Universal Waste Management


Please see the Environmental Documents page for program-specific environmental documents and work instructions.

Universal wastes are hazardous wastes that are subject to less stringent hazardous waste management regulations, particularly by allowing more time for accumulation of these wastes in order to facilitate appropriate recycling or disposal. Five types of waste are covered under the universal waste regulations:

Universal waste can be stored for up to one calendar year before being shipped off site. However, Fort Novosel requires generators to turn them in for disposal within six months in order to ensure the shipment timeframe is met.

The accumulation start date must be marked on all universal waste containers, indicating the date the first item was added.

Labeling and storage requirements differ for hazardous waste and universal waste. Please ensure personnel handling these wastes receive proper training and follow the proper procedure for each type. For additional information on Universal Waste Management, please refer to the HWMP and the associated Work Instructions. For more information on hazardous waste, please see the Hazardous Waste Management program page


A used battery is a device that produced electricity and may have several primary or secondary cells arranged in parallel or series. The following table provides common battery types used on Fort Novosel. Non-hazardous, universal waste, and lead-acid batteries should each be segregated from the other types to ensure proper handling.

All containers of batteries will be reviewed by HMCC staff prior to turn in. Please coordinate in advance with HMCC (Bldg. 1315, 334-598-1037) for amounts in excess of one 5-gallon container of batteries. Following HMCC review, of large quantities of batteries should be taken to the Fort Novosel Recycling Center (Bldg. 9322, 334-255-0468).

Used batteries must be accumulated in a properly labeled, DOT-approved container with a closing lid; or, for larger lead-acid batteries, stored in covered areas on pallets or in a covered spill containment pallet. Batteries should not be stored directly on the ground or the floor. All batteries must be stored with consideration for potential compatibility issues. Example labels by battery type are provided in the table below. 

Battery Types


Example Label

Alkaline (9-volt, D, C, AA, AAA, alkaline button, etc.)

Non-Hazardous Waste (NR), recycled when possible

Lithium, Nickel-Cadmium, Mercuric-Oxide (button and other), Nickel-Metal Hydride, Silver Oxide, Silver-Zinc, Zinc-Carbon, Zinc Air

Universal Waste (UW), recycled when possible. Generators are required to prevent short-circuiting by:

·         Placing batteries in the original inner package,

·         Taping the positive end of the batteries, or

·         By using plastic "baggies" to separate individual batteries

Leaking / Damaged NR or UW Batteries

Place in a sealed plastic bag or wrap with plastic and seal with tape before adding to container with intact used batteries

Either NR or UW label depending on type


Managed as one-for-one exchange for recycling; coordinate through HMCC

No label required

Leaking / Damaged Lead-Acid Batteries


Hazardous Waste (HW), turn in through 90-Day site.

Refer to ENV-SW010: Contractor Hazardous Waste Management and call 334-255-1024 for assistance.

Battery Containing Equipment

Remove and manage batteries by type when possible; turn in batteries to HMCC and equipment to Recycling Center.


If batteries cannot be safely removed, ensure they are securely installed in the equipment and turn in to Recycling Center.

Label container with removed batteries by type.

No label required on equipment.

Please refer to the HWMP and ENV-SW002: Used Battery Management for details.


The universal waste requirements do not apply to pesticides that are not wastes or are not hazardous wastes. See Pest Management program page for more information on pesticides.

Mercury-Containing Equipment

Mercury-containing equipment means a device or part of a device (including thermostats but excluding batteries and lamps) that contains elemental mercury integral to its function. Thermostats and thermometers that contain mercury are the most common types of this equipment found on Fort Novosel.

Organizations manage these items as a universal waste when they are no longer usable. The items must be accumulated in a DOT-approved closed container that is labeled “UNIVERSAL WASTE - MERCURY CONTAINING EQUIPMENT.” Because the thermostats and thermometers can be easily broken, care must be taken when packaging this waste. Organizations should obtain vermiculite to package these items in a manner to prevent accidental breakage. Before the six-month mark is reached, the organization should turn in the waste to the HMCC for disposal through the DLADS contractor.


Lamps are the bulb or tube portion of an electric lighting device. Universal waste lamps include all fluorescent and high-intensity discharge (HID) lamps, including mercury vapor, metal halide, metal hydride, halogen and high-pressure sodium lamps, as described in ENV-SW003: Used Lamps Management. Many of these lamps contain levels of mercury which require special handling and disposal. Lamps that are not waste because they have not been discarded or that are not hazardous waste are not universal wastes.

Used lamps must be accumulated in a DOT-approved container (or the original container and sealed with tape), labeled “UNIVERSAL WASTE – USED LAMPS”. The container must be kept closed at all times except when adding or removing bulbs.

Broken lamps shall be collected, doubled-bagged in plastic bags, and containerized in accordance with the procedures in ENV-SW003: Used Lamps Management. The collected waste shall be managed as hazardous waste in a HWSAA or 90-HWCAA in accordance with the HWMP. Vacuums/HEPA vacs shall not be used to clean up broken lamp spill residue because the mercury vapor may be released when heated during subsequent uses of the equipment.

Aerosol Cans

An aerosol can is a non-refillable receptacle containing a gas compressed, liquefied, or dissolved under pressure, the sole purpose of which is to expel a liquid, paste, or powder and fitted with a self-closing release device allowing the contents to be ejected by the gas. (40 CFR 273.9)

All aerosol containers must be turned in to the HMCC for proper management and/or disposal. The HMCC will make the determination of aerosol serviceability.

Used aerosol cans must be accumulated in a compatible, structurally sound container labeled “USED AEROSOL CANS” and “RETURN TO HMCC”. Leaking aerosol cans must be packaged in a separate closed container or overpacked with absorbents and be turned in immediately to be safely punctured and drained by HMCC staff.

Aerosol cans with product may be put into the Free Issue Program. The Free Issue Program allows excess, usable materials to be donated back to the HMCC for redistribution to minimize hazardous waste generation.

Aerosol cans that are not a hazardous waste are not a universal waste (ex: compressed air for cleaning electronics, sunscreen or whipped cream). Empty aerosol cans (defined in 40 CFR 261.7) are not a universal waste. Nonhazardous and empty aerosol cans are punctured and recycled as scrap metal.

Aerosol cans are frequently hazardous due to flammable propellants such as propane or butane, or for other listed hazardous components or characteristics. Aerosols that are not functioning will either be punctured and processed as scrap metal or will be properly disposed of by the HMCC. 

Universal Waste Inspections

In order to help ensure universal waste is properly managed, organizations are encouraged to use the universal waste section of USAACE Form 2717, Environmental Compliance Inspection Checklist (from the link on this page) to assess compliance of their accumulation practices.

Contact Information

Hazardous Waste Program Manager: Bldg. 1121, 334-255-1024

Hazardous Materials Control Center (HMCC): Bldg. 1315, 334-598-1037