Managing Universal Waste
| Please note that this page
deals with federal requirements. State definitions
and regulations relating to universal wastes may
differ. Check the page for your state on the VetCA
Universal Waste State Resource Locator for links to more information.
Universal Waste Handlers
EPA ID Number and Notification
Accumulation Time Limits
Managing Common Universal Wastes at
Fluorescent Light Bulbs
EPA finalized the universal waste rule on May
11, 1995 as a way of streamlining the recycling efforts of commercial and industrial
groups. Under this rule, a hazardous waste generator has the option of designating
certain hazardous waste as universal waste, making them subject to less stringent
environmental regulations. These wastes are hazardous waste batteries, hazardous
waste thermostats (such as mercury-containing thermostats), certain hazardous
waste lamps, and certain hazardous waste pesticides.
States do have autonomy when it comes to the
universal waste rule. They do not have to accept it, they can add or remove
wastes, or they can have more stringent requirements. Thus, before you designate
any hazardous waste as a universal waste, you will need to check with your state
agency to see if they will allow it. Most states follow the federal rule.
EPA has added all mercury-containing
equipment, including mercury thermometers to the federal list of universal
waste effective in
This section has been created to help healthcare facilities
comply with the federal universal waste regulations found in 40
Universal Waste Handlers
The federal universal waste rule establishes two types of universal waste handlers. The small quantity handler of universal waste (SQHUW) who accumulates less than 5,000 kg of universal waste on site at any one time and the large quantity handler of universal waste (LQHUW) who accumulates 5,000 kg or more of universal waste. Veterinary facilities typically fall within the small quantity handler category. The vast majority, if not all veterinary clinics, fall into the SQHUW category. Veterinary facilities associated with large universities or research facilities may be classified as LQHUW.
Please note that once you have accumulated 5,000 kg of universal waste on site, you will remain a LQHUW for the rest of the calendar year. So if you find yourself with 5,000 kg of fluorescent light bulbs in January, even if you got rid of all of them in February and never accumulated that much again, you would still be considered a LQHUW until next January. Also keep in mind that what type of universal waste handler you are is not calculated on a month by month basis like we do for hazardous waste generation but on the total amount of universal waste accumulated at your facility at one time.
EPA ID Number and Notification
Only large quantity handlers of universal waste
(LQHUW) need to obtain an EPA ID number and send a written notification to
EPA that includes:
- A statement indicating that you are now
- The name of your facility
- Your street and mailing addresses
- The name and phone number of the person
at your facility responsible for managing your universal waste
- The types and quantities of universal
waste managed at your facility
All handlers of universal waste, whether one
fluorescent light bulb or a million fluorescent light bulbs, need to manage
their universal waste in such a way as to prevent releases of the universal
waste or component of the universal waste to the environment. For example,
lamps, because they can easily break, must always be kept in containers or
packages that are closed, structurally sound, adequate to prevent breakage,
and compatible with the contents of the lamp.
All handlers of universal waste need to mark
or label the universal waste or a container of the universal waste for the
purposes of identifying the type of universal waste and to let inspectors know
that you have chosen to handle these hazardous wastes as universal wastes. An
inspector will assume these wastes are hazardous wastes unless you clearly
designate otherwise. The regulations give you the following labeling
- Universal Waste ' Battery(ies); or Waste
Battery(ies); or Used Battery(ies)
- Universal Waste-Pesticides; or Waste Pesticides
- Universal Waste- Mercury Thermostat(s);
or Waste Mercury Thermostat(s), or Used Mercury Thermostat(s)
- Universal Waste-Lamp(s); or Waste lamp(s);
or Used lamp(s)
Please note that you can not put a label on
the wall. It must be either on the individual piece of universal waste or on
the container in which the universal waste is stored.
Accumulation Time Limits
The federal universal waste regulations allow
universal waste handlers to keep universal waste on site for a year. Although
handlers can extend that period if they need more time to facilitate proper
recovery, treatment, or disposal. For example, if your recycler will not pick
up your universal waste until you reach a certain quantity, the law will allow
you more than a year to accumulate that amount. You just need to show documentation
to the inspector that you needed that longer period.
