Universal Waste Recycling: A Comprehensive Guide

In today's world, responsible waste disposal is paramount. Many people are prone to take shortcuts or search for alternative solutions when a task has many steps or requires a lot of time, and the same goes for waste disposal. A perfect world would see all materials properly disposed of, but that is not currently the reality. Universal waste represents a specific category of hazardous waste, commonly generated by both households and businesses. These materials contain harmful toxic substances, including mercury, lead, and phosphor.

Understanding Universal Waste

Universal wastes are a specific classification of hazardous waste commonly produced by households and businesses. These waste materials contain a myriad of harmful toxic substances including mercury, lead, and phosphor. The Environmental Protection Agency (EPA) created the Universal Waste Program in 1995 to endorse the process of proper waste collection and recycling. This program streamlines hazardous waste management standards for specific categories of hazardous waste that are commonly generated by a wide variety of establishments. The streamlined regulations promote the collection and recycling of universal waste, ease the regulatory burden on retail stores and other generators that wish to collect these wastes and transporters of these wastes, and encourage the development of municipal and commercial programs to reduce the quantity of these wastes going to municipal solid waste landfills or combustors.

What Makes a Waste "Universal"?

The EPA has designated certain materials as hazardous waste but recognizes that these materials are commonly used. To streamline the recycling process and reduce the burden on businesses and individuals, the EPA established the Universal Waste Program. This program provides a set of simplified regulations for managing these specific hazardous wastes, encouraging their proper collection and recycling.

Why is Universal Waste a Concern?

Landfills, in particular, are especially intolerant of various types of universal waste materials. Mercury and lead found in batteries and lamps can leach into and contaminate nearby groundwater sources. Additionally, alternative disposal methods, such as incineration, can create mercury vapors that can travel more than 200 miles.

Types of Universal Waste

The federal regulations identify five specific categories of materials that can be managed as universal wastes: batteries, pesticides, mercury-containing equipment, lamps, and aerosol cans.

Batteries: A battery consists of connected electrochemical cells that receive, store, and deliver electrical energy. Universal waste batteries include rechargeable nickel-cadmium batteries, silver button batteries, mercury batteries, small sealed lead acid batteries (burglar alarm and emergency light batteries), most alkaline batteries, carbon-zinc batteries, and any other batteries that exhibit a characteristic of a hazardous waste. NOTE: Spent automotive-type lead acid storage batteries are not universal waste. They are hazardous wastes that are managed under a different set of regulatory requirements.
Pesticides: Pesticides are substances used to kill or ward off unwanted plants or animals. A universal waste pesticide is defined as an unused, suspended, or recalled substance that is eligible for management. This covers a broad range of pesticides, but only if they are a recalled, suspended, or canceled stock; or if they have been collected as part of a waste pesticide collection program.
Mercury-Containing Equipment: This is any device (or part of a device) that includes mercury, according to the Title 40 of the Code of Federal Regulations (CFR) part 273. This could include things such as switches, relays, and thermometers, but not batteries and lamps, which are covered under their own categories. These thermostats contain small glass capsules with mercury, a shiny liquid metal, to make electrical contact. Motor vehicle switches that contain mercury. Any mercury switch that is removed from a vehicle is a universal waste. Non-automotive mercury switches and products that contain them. These switches include thermostats and tip switches in portable heaters, washing machine out-of-balance switches, silent wall switches, and other mercury-containing switches and products containing them.
Lamps: Lamps are defined as the bulb or the tube portion of an electrical lighting device. To be classified as universal waste, a lamp must contain specific contaminants. This covers a comprehensive range of lightbulbs as found in many businesses, including fluorescent, high-intensity discharge, neon, mercury vapor, high-pressure sodium, and metal halide lamps. Universal waste lamps include fluorescent tubes and bulbs, high intensity discharge lamps, sodium vapor lamps, and any other type of lamps that exhibit a characteristic of a hazardous waste. Also, any electric lamp that contains added mercury, whether or not it exhibits a hazardous waste characteristic, is a universal waste. While the EPA doesn’t explicitly mention LED lamps, which are increasingly common in homes and offices, they would seem to fall under the very broad definition of what constitutes a lamp: “…the bulb or tube portion of an electric lighting device.
Aerosol Cans: A non-refillable container of a compressed or liquefied gas, aerosol cans are used to propel liquid, paste, or powder under pressure. These are universal wastes if they contain an ignitable, corrosive, reactive, or toxic propellant or if the contents exhibit any hazardous waste characteristic.

Some states include additional materials in their universal waste program beyond those that are included in the federal program. For example, Ohio includes paint and paint waste while Michigan includes pharmaceuticals. Maine, New Hampshire, and Rhode Island all have regulations regarding Cathode Ray Tubes (CRTs).

