Handling Universal Waste


Universal wastes (UW) are a subset of hazardous wastes that generators may manage under a “relaxed” set of handling, storage and disposal requirements. The Ohio EPA, in Ohio Administrative Code (OAC) 3745-273, defines the Universal Waste Rules (UWR) as well as the categories of waste covered by these rules. Regulators have offered these time- and money-saving alternatives to promote the recycling of these common commercial products and to keep them out of municipal landfills. This guidance document is intended to summarize the UWR and to clearly define the procedures and practices that have been adopted by Miami University in order to assure compliance with the rules.

Please note that a waste must first be classified as a hazardous waste before it can be handled as a universal waste. If a universal waste is not correctly handled under the UWR, then it must be handled under the more stringent hazardous waste regulations (see “Waste Management Guide” at www.muohio.edu/ehso).

Types of Universal Waste & Handling Instructions

The Ohio EPA lists the following categories of UW that can be managed under the UWR.


In OAC 3745-50-10(A), lamps are defined as the bulb or tube portion of an electric lighting device. These can include incandescent, fluorescent, high-intensity discharge (HID), neon, mercury vapor, high pressure sodium and metal halide lamps. Many lamps and/or lamp components can exhibit toxicity characteristics for regulated heavy metals (mercury, lead, cadmium, etc.). Though not every category of lamp contains these metals, Miami handles each type of lamp under the UWR.

Spent lamps can be returned to the original manufacturer’s container (usually a box) during “change-outs”. Upon adding the first lamp(s), each container must be dated and should be marked with the words “Universal Waste – Used Lamps” or “Universal Waste – Waste Lamps”. The containers will normally be accumulated in a building’s loading dock or designated maintenance area until full, at which time they should be moved by Trucking to the Recycling Center.

NOTE: Broken fluorescent bulbs (or bulbs containing mercury or other heavy metals) must be handled as hazardous waste. Glass & debris from a broken bulb should be swept up and properly contained (do not use a shop-vac or cause excessive dust); contact EHSO for pick up and disposal.


In OAC 3745-50-10(A) and 3745-273-09, batteries are defined as devices consisting of one or more electrically connected electrochemical cells that are designed to receive, store and deliver electric energy. Varieties of batteries include alkaline, nickel cadmium, nickel metal-hydride, lithium ion, and lead-acid. Like lamps, many types of batteries exhibit characteristics of toxicity for heavy metals (most notably lead and cadmium). They may also contain a corrosive electrolyte (i.e. sulfuric acid in lead-acid batteries). Though not every type of battery exhibits these characteristics, Miami handles each type of battery under the UWR.

Miami’s Recycling Office has set up drop-off boxes at several campus locations for small, spent battery recycling. Each box has attached instructions for the safe handling, as some spent batteries may still hold an electrical charge. For the recycling/disposal of larger batteries (i.e. car- type lead-acid batteries or liquid electrolyte batteries from back-up power systems), please contact EHSO for pick-up.

Mercury-Containing Thermostats

Mercury-containing thermostats are temperature control devices that contain metallic mercury in an ampule attached to a bimetal sensing element. The mercury-containing ampule should only be removed according to the UWR and should be handled as a UW thermostat. EHSO prefers that all thermostats be removed intact, with no disassembly prior to recycling/disposal.

Contact EHSO for pick-up of all mercury-containing thermostats.

Container Labels

EHSO keeps a supply of Universal Waste labels specific to spent bulbs as well as generic Universal Waste labels. It is important that each label lists container contents as well as the accumulation start date. The accumulation start date is the date at which the first waste item is placed into the container. The University, as a small quantity Universal Waste generator, has one (1) calendar year from the accumulation start date to ship the container off-site for recycling/disposal.

Please contact the Environmental Program Manager (Dan Fetrow) at (513) 529-7213 to obtain Universal Waste labels or with any questions pertaining to Universal Waste.