Given that there is a time limit on the storage
of universal waste, all universal waste handlers need to be able to demonstrate
the length of time the universal waste has been on-site. The regulation gives
the following suggestions on how to do this but you can choose any method that
works even ones not on the suggested list.
- Labeling a container of universal waste
with the earliest date that any universal waste in the container became
- Labeling each individual waste with the
date it became a waste
- Maintaining an inventory system on-site
that identifies the date each universal waste became a waste
- Maintaining an inventory on-site that identifies
the earliest date that any universal waste items or a group of containers
of universal waste became a waste
- Placing the universal waste in a specific
accumulation area and identifying the earliest date that any universal
waste in the area became a waste
It should go without saying that all handlers
of universal waste need to train their employees on the proper handling and
emergency procedures associated with the universal waste managed at their facility.
For instance, if you are storing fluorescent light bulbs, your employees should
know what to do if one breaks.
If there is a release of universal waste or
a component of universal waste to the environment, one must immediately contain
the release and then determine if any material resulting from the release (e.g.
contaminated carpet, soil, personal protective equipment) is a hazardous waste
and properly handle it as such.
All universal waste handlers are prohibited
from treating or diluting universal waste on site. There are some exceptions
made for batteries and thermostats. For example, you are allowed to remove
electrolyte from batteries and mercury containing ampules from thermostats
and still handle the batteries and thermostats as universal wastes. However,
there are no exceptions made for lamps. So if you have a bulb crusher on site,
you cannot manage your lamps as universal waste, you must handle them as hazardous
waste and comply with all applicable treatment requirements under RCRA.
Furthermore, bulb crushers need to be operated
in a manner that minimizes the potential for releases. For example, the
bulb crushing operation shown in the photo 1 will not be acceptable to EPA
since the ground glass from the bulbs will be strewn throughout the area and
all over the equipment. On the other hand, the bulb crushing operation in photo
2 will be allowed because it contains all of the crushed glass and ensures
that none of the materials from the bulb escapes into the atmosphere.
In regards to disposal, all universal waste handlers can
send their universal waste to either another universal waste handler, a destination
facility which is defined by the regulations to be one who treats, recycles
or disposes of universal waste, or a foreign destination. One, of course, must
comply with all applicable Department of Transportation shipping requirements.
Please note that unlike hazardous
waste, you can transport your universal waste from one handler to another
so if you have several hospitals in an area, you can send your waste to one
of the hospitals who would then send it on to the destination facility. By
doing this you may be able to reduce your shipment costs if there is a discount
for bulk deliveries.
As for recordkeeping, only large quantity handlers of universal
waste (LQHUW) are required to keep records of where they are sending their
universal waste and if applicable, any universal waste they are receiving from
others. There is no specified form for these records. Use whatever works for
you (i.e., logs, invoices, manifests, bill of ladings etc.).
The only requirement is that when a LQHUW is shipping universal
waste off site, the records must show the name and address of the facility
to whom the wastes are being sent; the quantities and types of waste they are
sending that facility; and the date of shipment.
Similarly, if they are receiving wastes from other handlers,
they must keep records of the names and addresses of the facilities sending
them waste; the types and quantities of universal waste they are receiving
from each facility; and when they received the waste.
These records must be kept for three
Managing Common Universal Wastes
at Veterinary Facilities
The EPA defines a battery as a device consisting of one
or more electrically connected electrochemical cells, which is designed to
receive, store, and deliver electric energy. An electrochemical cell is a
system consisting of an anode, cathode, and an electrolyte, plus such connections
(electrical and mechanical) as may be needed to allow the cell to deliver
or receive electrical energy. The term battery also includes an intact, unbroken
battery from which the electrolyte has been removed.
Hospitals use batteries in equipment such as pacemakers,
defibrillators, fetal monitors, heart monitors, pagers, telemetry devices,
temperature alarms and blood analyzers, pumps, diagnostic equipment, otoscopes,
opthalmoscopes, dictation machines, pen lights, glucometers, flashlights
and telemetry devices. Batteries are used in portable generators,
lighting and a myriad of electronic devices.
So why should healthcare facilities recycle batteries? Batteries contain
heavy metals such as mercury, lead, cadmium, and nickel. If batteries are
not managed and disposed of properly, they can cause harm to the environment
and to human health.
