Universal waste is a special designation given to several types of hazardous waste that are considered ubiquituous and are afforded special management programs. One major component of this program is that the wastes are labeled using exact wording as described here. The types of universal waste typically managed on campus are paint and paint related waste, mercury-containing equipment, batteries, and lamps.
Paint and Paint-related Waste
Paint and paint-related waste must be labeled as "Universal Waste - Paint and Paint-related Waste" in order to be managed under these special rules. No satellite accumulation limit (55-gallons) is imposed, and the University can manage the timing of removal more effectively. Be aware that many of these items are flammable, and the quantity of flammable materials stored will still apply. Be sure to adequately contain paint and paint-related waste. It can include things like overspray, aerosol paint cans, oil-based paints, and even paint thinner or contaminated rags. Contact EHS should you have any questions.
Mercury-containing equipment must be labeled as "Universal Waste - Mercury-containing Equipment" in order to be managed under these special rules. No satellite accumulation limit (55-gallons) is imposed, and the University can manage the timing of removal more effectively. This allows EHS to manage shipments of these items to achieve the most value. Just because there is no accumulation limit on quantity, please do not accumulate these items without submitting a waste removal request as a single spill can be very costly. These items require protection from breakage and adequate secondary containment. Broken mercury-containing equipment cannot be classified as a universal waste.
Universal waste batteries must be labeled as "Universal Waste - Batteries" to be managed under these special rules. The rules only apply to batteries that would be classified as hazardous waste, so normal contemporary alkaline batteries are not managed under this set of rules. Broken, damaged, or batteries that are not intact cannot be managed under this standard either. Some lead-acid batteries, lithium ion batteries, and nickel-based batteries may be managed as scrap metal instead, so contact EHS for more information on how to manage specific batteries. There is no accumulation limit on quantity, but remember that these items are corrosive and there may be a general storage limit on corrosives. These items require protection from short circuiting, puncture or damage, and adequate secondary containment.
Lamps, or more commonly bulbs, must be labeled as "Universal Waste - Lamps" to be managed under these special rules. They extend to fluorescent tubes that would be hazardous due to mercury, metal vapor lamps using metals like sodium, or other lamps or bulbs that would be considered hazardous when disposed. They do not apply to incandescent bulbs that would not be hazardous. There is no accumulation limit on quantity, but remember that a single broken lamp can cause a costly cleanup so do not accumulate these longer than necessary. Lamps must be protected from breaking when stored.
Other Universal Wastes
Pesticides are considered a universal waste under some circumstances, but managing pesticides as a universal waste is not a normal management method at the university as special circumstances are required. Contact EHS for more information on waste pesticide management.
Aerosol cans are considered a universal waste under federal rules, but under state rules this change has not yet been adopted. More information will be available once the rule is implemented at the state level.