Specific Examples of Universal Waste

Cathode ray tubes (CRTs), also known as picture tubes, are found in devices such as older televisions and computer monitors. Cathode ray tube (CRT) glass is any glass that came from the treatment or breakage of a CRT or CRT device. CRT glass includes CRT funnel glass and CRT panel glass.
Universal waste PV modules includes any device consisting of, or containing, one or more electrically connected photovoltaic cells that are designed to convert solar radiation into electrical energy. PV modules include integrated components that cannot be separated without breaking the PV module glass.

Regulations and Compliance

The federal universal waste regulations are explained in Title 40 of the Code of Federal Regulations (CFR) in part 273. The universal waste regulations can vary from state to state in the United States. The majority of states have adopted the full federal universal waste program, however, others have only adopted some of the federal universal wastes. A state does not have to include all of the federal universal wastes when they adopt the universal waste regulations. If a state doesn’t adopt a certain universal waste and the waste meets the definition of a hazardous waste, then it must be managed under the applicable hazardous waste regulations in that state. Additionally, states may add additional universal wastes to the state's universal waste program.

Key Regulatory Aspects

Storage: In general, the EPA states that materials managed as universal waste can be stored for a year. A handler may accumulate universal waste for no longer than one year from the date the waste was generated or received from another handler. Small and large quantity handlers of universal waste who accumulate universal waste must be able to demonstrate the length of time that the universal waste has been accumulated from the date it becomes a waste or is received.
Labeling: The EPA also requires labeling, since documenting the waste’s identity prepares others for safe handling and excludes it from being subjected to the more stringent hazardous waste generation restrictions. You also must properly identify universal waste with universal waste labels.
Transportation: Materials managed as universal waste are not required to be shipped with a manifest or by a hazardous waste transporter. Universal waste regulations do not require small or large quantity handlers of universal waste to use a manifest for transportation off site.
Record Keeping: Large quantity handlers of universal waste must follow the tracking requirements in Section 273.39, which include keeping a record of each off-site shipment of universal waste from the handler to other facilities. A large quantity handler of universal waste must keep a record of each shipment of universal waste received and sent and must retain those records for at least three years (Section 273.39).
Destination Facilities: A universal waste handler can send or take a shipment of universal waste to another universal waste handler, a foreign destination, or a destination facility (273.18(a) and 273.38(a)). A "destination facility" is a facility that treats, disposes of, or recycles a particular category of universal waste (273.9). The standards for destination facilities can be found in Part 273 Subpart E.
Employee Training: Handlers of universal waste need only comply with the employee training requirements in Part 273. For example, small quantity handlers must inform all employees who handle universal waste of the proper waste handling procedures appropriate to the type of universal waste handled at the facility (Section 273.16). Large quantity handlers must ensure that all employees are thoroughly familiar with proper waste handling and emergency procedures (Section 273.36).
Release Response: The universal waste regulations do require that the materials be managed in a way that prevents releases to the environment. The requirements are tailored to each specific type of universal waste and differ for small quantity handlers and large quantity handlers. Finally, the standards also include a labeling requirement, a requirement to respond to releases, and a requirement for universal waste to ultimately be managed at a facility that is permitted or otherwise designated for receiving hazardous waste, like a hazardous waste recycler.

Handlers of Universal Waste

There are also four types of regulated participants in the universal waste system:

Small quantity handlers of universal waste (accumulates less than 5,000 kg of universal waste)
Large quantity handlers of universal waste (accumulates 5,000 kg or more of universal waste)
Universal waste transporters
Universal waste destination facilities

State-Specific Programs

While the Universal Waste Act covers a core set of products and materials, each state has its own set of regulations as to what constitutes universal waste. Most states have adopted the full federal Universal Waste Program, but others have adopted only some of it. A number of states have added their own materials that are classified as universal waste.

EPA encourages states to develop and run their own hazardous waste programs as an alternative to direct EPA management. States can create different standards (except for batteries due to the Battery Act), but they have to be equivalent to the federal regulations (i.e., they must provide equivalent protection, cannot regulate fewer handlers, etc.). Authorized states may expand their state universal waste programs to include additional wastes beyond the federally recognized universal wastes (i.e., batteries, pesticides, mercury-containing equipment, lamps, and aerosol cans). EPA established criteria that a waste stream should meet to be included as a universal waste (Section 273.81). States should evaluate potential additional wastes against these criteria. However, a state may not designate as a universal waste any waste which is not a hazardous waste in that state.

Example Scenario

An elementary school is in the process of remodeling and is replacing its light fixtures with more energy-efficient lamps. This process will generate more than 5,000 kg of spent hazardous waste lamps that will be subject to the universal waste management. Both the school and the contractor will be subject to the universal waste handler standards in Part 273 because they would both be considered universal waste handlers. A universal waste handler is defined as a generator of universal waste or the owner or operator of a facility that receives universal waste from other universal waste handlers (Section 273.9). In this case, the school used the lamps and made the determination to discard them and is thus a generator. The contractor that actually removes the universal waste lamps from service is considered a handler and generator of the waste making the school and the contractor co-generators of the waste.