Resources for Reducing Battery Wastes:
Fact Sheet: Disposal of Alkaline Batteries is intended for users
of alkaline batteries. It describes how alkaline batteries should be
handled, provided general information on regulations governing these
batteries and gives suggested disposal procedures.
Health Care Without
Harm is a global coalition of 443 organizations in 52 countries
working to protect health by reducing pollution in the health care industry.
This site contains a valuable fact sheet for hospitals called Battery
Roundups: Get Charged! This fact sheet provides an overview of the
different types of batteries used in hospitals and discusses how, through
a battery roundup, hospitals can safely and properly collect, manage,
and properly dispose of or recycle batteries.
Fluorescent Light Bulbs
The EPA defines a 'lamp' also referred
to as 'universal waste lamp,' as the bulb or tube portion of an electric
lighting device. A lamp is specifically designed to produce radiant energy,
most often in the ultraviolet, visible, and infrared regions of the electromagnetic
spectrum. Examples of common universal waste electric lamps include, but are not limited to, fluorescent, compact fluorescent, high intensity discharge, neon, mercury vapor, high-pressure sodium, and metal halide lamps.
Healthcare facilities operate all day, every day, year round. Fluorescent
lamps can help healthcare facilities significantly reduce their energy consumption. They
use one quarter the energy of incandescent lamps and last as much as ten
times longer. However, fluorescent lamps contain the toxic element mercury.
When broken or improperly disposed of, fluorescent lamps may release mercury
into the air, water and soil, and thus pose a threat to human health and
the environment. While fluorescent lamps offer tremendous environmental advantages
through energy savings, the disposal of used fluorescent lighting raises
serious environmental concerns. Recycling spent mercury-containing lamps
offers an environmentally sound alternative to expensive hazardous waste
disposal. Recycling used fluorescent lamps is a good way to eliminate mercury
emissions, as well as reduce waste and other toxic material disposal. Use
the following resources to start or improve your recycling program.
Resources for Reducing Fluorescent Bulb Waste:
Bulb - Mercury Conversion Spreadsheet calculates the amount of
mercury and materials recycled for each bulb recycled enabling you to
track and report on this information. (XLS format, 1 sheet, 30KB, requires Microsoft
Excel Viewer to view)
Recycling: 10 Steps to a Successful Program is a fact sheet from
the Practice Greenhealth Program. This guide also
contains links to other resources for fluorescent lamp recycling. (PDF
format, 4 pages, 396KB, requires Acrobat Reader to view)
LampRecycle.org is a resource for
any light bulb ("lamp") user seeking details on recycling spent
mercury-containing lamps and is sponsored by the National Electrical Manufacturers
Association (LAMP section).
Technological advances in all electronic equipment, particularly
computers, continually shorten their useful life, resulting in a complex
and rapidly growing waste stream. Computers, televisions, lab analyzers,
EKG monitors and other types of biomedical equipment contain many hazardous
constituents ' from lead in cathode ray tube (CRT) monitors, chlorinated
plastics in cable wiring, brominated flame retardants in circuit boards to
mercury in LCD displays. CRTs alone contribute almost one third of the lead
found in the municipal waste stream. Improper management or disposal of electronic
equipment poses a significant threat to public health and the environment.
Veterinary facilities need to manage their electronic equipment in a way
that controls costs, protects data and complies with federal, state and local
The EPA is planning to add used CRTs from computers and
television monitors to the federal Universal Waste Rule. In addition, EPA
is currently developing a regulatory exemption for processed glass sent for
CRT glass-to-glass recycling. Some states have already added CRTs to their
lists of universal waste.
Resources for Electronics Waste:
Alliance (EIA) Consumer Education Initiative) The Electronic
Industries Alliance (EIA) is a national trade organization that includes
the full spectrum of U.S. manufacturers. The EIA Consumer Education Initiative
or "CEI" is a web-based information resource that provides
consumers and others with information on recycling and reuse opportunities
for used electronics. Participating manufacturers include an industry
statement in a variety of media, including owner's manuals, company web
sites, and product literature, directing consumers to the CEI web page
where consumers can find recycling and reuse opportunities for used electronics
in their area.
