800
-662-9278 Michigan.gov/EGLEWaste Rev. 5/2022
INTRODUCTION
The universal waste rules were designed to promote recycling and simplify disposal for certain types of
commonly generated hazardous waste. The universal waste rules reduce the regulatory burden in
managing certain types of hazardous wastes without compromising human health and environmental
protections. When managing waste under the universal waste rules, a generator can presume the
waste is a hazardous waste and manage it to meet all of the universal waste requirements.
UNIVERSAL WASTE DEFINITION
All facilities, including manufacturing industries, commercial businesses, governmental agencies,
health care providers, administrative offices, and other non-household waste generators, are
required to determine if they generate hazardous waste (see the Waste Characterization guidance).
Michigan facilities may choose to handle the following hazardous waste types as universal waste
under the streamlined universal waste standards:
• Aerosol cans: A container in which gas under pressure is used to aerate and dispense any
material through a valve in the form of a spray or foam.
• Antifreeze: A mixture containing ethylene glycol or propylene glycol used as a heat transfer
or dehydration fluid.
• Batteries: A device which consists of one or more electrically connected electrochemical
cells and which is designed to receive, store, and deliver electric energy. This category
includes hazardous waste batteries such as nickel-cadmium, spent lead-acid, and lithium
batteries.
• Consumer electronics: A device containing an electronic circuit board, liquid crystal display,
or plasma display which is commonly found in homes and offices and these devices when
used in other settings.
• Devices containing elemental mercury: A device or part of a device (excluding batteries and
lamps) that contains elemental mercury integral to its function. Some commonly recognized
devices are thermostats, barometers, manometers, temperature and pressure gauges, and
mercury switches, such as light switches in automobiles.
UNIVERSAL WASTE
GUIDANCE
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• Lamps: The bulb or tube portion of a lighting device specifically designed to produce radiant
energy, most often in the ultraviolet, visible, and infrared regions of the electromagnetic
spectrum. Lamps can exhibit the toxicity characteristic for some heavy metals (i.e., mercury,
lead, cadmium). Examples of universal waste lamps include incandescent, fluorescent, high
intensity discharge, neon, mercury vapor, high pressure sodium and metal halide lamps.
• Pesticides: Certain suspended, canceled, or unused pesticides.
• Pharmaceuticals: Drugs for both human and veterinary use.
Universal waste has alternative management standards found in Rule 228 of the Part 111 hazardous
waste rules. Generators may elect to manage universal waste types following these standards instead
of managing it as a fully regulated hazardous waste. The designation of consumer electronics,
antifreeze, and pharmaceuticals as a universal waste type is unique to Michigan. Moreover, by
February 22, 2022, EGLE is required to adopt new federal hazardous waste regulations for handling
hazardous waste pharmaceuticals from healthcare and rescind the designation of pharmaceuticals as a
universal waste type.
When households generate these types of wastes, they are not regulated in the same way unless the
household waste is mixed with universal waste from a non-household. If mixed, the mixture must all be
managed to meet the universal waste standards.
If generators choose not to handle these waste streams as universal waste, they need to manage them
to meet the requirements that apply to their generator category. Those requirements vary depending on
the weight of hazardous waste generated at the site each month. This information is used to determine
the site’s hazardous waste generator category — large quantity generator (LQG), small quantity
generator (SQG), or very small quantity generator (VSQG) of hazardous waste. The more hazardous
waste a site generates, the greater the hazard associated with the waste, and the more regulation the
site must meet. To understand the generator categories and requirements that apply, see the
Hazardous Waste Generator Category and Summary of Accumulation Requirements.
Universal waste spill and cleanup materials are not eligible for management as a universal waste. The
weight of the spill and clean-up materials must be included when making a site’s monthly generator
category determination. SQGs and VSQGs may consider using the episodic generator requirements
found under Rule 316 of the Part 111 hazardous waste rules to maintain their existing generator
category. For a summary of the episodic generator requirements, see the SQG Requirements and VSQG
Requirements guides.
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UNIVERSAL WASTE BENEFITS
Some of the biggest benefits to managing wastes under the universal waste standards include:
• The generator does not need to maintain elaborate waste characterization data, as the
waste is being managed as a hazardous waste under the most stringent environmental
standards for recycling or disposal.
• The generator does not include the weight of the waste when determining the site’s monthly
generator category. This can decrease a site’s generator category, minimize the regulatory
requirements the site must meet, and eliminate some of the recordkeeping needed for
generator category determinations.
• The generator may accumulate universal waste on-site for up to one year, much longer than
the 90 or 180 days allowed for LQGs and SQGs, respectively. This generally reduces cost by
minimizing the number of pick-ups needed for recycling or disposal.
• The generator has greater flexibility in locating accumulation containers. Containers can be
placed in areas convenient for staff. Universal waste containers do not have to be located
at the point of generation under the control of an operator or in an accumulation area with
secondary containment as is required when managing the waste under the SQG and LQG
regulations.
