Greening the workplace involves more than recycling paper. A key part of putting the environment first in any work place has to learn how to handle what is widely known as “universal waste.” According to the United States Environmental Protection Agency (EPA), the main categories of universal waste are batteries, pesticides, and mercury-containing equipment and bulbs (lamps). While not every workplace has all four forms of universal waste present, nearly every type of workplace has one or more of these forms of waste on site. Also, bear in mind that in some cases, seemingly innocuous items, which are also found in many family homes, are identified as universal waste. These items include mercury thermometers, thermostats, switches, non-empty aerosol cans and old television monitors. Today’s post discusses each form of universal waste, how to dispose of the forms properly and how and why to ensure employees are well trained to handle universal waste in accordance with EPA guidelines.

Disposing of Universal Waste in the Workplace


The EPA defines batteries as follows: “Battery means a device consisting of one or more electrically connected electrochemical cells which is designed to receive, store, and deliver electric energy. An electrochemical cell is a system consisting of an anode, cathode, and an electrolyte, plus such connections (electrical and mechanical) as may be needed to allow the cell to deliver or receive electrical energy. The term battery also includes an intact, unbroken battery from which the electrolyte has been removed.” Batteries are found in nearly every type of business, but depending on the type of business, the type and quantity of business varies and so does one EPA obligations. Whether you are a small or large quantity handler of universal waste, you’ll be expected to dispose of your workplace batteries in a closed and structural sound container to minimize leakage and waste over time. The container must also be labeled as “Universal Waste— Battery(ies),” or “Waste Battery(ies),” or “Used Battery(ies).”


The EPA defined pesticides as follows “any substance or mixture of substances intended for preventing, destroying, repelling, or mitigating any pest, or intended for use as a plant regulator, defoliant, or desiccant.” Again, whether you’re a small or large handler, any waste must be contained in a closed container that will not breakdown over time and properly labeled as “Universal Waste-Pesticide(s)” or “Waste-Pesticide(s).” For more details, also see the EPA’s website.

Mercury-containing Equipment

Mercury-containing equipment is defined by the EPA as “a device or part of a device (including thermostats, but excluding batteries and lamps) that contains elemental mercury integral to its function.” This includes common household items too, including thermostats. Once again, any equipment that contains mercury must be placed in a container “reasonably designed to prevent the escape of mercury into the environment by volatilization or any other means” and properly labeled as “Universal Waste-Mercury Containing Equipment,” “Waste Mercury-Containing Equipment,” or “Used Mercury-Containing Equipment.” or for thermostats as “Universal Waste-Mercury Thermostat(s),” “Waste Mercury Thermostat(s),” or “Used Mercury Thermostat(s).”

Bulbs and Lamps

Another common workplace safety item that requires special care are bulbs and lamps. While seemingly innocuous, a fluorescent lamp or tube is a gas-discharge lamp that uses electricity to activity mercury vapor; as a result, they contain mercury. Other bulb options that are less toxic still contain some substances that need to be handled with care. Halogen lamps, for example, contain substances such as iodine and bromine. For bulbs and lamps, however, the best option for disposals is not containment but recycling. For details on how to properly recycle your bulbs and lamps, see the EPA’s guidelines.

How to Start a Universal Waste Training Program

To ensure you’re in compliance and doing your part to prevent toxic waste from seeking into the ecosystem, it is important to ensure that all workers understand what items are fall under the universal waste category and how to dispose of these items in the workplace. Of course, the first step is to start a universal waste disposal program. To learn more about how to start a universal waste disposal program sing of universal waste in accordance with EPA guidelines, see eLeaP’s training video: Universal Waste: Bulbs, Batteries, Bugs and Barometers.