Hazardous and Solid Waste

Do Universal Waste Standards Apply to You?

Instead, EPA has determined that these wastes can be more effectively managed in accordance with "streamlined" hazardous waste management rules that subject handlers of universal wastes to less stringent standards for storing, transporting, and collecting the wastes. However, universal wastes are still subject to the full hazardous waste requirements for final recycling, treatment, or disposal.

EPA classifies the following as universal wastes:

  • Batteries (nickel cadmium batteries, in particular)
  • Pesticides
  • MCE (which includes thermostats)
  • Lamps

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Stay tuned! EPA may add additional wastes to the list in the future.

The universal waste management standards apply to universal waste handlers, universal waste transporters, and destination facilities.

"Universal waste handlers" are:

  • Generators of universal wastes
  • The owner or operator of a facility that receives universal waste from other universal waste handlers, accumulates universal waste, and sends universal waste to another universal waste handler or to a destination facility or foreign destination

Who Is a Universal Waste Generator?

A “universal waste generator” is the person who used the universal waste and then determined that it was no longer usable and therefore should be discarded. Generated universal waste is not counted in a generator’s hazardous waste quantity if it is managed according to universal waste rule standards (40 CFR 261.5(c)(6)). Contractors who remove universal wastes from service (e.g., lamps) are considered handlers and co-generators of the waste.

Small Quantity Handler of Universal Waste (SQHUW). An SQHUW is a universal waste handler who does not accumulate 5,000 kg or more total of universal wastes at any time.

Large Quantity Handler of Universal Waste (LQHUW). An LQHUW is a universal waste handler who accumulates 5,000 kg or more total of universal wastes at any time. This status is retained through the end of the calendar year in which the 5,000 kg or more total of universal waste was collected.

In general, the standards for SQHUWs and LQHUWs managing universal waste are identical, with the exception of requirements in connection with notification to EPA, employee training, waste tracking, and recordkeeping, as discussed in this section.


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Facilities

Owners and operators of facilities that accumulate universal waste but do not treat, recycle, or dispose of them are universal waste handlers.

Who Is a Universal Waste Transporter?

A “universal waste transporter” is a person engaged in the off-site transportation of universal waste by air, rail, highway, or water. Persons who meet this definition include those who transport universal waste from one universal waste handler to another, to a destination facility, or to a foreign destination.

What Is a Universal Waste Destination Facility?

A “universal waste destination facility” is a facility that treats, disposes of, or recycles a particular category of universal waste, except those management activities performed by SQHUWs and LQHUWs. A facility at which a particular type of universal waste is only accumulated is not a destination facility for purposes of managing that category of universal waste.

See tomorrow’s Advisor for an overview of universal waste regulations in an easy-to-read chart.