Managing Universal Waste Responsibly

Effective 2016, the state also instituted a Mandatory Organic Waste Recycling law (AB 1826). Not only do you have to dispose of hazardous materials and any other universal waste in a regulated and controlled manner, you should also have a standard protocol put into place if you are a waste generator. Trained professionals understand these regulations, which are frequently updated.

Best Practices

Proper Identification: You also must properly identify universal waste with universal waste labels.
Partner with Professionals: Often, to ensure the proper disposal of universal waste, the simplest solution for a business is to partner with a waste management company such as RTS. Talk to a trained and certified professional hazardous waste management company, which can maximize your universal waste disposal concerns in a regulated, controlled, and efficient way.
Diversion from Landfills: At Lowcountry, the goal is to ensure that all universal waste is sustainably diverted away from landfills to the suitable and licensed collection facilities.
Recycling: Lowcountry Environmental Services makes every effort to ensure that universal waste material gets recycled appropriately. Universal waste handlers, as defined in 40 CFR Section 273.9 , are not required to recycle their wastes in order to take advantage of the less stringent requirements in Part 273 .
Approved Destination Facilities: Lowcountry Environmental Services relinquishes all universal waste to an approved destination facility. These facilities have the necessary permits to treat, store, recycle, or dispose of hazardous waste materials.
Documentation: Lowcountry Environmental Services will also provide you with the appropriate certificates and paperwork or any other certification.

The Role of Waste Management Companies

One resource available to you that can help you understand and deal with any waste you generate is a universal waste disposal company. Companies that specialize in the disposal of your universal waste have an in-depth knowledge of the rules and regulations, which ensures you suffer no fault in problems regarding waste management. We are able to comply with the various caveats of universal waste disposal, such as providing diversion reports and ‘Certificates of destruction’ verifying responsible recycling.

Specific Management Standards for Different Types of Universal Waste

Batteries: Specific management standards for batteries include containing any universal waste battery that shows evidence of leakage, spillage, or damage that could cause leakage. The container must be closed, structurally sound, and compatible with the batteries. Batteries or battery packs may be sorted, mixed, discharged, regenerated, disassembled into individual batteries, or removed from products as long as the individual battery cell is not breached. Cells may be opened to remove electrolyte from the battery, but must be closed again immediately. A handler of universal waste may only manage broken or damaged hazardous waste batteries as universal wastes if the breakage or damage does not constitute a breach in the cell casing. Therefore, universal waste batteries are intended to be intact (i.e., where the casing of each individual battery cell is not breached). EPA recognizes that batteries may become damaged or broken during handling. Therefore, the requirements for handlers of universal waste require that they contain any universal waste battery that shows evidence of leakage, spillage, or damage that could cause leakage under reasonably foreseeable conditions in a container (Sections 273.13(a)(1) and 273.33(a)(1)). The container must be closed, structurally sound, compatible with the battery's contents, and capable of enclosing potential releases. Generators may choose the management standards with which they will comply. That is, they may either manage their batteries under the standards provided in Subpart G of Part 266 for spent lead- acid batteries that are being reclaimed or they may comply with the universal waste regulations in Part 273 (60 FR 25505; May 11, 1995).
Pesticides: Specific management standards for pesticides include preventing releases to the environment by containing them in tanks, containers, or transport vehicles or vessels that are structurally sound and adequate to prevent leakage.
Mercury-Containing Equipment: Specific management standards for mercury-containing equipment include preventing releases to the environment by containing them in containers that are structurally sound and adequate to prevent breakage.
Lamps: Specific management standards for lamps include preventing releases to the environment by containing them in containers that are structurally sound and adequate to prevent breakage. The containers must be kept closed and cannot show any damage or leakages. Under the universal waste regulations of 40 CFR Part 273, universal waste lamps must be stored and packaged in a way that minimizes breakage. The containers or packages must remain closed and lack evidence of leakage, spillage or damage that could cause leakage under reasonably foreseeable conditions (Sections 273.13(d)(1) and 273.33(d)(1)). If, however, any unintentional breakage does occur, then universal waste handlers must immediately clean up and contain any lamps that are broken or show evidence of breakage, leakage, or damage that could cause the release of mercury or other hazardous constituents into the environment (Sections 273.13(d)(2) and 273.33(d)(2)).

The Importance of Proper Disposal

While many businesses and individuals may not realize it, there are a lot of everyday materials and goods that can’t be tossed in the garbage. These materials are called universal waste, and since 2006, the Universal Waste Law has made it illegal for residents or small businesses to dispose of anything that falls within its remit into the trash. Hazardous waste includes anything that, when disposed of, has the potential to cause or contribute to an increase in death or serious illness, or pose a threat to human health or the environment. Many of these waste types are not common, and universal waste only covers those that are very likely to be disposed of by a home or small business. Every office in America, for example, will likely discard a few batteries and a can of air freshener at some point.

It’s easy to get overwhelmed by bureaucracy, but hazardous material laws are put into place to protect the environment and community that you serve as a business owner.

Future Trends

EPA is planning to propose new rules to improve the management and recycling of end-of-life solar panels and lithium batteries.

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