How does an MRW facility comply with the Universal Waste Rule?
Moderate Risk Waste (MRW) collection facilities can collect Universal Waste if they comply with the provisions for Universal Waste Handlers under the Dangerous Waste Rule, WAC 173-303-573. According to the definition in WAC 173-303-040, a Universal Waste Handler can accept Universal Waste from any of the three different generator classes: • Conditionally Exempt Small Quantity Generators (CESQGs) if they say that they want to have any of their MRW managed as Universal Waste • Medium Quantity Generators (MQGs) • Large Quantity Generators (LQGs) Household Hazardous Waste (HHW) is categorically exempt from the Universal Waste part of the Dangerous Waste Rule. CESQGs have two options. They can either direct a facility to manage the waste as Universal Waste or manage it in accordance with CESQG regulations. However, if MRW (HHW or CESQG waste not intended for handling as Universal Waste) is mixed with Universal Waste it loses its exemption and becomes subject to the Universal Waste part of t