Universal Hazardous Waste Image

General Description

A classification whereby waste batteries, waste excess pesticides, waste fluorescent tubes, and waste mercury-containing equipment do not have to be disposed of as hazardous waste.

Summary of Federal Requirements

By disposing of potentially hazardous waste as Universal Waste, when applicable, a facility can reduce the amount of hazardous waste generated per month and potentially move to a lower classification of hazardous waste generator.

Waste that is federally regulated as Universal Waste includes batteries (all types), mercury thermostats, waste pesticides, and lamps (i.e., electric lamps including fluorescent, high intensity discharge, neon, mercury vapor, high pressure sodium, and metal halide lamps).

Generators of Universal Waste are either Small Quantity Handler of Universal Waste (accumulates less than 5.000 kg of universal waste at any one time) or a Large Quantity Handler of Universal Waste (everyone else). Except for documentation requirements, there is no difference in how a Small Quantity handler and a Large Quantity handle managed the universal waste.

It takes about 17, 000 four foot fluorescent lights to make 5,000 kg [11,000 lb]

Universal Waste Management

  • Do not dispose, treat, or dilute universal waste onsite.
  • Do not accumulate universal waste for more than 1 yr from the date that the universal waste is generated, or received from another handler.
  • Be able to demonstrate how long the universal waste has been accumulating through one of the following options:
    • labeling the container that the universal waste is in with the earliest date any universal waste was added;
    • label each individual universal waste item as to when it became universal waste;
    • maintain an inventory system.
  • Universal waste received from a foreign country must be managed according to U.S. Universal waste regulations.


  • Universal waste containers for items which might leak must be closed, structurally sound, compatible with the contents, and lack evidence of leakage, spillage, or damage that could cause leakage under reasonably foreseeable conditions.
  • Each universal waste lamp or a container or package in which lamps are contained is labeled or marked clearly with one of the following phrases:
    • USED LAMP(S).
  • Universal waste batteries (each battery), or a container in which the batteries are contained, are labeled or marked clearly with any one of the following phrases:
  • Universal waste mercury-containing equipment (i.e., each device), or containers in which the equipment is contained must be labeled or marked clearly with one of the following phrases:
    • Universal Waste--Mercury Containing Equipment
    • Waste Mercury-Containing Equipment
    • Used Mercury-Containing Equipment.
  • Universal waste mercury-containing thermostat or containers containing only universal waste mercury-containing thermostats must be labeled or marked clearly with one of the following phrases:
    • Universal Waste--Mercury Thermostat(s)
    • Waste Mercury Thermostat(s)
    • Used Mercury Thermostat(s).
  • The container, tanks, or transport vehicles or vessels in which unused pesticide products are contained are labeled or marked clearly with:
    • the label that was on the product when purchased, if still legible
    • if this is not feasible, the appropriate DOT label
    • if it is not feasible to use the original or DOT label, an alternate label prescribed or designated by the waste pesticide collection program administered or recognized by a state


  • Employees must be trained in the proper handling and emergency response procedures appropriate to the types of universal waste handled at the facility.


  • When it leaves the facility, universal waste must go to another universal waste handler, a destination facility, or a foreign destination.


  • This is the only difference between a Small Quantity Handler of universal waste and a Large Quantity Handler of Universal waste. The Large Quantity Handler must send written notification of universal waste management to the Regional Administrator and received an USEPA identification number before meeting or exceeding the 5000 kg (11,111 lb] storage limit, unless:
    • the handler has already notified the USEPA of hazardous waste management activity and has received a U.S. USEPA identification number
    • recalled pesticides are being managed and notification has already been sent in under 40 CFR 165.)
  • The Large Quantity Handler must maintain a record of each shipment of universal waste shipped offsite for 3 yr and it can be kept in one of the following:
    • a log
    • invoices
    • manifests
    • bill of lading
    • other shipping document.

Summary of State Requirements

States may identify additional waste streams as universal waste, for example: paint and paint-related wastes, aerosol cans, electronic devices, fluorescent light ballasts that contain PCBs, and antifreeze.

State-by-state guidance concerning mercury-containing equipment or products and/or mercury spills can be found at ENVCAP's Mercury Resource Locator.

State-by-state guidance concerning mercury waste can be found at CICA's Mercury State Resources Tool.

Laws and Statutes

The Resources Conservation and Recovery Act, Subtitle C

Back to Top  Page Top