Compliance Summary
Compliance Summary Tool
Transportation Modes
Service Functions
Regulations
All Topics
Please note: This summary is provided to help you understand the regulations. Consult the references provided for links to the full text of the regulations.

Universal Waste

Road Rail Air Water

Some common items contain materials that would cause them to be classified as hazardous wastes, according to federal rules. EPA has developed a special category of such materials, called "universal wastes," to ease the burden of complying with hazardous waste regulations and encourage the recycling or proper disposal of these items.

Most states have enacted their own hazardous waste rules, which may vary from the federal regulations. Consult the RCRA Hazardous Waste State Resource Locator for state-specific information.


Who is covered by the regulations?

The rule applies to anyone who disposes of several common waste products, including

  • Batteries
  • Pesticides
  • Mercury-containing equipment
  • Fluorescent light bulbs

(Household wastes are exempt from hazardous waste regulations.)

What is the purpose of the regulations?

The universal waste rule was designed to make it more likely that the products it covers will be recycled or disposed of safely. It recognizes that the compliance burden associated with hazardous waste management can sometimes act as a disincentive to comply. The rule provides a mechanism for reviewing other products not yet covered, and for adding them to the universal waste classification if warranted. It also allows states to develop their own categories of universal wastes.

Regulations

Introduction

EPA finalized the universal waste rule on May 11, 1995 as a way of streamlining the recycling efforts of commercial and industrial groups. Under this rule, a hazardous waste generator has the option of designating certain hazardous waste as universal waste, making them subject to less stringent environmental regulations. These wastes are hazardous waste batteries, hazardous waste thermostats (such as mercury-containing thermostats), certain hazardous waste lamps, and certain hazardous waste pesticides.

States do have autonomy when it comes to the universal waste rule. They do not have to accept it, they can add or remove wastes, or they can have more stringent requirements. Thus, before you designate any hazardous waste as a universal waste, you will need to check the Universal Waste State Resource Locator to see if your state agency will allow it. Most states follow the federal rule. 

This website has been created to help transportation facilities comply with the federal universal waste regulations found in 40 CFR 273

Universal Waste Handlers

The federal universal waste rule establishes two types of universal waste handlers. The small quantity handler of universal waste (SQHUW) who accumulates less than 5,000 kg (11,000 lbs) of universal waste on site at any one time and the large quantity handler of universal waste (LQHUW) who accumulates 5,000 kg or more of universal waste. Please note that once you have accumulated 5,000 kg of universal waste on site, you will remain a LQHUW for the rest of the calendar year.  So if you find yourself with 5,000 kg of lead acid batteries in January, even if you got rid of all of them in February and never accumulated that much again, you would still be considered a LQHUW until next January. Also keep in mind that what type of universal waste handler you are is not calculated on a month by month basis like we do for hazardous waste generation but on the total amount of universal waste accumulated at your facility at one time.

EPA ID Number and Notification

Only large quantity handlers of universal waste (LQHUW) need to obtain an EPA ID number and send a written notification to EPA that includes: 

  • A statement indicating that you are now a LQHUW;
  • The name of your facility;
  • Your street and mailing addresses;
  • The name and phone number of the person at your facility responsible for managing your universal waste; and
  • The types and quantities of universal waste managed at your facility.

Proper Management

All handlers of universal waste, whether one fluorescent light bulb or a million fluorescent light bulbs, need to manage their universal waste in such a way as to prevent releases of the universal waste or component of the universal waste to the environment. For example, lamps, because they can easily break, must always be kept in containers or packages that are closed, structurally sound, adequate to prevent breakage, and compatible with the contents of the lamp.

Labeling

All handlers of universal waste need to mark or label the universal waste or a container of the universal waste for the purposes of identifying the type of universal waste and to let inspectors know that you have chosen to handle these hazardous wastes as universal wastes.  An inspector will assume these wastes are hazardous wastes unless you clearly designate otherwise.  The regulations give you the following labeling options:

  • Universal Waste - Battery(ies); or Waste Battery(ies); or Used Battery(ies)
  • Universal Waste - Lamp(s); or Waste lamp(s); or Used lamp(s)
  • Universal Waste - Pesticides; or Waste Pesticides

Please note that you can not put a label on the wall. It must be either on the individual piece of universal waste or on the container in which the universal waste is stored.

Accumulation Time Limits

The federal universal waste regulations allow universal waste handlers to keep universal waste on site for a year. Although handlers can extend that period if they need more time to facilitate proper recovery, treatment, or disposal. For example, if your recycler will not pick up your universal waste until you reach a certain quantity, the law will allow you more than a year to accumulate that amount. You just need to show documentation to the inspector that you needed that longer period.

