Universal Waste Program

1. Purpose

a) The ESCO Group Universal Waste Program has been established to provide guidelines to safely dispose of and store materials that have a potential to pose a risk to our employees.

2. Scope

a) This program applies to all employees that may have to store or dispose of fluorescent and other non-incandescent lamps, light bulbs, ballasts, PCB’s and any other materials recommended by a manufacturer to be disposed of by other means than conventional trash/recycle. 

3. Responsibilities

a) ESCO Group’s Safety Director is the administrator of our Universal Waste Program and the Director of Safety Operations is the approver of the program.

i. Administrator’s responsibilities will include:

1. Ensuring that this program is implemented at facilities ESCO Group works in that do not currently have universal waste programs and procedures or the policies and procedures in place at a customer facility are deemed inadequate to protect ESCO Group employees.

2. Provide training to any ESCO Group employees that work with any material that meets the criteria.

3. Ensure that this program is reviewed on an annual basis.

ii. ESCO Employee Responsibilities will include:

1. Adhering to all policies and procedures outlined in the program.

2. Communicating with the customer and ESCO Group Supervision, if any potential materials are present on the job site.

3. Being familiar with the customer’s site specific universal waste policies and procedures, if they exist.

4. General Requirements

a) ESCO Group is classified as a Small Universal Waste Generator and will follow the Code of Federal Regulations Part 273 – Standards for Universal Waste Management. 

b) ESCO Group will recognize and evaluate the chemicals and materials brought on site that need to be disposed of properly.

c) Materials shall be stored in a manner adequate for the Code of Federal Regulations and manufacturer recommendations. At no time should any universal waste materials/equipment be collected or stored with non-universal waste materials/equipment.

d) At any point, if ESCO Group employees are required to wear personal protective equipment beyond their daily requirements, it will be provided and worn as necessary by the Code of Federal Regulations or manufacturer recommendations.

e) Any universal waste products stored on ESCO Group job sites will be marked and properly labeled.

f) If any universal waste products become damaged or broken, proper clean up and storage of materials until pick-up will be followed.

g) At any point, if any materials pose a threat to ESCO employees or other contractor/client employees, ESCO and client supervision should be notified immediately. 

h) At no time will ESCO Group employees dispose of universal waste. Approved third party companies will dispose of our universal waste properly. 

i) For work held out of the state of Iowa, ESCO Group will follow the codes and regulations of the state work will be held in. 

5. Training

a) Employees that may have to perform work with universal waste products or possible be exposed to any universal waste products shall receive training on this policy as a part of new hire safety orientation as well as annual refresher training.