Navigating Title 22 § 66266.81: Common Universal Waste Violations in Casinos

When it comes to managing universal waste in California's bustling casinos, Title 22 § 66266.81 sets the standard. However, even with these regulations in place, certain violations seem to crop up more frequently than others.

Improper Labeling and Storage

One of the most common issues we see is improper labeling and storage of universal waste. Casinos often handle batteries, lamps, and electronic devices, all of which fall under this category. The regulation requires that these items be clearly labeled as "Universal Waste" and stored in a way that prevents releases. From my experience, it's not uncommon to walk into a casino's maintenance area and find a box of spent batteries without any indication of what they are or how they should be handled.

Failure to Train Employees

Another frequent violation is the failure to properly train employees on the handling of universal waste. Under Title 22 § 66266.81, casinos are required to ensure that all personnel who manage or handle universal waste are trained in proper procedures. I've seen instances where staff were unaware of the specific requirements for managing these wastes, leading to improper disposal or storage practices.

Non-Compliance with Accumulation Time Limits

Casinos must also adhere to strict time limits for the accumulation of universal waste. According to the regulation, universal waste can be accumulated for up to one year from the date it was generated or received. However, many casinos struggle with tracking these dates, resulting in violations. It's crucial for casinos to implement systems that monitor the age of their universal waste to stay compliant.

Documentation and Recordkeeping

Proper documentation and recordkeeping are also areas where casinos often fall short. Title 22 § 66266.81 mandates that records be kept of the type and quantity of universal waste managed, as well as the dates of accumulation and shipment off-site. Without robust systems in place, these records can become disorganized or incomplete, leading to potential violations during inspections.

Best Practices for Compliance

To mitigate these common violations, casinos should consider the following best practices:

• Regular Training: Implement ongoing training programs to ensure all employees are up-to-date on universal waste management procedures.
• Clear Labeling: Use clear, standardized labels for all universal waste containers to prevent confusion.
• Tracking Systems: Utilize software or manual systems to track the accumulation time of universal waste and ensure compliance with the one-year limit.
• Audits and Inspections: Conduct regular internal audits and inspections to identify and correct any non-compliance issues before they become violations.

By focusing on these areas, casinos can significantly reduce the risk of violating Title 22 § 66266.81 and maintain a safer, more compliant operation. For more detailed guidance on managing universal waste, casinos can refer to the California Department of Toxic Substances Control, which provides comprehensive resources and regulatory information.