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Universal Waste Management for Facility Staff

For facility staff who handle spent lamps, batteries, aerosol cans, mercury equipment and waste pesticides: recognize universal waste, contain it, label it, date it, and respond to breaks and leaks.

Based on EPA 40 CFR Part 273, Subparts A and B, with 273.32 and 273.36 (Standards for universal waste management) · about 6 min read

Need proof of training? The full course (20 min) adds practice questions, a job scenario, the final quiz and a certificate your employer can verify.

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What is universal waste?

Five types, and when they become waste

Universal waste is a set of common hazardous wastes that EPA lets you manage under a simpler set of rules instead of the full hazardous waste rules. There are five types:

BatteriesSpent batteries that are hazardous waste.

LampsThe bulb or tube of a light, for example fluorescent, high intensity discharge, neon, mercury vapor, high pressure sodium and metal halide lamps.

Mercury-containing equipmentDevices with elemental mercury integral to their function, such as thermostats (batteries and lamps are their own types).

Aerosol cansWaste aerosol cans that are hazardous waste. Cans that meet EPA's standard for empty containers are not covered.

PesticidesCertain recalled pesticides, and unused pesticides collected and managed in a waste pesticide collection program.

When does it become waste?

A used lamp becomes a waste on the date it is discarded. An unused lamp becomes a waste on the date the handler decides to discard it. The same rule applies to batteries, mercury-containing equipment and aerosol cans (a used battery is discarded, for example, when it is sent for reclamation).

Each type is covered only if it is a hazardous waste; your environmental coordinator decides which of your site's items qualify.

Reference: 40 CFR 273.9 "Universal waste" · 40 CFR 273.1(b) · 40 CFR 273.5(c) · 40 CFR 273.2(c) · 40 CFR 273.6(b)(3) · 40 CFR 273.5(b)(2) · 40 CFR 273.3(a) · 40 CFR 273.4(c) · 40 CFR 273.6(c) · 40 CFR 273.9 "Lamp" · 40 CFR 273.9 "Mercury-containing equipment" · 40 CFR 273.4(c)(2) · 40 CFR 273.6(c)(2)

What is universal waste?

Small and large quantity handlers

A facility that generates universal waste is a universal waste handler. Its category depends on how much it holds at one time, counting all five types together:

Small quantity handlerDoes not accumulate 5,000 kilograms or more of universal waste at any time. Not required to notify EPA.

Large quantity handlerAccumulates 5,000 kilograms or more total at any time. Must notify EPA and get an EPA Identification Number before reaching that limit (unless it already has one), and follows extra rules.

Most of this course describes the small quantity handler rules in Subpart B of Part 273. Large quantity handlers follow parallel rules in Subpart C.

Reference: 40 CFR 273.9 "Small quantity handler of universal waste" · 40 CFR 273.9 "Large quantity handler of universal waste" · 40 CFR 273.12 · 40 CFR 273.32(a)(1) · 40 CFR 273.32(a)(2) · 40 CFR 273.9 "Universal waste handler" · 40 CFR 273.10 · 40 CFR 273.30

Contain it, do not dispose of it

No disposal, no dilution, no treatment

A small quantity handler is prohibited from disposing of universal waste. That means a spent lamp, battery or aerosol can does not go in the dumpster.

It is also prohibited from diluting or treating universal waste, except when responding to a release, or for the specific activities the rules allow (such as sorting batteries or puncturing aerosol cans with the right equipment and procedures).

Universal waste may only be sent or taken to another universal waste handler, a destination facility, or a foreign destination.

Your part: never crush or break lamps or break open battery cells. Part 273 lists no lamp-crushing activity for a small quantity handler, and it allows battery activities only as long as the casing of each individual battery cell is not breached and remains intact and closed. Puncture aerosol cans only if your site uses a device specifically designed to safely puncture aerosol cans, follows a written procedure for it, and has trained you in that procedure.

