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Are You Properly Managing Your Universal Waste?

The Massachusetts Department of Environmental Protection (MA DEP) has specific requirements for the collection and management of universal waste. These requirements can be found in 310 CMR 30.1000, the Standards for Universal Waste Management.

What is Universal waste? Universal waste includes:

  • Hazardous batteries (e.g., nickel cadmium, button batteries); note that alkaline batteries are not considered universal waste, but can still be collected for disposal through the waste ​​hauler or a battery recycling vendor
  • Mercury-containing devices such as thermostats, thermometers, and gauges
  • Mercury-containing lamps such as fluorescent lamps and bulbs
  • Hazardous pesticides

When collecting universal waste, it’s important to dedicate a universal waste accumulation area that is clearly segregated and signed.  If the universal waste accumulation area and main accumulation area for hazardous waste are located within the same room, be sure to clearly define and sign the areas as separate accumulation areas.

All universal waste containers must be labeled with the contents and the words universal waste (e.g., Universal Waste- Mercury Thermostat).  Containers, or individual universal waste items not in containers, must be labeled with the date that accumulation began, and must be disposed of within one year from the date the waste was generated.  Universal waste must also be managed in a way that prevents releases of any universal waste or component of a universal waste to the environment.

Additional handling requirements depend on the type of universal waste and are described in 310 CMR 30.1034. 310 CMR 30.1034, Waste Management. For instance, thermostat mercury-containing ampoules may be removed from thermostats over or in a container to assure that any broken ampoules that may result in spills or leaks are contained immediately and removed ampoules can then be disposed of as a hazardous waste.

There are also specific training requirements related to universal waste. All employees who handle or have responsibility for managing universal waste must be trained on proper handling and emergency procedures appropriate to the type(s) of universal waste handled at the facility.

For additional information on universal waste or for assistance with reviewing your facility’s universal waste management practices, please contact info@safetypartnersinc.com.

This blog was written by Beth Graham, our Associate Director of Quality, Research, and Training who has been with Safety Partners for the last 11 years.

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