Universal Waste

 Universal waste is a subset of hazardous waste that includes batteries, lamps (bulbs), mercury-containing devices,  certain pesticides and aerosol cans. Universal wastes may contain mercury, lead, cadmium, copper and other substances hazardous to human and environmental health.

EPA developed streamlined management requirements to encourage the collection and recycling of these commonly generated hazardous wastes. Managing qualifying hazardous wastes as universal waste is optional. Generators have the choice to manage hazardous wastes that fit into the categories of universal waste as universal wastes or under the complete hazardous waste requirements.

Categories of Universal Waste 

The applicability of the universal waste requirements to each category of waste described below can be found here. Universal wastes that are mixed with hazardous wastes are fully regulated as hazardous wastes.

Mercury-Containing Equipment: Devices that contain elemental mercury integral to their function, including thermostats, but does not include batteries or lamps.

Pesticides: Substances that are intended for preventing or mitigating pests or intended for use as a plant regulator or defoliant. Excludes animal drugs and animal feed containing animal drugs.

Batteries: Devices consisting of one or more electrically connected electrochemical cells designed to receive, store and deliver electric energy. Includes nickel cadmium batteries and lead acid batteries.

Lamps: Bulbs or the tube portion of electric lighting devices that are specifically designed to produce radiant energy. Includes mercury vapor lamps, fluorescent light bulbs, and neon lights, as well as other types of bulbs.

Aerosol Cans: Non-refillable receptacle containing a gas compressed, liquefied or dissolved under pressure, the sole purpose of which is to expel a liquid, paste, or powder and fitted with a self-closing release device allowing the contents to be ejected by the gas.

Universal Waste Lamp Crushing for Size Reduction

DEQ allows the use of lamp crushing devices meeting certain standards of operation under the DEQ universal waste regulations. The specific requirements for applicability, management and use of lamp crushing devices can be found at the VHWMR universal waste requirements and  additional VHWMR universal waste requirements. Additional information regarding lamp crushing in Virginia can be found in DEQ’s Universal Waste Mercury-Containing Lamp Crushing Guidance.

Management of Universal Waste 

The universal waste regulations were developed to encourage the recycling of these hazardous wastes, to improve the management in order to reduce the amount of hazardous waste that ends up in solid waste landfills and combustors, and to ease the regulatory burden on the facilities that manage these wastes by allowing more time for accumulation in order to facilitate appropriate recycling or disposal and to ensure that these wastes go to appropriate treatment or recycling facilities.

Advantages:

• Universal waste volume is not included when determining hazardous waste generator status
• Universal waste can be accumulated for up to one year
• Less labeling is required on universal waste containers
• A hazardous waste manifest is not required to accompany a universal waste shipment in Virginia or within any other state that recognizes it as universal waste
• Less recordkeeping is required
• A shipment of universal waste can be transported via a universal waste transporter rather than a hazardous waste transporter

Waste Specific Management Requirements

Each type of universal waste has specific management requirements designed to prevent releases to the environment that handlers must comply with. These standards can be found here for Small Quantity Handlers of Universal Waste (SQHUWs) and here for Large Quantity Handler of Universal Waste (LQHUWs) Additionally, these sections discuss those activities that universal waste handlers can perform under the universal waste regulations such as ampule removal from mercury containing equipment, mixing or discharging batteries, puncturing and draining aerosol cans, and what standards they have to follow in order to do them.

Solar Panels

Currently solar panels are not a federal universal waste, so generators in Virginia cannot manage them as universal waste. However, EPA received a petition to add solar panels as a federal universal waste and has initiated a proposed rulemaking effort to add solar panels as a federal universal waste. More information will  be added to this website if any new rules are adopted regarding solar panels. Unless and until solar panels become a universal waste, It is a waste generator’s responsibility to determine if their solid waste is a listed or characteristic hazardous waste, either through analysis or through generator knowledge of the waste. There are numerous types and designs of solar panels in circulation, making a one-size-fits-all hazardous waste determination difficult.  Solar panels can be hazardous waste when discarded if a representative sample of the waste contains heavy metals, such as arsenic, cadmium, chromium, lead or selenium, at concentrations above the toxicity characteristic.  The solar panel manufacturer may be able to assist the generator with information relevant to the hazardous waste determination and recycling options.

If solar panels are dismantled, sorted, and each component is managed separately, any components that meet the definition of hazardous waste must be managed in accordance with the Virginia Hazardous Waste Management Regulations, and sent to a RCRA recycling facility or permitted RCRA Treatment, Storage, and/or Disposal (TSD) facility.** Any components that meet the definition of Universal Waste, such as batteries, can be managed in accordance with the Universal Waste requirements. Glass, copper wire and aluminum framing from the solar panel, if found to be non-hazardous, can be taken to a solid waste landfill or recycling center for reclamation.

Solar panels generated by households are exempt from the Virginia Hazardous Waste Management Regulations (VHWMR) per 40 CFR §261.4(b)(1). Homeowners should contact their locality or trash hauler directly to determine whether solar panels are accepted for disposal or if any recycling opportunities exist.

For more information, see Solar Panel Frequently Asked Questions