Universal Waste

Summary

How to identify, collect, store, and manage universal waste.

Who is this for?

Building and operations management.
Lab and research staff.

Managing universal waste

Universal waste includes:

Fluorescent and compact fluorescence light bulbs.
Hazardous batteries, including nickel cadmium (NiCd), lithium, and mercury-containing button batteries.
Mercury-containing devices, including switches and fluorescent lamps.
Thermostats.

You must use alternate means to recycle lead acid batteries. Contact EHS to learn about recycling options.

You do not need to follow hazardous waste disposal requirements if you properly collect, store, and recycle universal waste.

Storing waste

Collect and store these waste materials in universal waste storage areas:

Batteries.
Fluorescent and compact fluorescence light bulbs.
Thermostats.

To collect and store universal waste:

Designate a universal waste storage area.
Post a universal waste accumulation area poster.
Use appropriate containers to collect and store universal waste:
- Use containers and boxes in good condition and keep them closed.
- Store non-leaking batteries, unbroken mercury-containing devices, and intact fluorescent lamps in a secure drum or box.
- Consider storing universal waste on pallets that allow for secondary containment.
Label all containers with a Harvard universal waste label. Include the specific name of the waste materials and the date you began storing the materials.

You can store universal waste onsite for up to one year.

Contact EHS or Recycling and Waste Management to request universal waste labels.

Waste disposal

If your facility or department has a contract in place, contact Recycling and Waste Management to schedule a universal waste pickup.

Otherwise, contact EHS or a recycling vendor.

Disposal records

Recycling and Waste Management has shipment logs for contracted universal waste pickups.

If you use a recycling vendor, you must maintain shipment records that include the quantities of universal waste removed from your facility. You must keep shipment records for at least three years.

Enforcement penalties can result in fines of up to $25,000 per day for each violation.