1. Universal Waste Management Training
The Texas A&M University System
Environmental, Health & Safety

2. In this training, you will learn:
Training Objectives
In this training, you will learn:
What is a Universal Waste
Universal Waste management requirements
Steps for responding to a spill or breakage
Where to go for more information

3. What is a Universal Waste?
A special subset of hazardous waste, including:
Batteries
Lamps
Pesticides
Mercury-Containing Equipment
Paint & Paint-Related Wastes (Texas)
Termed “universal wastes” by EPA because these hazardous wastes are generated in a wide variety of settings by a vast community
Pesticide

4. Rules for “Universal Waste Handlers”
(Differ from RCRA Hazardous Waste Generator Rules)
Small Quantity Handler of Universal Waste (SQHUW)
< 5000 kg or 11, 000 lbs accumulated at any one time
One year accumulation limit
Inform employees about universal waste
Send universal waste to handler, or designated TSD
Containers labeled, dated, closed and compatible
Clean up spills
Keep shipping records for 3 years (recommended)
Large Quantity Handler of Universal Waste (LQHUW)
> 5000 kg or 11, 000 lbs accumulated at any one time
One year accumulation limit
Train employees about univer. waste & emergencies
Send universal waste to handler, or designated TSD
Containers labeled, dated, closed and compatible
Clean up spills
Keep shipping records for 3 years (required)
Notify as LQHUW and obtain EPA ID number

5. Rules for “Universal Waste Handlers”
Small Quantity Handler of Universal Waste (SQHUW)
< 5000 kg or 11, 000 lbs accumulated at any one time
One year accumulation limit
Inform employees about universal waste
Send universal waste to handler, or designated TSD
Containers labeled, dated, closed and compatible
Clean up spills
Keep shipping records for 3 years (recommended)
Universities and agencies should easily stay below the 11,000 lb limit
Possible exceptions:
Major re-lampings
Building demolitions
Challenges
Tracking wastes scattered among many locations
Keeping track of the 1 yr time limit

6. What is a Universal Waste - Batteries -
Many types must be
managed as Universal Wastes,
including those that contain:
Lead Acid Batteries (e.g. car batteries) may be taken or shipped to a facility for regeneration or managed as UW
Common consumer batteries, including alkaline (AA, AAA, C, D, 9 volt), lithium batteries, and nickel-metal hydride batteries
(These types are non-hazardous and may be discarded with solid waste (trash) without special requirements.)
Nickel & Cadmium (e.g. NiCad)
Mercury (e.g. Hg or Ag Oxide)
(i.e., most rechargeable batteries)
Exceptions

7. Look for the Recycling Seal

8. Look for the seal CAUTION FIRE DANGER
Recycle Rechargeable Batteries and Cell Phones
Look for the seal
CAUTION
Bag all batteries, one per bag, and place in box.
FIRE DANGER
if battery terminals touch!

9. Rechargeable Battery Recycling

10. How to Recycle Rechargeable Batteries & Cell Phones
Step 1 – Place battery or cell phone in its own plastic bag (to prevent fire) and put it in the box
Step 2 – Periodically police box for foreign objects
Step 3 – When box is full, fold down and seal flap
Step 4 – Ship box (UPS prepaid) to RBRC, who will replenish your boxes

11. Example Battery Recycling Poster from Tarleton State University

12. What is a Universal Waste - Lamp(s) -
Contain leachable amounts of toxic components (e.g. mercury or lead) that fail the EPA’s TCLP test.
Examples: Fluorescent, Halogen, Metal Halide, High or Low Pressure Sodium, Mercury Vapor, Incandescent
Not “green” lamps (e.g., Phillips AltoTM, GE EcoluxTM, or OSRAM SYLVANIA ECOLOGICTM) passing TCLP

13. What is a Universal Waste - Lamp(s) -
Fluorescent (Hg)
Halogen (Hg)
Metal Halide (Hg)
High/Low Pressure Sodium (Hg)
Mercury Vapor (Hg)
Incandescent (Pb)

14. What is Universal Waste -Mercury-Containing Equipment-
Contain the toxic component (Mercury)
Commonly recognized mercury-containing devices
Thermostats
Thermometers
Barometers
Manometers / sphygmomanometers
Flow meters
Mercury light switches
Mercury regulators
Pressure relief gauges
Water treatment gauges, and
Gas safety relays

15. What is Universal Waste -Mercury-Containing Equipment-
Thermostats may be handled and labeled separately as Universal Waste – Mercury Thermostats

16. What is a Universal Waste - Pesticide(s) -
The Universal Waste Regulations for pesticides are limited to
Recalled pesticides subject to FIFRA procedures, and
Unused pesticide products collected and managed as part of a waste pesticide collection program (e.g., for farmers).
Consult your Compliance Manager if you have pesticides which have been recalled or are no longer needed at your facility.

