations?
Pesticides
1 / Are universal waste pesticides being handled in a manner that will prevent releases to the environment?
2 / Are universal waste pesticides being managed in containers that are compatible with the contents and closed?
3 / Are damaged containers over-packed?
Thermostats:
1 / Are universal waste thermostats being handled in a manner that will prevent releases to the environment?
2 / Are universal waste thermostats being managed in containers that are compatible with the contents and closed?
3 / Has the handler removed mercury containing ampoules from universal waste thermostats in one of the following ways:
  • Remove ampoules in such a way to prevent breakage
  • Remove ampoules over containment device (e.g., tray or pan)
  • Ensure that mercury clean-up system is available & that spills and releases are transferred to a container the meets subpart I requirements?
  • Ensure the area where ampules are removed is well ventilated and meets OSHA exposure limits for mercury.
  • Ensure that employees removing ampules are thoroughly familiar with proper waste handling and emergency procedures.Stores removed ampules in closed, non-leaking containers in good condition.
  • Packs removed ampules in container with adequate packing material to prevent breakage.
  • Has the handler determined that material generated from separating ampules from thermostats exhibits the characteristics of hazardous waste?

Lamps
1 / Has handler managed lamps in such a way to prevent releases of any universalwaste to the environment?
2 / Are universal waste lamps managed in containers that are closed, structurally sound, adequate to prevent breakage, and compatible with the contents?
3 / Are broken lamps immediately cleaned up and placed in containers that are closed, structurally sound, adequate to prevent breakage, and compatible with the contents?
Labeling
1 / Has the handler ensured that universal wastes are labeled/marked with one of the following:
  • For batteries; “universal waste – battery (ies),” or “waste battery (ies),” or “used battery(ies).”
  • For pesticides; the original manufacturers product label, or “universal waste-pesticide(s)”, or “waste pesticide(s).”
  • For thermostats; “universal waste-mercury thermostat(s)”, or “wastemercury thermostat(s)”, or “used mercury thermostat(s)”.
  • For lamps; “universal waste-lamp(s)”, or waste lamp(s)”, or “used lamp(s)”.

Accumulation time limits
1 / Has the handler accumulated universal wastes for longer than one year?
2 / If wastes were accumulated longer than one year, was it for the purpose of accumulating sufficient quantities to facilitate proper recovery, treatment, ordisposal?
3 / Is the handler able to demonstrate the length of time universal wastes have been accumulated? Which of the following methods in used:
  • Waste is placed in containers that are marked with the earliest date
  • each individual item labeled with a date
  • an inventory system that ID’s the date of each universal waste
  • an inventory system that ID’s the earliest date any universal waste in a group of universal waste items or a group of containers became a waste
  • waste is placed in a specific accumulation area identifying the earliest datethat any universal waste in the area became a waste
  • any other method that clearly demonstrates the length of time that universal wastes have been accumulated

Employee training
1 / Has the handler informed all employees who handle universal waste of proper handling and emergency procedures?
Off site shipments
1 / Has handler sent universal waste to only another universal waste handler, destination facility, or a foreign destination?
2 / Has handler transported his own universal waste? If so:
  • Does he comply with USDOT shipping requirements?
  • Does handler ensure that receiving facility agrees to accept shipment?

3 / Receipt of shipments: Does handler track each shipment of Universal waste showing the name/address of the originator, quantity of waste received, and the date of receipt?
4 / Off-site shipments: Does handler keep a record of each shipment sent which includes name/address of handler, destination facility: the quantity and type of each universal waste sent: the date the shipment was sent?
5 / Does handler retain these records for at least three years?
6 / Has transporter complied with all applicable USDOT regulations in 49 CFR part 171-180?

USC EHS Office of Environmental Management Destroy Previous Revisions

EHS-F-189 Issue Date: 6/18/07

Page 1 of 4 Reviewed: ______