Hazardous and universal waste labelsGeneral Regulatory Information

Most activities at UW System campuses generate waste. Solid waste is any garbage, refuse or other discarded material, including solid, liquid, semi-solid or contained gaseous materials. At the federal level, the US EPA regulates the management of both hazardous and non-hazardous solid waste under the Resource Conservation and Recovery Act (RCRA). Proper waste management is the responsibility of each person on campus and helps ensure the protection of human health, the environment and university assets. It is mandatory that all hazardous waste generated at UW System campuses and facilities be handled under the state hazardous and universal waste contract.

Hazardous waste is a specific category of solid waste that requires special management and disposal practices, as dictated by RCRA and the Wisconsin DNR under Wisconsin Administrative Code Chapters 600-699: Hazardous Waste Management. Hazardous wastes are commonly generated from a variety of activities on campuses, including wastes from research laboratories, art studios, classrooms, grounds and facilities maintenance and custodial services, among others.

Wastes generated at UW System campuses that are not hazardous wastes still may be prohibited from landfills or incineration. Please see the Wisconsin DNR Waste Reduction and Recycling Law webpage for more detail. Other regulated wastes that have specific management and disposal requirements include:


Hazardous waste is any solid waste not specifically excluded from the RCRA regulations and is either a listed waste or characteristic waste. Listed wastes are those that are specifically listed under the F-, K-, P- or U-list tables, while characteristic wastes are those that exhibit any one or more of the following hazardous properties: ignitability, corrosivity, reactivity or toxicity. For more detail, please see the US EPA Defining Hazardous Waste webpage.


Universal Waste

Universal waste is a specific category of hazardous wastes that qualifies for reduced hazardous waste management standards if managed properly under the alternative universal waste requirements. In Wisconsin, universal wastes include:

For more detail, please see the Wisconsin DNR Universal Waste webpage, which includes guidance documents for each type of universal waste.


Hazardous Waste Generator classifications

UW campuses that generate hazardous waste will fall into one of three classifications, depending on the volume of hazardous waste generated monthly: very-small-quantity generator (VSQG), small-quantity generator (SQG) or large-quantity generator (LQG). Please see the Wisconsin DNR Hazardous Waste webpage and the US EPA Categories of Hazardous Waste Generators webpage for more information on the regulations and requirements for each generator type.

Prior to discarding a material, a waste determination must be made to decide how to properly and legally dispose of the material. The federal and state waste determination requirements may be met using two methods: sampling and analysis or generator knowledge. Often the preferred method is waste sampling and analysis because this method is more accurate and defensible than applying generator knowledge.

If generator knowledge is used alone or in conjunction with sampling and analysis to make a waste determination, detailed documentation that clearly demonstrates the information is sufficient to identify the waste must be maintained. Documenting both generator knowledge and any analytical data is essential. Documentation used to support generator knowledge may include, but is not limited to: safety data sheets (SDS) or similar documents; a thorough process description, including data on all raw materials used in the process; and/or other forms of detailed documentation. In Wisconsin, hazardous waste determinations are governed by Wisconsin Administrative Code Chapter NR 661: Hazardous Waste Determination and Listing. Also, see the Wisconsin DNR Waste Determinations & Recordkeeping guidance document for more information.

The Hazardous Waste Manifest System is a set of forms, reports and procedures designed to seamlessly track hazardous waste from the time it leaves the generator facility until it reaches the off-site waste management facility that will store, treat or dispose of the hazardous waste. The system allows the waste generator to verify that their waste has been properly delivered and that no waste has been lost or unaccounted for in the process.

The key component of this system is the Uniform Hazardous Waste Manifest, which is a form prepared by all generators who transport, or offer for transport, hazardous waste for off-site treatment, recycling, storage or disposal. The manifest is required by the Wisconsin DNR, US EPA and DOT. Each party that handles the waste signs the manifest and retains a copy. This ensures critical accountability in the transportation and disposal processes. Once the waste reaches its destination, the receiving facility returns a signed copy of the manifest to the generator, confirming that the waste has been received by the designated facility.

Staff at UW System campuses who sign Uniform Hazardous Waste Manifests must be trained hazmat employees (49 CFR 172 Subpart H). Additional information on signing authority considerations for waste manifests and documentation is provided on the UWSA Signatory Authority webpage. Please see the Wisconsin DNR Hazardous Waste Manifest Requirements for more detail.

The hazardous waste regulations also include requirements for waste minimization efforts (40 CFR 262.27). The US EPA provides some guidance on waste minimization frequently asked questions, and the Wisconsin DNR Pollution Prevention webpage provides additional resources at the state level. Efforts at pollution prevention, source reduction, recycling and reclamation can all fall under the umbrella of waste minimization. Some possibilities for minimization efforts at UW System campuses include:

  • Substituting less hazardous and/or more recyclable materials in any application
  • Improving chemical inventory management and redistribution
  • Implementing a mercury thermometer replacement program
  • Promoting microscale techniques in laboratories

Hazardous materials releases (i.e., spills) can occur at any time and anywhere on campus, especially in laboratories and facilities and maintenance areas. All personnel at UW System campuses who work with or within areas that contain hazardous materials should be trained on the proper prevention of and response to spills, fires or other emergencies. In addition, hazardous materials spills often require immediate reporting to both internal and external agencies. The Wisconsin DNR broadly defines a reportable spill as a discharge of a hazardous substance that adversely impacts, or threatens to adversely impact, human health, welfare or the environment and requires an immediate response. Please consult the Wisconsin DNR Hazardous Substances Spill webpage for detailed spill and reporting requirements.

24-Hour Wisconsin Spill Reporting Hotline: 1-800-943-0003

National Response Center Reporting Hotline: 1-800-424-8802



Additional Resources


This publication was prepared for environmental, health and safety staff at University of Wisconsin System campuses, to assist in finding resources and information for regulatory compliance. It is not intended to render legal advice.

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