Section 8: Universal Waste

New York State defines universal waste as hazardous waste such as batteries, pesticides, thermostats and lamps that are managed under the universal waste requirements of 6NYCRR  Subpart 374-3. The University currently utilizes the universal waste management requirements for lamps and batteries. Most pesticides and mercury switches from thermostats are managed as a hazardous waste, although all elemental mercury on campus is recycled.

Lamps/Bulbs (Fluorescent, Mercury Vapor, Metal Halide, High-Pressure Sodium, High Intensity Discharge, etc.)

Currently there is a fluorescent lamp disposal program for the correct disposal of fluorescent, metal halide and high-pressure sodium bulbs on campus.  The inside of a fluorescent, metal halide or high-pressure sodium tube is coated with chemicals and the tube contains a small amount of mercury vapor. All University fluorescent (including HID), metal halide and high-pressure sodium lamps must be collected and stored properly per the universal waste collection regulations listed in this Manual until pick up by EHSS. EHSS will manage the recycling of these lamps at a University approved recycling facility.

Mercury Thermostats

Mercury switches were frequently used in thermostats.  Elemental mercury from these devices can be recycled through the Universal Waste Program. Thermostats must be kept in-tact or the Department must contact EHSS to ensure that they follow all procedures necessary to manage thermostats in compliance with universal waste regulations. Mercury thermostats should be collected as a hazardous waste. EHSS manages thermostats through normal waste pickup procedures. Every effort must be made to minimize mercury waste mixtures.


Batteries contain hazardous components that must not be disposed of in the regular trash.  EHSS facilitates the battery collection program for the University.  Each department must use specially designed battery collection containers which are available through EHSS.

A battery collection container should be placed in a central location such as a department’s main office.  Contact EHSS (x-4132) for waste battery removal when the containers are full or for special pick-ups. Special pick-ups may include times when areas have large batteries, such as car batteries, or when a battery must be removed prior to disposing of a piece of equipment.


Refer to the University’s Pesticide Management Manual for detailed instruction on cleaning and disposing of pesticide containers and pesticide waste. The Pesticide Management Manual can be found on the EHSS website under Environmental Compliance.

Universal Waste Collection

  • All containers must be compatible with the waste and in good condition.
  • All containers must be stored closed except when adding or removing waste from the container.
  • All containers must be labeled with the words “Universal Waste” and the contents, such as fluorescent lamps, batteries, thermostats, etc.
  • All containers must be labeled with the start date. The date when the first item of waste is placed into the container.
  • Only University approved labels should be used for Universal Waste. These labels are provided by EHSS.
  • Universal waste may only be stored for one year from the start date. Please notify EHSS to remove any universal waste containers which have been stored for 8 months or longer.
  • Universal waste should be stored in a limited access area approved by EHSS.

Universal Waste Spills

Universal waste regulations state that if there is a release of a universal waste, it must be immediately contained. A release of universal waste and the resultant spill clean up material must be assessed and a hazardous waste determination made. If it is determined that the resultant clean up material is a hazardous waste, it must be placed in an appropriate container, labeled and stored as a hazardous waste. If the material is determined not to be a hazardous waste, it may be repackaged in an appropriate container and labeled as a universal waste.

Examples of materials which may be determined to be a hazardous waste, as the result of a spill of a universal waste include:  fluorescent lamps, lead acid batteries, mercury thermostats, high-pressure sodium lamps, mercury vapor lamps, metal halide lamps, etc.

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