Reference: 40 CFR 273.11(a) · 40 CFR 273.11(b) · 40 CFR 273.18(a) · 40 CFR 273.13(a)(2) · 40 CFR 273.13(a)(2)(i) · 40 CFR 273.13(e)(4)(i) · 40 CFR 273.13(e)(4)(ii)

Contain it, do not dispose of it

Containers for each type

All universal waste must be managed in a way that prevents releases to the environment. What the container must do depends on the type:

Lamps: any lamp goes in a container or package that is structurally sound, adequate to prevent breakage, compatible with the lamps, and kept closed, with no sign of leakage, spillage or damage.
Batteries: any battery that shows leakage, spillage or damage that could cause leakage goes in a container that is closed, structurally sound and compatible with the battery's contents.
Aerosol cans: collected in a container that is structurally sound, compatible, without leakage or damage, and protected from sources of heat.
Mercury-containing equipment: any device with loose mercury, or that shows leakage or damage, goes in a closed container designed to keep mercury from escaping.
Pesticides: in a closed, structurally sound, compatible container with no leakage (or overpacked in one), or in an allowed tank or transport vehicle.

Reference: 40 CFR 273.13(d)(1) · 40 CFR 273.13(a)(1) · 40 CFR 273.13(e)(1) · 40 CFR 273.13(c)(1) · 40 CFR 273.13(b)(1) · 40 CFR 273.13(d) · 40 CFR 273.13(b)(2) · 40 CFR 273.13(b)(3) · 40 CFR 273.13(b)(4)

Label and date it

One year, and you must be able to show it

A small quantity handler may accumulate universal waste for no longer than one year from the date it is generated or received from another handler. Longer is allowed only if it is solely to gather enough for proper recovery, treatment or disposal, and the handler bears the burden of proving that.

The handler must be able to demonstrate how long the waste has been accumulated. Ways to do that include:

Marking the container with the earliest date any waste in it became a waste or was received
Marking each item (for example, each battery or thermostat) with its date
Keeping an on-site inventory system that identifies the dates
Using a specific accumulation area and identifying the earliest date for the area
Any other method that clearly shows the length of time

Your part: when you put the first spent lamp in a new box, date the box the way your site's procedure says.

Reference: 40 CFR 273.15(a) · 40 CFR 273.15(b) · 40 CFR 273.15(c) · 40 CFR 273.15(c)(1) · 40 CFR 273.15(c)(2) · 40 CFR 273.15(c)(5) · 40 CFR 273.15(c)(3) · 40 CFR 273.15(c)(6)

Breaks, leaks and training

When a lamp breaks or a battery leaks

All releases of universal waste and its residues must be contained immediately.
A broken lamp must be immediately cleaned up and placed in a container. A lamp that shows breakage, leakage or damage that could release mercury also goes in a container.
A leaking aerosol can must be packaged in a separate closed container or overpacked with absorbents (or punctured and drained under the allowed procedure).
Material from a release, such as cleanup residue, must be checked to see if it is hazardous waste; if it is, it is managed under the full hazardous waste rules.

Training

A small quantity handler must inform all employees who handle or are responsible for universal waste about proper handling and emergency procedures for the types handled at the facility. (Large quantity handlers must ensure employees are thoroughly familiar with them.)

Your part: know where the cleanup supplies and spare containers are kept, and tell your coordinator about any release.

Reference: 40 CFR 273.17(a) · 40 CFR 273.17(b) · 40 CFR 273.13(d)(2) · 40 CFR 273.13(e)(2) · 40 CFR 273.16 · 40 CFR 273.36

Need proof of training? The full course (20 min) adds practice questions, a job scenario, the final quiz and a certificate your employer can verify.

Take the course

Sources

40 CFR 273

Fact-checked against the regulation text on October 09, 2026. This certificate records completion of awareness training based on EPA 40 CFR 273.1 through 273.6, 273.9, 273.11 through 273.17, 273.18(a), 273.32(a) and 273.36. It is not an OSHA card or license or an EPA or state certification, and it does not by itself meet the training requirements of 40 CFR 273.16 (small quantity handlers) or 40 CFR 273.36 (large quantity handlers). A small quantity handler must still inform all employees who handle or have responsibility for managing universal waste, with information that describes proper handling and emergency procedures appropriate to the type(s) of universal waste handled at the facility. A large quantity handler must still ensure that all employees are thoroughly familiar with proper waste handling and emergency procedures, relative to their responsibilities during normal facility operations and emergencies. Where the site punctures and drains aerosol cans, employees operating the device must also be trained in the proper procedures (40 CFR 273.13(e)(4)(ii)).

This guide explains the rule in plain words. Always read the regulation itself and your employer's site-specific procedures.