Universal Waste
The EPA issued an amendment to the RCRA regulations which created a "Universal Waste Rule" (adopted by GA EPD; 391-3-11-.18). This rule was designed to reduce the amount of hazardous waste items in the municipal solid waste (MSW) stream, encourage recycling and proper disposal of certain common hazardous wastes, and reduce the regulatory burden on waste generators.
Universal wastes include batteries such as nickel-cadmium (Ni-Cd) and small sealed lead-acid batteries, agricultural pesticides that have been recalled or banned from use, are obsolete, have become damaged, or are no longer needed due to changes in cropping patterns or other factors, thermostats, which can contain as much as 3 grams of liquid mercury, and lamps, which typically contain mercury and sometimes lead (common types of lamps include fluorescent, high intensity discharge (HID), neon, mercury vapor, high pressure sodium, and metal halide lamps). Campuses were once required to handle these materials as hazardous wastes.
The Universal Waste Rule eases the regulatory burden and it streamlines the requirements related to notification, labeling, marking, prohibitions, accumulation time limits, employee training, response to releases, offsite shipments, tracking, exports, and transportation. For example, the rule extends the amount of time that facilities can accumulate these materials on site. It also allows transport of universal wastes with a common carrier, instead of a hazardous waste transporter, and no longer requires a manifest.
The rule does not apply to campuses that generate less than 100 kilograms of universal wastes per month (Conditionally Exempt Small Quantity Generators); however, the Board of Regents strongly encourages these campuses to participate voluntarily in collection and recycling programs.
Although lamp ballasts are technically not defined as universal waste, the Board of Regents recommends, as a best practice, that all ballasts (PCB and non-PCB containing) also be included in the institution's recycling program.