17. What is a Universal Waste - Paint & Paint Related Waste - (Texas Only)
May include:
Used or unused paint
Spent solvents used in painting
PPE from painting
Paint removal wastes
Paint filters
Only if the material is a characteristic hazardous waste (ignitable or toxic)
Does Not Include
Aqueous-based paint & paint-related wastes or otherwise non-hazardous wastes
If shipped out of Texas - must be manifested as hazardous waste
For more information:

18. Minimizing Universal Waste - Paint & Paint-Related Wastes
Choose the Right Paint
Minimize use of ignitable oil / petroleum-based paints.
Avoid using oil-based aerosol paints
Use Paint Wisely
Use it all, leaving little to waste
Use aerosol cans until empty, puncture and drain
For leftover paint, use it or give it away, don’t throw it away
Conserve Thinners
Reuse thinner until it becomes thick with paint residues
Consider disposable brushes to reduce thinner usage

19. UW Requirements - Accumulation-
Container Start Date: 12/05/08
Container Start Date: 10/17/08
Universal Waste - Lamps
- Lamps
04/23/08
07/14/08
Must have designated accumulation area(s) for
each Universal Waste Subset accumulated at your facility.
May designate with a sign or the
guidance sheet from Universal
Waste Management Plan
Designated area must be
out-of-the-way so as to prevent breakage or damage of Universal Waste(s)
Universal Waste
- Lamps -

20. Common Universal Waste Accumulation Areas
Satellite Locations
Custodial / housekeeping closets
Shops
Basements
Mechanical rooms
Near building manager offices
Central Accumulation
Adjacent to hazardous waste central accumulation area
Physical Plant Storage Building

21. UW Requirements - Containers -
Container Start Date: 12/05/08
Container Start Date: 10/17/08
Universal Waste - Lamps
- Lamps
04/23/08
07/14/08
Universal Waste
- Lamps -
Containers Must Be:
Labeled
Dated
Compatible
Kept closed
Able to reasonably prevent releases if internal contents are broken or leaking
Universal
Waste -
Batteries
12/05/00

22. UW Requirements - Labels -
Label must state:
Universal Waste – ********
Container Start Date: ____
Pesticides require the original manufacturers or other state approved label in addition to the Universal Waste Label
(Consult your Compliance Manager)
UNIVERSAL WASTE
BATTERIES
LAMPS
MERCURY-CONTAINING EQUIPMENT
PESTICIDES
PAINT & PAINT-RELATED WASTES
Container Start Date: ____________
TEXAS & FEDERAL LAW PROHIBIT IMPROPER DISPOSAL
THESE MATERIALS ARE REGULATED BY 40 CFR §273
AND 30 TAC § & 262
SHIPMENTS MUST COMPLY WITH APPLICABLE U.S. DOT REGULATIONS (49 CFR Parts 172 – 180)
HANDLE WITH CARE!
Example Label

23. Alternate Universal Waste Label
CONTENTS ________________________
NUMBER PER CONTAINER __________
CONTAINER START DATE ___________
SHIPPER ____________________
____________________

24. UW Requirements - Shipping of UW -
Must package, label, mark and placard the shipment in accordance with DOT regulations
Must use a qualified Universal Waste Transporter for transportation of Universal Wastes
Must ship to:
A Universal Waste Handler
A Universal Waste Destination Facility

25. UW Requirements - Recordkeeping and Notification -
Must keep shipping papers for three years
Must be able to prove annual accumulation quantities.
May use a tracking form (preferred), or
Maintain shipping papers
Prior to accumulating 11,000 lbs of Universal Waste at any time, you need to notify the EPA using EPA Form
(Consult your Compliance Manager for further information)

26. Responding to a Spill or Breakage
If conditions are deemed safe, immediately contain the release and overpack any leaking containers
Clean up released material
You may not place released material or broken, leaking items back into the container with Universal Waste -
A hazardous waste determination must be conducted on the released material.
If it is found to be hazardous it must be handled as a hazardous waste rather than as a universal waste.
Always use proper safety precautions

27. For Further UW Guidance
Universal Waste Management Plan
Compliance Manager
Gordon Evans, A&M System Environmental Manager, or
Jay Abbt & Daron White, PVAMU Environmental Health & Safety Dept
Texas Universal Waste Regulations
30 TAC § Universal Waste Rule
30 TAC § Standards for Management of Paint and Paint-Related Waste