Universal Waste Program

                                                                                                                                                     April 2022


To ensure that employees know about proper handling and emergency procedures appropriate to the types of universal wastes being handled at Amherst College.


Applies to employees who handle or manage universal waste.

  • The United States Environmental Protection Agency (U.S. EPA) enacted the Universal Waste Rule to reduce the amount of hazardous waste and encourage recycling.


Generator: A person, by site, who by act or process produces hazardous waste identified or listed in 310 CMR 30.1000, or whose act first causes a hazardous waste to become subject to regulation.

Universal Waste Handler:

  1. A generator of universal waste; or
  2. The owner or operator of a facility that receives universal waste from other universal waste handlers, accumulates universal waste, and sends universal waste to another universal waste handler, to a destination facility, or to foreign destination.

Types of Universal Waste Recycled at Amherst College

  • Batteries such as Lithium-ion (Li-ion), mercury-containing button-cell (Alkaline Manganese Oxide, and Silver Oxide), Nickel Cadmium (NiCd), Nickel Metal Hydride (NiMH) and sealed Lead-Acid batteries.  Examples: calculator, camera, car, cell phone, laptop and watch batteries.
  • Mercury-containing devices such as manometers and non-broken thermometers.
  • Mercury-containing lamps such as compact fluorescent, fluorescent, and high pressure sodium bulbs.
  • Pesticides (e.g., arsenicals, chlorinated, mercury-based), pesticides that have been recalled or banned from use, and/or pesticides that are obsolete, have become damaged or are no longer used due to changes in application practices.

Universal Waste Guidelines

  • Universal wastes must be stored in a separate area marked as “Universal Waste Storage Area.”
  • Label universal waste containers/boxes with a Amherst College universal waste label.
  • Date the universal waste container/box when the first item of waste is placed into the container.
  • Store containers/boxes in a manner to prevent breakage of the contents.
  • Keep containers and boxes closed unless adding or removing universal waste.
  • Use only containers that are structurally sound, closed, and compatible with contents.
  • For lamps, it is recommended that the original box which the lamp was purchased in be used to store the waste lamp.  Thus, please ensure that you keep these containers.
  • For batteries, it is recommended that universal waste batteries be stored in an approved plastic container with a lid. Recycling containers can be obtained by contacting the Service Center at (414) 542-5038.
  • Keep storage areas clean and orderly at all times.

Disposing of Universal Waste

  • When containers of lamp boxes are full, tape the box closed.
  • To arrange for disposal of batteries, mercury-containing lamps, and mercury-containing devices, contact the Recycling Office at (413) 542-5038.
  • To arrange for disposal of pesticides, contact the EH&S Office at (413) 542-8189.
  • Please keep in mind that materials you use for personal use and dispose of at home may be considered hazardous waste when used and disposed of at Amherst College.
  • No employee should transport universal waste from home to Amherst College for disposal.

Handler Category and Accumulation Time Limits

  • Amherst College is small quantity handler (accumulates <5,000 kg of combined universal waste on site at any one time) of universal waste.
  • We may accumulate universal waste for no longer than 1 year from the date the universal waste is generated.
  • Universal waste must be shipped by a Universal Waste Transporter to an approved facility. Amherst College is not a Universal Waste Transporter.

Employee Information and Training

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

At Amherst College, handlers of universal waste shall be trained:

  • Upon initial assignment and annually, thereafter.

Guidance for Leaking Batteries

If you see any leaking or deformed batteries, or suspect any other issues with universal wastes:

  • Notify others in the area and post a warning sign.
  • Dial the EH&S Office at (413) 542-8189 or the Service Center at (413) 542-2254 to report nature and location of emergency.