Hazardous and Solid Waste, Q&A

Managing Universal Waste

Q. If I’m a large quantity generator, can I take advantage of managing my universal waste rechargeable batteries and compact fluorescent bulbs at hardware retailer locations?

A. As the generator of batteries and fluorescent bulbs that you specify qualify as universal wastes, you are considered a universal waste handler (40 CFR 273.9). The term also includes 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.

A universal waste handler may only send universal waste to another universal waste handler, a destination facility, or a foreign destination (40 CFR 273.18(a) and 40 CFR 273.38(a)).

A destination facility is defined as a facility that treats, disposes of, or recycles a particular category of universal waste, except those management activities performed by small or large quantity handlers of universal waste. 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 (40 CFR 273.9). Destination facilities are subject to all hazardous waste management requirements applicable to permitted or interim-status hazardous waste treatment, storage, and disposal facilities, including those at 40 CFR 264, 40 CFR 268, and the hazardous waste permit standards of 40 CFR 270.

So if the hardware retailer meets the definition of either “universal waste handler” or “destination facility” you may send or take your universal waste to them (assuming you have both complied with all applicable universal waste requirements and have the store’s agreement to receive the universal waste). For more information, we suggest you contact the stores directly.


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