Kevin Ian Schmidt

Universal Waste Management Policy

The universal waste regulations at 40 CFR 273 are less burdensome alternatives to the RCRA requirements of 40 CFR 260–270 that apply to regular hazardous waste. Part of US EPA’s reason for creating universal waste rules was that small and conditionally exempt (now called “very small”) generators create a high volume of universal waste.

Without the less burdensome alternative management standards, small businesses and facilities that generate only relatively low-hazard wastes like batteries and lamps may face an undue burden.


The federal universal waste regulations are found in Title 40 of the Code of Federal Regulations (CFR) in part 273

4 Types of Federal Universal Waste

  • Batteries
  • Pesticides
  • Mercury-Containing Equipment
  • Lamps

State Environmental Protection Agencies have their own rules and regulations pertaining to universal waste, so ensure your Universal waste program is compliant with your state’s regulations as well. They can be found here.

Who is impacted by the universal waste regulations?

Some generators that commonly use or manage hazardous wastes that are affected by universal waste regulations include:

  • Commercial and industrial businesses and other entities such as hospitals,
  • schools and universities,
  • state and local governments, as well as
  • other generators of hazardous wastes considered to be universal waste.
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What are the general requirements for small and large quantity handlers of universal waste?

Regulatory requirements differ for small and large quantity handlers of universal waste, but in both cases, handlers of universal waste follow streamlined requirements for

  • notifying EPA about their waste activities,
  • labeling containers,
  • storing materials on site,
  • training personnel and
  • tracking and transporting waste.

What are the employee training requirements for universal waste handlers?

Universal waste handlers are required to comply with the employee training requirements of 40 CFR Part 273 although states may have more stringent requirements. Small quantity handlers of universal waste must inform all employees that handle or have responsibilities for managing universal waste. This information must include the proper handling and emergency procedures appropriate to the type of universal waste managed at the facility (40 CFR Section 273.16).

Download & view the Universal Waste Management Policy below

Universal Waste Management Policy


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