Universal Waste Requirements

Universal waste is a special category of hazardous waste that includes batteries, pesticides, mercury-containing equipment and lamps.  For the most part, these wastes are self-explanatory but often confusion arises from mercury-containing equipment which includes a device or part of a device (including thermostats, but excluding batteries and lamps) that contains elemental mercury integral to its function.  Some items that are typically included in this category are relays, switches (i.e. automobile switches), barometers, manometers, temperature and pressure gauges, and thermometers.  

Similar to hazardous waste, companies that generate universal waste are classified by how much waste is generated.  The two categories are:

1. Large Quantity Handler of Universal Waste (LQH) accumulates 5,000 kilograms or more total of all universal waste  at any time.
2. Small Quantity Handler of Universal Waste (SQH) accumulates less than 5,000 kilograms of all universal waste at any time.

Unlike hazardous waste generator status which is calculated monthly, universal waste handler status is determined for the total calendar year–if at any time during the year the generator accumulates more than 5,000 kg it qualifies for LQH status.  SQHs are not required to notify the Environmental Protection Agency (EPA) of their generator status, however LQHs are.   This is typically done by using the state’s hazardous waste generator status form (if the company also generates hazardous waste) or by submitting a notification to Regional Administrator.  Not certain which EPA Region your state is in, check this resource.

One of my favorite things about universal waste is that the accumulation time is one year.  A company must demonstrate compliance with this requirement by labeling the waste with the date it was generated, in addition to the other labeling requirements.  Each universal waste must also be labeled “universal waste—name of waste (i.e. batteries, pesticides, lamp, mercury-containing equipment)” alternatively, the word “universal” can be replaced with “used” or eliminated all together.

As with hazardous waste, EPA requires training for both categories of universal waste handlers;  however there is no requirement for timeframe of initial training or recurrent training.  The training must include proper waste handling and emergency procedures appropriate to the type(s) of universal waste handled at the facility.  I like to include a review of the universal waste procedures with the annual RCRA or other recurrent compliance training for my clients.

Keep in mind that the requirements discussed above address those of the EPA; be certain to consult your state environmental regulations to ensure that additional requirements do not exist.  A resource to do so is EPA’s State Specific Universal Waste Regulations website.  In Florida, for example, universal waste includes pharmaceutical waste and both California and Colorado include aerosol cans in this classification.

Following are some additional resources for universal waste:
EPA Universal Waste Homepage
Introduction to Universal Waste
EPA’s Mercury Management Website
If you require additional information, you can contact our office to schedule a free consultation.