Universal Waste

MoDNR Topics

Universal Waste

From the archives of the Enforcement and Compliance Listserv for Hazardous Waste Generators

May 31, 2007

Labeling or Marking Universal Waste

As with satellite containers, universal waste also has labeling options.

For mercury switches, in Missouri the label should read "Universal
Waste-Mercury Switch(es)", or "Waste Mercury Switch(es)" or "Used Mercury
Switch(es)";
For batteries, the label should read "Universal Waste-Battery(ies)", or
"Waste Battery(ies)" or "Used Battery(ies)";
For thermostats, the label should read "Universal Waste-Mercury
Thermostat(s)", or "Waste Mercury Thermostat(s)" or "Used Mercury
Thermostat(s)";
For lamps, the label should read "Universal Waste-Lamp(s)", or "Waste
Lamp(s)" or "Used Mercury Lamp(s)";
For pesticides, the label should read "Universal Waste-Pesticide(s)", or
"Waste Pesticide(s)".

Remember, hazardous waste pesticides may only be managed as a universal
waste as long as they are sent to a Missouri approved universal waste
pesticide collection program, to a Certified Resource Recovery Facility,
or to a Universal Waste Destination Facility.

Dec. 4, 2006

Fluorescent Bulbs

Almost every business generates some type of fluorescent bulb. Most fluorescent bulbs contain mercury vapor that, when released, is dangerous to inhale. So, how must businesses handle their fluorescent bulbs? Businesses have two options, they can manage the bulbs as a universal waste or as a hazardous waste. Most businesses choose to manage their bulbs as a universal waste because the universal waste laws are less stringent. To review the advantages of managing your bulbs as a universal waste, see our listserv topic below.

Some companies offer devices for on-site bulb crushing, however, use of such devices is not allowed in Missouri. The U.S. Environmental Protection Agency recently released a study entitled "Mercury Lamp Drum-Top Crusher Study." In summary, the EPA discovered that even properly working bulb crushing machines release some mercury, and if the drum is poorly designed, mercury levels above the Occupational Health and Safety Administration's Permissible Exposure Limits may occur. Visit the US EPA document entitled "Mercury Lamp Drum-Top Crusher Study" to learn more. For more information on properly managing your waste fluorescent bulbs and a list of bulb recyclers, visit Fluorescent Bulbs.

July 5, 2006

What is Universal Waste? Universal wastes are specific types of hazardous waste that are defined in Missouri's Universal Waste Regulations (see 10 CSR 25-16.273). Another way to think of it is that hazardous waste is the broad category and universal waste is a special subset of that broad category. Universal waste is typically items that are common, widespread, and exhibit only a low level hazard or can be easily managed. In Missouri, universal waste includes batteries, pesticides, thermostats, and hazardous lamps (fluorescent, metal-halide, High-Intensity-Discharge, and mercury containing lamps). For more specific information, please review our Universal Waste Rule in Missouri PDF technical bulletin -- PUB2058. The U.S. Environmental Protection Agency, recognizing the difficulty associated with following hazardous waste regulations for such common items, developed the universal waste rules. Universal waste rules allow businesses to manage universal waste in a less-stringent manner, yet still protects workers and the environment from exposure to that hazardous waste. Some of the advantages to managing your qualifying waste as a universal waste include:

you may accumulate universal wastes on-site for one year;
you may self-transport universal waste to an authorized destination facility or Missouri Certified Resource Recovery if you meet universal waste transporter requirements;
small quantity universal waste handlers (less than 11,000 pounds at any one time) need not keep records of universal waste received or shipped, large quantity universal waste handlers do have some record keeping requirements;
the transporter, rather than the universal waste handler, can prepare the shipping papers;
hazardous waste generator fees do not apply to universal waste;
no quarterly or annual reporting to the Missouri Department of Natural Resources is required;
universal waste is counted separately from your total hazardous waste generated, thus universal waste does not increase your hazardous waste generator status.

For information about fluorescent lamps and recyclers, please visit our Fluorescent Bulbs page.

If you would like to unsubscribe to the e-newsletter, please visit MoDNR Enforcement and Compliance Assistance Newsletter Generators Subscription. If you know of anyone else who would like to be added to this listserv, they can visit MoDNR Enforcement and Compliance Assistance Newsletter Generators Subscription to sign up.

If you need further assistance, please e-mail or contact the Department of Natural Resources' Hazardous Waste Program at 573-751-2032 or 800-361-4827.

Return to listserv topics at MoDNR Hazardous Waste Generator Archive.