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Universal Waste 


See Resource Conservation and Recovery Act — General and Resource Conservation and Recovery Act — Solid and Hazardous Waste.

To encourage recycling of three kinds of “universally” generated hazardous wastes, Environmental Protection Agency (EPA) published the Universal Waste (UW) Rule on May 11, 1995. It is one of many revisions to the Resource Conservation and Recovery Act(RCRA). In its original form, the Universal Waste (UW) Rule applied to waste batteries, certain hazardous waste pesticides, and mercury-containing thermostats. In July 1999, EPA added a UW management option for certain lamps.

EPA designed the Universal Waste Rule to encourage recycling of these high-volume waste streams by

  • extending storage time limits to 1 year to allow collection of larger quantities to increase the economically feasibility of recycling,
  • minimizing the certification and licensing requirements for UW transporters,
  • excluding wastes recycled under the Universal Waste Rule from volume and rate calculations of generator status, and
  • eliminating the requirement for hazardous waste manifests for shipments of UW.

The Universal Waste Rule is a management option under RCRA. Campuses may still opt to treat these waste streams as hazardous waste. State-specific requirements for UWs may vary. For instance, some states allow management of computer wastes under the Universal Waste Rule.

There is no obligation to manage solid wastes that are not hazardous as UWs. The UW regulations exist to ease the management of hazardous wastes while still protecting public health and environment.

Key Concepts

See Resource Conservation and Recovery Act — General and Resource Conservation and Recovery Act — Solid and Hazardous Waste.

Universal Wastes (UW)

Under federal rules, campuses can manage four hazardous waste streams as UWs. Not all of these options may be available in any given state, and some states may have other UW options.

  • Batteries: These include all batteries that meet the definition of hazardous waste, including nickel–cadmium and lead–acid batteries. Most domestically produced alkaline batteries no longer meet the definition of hazardous waste and thus are solid wastes.
  • Thermostats: These include any temperature-control device that contains metallic mercury in an ampoule attached to a sensing element or the ampoule only after removing it from the device.
  • Pesticides: These include unused pesticides that have been suspended, recalled, or canceled under the Federal Insecticide, Fungicide, and Rodenticide Act (see Federal Insecticide, Fungicide and Rodenticide Act — General).
  • Lamps: These are lamps or bulbs that meet the RCRA definition of hazardous waste, including fluorescent lamps, high-intensity discharge (HID) lamps, neon, mercury vapor, high-pressure sodium, and metal halide lamps.

Universal Waste Handler

The term “handler” of UW is much the same as “generator” of hazardous waste. Two categories of handlers exist, based on the total quantity of all UW stored at a facility at any one time. A nearby table describes the limits of these categories and provides a summary of applicable management requirements.

Electronic or Computer Wastes (e-Waste)

Computers, televisions, and other electronic equipment may meet the RCRA definition of hazardous waste because of heavy metals in monitors and circuitry. Some states include electronic waste (or “e-waste”) within their Universal Waste Rules. Many others have not but may have identified other recycling options. Colleges and universities should confirm requirements in their state.

Does this apply to my campus?

UW is a hazardous waste management option under RCRA. You are not required to use this option, but the requirements are less stringent for eligible waste streams. If your campus generates any of these four specific hazardous wastes, you can consider managing them as UWs as an alternative to hazardous waste management. Moreover, you are under no obligation to manage nonhazardous wastes as UW.

States may choose not to adopt these options. Thus, they may not be available in your state or for your waste streams.

What do I have to do?

Determine whether your campus generates any of the four specific UW streams. Then determine whether the UW management option is viable for your campus. If any or all of these options are available, you can implement one, some, or all of your UW streams. Monitor the program to ensure continued effectiveness.

The weight of UW you manage will determine the requirements for training and record keeping. Under federal regulations, keeping less than 5,000 kilograms onsite at any time will reduce these requirements.

Regardless of how much UW your campus manages, you must

  • recycle all UWs,
  • have a spill response plan,
  • label all UWs,
  • maintain containers in good condition,
  • never keep UWs longer than 1 year, and
  • never treat UWs (state rules may consider bulb crushing to be treatment).

Universal Waste (UW) Handler Status and Management Requirements


Small-Quantity UW Handler

Large-Quantity UW Handler

UW storage limits

Less than 5,000 kg
(11,200 lb.)

More than 5,000 kg
(11,200 lb.)

EPA notification

Not required


Employee training

Distribute information

Ensure familiarity

Shipping documentation

Not required

Required (bill of lading, log, or hazardous waste manifest) and retained for 3 years

Spill response


Disposal options

All UW must be recycled. If not, it must be managed and disposed of as hazardous waste

Storage time limits

1 year

Storage container labeling

All UW containers must be labeled with the words “Universal Waste” and the date the wastes were first put in the container

Storage container management

All containers for UWs must be in good condition and kept closed except when filling


Treatment and disposal; bulb crushing may be treatment, depending on state rules


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