Given that there is a time limit on the storage of universal waste, all universal waste handlers need to be able to demonstrate the length of time the universal waste has been on-site. The regulation gives the following suggestions on how to do this but you can choose any method that works even ones not on the suggested list.

  • Labeling a container of universal waste with the earliest date that any universal waste in the container became a waste;
  • Labeling each individual waste with the date it became a waste;
  • Maintaining an inventory system on-site that identifies the date each universal waste became a waste;
  • Maintaining an inventory on-site that identifies the earliest date that any universal waste items or a group of containers of universal waste became a waste;
  • Placing the universal waste in a specific accumulation area and identifying the earliest date that any universal waste in the area became a waste.

Training

It should go without saying that all handlers of universal waste need to train their employees on the proper handling and emergency procedures associated with the universal waste managed at their facility. For instance, if you are storing fluorescent light bulbs, your employees should know what to do if one breaks.

Emergency Response

If there is a release of universal waste or a component of universal waste to the environment, one must immediately contain the release and then determine if any material resulting from the release (e.g. contaminated carpet, soil, personal protective equipment) is a hazardous waste and properly handle it as such.

Treatment

All universal waste handlers are prohibited from treating or diluting universal waste on site. There are some exceptions made for batteries and thermostats. For example, you are allowed to remove electrolyte from batteries and mercury containing ampules from thermostats and still handle the batteries and thermostats as universal wastes. However, there are no exceptions made for lamps. So if you have a bulb crusher on site, you cannot manage your lamps as universal waste, you must handle them as hazardous waste and comply with all applicable treatment requirements under RCRA.

Furthermore, bulb crushers need to be operated in a manner that minimizes the potential for releases.  For example, the bulb crushing operation shown in the photo 1 will not be acceptable to EPA since the ground glass from the bulbs will be strewn throughout the area and all over the equipment. On the other hand, the bulb crushing operation in photo 2 will be allowed because it contains all of the crushed glass and ensures that none of the materials from the bulb escapes into the atmosphere.

Photo 1

Photo 2

Proper Disposal

All universal waste handlers can send their universal waste to either another universal waste handler, a destination facility which is defined by the regulations to be one who treats, recycles or disposes of universal waste, or a foreign destination. Of course, one must comply with all applicable Department of Transportation shipping requirements.

Please note that unlike hazardous waste, you can transport your universal waste from one handler to another so if you have several maintenance facilities in an area, you can send your waste to one of the shops who would then send it on to the destination facility. By doing this you may be able to reduce your shipment costs if there is a discount for bulk deliveries.

Recordkeeping

Only large quantity handlers of universal waste (LQHUW) are required to keep records of where they are sending their universal waste and if applicable, any universal waste they are receiving from others. There is no specified form for these records. Use whatever works for you (i.e., logs, invoices, manifests, bill of ladings etc.).

The only requirement is that when a LQHUW is shipping universal waste off site, the records must show the name and address of the facility to whom the wastes are being sent; the quantities and types of waste they are sending that facility; and the date of shipment.

Similarly, if a LQHUW is receiving wastes from other handlers, they must keep records of the names and addresses of the facilities sending them waste; the types and quantities of universal waste they are receiving from each facility; and when they received the waste.

These records must be kept for three years.

Back to Top

Managing Common Universal Wastes at Transportation Facilities

Batteries

The EPA defines a battery as a device consisting of one or more electrically connected electrochemical cells, which is designed to receive, store, and deliver electric energy. An electrochemical cell is a system consisting of an anode, cathode, and an electrolyte, plus such connections (electrical and mechanical) as may be needed to allow the cell to deliver or receive electrical energy. The term battery also includes an intact, unbroken battery from which the electrolyte has been removed.

Nearly 90 percent of all lead-acid batteries used in the U.S. are recycled. Almost any retailer that sells lead-acid batteries collects used batteries for recycling, as required by most state laws. Reclaimers crush batteries into nickel-sized pieces and separate the plastic components. They send the plastic to a reprocessor for manufacture into new plastic products and deliver purified lead to battery manufacturers and other industries. A typical lead-acid battery contains 60 to 80 percent recycled lead and plastic. Lead-acid batteries that are recycled off-site in this manner qualify as universal waste. Batteries sent off-site for disposal must be managed as hazardous waste.

Certain batteries used to power cell phones, cameras, smoke alarms, railroad signals and other electronic devices may also qualify as Universal Waste, when properly managed and recycled. Other than common alkaline batteries, most small batteries, such as lithium, mercuric oxide (button type), and nickel-cadmium, contain toxic metals, including chromium, cadmium and silver. When recycling these batteries as universal waste:

  • Tape ends to prevent sparking
  • Package in non-flammable containers
  • Work with a Universal Waste hauler
  • Haulers often supply containers and you pay by the 'bucket'
  • Set up battery collection containers that are properly labeled and packaged
  • Hold for Battery Round-up for recyling

Resources for Reducing Battery Wastes:

Battery Council International. Summary of U.S. State Lead-Acid Battery Laws.

