Back to Basics, Hazardous Waste Management

Back to Basics: Universal Waste Requirements

Back to Basics is a weekly feature that highlights important but possibly overlooked information that any EHS professional should know. This week, we examine the Environmental Protection Agency’s requirements for universal waste.

Hazardous waste management is a topic that encompasses a wide variety of wastes and procedures that helps to keep the harmful effects of waste on human health and the environment to a minimum. According to the Environmental Protection Agency (EPA), the universal waste regulations streamline the hazardous waste management standards for certain categories of hazardous waste that are commonly generated by a wide variety of establishments. These regulations:

  • Promote the collection and recycling of universal wastes
  • Ease the burden on generators to collect and transport wastes
  • Encourage the development of municipal and commercial programs to reduce the quantity of these wastes going to landfills and combustors

Basic requirements

The federal universal waste regulations apply to five types of universal waste: batteries, pesticides, mercury-containing equipment, lamps, and aerosol cans. The universal waste system must be followed by small and large quantities of universal waster, universal waste transporters, and universal waste destination facilities.

The EPA states that in general, materials managed as universal waste can be stored for a year and are not required to be shipped with a manifest or by a hazardous waste transporter. Universal wastes also do not need to be counted towards a generator’s category, which is a generator’s classification as a very small, small, or large quantity generator.

Under the universal waste requirements, materials must be managed in a way that prevents releases into the environment. The standards are specific to each kind of universal waste, and are different depending on if the generator is a small or large quantity handler. There are also standards for labeling, responding to releases, and for universal waste to be managed at a facility that is permitted or designed to receive hazardous waste.


The universal waste requirements define a battery as a device consisting of one or more electrically connected electrochemical cells which is designed to receive, store, and deliver electric energy. In this case, batteries also include intact, unbroken batteries from with the electrolyte has been removed.

Some batteries are not included in the universal waste standard, such as spent lead-acid batteries that are being managed under a different standard. Other exceptions include batteries that are not waste because they have not been discarded, and batteries that are not hazardous waste.


A pesticide is any substance or mixture of substances intended for preventing, destroying, repelling, or mitigating any pest, or intended for use as a plant regulator, defoliant, or desiccant, with some exceptions, says the EPA. The universal waste regulations can be used to manage pesticides that have been recalled if there are either:

  • Stocks of a suspended and canceled pesticide that are part of a voluntary or mandatory recall under FIFRA Section 19(b)
  • Stocks of a suspended or canceled pesticide, or a pesticide that is not in compliance with FIFRA, that are part of a voluntary recall by the registrant

The EPA also states that universal waste can be used to manage stocks of other unused pesticides that are collected and managed as part of a waste pesticide collection program.

Mercury-containing equipment

The universal waste standard says mercury-containing equipment include any devices or parts of a device that contains elemental mercury that is integral to its function. According to the EPA, these devices can include thermostats, but not batteries or lamps.

Certain kinds of mercury-containing equipment meet this definition, but are not considered to be universal waste. Examples of this are pieces of equipment or devices from which the mercury-containing components have been removed. This also applies to mercury-containing equipment that is not waste because it has not been discarded, and mercury-containing equipment that is not hazardous waste.


Lamps are considered by the universal waste requirements to be the bulb or tube portion of an electric lighting device that are designed to produce radiant energy in the ultraviolet, visible, and infrared regions of the electromagnetic spectrum. Some of the common types of universal waste electric lamps include:

  • Fluorescent
  • High intensity discharge
  • Neon
  • Mercury vapor
  • High pressure sodium
  • Metal halide

Lamps that are not waste because they have not been discarded or that are not hazardous waste are not considered to be universal wastes, the EPA says.

Aerosol cans

Aerosol cans are defined as non-refillable receptacles containing a gas that has been compressed, liquified, or dissolved under pressure, which are used to expel a liquid, paste, or powder. Aerosol cans are also fitted with a self-closing release device allowing the contents to be ejected by the gas.

Additionally, aerosol cans frequently contain flammable propellants, such as propane or butane, which can cause aerosol cans to demonstrate ignitability, which qualifies them as a hazardous waste. Aerosol cans that do not exhibit a hazardous characteristic or contain a hazardous waste substance are not hazardous waste and therefore not considered universal waste. Aerosol cans that are considered empty by the standard’s definition are also not universal waste.

Federal vs. state programs

The universal waste requirements can vary in each state in the United States, and though the majority of them have adopted the full federal universal waste program, others have only adopted some of the federal universal wastes.

According to the EPA, a state does not have to include all of the federal universal wastes when they adopt the universal waste regulations. Also, if a state does not adopt a certain universal waste that is considered hazardous, then it must be managed under the applicable state hazardous waste regulations. Lastly, states can add additional universal wastes to their individual universal waste programs.

For more details about the EPA’s universal waste regulations, click here.

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