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Univeral Waste

What are universal wastes? Universal wastes are specific hazardous waste streams that a company can choose to manage in an alternative manner in place of the more complex hazardous waste requirements. These wastes are generated by numerous businesses and are often not properly managed according to the hazardous waste regulations. Universal wastes include:

  • Electric lamps, including fluorescent, high intensity discharge, sodium vapor, mercury vapor, neon, incandescent lamps, and cathode ray tubes from computers, televisions, etc.;
  • Batteries, including spent dry cell and lead-acid batteries;
  • Pesticides, including certain suspended, canceled, or unused pesticides;
  • Devices containing elemental mercury, including thermostats, switches, thermometers, manometers, barometers, and various medical devices. Some advantages of handling these wastes as universal waste include:

    • Universal waste volume is not included when determining the hazardous waste generator status [R 299.9205(5)(i)]. This may allow some companies to reduce their generator status level. For example, a large quantity generator who manages part of its hazardous waste stream as universal waste may be able to become a small quantity generator.
    • Universal waste can be accumulated up to one year which is a longer accumulation time than allowed for a small quantity and large quantity generator(tm)s hazardous waste [40.CFR.273.15.and.273.35].
    • Less labeling is required on universal waste [40 CFR 273.14 and 273.34; and R 299.9228(4)(c)].
    • A hazardous waste manifest is not necessary to ship universal waste [40 CFR 273.52(a)], unless it is being shipped to or through another state that does not recognize it as universal waste. For example, not all states have adopted electric lamps as universal waste. However, shipping papers are required for universal waste if the waste is a US Department of Transportation (US DOT) hazardous material.
    • A handler may use a universal waste transporter to haul the universal waste off-site [40.CFR.273, Subpart D], or the handler may transport the waste themselves if they meet the transporter requirements [R 299.9228(4)(b) and 9228(5)(c)] instead of using a permitted and registered hazardous waste transporter. If the waste is going to or through a state that does recognize it as universal waste, it may be necessary to use a licensed hazardous waste transporter in that state.


The recycling area for these products is located at the Campus Safety Department. Anyone wishing to recycle these items can bring them to the Campus Safety Department and put them in the "Bulb Recycling Area" between the Campus Safety Department and the Art Department.