Recycling Hazardous Waste: Safety Topics - July 2021 - Week #6


Weekly Safety Briefings

Week # 31 – July 30, 2021

Universal Waste Recycling

Monday - Batteries

Many different types of batteries are eligible for universal waste management. The rule defines a battery as “a device consisting of one or more electrically connected electrochemical cells which is designed to receive, store and deliver electric energy.” Some examples include:

• Alkaline

• Mercuric-oxide

• Alkaline-manganese

• Zinc carbon nickel cadmium (Ni-Cad)

• Button cell

• Silver oxide

• Lithium ion (Li-Ion)

Not all batteries are universal wastes. For example, lead acid batteries that can be managed by 40 CFR 266 (spent automotive batteries that are going to be reclaimed) are ineligible.  Different types and styles of batteries may be stored together. The terminals of each battery must be taped or otherwise shielded to prevent unintended discharges and fires while the batteries are in storage or being transported. If tape is used, it must not be duct tape or any tape that has aluminum or other metal components in its composition.

Individual battery cells may be opened to remove the electrolyte, but must be resealed as soon as the electrolyte has been removed. Any electrolyte that has been removed is not a universal waste and must be properly managed.

Tuesday – Pesticides

Waste pesticides that prevent, destroy, repel or mitigate pests or formulas that regulate exfoliated or desiccated plants are pesticides that may be managed under universal waste rule [40 CFR 273.9]. Examples include:

• Recalled, suspended, and canceled pesticides that are part of a voluntary or mandatory recall

• Pesticides that are not in compliance with the Federal Insecticide, Fungicide, Rodenticide Act (FIFRA)

• Unused pesticides that are collected and managed as part of a waste pesticide collection program

More than 25,000 different types of pesticides are available in the United States, and more than one billion pounds are used each year. Proper management helps to prevent these materials from contaminating water and soil. Pesticides may be managed in either containers or tanks that are nonleaking, properly labeled and compatible with pesticides being stored.

Wednesday Mercury-Containing Equipment

Because batteries and lamps are specifically designed as universal wastes, they are not managed as mercury-containing equipment. The devices that may be managed as mercury-containing equipment have elemental mercury somewhere inside them to function properly. Examples include:

• Thermostats

• Thermometers

• Mercury switches

• Ballasts

• Barometers

• Manometers

The mercury in these devices is contained in ampules. Under universal waste management standards, ampules may be managed intact in the device that contains them or the ampules may be removed from the device if it can be done so without damaging the ampule.

Facilities that choose to remove mercury ampules must properly train their personnel, perform the removal over a containment device and ensure that the area is properly ventilated. Broken mercury ampules must be properly cleaned up and managed under RCRA standards.


Unlike mercury-containing equipment, facilities are not permitted to remove mercury from lamps. The lamps must

be kept intact to qualify for management as universal waste. Although different styles or lengths of lamps may be

managed together, it can sometimes be more difficult to do this without the risk of breaking the lamps.

The universal waste management requirements are clear about the bulbs remaining intact if facilities are going to

manage them as a universal waste. Crushing bulbs can help some facilities better manage the amount of space

required to store them, but it disqualifies the lamps for management as universal waste and makes them subject to

full RCRA regulation as a hazardous waste.

FridayAerosol Cans

Aerosol cans hold anything from solvents and paints to food, beauty product and pesticides. The hazards presented by “empty” aerosol cans are often two-fold: the can may contain residual hazardous materials, such as solvents, paints or flammable propellants that can harm the environment; plus, it remains pressurized and can explode if it is subject to heat.

The EPA sought to include all types of products when developing the Universal Waste Rule for Aerosol Cans — no matter what is in the can, they all may be managed under the same standard. The broad definition of an aerosol can is “a non-refillable receptacle containing a gas compressed, liquefied, or dissolved under pressure, the sole purpose of which is to expel a liquid, paste, or powder and fitted with a self-closing release device allowing the contents to be ejected by the gas.” [40 CFR 260.10]

Facilities that manage aerosol cans as universal waste must meet the general requirements for universal waste management, but they have two options for what happens to the waste. They can either:

• Keep the cans intact and send them to a universal waste handler for processing and recycling; or

• Safely puncture the cans then recycle the empty, punctured cans and manage any residual liquids appropriately. 

If cans will be punctured onsite, the facility must also:

• Develop written procedures for safely puncturing the cans in a device designed for can puncturing

• Maintain the manufacturer’s specifications and instructions for the can puncturing device

• Train employees

The EPA estimates that more than 25,000 facilities in the United States use aerosol cans each year and that recycling those aerosol cans can save up to $47.8 million annually.


206 College Street, P.O. Box 236 • Pineville, NC 28134
Phone: 844-264-2357

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