EPA's Universal Waste Website provides regulatory and comparative information about universal waste, how universal wastes are regulated in your state, guidance and recycling resources.

Fluorescent Light Bulbs

The EPA defines a 'lamp' also referred to as 'universal waste lamp,' as the bulb or tube portion of an electric lighting device. A lamp is specifically designed to produce radiant energy, most often in the ultraviolet, visible, and infrared regions of the electromagnetic spectrum. Examples of common universal waste electric lamps include, but are not limited to, fluorescent, high intensity discharge, neon, mercury vapor, high-pressure sodium, and metal halide lamps.

Fluorescent lamps can help transportation facilities significantly reduce their energy consumption. They use one quarter the energy of incandescent lamps and last as much as ten times longer. However, fluorescent lamps contain the toxic element mercury. When broken or improperly disposed of, fluorescent lamps may release mercury into the air, water and soil, and thus pose a threat to human health and the environment. While fluorescent lamps offer tremendous environmental advantages through energy savings, the disposal of used fluorescent lighting raises serious environmental concerns. Recycling spent mercury-containing lamps offers an environmentally sound alternative to expensive hazardous waste disposal. Recycling used fluorescent lamps is a good way to eliminate mercury emissions, as well as reduce waste and other toxic material disposal.  Use the following resources to start or improve your recycling program.

Resources for Reducing Fluorescent Bulb Waste:

EPA's Universal Waste Website provides regulatory and comparative information about universal waste, how universal wastes are regulated in your state, guidance and recycling resources.

Fluorescent Bulb - Mercury Conversion Spreadsheet calculates the amount of mercury and materials recycled for each bulb recycled enabling you to track and report on this information. (XLS format, 1 sheet, 30KB, requires Microsoft Excel Viewer to view)

LampRecycle.org is a resource for any light bulb ("lamp") user seeking details on recycling spent mercury-containing lamps and is sponsored by the National Electrical Manufacturers Association (LAMP section).

Electronics

Technological advances in all electronic equipment, particularly computers, continually shorten their useful life, resulting in a complex and rapidly growing waste stream. Often electronic equipment contains hazardous constituents including lead in cathode ray tube (CRT) monitors, chlorinated plastics in cable wiring, brominated flame retardants in circuit boards, and mercury in LCD displays. CRTs alone contribute almost one third of the lead found in the municipal waste stream. Improper management or disposal of electronic equipment poses a significant threat to public health and the environment. Transportation facilities need to manage their electronic equipment in a way that controls costs, protects data and complies with federal, state and local regulations.

The EPA is planning to add used CRTs from computers and television monitors to the federal Universal Waste Rule. In addition, EPA is currently developing a regulatory exemption for processed glass sent for CRT glass-to-glass recycling. Some states have already added CRTs to their lists of universal waste. Use the E-Waste State Resource Locator to find out more about electronics recycling in your state.

Resources for Electronics Waste:

EPA's e-Cycling website provides basic information about electronic waste, current recycling and disposal options, regulations, publications and other resources.

EPA's Universal Waste Website provides regulatory and comparative information about universal waste, how universal wastes are regulated in your state, guidance and recycling resources.

Electronic Industries Alliance (EIA) Consumer Education Initiative) The Electronic Industries Alliance (EIA) is a national trade organization that includes the full spectrum of U.S. manufacturers. The EIA Consumer Education Initiative or "CEI" is a web-based information resource that provides consumers and others with information on recycling and reuse opportunities for used electronics. Participating manufacturers include an industry statement in a variety of media, including owner's manuals, company web sites, and product literature, directing consumers to the CEI web page where consumers can find recycling and reuse opportunities for used electronics in their area.

National Recycling Coalition (NRC) has implemented an Electronics Recycling Initiative. This project is made possible with support from the U.S. Environmental Protection Agency and the U.S. Postal Service. The goal of the NRC's Electronics Recycling Initiative is to promote the recovery, reuse and recycling of obsolete electronic equipment, and to encourage the design, manufacture and purchase of environmentally responsible electronic equipment. *This site contains valuable fact sheets on managing, recycling and reuse options for electronic equipment.

World Computer Exchange (WCE) is an international educational nonprofit focused on helping the world's poorest youth to bridge the disturbing global divides in information, technology and understanding. WCE keeps donated computers out of landfills and gives them new life connecting youth to the Internet in developing countries

Back to Top


TERC Home