Universal Waste Management


"Universal wastes" are a special group of hazardous wastes that are widely generated by many different segments of EPA regulated businesses. In an effort to make it easier and more cost effective to properly manage these wastes, the "Universal Waste Rule" exempts the wastes from the more burdensome "Hazardous Waste Rule" requirements, as long as they are managed to prevent release to the environment and properly recycled or disposed of.

There are four separate types of materials which are classified as universal wastes. They consist of:

  • Fluorescent lamps (including HIDs)
  • Batteries (non-alkaline)
  • Mercury Thermostats
  • Pesticides

RIT is a small quantity generator of universal waste because we do not accumulate 5,000 kilograms or more of universal waste (collectively) at any time. Of the universal waste that RIT generates, the majority consists of fluorescent lamps and batteries. The RIT EH&S Department ensures that all of the universal waste generated across campus is either recycled or disposed in accordance with all applicable regulations.

Applicable Regulation

6 NYCRR 374.3

Management Requirements

There are several management requirements that apply to RIT while universal waste is stored on campus awaiting off-site disposal. These requirements, including RIT internal practices, are listed below. In order to ensure compliance with these requirements, applicable RIT personnel are trained on an annual basis.

  • All areas across campus that generate universal waste on an ongoing basis must designate a universal waste storage area. Each designated area must be posted with a "Universal Waste Storage Area" sign.
  • Universal waste must be labeled or marked to specify the type of universal waste being stored. The RIT EH&S Department has developed a label that encompasses each of the four types of universal waste.


  • Each universal waste item must be date labeled to ensure that it is stored for no longer than one year's time.
  • Universal waste must be stored in containers or packages that are structurally sound, adequate to prevent breakage, compatible with the contents, and closeable.
  • Universal waste containers and packages must remain closed and must lack evidence of leakage, spillage or damage that could cause leakage under reasonably foreseeable conditions.

Training Requirements

"A small quantity handler of universal waste must inform all employees who handle or have responsibility for managing universal waste. The information must describe proper handling and emergency procedures appropriate to the type(s) of universal waste handled at the facility."

The RIT universal waste training presentation is available online through Talent Roadmap and linked below.

If you have any questions, please contact RIT's Environmental Programs Manager