Fluorescent Tubes

If your facility generates spent batteries (excluding lead-acid batteries), mercury-containing equipment, universal waste lamps (e.g.: fluorescent tubes), or excess pesticides, it is subject to the universal waste requirements. General guidelines are outlined below.

General Requirements

  • Generators of Universal Waste cannot dispose of it on-site and dilute or treat the waste
  • Generators must train employees in the proper handling and storage of Universal Wastes
  • All releases/spills of Universal Waste must immediately be contained and clean-up materials properly disposed of

Benefits of Using Universal Waste Rule

The Universal Waste (UW) Rule was put into place to ease the regulatory burden for businesses dealing with common hazardous wastes.  It allows a longer collection time (one year) making recycling these wastes more feasible.  The UW Rule also has fewer record keeping, training, and reporting requirements compared to those for other hazardous wastes.


  • All UW must be handled in a way that prevents release during accumulation, storage, and disposal.
  • All spills and residues of UW must immediately be contained.
  • All materials (including clean-up materials) resulting from spills of a UW must be handled in compliance with applicable federal, state, and local regulations.
  • If a release of one pound or more of a UW occurs please contact the IWRC.
  • For more, download full regulation information on the right.

Labeling, Recordkeeping, and Storage Quantity Requirements

  • Handlers of UW cannot accumulate UW for more than one year unless it is done for the sole purpose of feasible recycling
  • Store UW in a container that remains closed, is structurally sound, compatible with the waste, prevents breakage, and lacks evidence of leakage or damage
  • Clearly identify the length of time the waste has been accumulated (i.e., labeling containers or waste, inventory system, etc.)
  • Batteries - Label each battery or container “Universal Waste - Batteries,” “Waste Batteries,” “Used Batteries”
  • Pesticides - Label each storage container, vessel or tank with the label that accompanied the product and “Universal Waste - Pesticides” or “Waste Pesticides”
  • Mercury Containing Equipment - Label each piece of equipment or container: “Universal Waste - Mercury Containing Equipment”; “Waste Mercury-Containing Equipment”; or “Used Mercury-Containing Equipment”
  • Universal Waste Lamps - Label each lamp or container “Universal Waste - Lamps,” “Waste Lamps” or “Used Lamps”

Testing Requirements

TCLP testing may be required to determine if clean-up materials and/or removed components/parts are considered hazardous wastes.

Permits and Registrations

  • SQHUW (small quantity handler of UW) are not required to obtain a hazardous waste identification number from the EPA if only universal hazardous wastes are generated
  • LQHUW (low quantity handler of UW) must obtain an EPA ID number prior to accumulating more than 11,000 pounds of UW
  • EPA notification to obtain the number (LQHUW only)
  • LQHUW that already have an EPA ID number do not need to notify the EPA of UW activities but must maintain their existing number

Training Requirements

  • SQHUW must train all employees that handle UW in proper handling and emergency procedures
  • LQHUW must formally train (including documentation) all employees in proper handling and emergency procedure(s) for UW related to their responsibilities during normal facility operations and emergencies


  • UW waste must be sent to a UW handler, destination facility, or foreign market
  • Shipments must be packaged, labeled, marked, and placarded in a manner that prevents releases and follows all DOT requirements
  • The receiving party must agree to accept the waste
  • Handlers may self-transport universal waste, however, the handler must also comply with UW transporter regulations (summarized below)
  • Exporting UW to a foreign market requires compliance with export regulations including notification of EPA and consent of the receiving country
  • UW handlers that also receive quantities of UW from other facilities should contact the IWRC


  • Transporters cannot dispose of, dilute, or treat UW (except when responding to a release)
  • Transporters of UW must comply with all DOT regulations
  • UW can only be stored at a transfer site for 10 days without further regulation
  • Transporters must immediately contain and clean up all releases/spills of UW and properly dispose of clean-up materials
  • Transporters must take UW to a destination facility, handler, or foreign market agreed upon by the generator/handler


  • SQHUW are not required to keep records of shipments, however, as with all hazardous wastes, tracking quantities, dates of disposal, and destination facilities is advisable
  • LQHUW must track shipment of all UW
  • SQHUW that accumulates more than 11,000 pounds of UW at one time, become a LQHUW and must then comply with LQHUW regulations for the remainder of the calendar year