4 The record articles

Universal Waste Series – Common Mistakes Managing Waste Batteries

Posted: October 11th, 2022

Authors: A.J. G. 

This article is the second in a series of 4 the Record articles providing common mistakes and best practices to maintain compliance with universal waste regulations.

Universal waste regulations allow a universal waste generator to not count the designated waste towards their hazardous waste generator status as long as they comply with Chapter 40 of the Code of Federal Regulations (CFR) §273. Handlers of universal waste can be classified as a small quantity handler, accumulates < 5,000 kg of universal waste at any one time, or a large quantity handler, accumulates > 5,000 kg of universal waste at any one time. A large quantity handler of universal waste must notify the Regional Administrator or State Agency where the state has primacy before exceeding the 5,000 kg accumulation storage limit to be issued a United States Environmental Protection Agency (U.S. EPA) identification number under the Resource Conservation and Recovery Act (RCRA) Subtitle C program.

The universal waste standards streamline the hazardous waste management standards for wastes that are commonly generated. There are three intended outcomes from the streamlined regulations according to the U.S. EPA website:

  • Promote the collection and recycling of universal waste
  • Ease the regulatory burden on retail stores and other generators that wish to collect these wastes and transporters of these wastes
  • Encourage the development of municipal and commercial programs to reduce the quantity of these wastes going to municipal solid waste landfills or combustors

There are general requirements to be followed by all universal waste generators for every type of universal waste. For more information about EPA’s request for information on the development of best practices for the collection of batteries to be recycled, voluntary battery labeling guidelines, and examples of proposed best practices, read our other article Collecting and Storing Waste Batteries: Best Practices.

General universal waste management requirements

  • One-year storage limit for universal waste accumulation
  • Universal waste must be stored in structurally sound containers that are compatible with the waste and prevent breakage, spillage, or damage
  • Universal waste containers must contain a label containing the phrases “Universal Waste” and the specific universal waste type. The start date of universal waste accumulation also needs to be included on the label
  • Employees must be trained on applicable waste handling and emergency procedures
  • Universal waste releases must be immediately contained
  • Universal waste that meets the definition of hazardous materials per the U.S. Department of Transportation (U.S DOT) must contain the proper hazardous materials label and proper shipping paperwork per 49 CFR 172. U.S DOT hazardous material training must also be completed by any employee involved in the transportation of hazardous materials
  • Track and maintain records of all universal waste shipments
  • Universal waste must be sent to a universal waste destination facility

How are batteries defined?

In 40 CFR §273.9, batteries are defined as “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.” A used battery becomes a waste when it is discarded, and an unused battery become a waste once it is determined to be discarded.

Common battery chemistries:

  • Alkaline
  • Carbon zinc
  • Lead acid
  • Lithium & lithium-ion
  • Mercury oxide
  • Nickel cadmium
  • Nickel metal hydride
  • Silver oxide

The chemistry for many batteries will be provided using the elemental name on the battery label (e.g., Pb for lead). Voltage will be commonly provided on the battery label with a numeric value and the capital letter “V” for voltage (e.g., 12V). Some batteries will also include the watt hours on the battery label; watt hours will be provided as a numeric value with the letters “Wh” (e.g., 600Wh). Management requirements for waste batteries can vary by voltage and chemistry and being able to properly identify the chemistry and voltage of waste batteries is imperative.

What are common waste batteries management mistakes?

  • Not having a dedicated and commonly known storage area for universal waste accumulation
  • Exceeding the one-year storage limit for waste battery accumulation
  • Storing waste batteries outside of a storage container
  • Not having available waste battery containers near common points of generation (e.g., maintenance shops)
  • Failing to label or appropriately label storage containers (using improper labels or not including the accumulation start date) for waste batteries
  • Failing to keep containers storing waste batteries completely sealed unless waste batteries are being added to the container
  • Using containers to store or ship waste batteries that are not compatible with the contents of the battery or approved by U.S DOT
  • Handling leaking or corroded waste batteries without proper PPE, or in a manner that increases the likelihood that hazardous constituents are released to the environment
  • Bagging or taping waste batteries together
  • Storing waste batteries with incompatible chemistries together (e.g., alkaline and lead acid)
  • Not managing waste batteries in accordance with applicable chemistry requirements (e.g., lithium-ion batteries)
  • Shipping waste batteries without terminal protection that have U.S. DOT terminal protection requirements (e.g., lead acid batteries)
  • Not completing the U.S. DOT hazardous material training if shipping universal waste that meets the definition of hazardous materials

How can I avoid the common waste batteries management mistakes?

  • Pick a dedicated and commonly known universal waste storage area that allows for proper storage and is reasonably close to the source of universal waste generation.
  • Include detailed instructions for proper waste batteries management in an annual universal waste training program. Also include the location of the universal waste storage area and which personnel are responsible for managing the universal waste program.
  • Develop a Standard Operation Procedure (SOP) for waste batteries management and distribute to applicable personnel. Review and update the SOP routinely.
  • Have a consistent inspection program that provides detailed corrective actions to employees responsible for waste batteries management.
  • Know how to find battery chemistry and voltage information on each battery and manage waste batteries in accordance with applicable chemistry or voltage requirements.
  • Minimize use of batteries with more stringent storage and shipping requirements.
  • Fully understand the management, labeling, and shipping requirements for waste lithium-ion batteries.
  • Keep track of supplies such as storage containers, labels, tape, or bags (terminal protection).
  • Schedule pick-ups at intervals that avoid exceeding the one-year storage limit.
  • Complete the U.S. DOT hazardous material training and complete the refresher training within the three-year requirement.

If you have any questions about universal waste or specifically waste batteries, please reach out to me at agolding@all4inc.com or Karen Thompson at kthompson@all4inc.com. ALL4 is here to answer your questions and assist your facility with all aspects of hazardous and universal waste management.


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