Universal Wastes, May 2012

Download Available: Universal Wastes

Reportedly, a porter at an automobile dealership tried to dispose 150 lamps at a household recycling center.  The recycling facility, meant for households wastes, declined the shipment and then cited the facility for improper disposal of fluorescent lamps (a Universal Waste).  In 2001, US EPA made changes to waste rules applying to spent mercury-containing light bulbs that would require recycling of these lamps and prohibit landfill disposal.  On the national level, exemption was created for businesses that generate a combination of hazardous wastes (RCRA wastes) and universal wastes in an amount of less than 100 kilograms a month.  California has enacted regulations that require all facilities, without any exemptions, to recycle Universal Wastes.  In Arizona, the state exempts dealers generating less than 100kg/month of RCRA and Universal Wastes under the federal regulations but the ADEQ strongly encourages the generators, to recycle the fluorescent lamps.



Electronic devices: Includes any electronic device that is a hazardous waste (with or

without a Cathode Ray Tube (CRT)), including televisions, computer monitors, cell

phones, VCRs, computer CPUs and portable DVD players.

Batteries: Most household-type batteries, including rechargeable nickel-cadmium

batteries, silver button batteries, mercury batteries, alkaline batteries and other batteries

that exhibit a characteristic of a hazardous waste

Electric lamps: Fluorescent tubes and bulbs, high intensity discharge lamps, sodium

vapor lamps and electric lamps that contain added mercury, as well as any other lamp that

exhibits a characteristic of a hazardous waste. (e.g., lead).

Mercury-containing equipment: Thermostats, mercury switches, mercury thermometers,

pressure or vacuum gauges, dilators and weighted tubing, mercury rubber flooring,

mercury gas flow regulators, dental amalgams, counterweights, dampers and mercury

added novelties such as jewelry, ornaments and footwear.

CRTs: The glass picture tubes removed from devices such as televisions and computer

monitors. A cathode ray tube that has been accidently broken or processed for

Non-empty aerosol cans



  • Do not dispose of universal waste or treat universal waste except as provided for in the regulations
  • Use proper containment—non-leaking, compatible containers
  • Segregate universal waste in distinct areas
  • Determine if materials generated when handling/recycling are hazardous wastes
  • Comply with applicable requirements for hazardous waste
  • If applicable, comply with zoning requirements when storing universal wastes
  • Have spill kits readily available to deal with accidental spills (mercury-containing devices)
  • Accumulate universal waste no longer than one year
  • Provide personnel training to personnel who manage universal waste, or who supervise personnel who manage universal waste and keep training records



  • Respond to releases of universal waste or its contents; determine if spill residuals are hazardous waste

CESQUWG are not required to comply with following requirements:

  • Use proper labeling and markings..
  • Notify DTSC and/or obtain an EPA identification number.
  • Track shipments by keeping records of what was received and shipped (name, address, quantities) for three years

CESQUWG (Conditionally Exempt Small Quantity Universal Waste Generator): A generator who generates less than 220 pounds/month of RCRA hazardous waste.  Auto dealers that generate more than 220lb/month of waste thinner lose the CESQUWG status.


Recycling or Disposal:  The dealership should contact a hauler and have the waste shipped to one of the recycling facilities. The hauler can provide the dealership with an appropriate container that is properly labeled.  Some recycling facilities for lamps are as follows:

  • Lighting Resources, Ontario, CA (909) 923-7252. lightingresourcesinc.com.
  • AERC Recycling, Hayward, CA (510) 429-1129. aercrecycling.com
  • Onyx Environmental, Azusa, CA (800) 556-5267. (actual recycling facility is in Arizona)
  • Lighting Resources, Inc. Phoenix, AZ 85040 (602) 276-4278
  • Waste Management Lamp Tracker, Phoenix, AZ 85063 (800) 414-0443
  • Veolia Environmental Services Phoenix, AZ 85043 (800) 368-9095


There are other facilities all over the US that can provide containers for storing used lamps that can later be shipped to remote location for recycling.  See http://www.lamprecycle.org, www.almr.org and www.nema.org.




Storage:  Generally, the container must be closed, structurally sound, compatible, and lacking evidence of leakage, spillage, or damage.  Fluorescent lamps are fragile so this would require special containers that prevent breakage or spillage.  Store non-automotive type batteries in plastic bucket.

Labeling:  The labeling requirements are quite simple, i.e., label “Universal Waste-Used Lamps” or “Universal Waste-Batteries” as other wastes appropriate.

Time Limitations:  Waste can be stored on-site for one year.  The dealership must be able to prove that the lamps have not been stored for more than one year. Put “Start Date_______” as well on container.

Training:  Employees needs to be trained for handling and disposal.  The training memo on managing waste mercury lamps covers the training requirements for handling fluorescent lamps is being sent to clients by mail.

Documentation:  Haulers disposing lamps are not required to have any special license or permits.  Disposal documents in the form of Bill of Lading or other shipping documents are to be retained on site for a period of three years.  The document that must list the record may take the form of a log, invoice, manifest, bill of lading, or other shipping document. The record for each shipment of universal waste shall include information as follows:

(1)     The name and address of the dealership and the destination facility

(2)     The quantity of each type of universal waste received (e.g., batteries, thermostats, lamps, mercury switches, etc.)

(3)     The date of receipt of the shipment of universal waste.

CSI recommends that the dealership also obtain some form of written assurance from the hauler that state that the waste was indeed delivered to one of the recycling facilities as listed above.  It is prudent to obtain Pollution Liability Insurance and General Liability Insurance documentation from the hauler as well.


Mailing Box Programs:  Many recycling facilities use mail-in boxes to collect waste mercury lamps. The recycler sells the box at a fixed price, which includes shipping costs. The customer fills the box with waste lamps and ships it back to the recycler.  Shipping paper is your proof of disposal.


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