Preferable Procurement Guidelines for Information Technology (IT) Equipment
in Health Care - Part I: The Issue (PDF,
2 pages, 110 KB) is a quick overview of issues to think about when purchasing
and disposing of electronics - from cost to environmental and health
Guidelines for IT Equipment in Health Care - Part II: Procurement Matrix
for Original Equipment Manufacturers (OEMs) and Vendors (PDF,
3 pages, 129 KB) is a checklist of criteria for purchasing environmentally
safe electronic equipment.
Guidelines for IT Equipment in Health Care - Part III: Post Contract
Reporting Requirements for Continual Improvement (PDF,
2 pages, 98.1 KB) helps in developing environmental health-related reporting
requirements for your facility's electronics vendor(s). This fact sheet
has specific suggested language to use.
Guidelines for IT Equipment in Health Care - Part IV: Recommendations
for the Bid Development Process (PDF, 3 pages, 151 KB) is a guide
to evaluating electronics vendor bids and proposals based on environmental
and public health criteria.
Guidelines for IT Equipment in Health Care - Part V: Sample Procurement
Evaluation Tool (PDF, 3 pages, 145 KB) is a checklist
tool that provides guidance for purchasers in evaluating bids for IT
equipment while incorporating environmental and public health concerns.
It can be used to evaluate bids from vendors for products and practices
that are environmentally preferable.
spreadsheet Procurement Evaluation Tool (Excel
spreadsheet, 1 page, 94 KB) is for use with the EPP Guidelines for
IT Equipment in Health Care - Part V: Sample Procurement Evaluation Tool
Choices for Electronic Equipment: From Procurement to End-of-Life (PDF, 5 pages, 138 KB) is a 10-step
guide to greening your purchase and disposal of electronics equipment.
Coalition (NRC) has implemented an Electronics Recycling
Initiative. This project is made possible with support from the U.S.
Environmental Protection Agency and the U.S. Postal Service. The goal
of the NRC's Electronics Recycling Initiative is to promote the recovery,
reuse and recycling of obsolete electronic equipment, and to encourage
the design, manufacture and purchase of environmentally responsible electronic
equipment. *This site contains valuable fact sheets on managing, recycling
and reuse options for electronic equipment.
Computer Exchange (WCE) is an international educational
nonprofit focused on helping the world's poorest youth to bridge the
disturbing global divides in information, technology and understanding.
WCE keeps donated computers out of landfills and gives them new life
connecting youth to the Internet in developing countries
Hospitals and healthcare facilities use equipment that contains
mercury. Due to the very serious effects that mercury exposure and releases
can have on human health and the environment, source reduction and mercury
recycling have become a high priority at the federal, state and local levels.
Indeed, some states have already banned products that contain mercury, if
alternative, mercury-free products are available.
Mercury-containing equipment used in hospital
and healthcare settings may include thermometers; sphygmomanometers; esophageal
dilators; Cantor, Miller Abbott, and feeding tubes; dental amalgam; certain
laboratory chemicals; and medical batteries. Mercury may also be present
in cleaning solutions; batteries; fluorescent lamps; thermostats; pressure
gauges and electrical switches.
Effective August 5, 2005, the EPA added discarded mercury-containing
equipment (MCE) to the list of universal wastes. MCE means a device or part
of a device (excluding batteries and lamps) that contains elemental mercury
integral to its function, including: thermostats; barometers; manometers;
temperature and pressure gauges; and mercury switches. EPA has concluded
that regulating spent mercury-containing equipment as a universal waste will
lead to better management of this equipment and will facilitate compliance
with hazardous waste requirements. *The actual list of universal wastes in
your state may include these items and/or different wastes. *The universal
waste category of MCE incorporates thermostats from the original list.
Resources for Reducing Mercury Containing Equipment
EPA Mercury contains
a section for healthcare facilities and provides resources relating to issues
of particular concern to people who work in the health care industry, including
the medical uses of mercury, programs to reduce the use of mercury, health
effects of mercury, workplace safety, how to handle mercury spills, and proper
disposal and treatment of mercury waste.
Health Care Without Harm is an international
coalition of 437 organizations in 52 countries working to transform the health
care industry so it is no longer a source of harm to people and the environment.