Managing Hazardous Waste Properly: Universal Waste Labels

Posted by author Richard Espinoza on Tue, Nov 28, 2017

When an organization generates an excessive amount of hazardous waste from its operations, it must follow strict state and federal waste management guidelines.

These guidelines include employee training, time and quantity limits on waste accumulation, storage containers, and proper hazardous waste labels. In order to ease the regulatory burden on hazardous waste generators, one category of waste, universal waste, is allowed simplified management processes. This category encompasses materials which are hazardous but are very commonly used.


Examples of universal waste


universal-waste-labelsBatteries: Included are sealed lead acid, nickel‐cadmium, lithium ion, mercuric oxide, silver oxide, and other alkaline batteries. This does not include low- or non‐mercury containing alkaline and carbon zinc batteries.

Mercury-containing equipment: Including devices that contain elemental mercury such as thermometers and thermostats and electrical switches and relays.

Lamps: These include electric lamps (or light bulbs) including fluorescent, high-intensity discharge, neon, mercury vapor, high-pressure sodium, and metal halide lamps. While newer light bulbs may be managed as nonhazardous solid waste, their identification as such must be supported with documentation.

Pesticides: May include pesticides that are being recalled or are part of a managed collection program.

In addition to the above, states may set aside other items, such as electronics or aerosol cans) as universal waste.


Proper Management


In order to take advantage of the relaxed restrictions, universal waste generators should follow proper management guidelines. These require that generators ensure that storage prevents releases to the environment, that they are prepared to handle an accidental release, and that there is a plan in place to transport the waste to a permitted facility. Before transport, however,  storing and labeling the waste is critical both for identification and for recordkeeping.


Universal Waste Labels


Not only does documenting the waste's identity prepare others for safe handling but it also works to exclude it from being subjected to the more stringent hazardous waste generation restrictions. Using labels allows generators to keep track of what’s been accumulated so that they do not violate any of the restrictions.

Universal waste labels can be attached to both the item and the container. The container’s label should convey the type of universal waste that it holds, and only that particular type of waste should be added to the container. They must be labeled as follows:

  • Batteries: "Universal Waste Batteries" or "Waste Batteries" or "Used Batteries"
  • Mercury-Containing Equipment:  “Universal Waste – Mercury-Containing Equipment”, “Waste Mercury-Containing Equipment”, or “Used Mercury-Containing Equipment”
  • Lamps:    “Universal Waste—Lamps,” or “Waste Lamps,” or “Used Lamps”
  • Pesticides
    • Universal Waste Canceled Pesticides: "Universal Waste - Pesticide(s)" or "Waste - Pesticide(s)"
    • Universal Waste Recalled Pesticides: Original Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) label that would be required under FIFRA if the pesticide were a product.

Universal waste must not be stored for more than one year, so the label should demonstrate the length of time it has been accumulating. The container's label should include the earliest date that waste was added to it, and the item's label should log when it became wast.  Following these simple labeling criteria documents compliance and shows waste management responsibility.


Free Hazardous Waste Labels