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New Hampshire Department of Environmental Services

Management of Universal Wastes

Universal wastes are wastes that meet the definition of hazardous waste in the NH Hazardous Waste Rules, they are generated by all segments of the population and, unfortunately, often improperly disposed by the people who generate them. In an effort to make it easier and more cost effective to properly manage these wastes, the "Universal Waste Rules" exempts the wastes from the more burdensome Hazardous Waste Rules requirements, as long as they are managed to prevent release to the environment and properly recycled or disposed. Wastes that NHDES has determined meet universal waste criteria include certain types of pesticides, mercury-containing lamps and devices, certain types of batteries, cathode ray tubes, used automobile antifreeze, and certain types of pesticides. Schools typically generate universal wastes that include fluorescent light bulbs, mercury thermometers, thermostats and relay switches, nickel cadmium batteries, and cathode ray tubes (computers and televisions). If the school offers an auto repair curriculum, the school may also be generating used antifreeze and lead acid batteries.

Schools should be aware of the following regulations pertaining to universal wastes.

Universal wastes are exempt from NH Hazardous Waste Rules EnvWm100-900, but are, instead, regulated under EnvWm 1000. Schools are not required to include universal wastes in their calculation of generator status under Env-Wm 503.

A school may accumulate no more than a combined total of 5,000 kilograms (11,000 pounds or 1,250 gallons) of universal wastes on-site at any one time, before it is subject to additional regulation.

All wastes must be clearly labeled with the words "Universal Waste."

Universal wastes may be accumulated for no longer than one year from the date the wastes are first generated, unless permission of extended storage is obtained from NHDES.

Schools must manage their universal wastes in a way that prevents any releases to the environment. Any universal wastes that show evidence of leaking must be stored in a closed, structurally sound container that is compatible with the contents.

Schools must keep records for three years on each shipment of universal waste. These records must include the date of each shipment, the quantities of each shipment, and the name and address of the handler or facility where wastes were shipped.

For further information, the NH Universal Waste Rules are available on-line, or by contacting the NHDES Public Information Center at (603) 271-2975.

Universal wastes found in schools may include:

  • Batteries
    Universal waste batteries are waste batteries that meet the definition of hazardous waste in the NH Hazardous Waste Rules. These include nickel-cadmium, small sealed lead acid, and lithium batteries. The NHDES fact sheets Universal Waste Batteries: Management Requirements for Handlers and Transporters Adobe Acrobat Reader Symboland All About Batteries Adobe Acrobat Reader Symbolprovide more information on this topic. If your school has an auto repair curriculum, lead-acid motor vehicle batteries may be considered universal wastes. Please refer to the NHDES fact sheet Management of Used Motor Vehicle Batteries Adobe Acrobat Reader Symbol. NHDES maintains a list of battery (dry cell and motor vehicle) collection services and recycling facilities.
  • Cathode Ray Tubes
    A cathode ray tube (CRT) is the video display unit found in computer monitors and televisions. Monitors can contain up to eight pounds of lead. CRTs generated from a school are considered a universal waste once they are no longer usable or repairable. Thus, the CRT must be recycled, donated (working), or sent to a hazardous waste disposal facility. NHDES also maintains a list of vendors who will dispose of electronic equipment. There are several "takeback" programs where manufacturers (e.g., IBM and Hewlett Packard) will accept monitors and televisions, either free of charge or for a fee ranging from $7 to $30. You should check with your individual manufacturer on any specific programs.
  • Mercury-Containing Lamps and Devices
    A number of school building products and devices contain mercury, such as fluorescent lamps, thermostats, switches, and relays. Schools should try to use mercury-free alternatives whenever possible. The NHDES fact sheet Mercury-Containing (Universal Waste) Devices: Management Requirements for Handlers and Transporters provides all requirements and regulations for proper disposal of these items. The NHDES fact sheet Waste Mercury-Containing Lamps: Management Requirements for Handlers and Transporters provides information specific to the management of fluorescent light bulbs. NHDES maintains a list of fluorescent lamp and ballast recycling facilities.

    The state uses specific contractors for disposal of mercury-containing devices, including fluorescent bulbs. Schools can request the same government rate. For more information, contact Alan Hofmann at 271-2550 or email:

  • Pesticides
    Certain pesticides that have been suspended or recalled under the Federal Insecticide, Fungicide and Rodenticide Act (FIFRA) are managed under the NH Universal Waste Rules, Env-1100. The NH Department of Agriculture, Division of Pesticide Control is the state agency responsible for pesticide registrations. If you have a question as to whether a pesticide in your school is considered to be a universal waste, please call the Division of Pesticide Control at 271-3550.
  • Used Automobile Antifreeze
    There are approximately 30 high schools in New Hampshire that offer vocational training which may include an automobile repair curriculum. Used automobile antifreeze is considered a universal waste and must be managed accordingly. The NHDES fact sheet Waste Antifreeze: Management and Requirements for Handlers and Transporters Adobe Acrobat Reader Symbolprovides information for managing this universal waste.

    Recycling is the preferred option for managing waste antifreeze. Recycling methods include filtration, distillation, and ion exchange. On-site recycling at a school is not subject to permitting requirements. Schools may purchase an antifreeze distillation or filtration unit and recycle their own antifreeze on-site, hire a contractor to come in with a mobile recycling unit, or ship the antifreeze to a recycling facility. Waste antifreeze should not be disposed of by throwing it in the trash or pouring it down the drain. Waste antifreeze should not be mixed with used oil or other hazardous wastes, such as gasoline or solvents. NHDES maintains a list of antifreeze recycling companies and antifreeze recycling equipment vendors.



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NH Department of Environmental Services | 29 Hazen Drive | PO Box 95 | Concord, NH 03302-0095
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