Within the provisions of the Resource and Conservation Recovery Act (RCRA), in 1995, EPA issued regulations for certain wastes called universal wastes. Universal waste rules provided regulatory flexibility by allowing longer storage times and reduced record-keeping requirements. Currently, federal universal wastes are batteries as described in 40 CFR 273.2; pesticides as described in §273.3; mercury-containing equipment as described in §273.4; and lamps as described in §273.5.

State of Wisconsin, as a delegated authority to manage hazardous waste, has added sealed mercury-containing equipment and antifreeze. These are known as state-specific universal wastes. Regulatory status is currently maintained via WIDNR memo.

Requirements for managing universal waste, though relaxed, are similar to your requirements for other hazardous waste.


A small quantity handler, that is a universal waste handler who accumulates less than 11,025 pounds must train employees who manage or handle universal waste in proper handling and emergency procedures appropriate to the waste handled at the facility.

Click here to view or save the ORM Universal Waste Presentation

Accumulation Limits

A small quantity handler may store universal waste no longer than one year. You must be able to demonstrate the length of time that the universal waste has been accumulated from the date it becomes a waste or is received (e.g., label each item with the date it became a waste or was received or label container with the earliest date a waste was added to the container.). For further information, see NR 673.15.

Container Requirements

Waste must be managed in a way that prevents releases. Containers must be closed, structurally sound and compatible with the contents. Label containers Universal waste XXXXX – Each XXXXX or a container in which the XXXXX are contained, shall be labeled or marked clearly with the phrase “Universal Waste—XXXXX”, “Waste XXXXX” or “Used XXXXX” [Replace “XXXXX” with “Batteries”, “Mercury Thermostats”, “Lamps”, “Mercury”, “Sealed mercury-containing devices”, “Antifreeze”; Pesticide labeling varies somewhat – requirements may be found in NR 673.14(2)&(3)]


Used lamps must be disposed through the State Contract Waste Lamp and Ballast Recycling, and PCB Waste Disposal Services.

Lead-acid batteries may be managed under NR 666 Subpart G.

Mercury and mercury-containing devices should be disposed through the State Hazardous Waste contract.

Pesticides should be applied legally whenever possible or disposed through the State Hazardous Waste contract.


NR 673.17  Response to releases. (1) A small quantity handler of universal waste shall immediately contain all releases of universal wastes and other residues from universal wastes. (2) A small quantity handler of universal waste shall determine whether any material resulting from the release is hazardous waste, and if so, shall manage the hazardous waste in compliance with all applicable requirements of chs. NR 660 to 670. The handler is considered the generator of the material resulting from the release, and shall manage it in compliance with ch. NR 662.

What Never to Do with a Mercury Spill

  • Never use a vacuum cleaner to clean up mercury. The vacuum will put mercury into the air and increase exposure.
  • Never use a broom to clean up mercury. It will break the mercury into smaller droplets and spread them.
  • Never pour mercury down a drain. It may lodge in the plumbing and cause future problems during plumbing repairs. If discharged, it can cause pollution of the septic tank or sewage treatment plant.
  • Never wash clothing or other items that have come in direct contact with mercury in a washing machine, because mercury may contaminate the machine and/or pollute sewage. Clothing that has come into direct contact with mercury should be discarded. By “direct contact,” we mean that mercury was (or has been) spilled directly on the clothing.
  • Never walk around if your shoes might be contaminated with mercury. Contaminated clothing can also spread mercury around.

If a Small Number of Bulbs Break

  • Carefully scoop up glass pieces and powder using stiff paper or cardboard and place them in a lamp box
  • Use sticky tape, such as duct tape, to pick up any remaining small glass fragments and powder.
  • Wipe the area clean with damp paper towels or disposable wet wipes. Place tape and towels in the box.
  • Do not use a vacuum or broom to clean up the broken bulb on hard surfaces.
  • If a large number of bulbs break or elemental “liquid” mercury spills, cleanup and disposal are more complicated. Contact your Environmental Officer for advice and assistance.


ORM Presentation for D2L

ORM Universal Waste Video

MIL Universal-Waste-Annual-Generator-Training

WIDNR Small Quantity Handler Inspection Report


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.

Read full legal disclaimer