Universal Waste Management

Scope and Purpose

Universal Waste (UW) is a hazardous waste that is widely generated in a variety of settings, is generated by another community, and is present in significant volumes in nonhazardous management systems.  Universal waste is regulated by 40 CFR Part 273 (EPA) and Maine Department of Environmental Protection (DEP) Chapter 851, Section 3A.

Bates College is a Central Accumulation Facility where the generator (Bates) consolidates its own universal wastes from various buildings or facilities.

Bates College is prohibited from disposing of, diluting, or treating universal waste.  The intentional breaking of lamps or cathode ray tubes is considered a form of treatment and may only be conducted at an authorized or licensed recycling facility.  Bates College is required to send all universal waste to either a central accumulation facility, consolidation facility, or a recycling facility for universal waste.

Please contact Bates EHS for any questions regarding training, types of waste, or if you need to schedule a waste pickup.  Bates EHS will pick up any college generated universal waste and from other locations upon request.  Bates EHS will then oversee its proper disposal.

Types of Universal Waste

  • Batteries: Nickel Cadmium, small sealed lead acid batteries, Lithium Ion, Mercuric Oxide, Zinc Air and Silver Oxide button batteries. Note – Vehicle batteries are NOT considered universal waste and may be recycled via the battery deposit system; if damaged or leaking they must be treated as hazardous waste.
  • Cathode Ray Tubes (CRT): square TVs , video display components of televisions, computer monitors, and other display devices.
  • Lamps containing mercury or lead, including fluorescent, high intensity discharge, neon, mercury vapor, high pressure sodium, and metal halide bulbs.
  • Mercury devices including thermometers, thermostats, switches, and gauges.
  • Totally enclosed non-leaking PCB ballasts.  Note – if the ballast is leaking it is considered hazardous waste and EHS should be notified.
  • Limited quantities of oil based paint (containers must be 5 gallons or less).


Bates College EHS has provided battery recycling containers at six locations across campus.  They may be used to discard alkaline, button, and phone batteries. Those locations are:

  1. Carnegie Science –                          Main Office (Room 109)
  2. Commons –                                        Milt’s Lounge
  3. Cutten Maintenance Center –      Room 125
  4. Kalperis Hall –                                    Main Lobby by Franklin Street
  5. Ladd Library –                                    Main Entry by Circulation Desk
  6. Pettingill Hall –                                  Foyer on 1st Floor

Storage and Recordkeeping

Bates College must comply with the requirements for the storage of universal waste in accordance with Chapter 858 of DEP.  The requirements are:

  1. Universal waste must be stored in a secured area, which can be locked when not in use.
  2. Universal waste storage areas must be designated by a clearly marked sign, which states “Universal Hazardous Waste Storage” or the type of waste being stored.
  3. Store all universal waste in containers, which must not show evidence of damage or leakage, must be closed when not in active use, and must be structurally sound.
  4. Each container must be labeled “Universal Waste” and have the start date of accumulation and the date the container becomes full.
  5. Universal waste containers should be marked with the type of waste they contain.
  6. Universal wastes cannot be stored for more than 365 days from the date the waste is first placed in the container.  Exceptions to this rule may be found in the Maine DEP UW Handbook.
  7. Universal waste may not be stored where exposure to weather is present.
  8. Universal waste containers must be packed to prevent breakage.  Packing materials may be used.
  9. Full waste containers must be sealed securely around box openings.  Any box must be immediately sealed if incidental breakage occurs.
  10. Universal waste boxes must not be stored more than 5 feet high.
  11. Universal waste storage areas must be inspected weekly.  Inspections must be documented.
  12. Universal waste containers must be stored to facilitate inspection of the container.
  13. Spills and leaks must be immediately contained and transferred to a proper container.
  14. Bates College EHS will maintain the universal waste inventory and mark the containers with the proper date and contents before removal from campus location.

Records Retention and Reporting

Generators, central accumulation facilities, and consolidation facilities must retain the following documents and paperwork at the facility:

  1. Inspection logs must be kept for one (1) year from the date of shipment or receipt or universal waste.
  2. Training documentation must be kept for at least three (3) years from the date of shipment, receipt of universal waste or length of employment whichever is longer.
  3. Bills of Lading, manifests and log forms must be kept for at least three (3) years from the date of shipment or receipt of universal waste.


Bates College, as a central accumulation facility, must comply the following requirements regarding universal waste shipments:

  1. The universal waste must be whole, intact, and unbroken.
  2. The universal waste must be in proper packaging that includes closed containers that are compatible with the type and amount of waste being shipped.  Packages must also meet standards found in DOT 49 CFR 171-180.


Bates College is required to train all employees who handle or manage universal waste on proper handling and emergency procedures.  Documentation must be maintained at Bates College for a minimum of three years.  For training in Universal Waste contact Bates EHS.