August Mack recently received a request, from a non-profit organization, to organize a Universal Waste recycling event for it's members. From looking at the Ohio EPA regulations, this is what we found.
One facility can ship universal wastes to another facility for consolidation/storage purposes. In such a case, both facilities would be considered universal waste handlers and must comply with applicable universal waste management standards. Small and large quantity handlers of universal waste can receive universal waste from other universal waste handlers. While off-site shipments of universal waste do not require a manifest, the transporter must comply with U.S. DOT requirements (if applicable).
It is also important to mention that if either facility collects greater than or equal to 5,000 kilograms (11,023 pounds) of the total accumulation of universal waste at any one given time (not by type) they become a large quantity handler of universal waste and may need to comply with additional universal waste requirements.
In summary, the non-profit organization would need to comply with UW Handler standards. The members would need to comply with both UW Handler and DOT standards.
August Mack will recommend a training session for the members on the labeling, packaging, and correct disposal of UW and introduce them to licensed UW handlers/transporters.