Universal waste is generated by nearly every facility in some form or another: batteries, pesticides, mercury-containing equipment, and lamps and fluorescent bulbs. Learn how properly handling your universal wastes can help you avoid the EPA's full hazardous waste handling requirements.
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Nearly every facility generates some form of universal waste. So what exactly is universal waste? The U.S. Environmental Protection Agency (EPA) classifies it as waste that does meet the regulatory definition of hazardous waste, but can be managed under specifically tailored regulations. The federal universal waste regulations are found in 40 CFR part 273.

Currently, the universal waste standard includes the following types of wastes:

  • Batteries
  • Pesticides
  • Mercury-containing equipment / thermostats
  • Lamps / fluorescent bulbs

You should be aware that state universal waste regulations vary; some have requirements that are more stringent than the federal requirements. Find your states regulations at http://www.epa.gov/osw/wyl/stateprograms.htm.

Take charge of battery management

EPAs universal waste regulations require that you handle spent universal waste batteries in a way that prevents releases to the environment:

  • Comply with packaging requirements
  • Implement procedures to follow when handling batteries
  • Place batteries that show evidence of leakage, spillage, or damage in a container that closes, is structurally sound and is compatible with the contents of the battery
  • Label / mark containers to identify the type of universal waste inside

Safe mercury management

Mercury-containing equipment includes devices, items, or articles that contain varying amounts of elemental mercury integral to their functioning. Some commonly recognized devices are thermostats, barometers, manometers, and mercury switches such as light switches in automobiles.

Mercury-containing equipment must be handled in a way that prevents releases of mercury to the environment, including:

  • Have implemented procedures in place to follow when removing mercury-containing ampules from universal waste mercury-containing equipment
  • Label / mark containers to identify the type of universal waste inside

Refer to 40 CFR 273.13(c) for additional information on how to handle and store universal waste mercury-containing equipment.

Lamp Management — To crush or not to crush?

EPAs universal waste regulations require management of fluorescent, high intensity discharge, neon, mercury vapor, high-pressure sodium, and metal halide lamps that will prevent releases to the environment:

  • Contain any lamp in containers or packages that are structurally sound, adequate to prevent breakage, and compatible with the contents of the lamps.
  • Immediately clean up and place in a container any lamp that is broken. Broken lamps should be stored separately. Place in a container any lamp that shows evidence of breakage, leakage, or damage that could cause the release of mercury or other hazardous constituents to the environment. Choose a container that is closed, structurally sound, or compatible with the contents of the lamps.
  • Label / mark each lamp (or container or package containing such lamps) with one of the following phrases: "Universal Waste-Lamp(s)," "Waste Lamp(s)," or "Used Lamp(s)".

Some states do allow mercury-containing bulbs to be crushed. Keep in mind that when bulbs are crushed, they no are no longer considered universal waste, and must be handled as hazardous waste. In addition, states often require permits for crushing.

For More Information

For information on the EPA-initiated mercury-containing lamp recycling outreach program see:
http://www.epa.gov/epaoswer/hazwaste/id/univwast/lamps/outreach.htm

To view state lamp recycling regulations and contacts go to:
http://lamprecycle.org/

Find local battery recycling facilities by zip code at:
http://www.earth911.org/master.asp?s=lib&a=electronics/bat_index.asp
http://www.rbrc.org/call2recycle/dropoff/index.php

Learn more about mercury-containing products and devices and recycling options at:
http://www.earth911.org/master.asp?s=lib&a=mercury/contain.asp

Find out about state legislation, regulations, resolutions, and county/city ordinances by visiting:
http://www.epa.gov/epawaste/hazard/wastetypes/universal/lamps/index.htm