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Store, Label, Dispose and Transport Universal Waste

June 16, 2021


In our last blog entry, we explained what universal wastes are and how they differ from what one usually thinks of as hazardous wastes, per se. Presently, we’ll expand on that, touching on universal-waste storage, labeling, packaging, transportation, and disposal requirements. 

But first, remember that universal wastes are a subcategory of hazardous waste, which is to say, they’re still hazardous waste—so you can’t just blow them off like you were only throwing away a bag of stale pretzels. 

Come to think of it, you might consider universal waste as “Hazmat Lite.”

By way of review, the EPA created the universal waste subcategory for certain kinds of hazardous waste that are generated in beaucoup amounts by households, businesses, and industry—and wrote relatively streamlined hazardous waste management rules for it. 

They did this to better the odds that people & entities will dispose of batteries, pesticides, lamps, aerosol cans, and mercury-containing garbage the way the agency wants. 

In effect, the EPA conceded in 1995 that the extant regulations—which subjected these things to the more-onerous rules of hazardous waste disposal—made it too tempting to just toss it all into the general trash-stream and hope nobody noticed. (BTY, a very bad idea.)


As universal waste rules are in abundant & dynamic supply, emanate from more than one agency, and differ from state-to-state, what follows cannot be comprehensive. 

What’s provided here is meant as a convenient first step to familiarize yourself with the many requirements relating to universal waste. It should not be used as a substitute for reading and understanding current federal, state, and local  requirements.  

As in all things concerning hazardous waste management—it’s imperative to get expert advice! 

Storage time-limits for universal waste

A common question about universal waste is how long can you keep it onsite without suffering the slings & arrows of one or another federal, state, or local functionary. Of course, the answer to this is way-complicated, which is totally on-brand for the EPA. Consider:

  • Both a Small Quantity Handler of Universal Waste (SQHUW) or a Large Quantity Handler of Universal Waste (LQHUW) may store such waste onsite for up to one year. If greater than one year is required, the handler must prove that such waste has a feasible recycling market.
  • A transporter of universal waste may store said waste at a transfer facility for up to ten days before delivering it to a LQHUW, a SQHUW, or a destination facility.

Okay…we knew you would ask. So be advised that “LQHUW” is an initialism for Large Quantity Handler of Universal Waste; and “SQHUW” is the same for a Small Quantity Handler of Universal Waste. What’s the difference?

An LQHUW  can accumulate up to (but fewer than) 5000 kg of universal waste onsite, while an LQHUW  can accumulate as much as they want, and both for up to a year without a storage permit. (If you’re metric-curious, 5000 kg is a tad over 11,023 lbs.)

Also let it be known that a “destination facility” is a place where hazardous wastes—and thereby universal wastes—are stored prior to recycling, incineration, or whatever; and they must have a waste installation & operation permit for storage to do so.

 And if the destination facility is additionally used for disposal of universal waste, then it must be permitted for hazardous waste disposal: reminding us once again that universal waste is a kind of hazardous waste, and must be treated as such.

Transportation rules for universal waste

The DOT rules for universal waste transporters are logically more lenient than the rules for hazardous waste transporters. And unlike small or large hazardous-waste generators, hazardous waste manifests aren’t required for universal waste handlers (although large handlers are required to keep basic shipping records). More specifically:

  • Either an SQHUW or an LQHUW may transport universal waste to another universal waste handler, to a destination facility, or to a foreign location.
  • A transporter of universal waste must comply with all applicable U.S. D.O.T. regulations applicable to hazardous material (once again evoking the factoid that universal waste is a kind of hazardous waste).
  • Either an SQHUW or an LQHUW  may qualify as a transporter in order to self-transport a universal waste; and in such cases the handler must also comply with all applicable U.S. D.O.T. regulations.
  • A destination facility may transport its universal waste to another destination facility, to another universal waste handler, or to a foreign destination.

Labeling requirements for universal waste

Labeling requirements are the same for both LQHUWs and SQHUWs. Each container of universal waste must be labeled with the dates that (1) the contents became a waste and (2) when it was received from another handler. 

Of course, a container of universal waste should never be labeled (and thereby misidentified) as “hazardous waste,” even though that’s what it is, as it’s not to be subject to the more-stringent rules of general hazardous waste disposal. 

Some other considerations:

  • Containers of spent batteries must be labeled “Universal Waste—Batteries.”
  • Containers of defunct mercury products must be marked “Universal Waste” followed by what it is. For example: “Universal Waste—Mercury Thermostats” or “Universal Waste—Mercury Thermometers.”
  • Pesticides must be labeled “Universal Waste—Pesticide,” and tanks or containers holding recalled pesticides must be marked with the original FIFRA label, as if they were still sellable.

Again—it’s important to get expert advice.

Packaging rules for universal wastes

Unwanted pesticides, batteries, and mercury-containing products must be stored in containers that show no evidence of leakage or spillage—or damage that could cause leakage. More specifically:

  • Pesticide universal waste can be stored in non-original containers provided that such containers remain closed. 
  • Battery universal waste must be stored in closed containers that are compatible with the batteries constituent chemicals. 
  • Unwanted mercury-containing products such as thermostats and barometers should be placed in closed, sturdy containers and marked “Universal Waste—MCE” (where MCE stands for “mercury-containing equipment”).
  • Aerosol cans that are damaged or leaking may be handled as universal waste as long as they’re packaged in a separate closed container, overpacked with absorbents, or immediately punctured & drained in accordance with EPA drainage requirements.

Disposal rules for universal wastes

Okay—not to belabor the point—but bear in mind that a universal waste is nonetheless a hazardous waste. So it cannot be disposed of in the trash and consequently wind up in landfills. 

Instead, universal waste must go into one of those afore-mentioned “destination facilities,” which are entities designated to treat and dispose of universal waste—and manage it in accordance with the requirements and conditions of their hazardous waste facility permit.

Two examples of destination facilities are hazardous waste landfills and hazardous waste recycling facilities. 

But you just can’t throw your universal waste into the back of your F-150 and take it to a destination facility. Instead, you need to employ the services of another kind of universal waste handler: one that specializes in collecting, storing, receiving, and shipping universal wastes.

As were apt to say: it’s crucial to get expert advice.

The Upshot

Hazardous Waste Experts offers you decades of nationwide experience helping industries and organizations dispose of all kinds of universal waste—safely and conveniently. Depend on us for custom, sustainable solutions built on best practices for its handling, both onsite and offsite. 

Contact us today. And thank you for reading our blog!

Disposal of hazardous waste doesn’t have to be painful.