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Retail Initial Discussion Topic - Universal Waste

Universal waste has alternative management requirements identified in Rule 228 of the Part 111 hazardous waste rules.  Hazardous waste may be managed to meet the streamlined universal waste standards instead of following the more stringent hazardous waste generator accumulation requirements.  Two primary benefits of managing hazardous waste as a universal waste is that the weight of the waste is not included when determining a site’s monthly hazardous waste generator status and the waste can be stored for up to one year, instead of the 90 or 180 days designated under the hazardous waste generator accumulations regulations.

Michigan includes additional types of universal wastes than what is included in the federal universal waste regulations and there are a few differences between the state and federal universal waste requirements.  If generators do not handle these materials as universal waste, they need to manage them under the hazardous waste regulations when they are listed hazardous waste or exhibit hazardous waste characteristics. Those requirements will depend on a company’s hazardous waste generator status — large quantity, small quantity, or conditionally exempt small quantity generator.

Michigan facilities may choose to handle the following types of waste as a universal waste nationally:

  • Batteries, including spent dry cell and lead-acid batteries.
  • Pesticides, including certain suspended, canceled, or unused pesticides.
  • Electric lamps, including fluorescent, high intensity discharge (HID), sodium vapor or high pressure sodium, mercury vapor, neon, metal halide, and incandescent lamps.
  • Devices containing elemental mercury, including thermostats, switches, thermometers, manometers, barometers, anti-locking braking systems (ABS), gas flow regulators, hydrometers, blood pressure cuffs and various medical devices, etc.

Michigan facilities may choose to handle the following types of waste as a universal waste in Michigan only:

  • Pharmaceuticals or drugs, both prescription and non-prescription, that are used to diagnose, treat, cure, prevent, care for, or mitigate physical or mental illness in both human and animals.
  • Consumer electronics or devices run by electricity containing circuit boards commonly found in offices and homes such as computers, fax machines, telephones, televisions, and printers.
  • Antifreeze, meaning a mixture containing ethylene glycol or propylene glycol used as a heat transfer or dehydration fluid.

For additional information regarding Michigan’s universal waste regulations, consider viewing the recorded universal waste webinar and/or reviewing the Universal Waste Guidance.  For additional information regarding Michigan’s universal waste pharmaceuticals regulations and ways to minimize pharmaceutical waste, visit