MANAGING UNIVERSAL WASTE
A business or government agency that generates or stores universal waste is a universal waste handler.
Sites that recycle, treat, or dispose of universal waste are universal waste destination facilities.
Destination facilities must comply with the state and federal requirements for recycling, treating, or
disposing of hazardous waste.
Universal waste handlers are classified as Small Quantity Handlers (SQH) or Large Quantity Handlers
(LQH) depending on the amount of universal waste accumulated at any one time. SQHs accumulate
less than 5,000 kilograms(kg) (11,000 pounds) total of all universal waste types combined at any time.
LQHs accumulate 5,000 kg (11,000 pounds) or more of all universal waste types combined at any time.
This designation as a LQH is retained through the end of the calendar year in which this amount of
universal waste accumulated exceeds the SQH limit.
The following table describes the requirements for both categories of universal waste handlers:
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REQUIREMENTS FOR SMALL AND LARGE QUANTITIY HANDLERS OF UNIVERSAL WASTE
Topic
Requirement
Site ID Number
SQH: Not required
LQH: Required before meeting or exceeding 5,000 kg of universal waste
Prohibitions
Must not dispose, dilute, or treat universal waste except when responding to
releases. Some limited activities are allowed and highlighted below.
Universal waste
accumulation
time limit
One year from the date the waste was generated or received from another
handler. The time limit must be tracked. Mark the universal waste with the
generated or received date or keep records to verify how long you have
accumulated it.
Labeling
Required, see below.
Accumulation
Containers and tanks must be in good condition, structurally sound, and
compatible with the type of universal waste accumulated in them. Containers
and tanks must be accumulated in a manner that prevents any spills or releases.
Tanks must meet all requirement found under Title 40 of the Code of Federal
Regulations, Part 256, Subpart J.*
Employee
training
SQH: Employees must be informed of proper universal waste handling and
emergency procedures. Training records are not required.
LQH:
Employees must be thoroughly familiar with proper universal waste handling
and emergency procedures. Training records are not required.
Releases from
universal waste
Must prevent releases of universal waste to the environment; must immediately
contain, clean up and properly characterize any such releases. Depending on the
type of universal waste and release, there may be release reporting requirements
under various regulations. Learn more at Michigan.gov/ChemRelease.
Hazardous
waste
manifests/Land
Disposal
Restriction
(LDR)
notification
forms for off-
site shipments
Hazardous waste manifests and LDR notices are not required for shipments of
universal waste within Michigan. For shipments received from a state that does
not recognize the universal designation, or if a receiving state does not recognize
the universal designation, use a hazardous waste manifest and include a note in
Box 14 indicating waste was managed as a universal waste when in Michigan.
For shipments of pharmaceuticals from states that adopted Subpart P, use a
hazardous waste manifest, include the “PHARM” or “PHRM” code in Box 13, and
note in Box 14 that it was managed as a universal waste when in Michigan and
list all applicable waste codes for the shipment. If waste is liquid, a permitted,
registered and insured liquid industrial by-products transporter is required and
the shipment must be documented on a liquid industrial by-products shipping
document. If shipment is a hazardous material, US DOT packaging, labeling,
marking, placarding, shipping papers and training rules apply.
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REQUIREMENTS FOR SMALL AND LARGE QUANTITIY HANDLERS OF UNIVERSAL WASTE - Continued
Topic
Requirement
Off-site
shipments
Ship only to a site that has agreed to accept the universal waste. Confirm the
universal waste destination facility receiving the shipment is an authorized
destination facility. If hauling own liquid waste generated from equipment which
you own, maintain required insurance for liquid industrial by-products transport.
Recordkeeping
SQH: Not specifically required but is recommended to:
demonstrate SQH category is maintained, and
universal waste is accumulated for no more than 1 year.
Labeling and signage may be used for demonstrating compliance as well as
records.
LQH: Must keep a record of each shipment received at, or sent from, the facility
for three years from the shipment date (e.g., logs, manifests, bills of lading). The
following must be recorded:
Name and address where the waste came from if received from another
handler or where it was shipped to.
Quantity of each waste type (e.g., batteries, electric lamps, pesticides, or
mercury containing devices) received or shipped out.
Date when shipment was received or sent out
Reporting
Required for universal waste handlers and destination facilities accepting
universal waste liquids from another universal waste handler.
* Depending on the type and amount of universal waste being accumulated, secondary containment and
surveillance may be required under the water regulations. To learn more, go to Michigan.gov/Part5.
AEROSOL CANS
Aerosol cans are a common waste generated by most businesses. Aerosol cans contain a product
and propellant under pressure. The product is released from the aerosol can (the container) in the
form of a spray or mist when the nozzle is pressed to apply the product. As the product is used, the
propellant is also used. An aerosol can is specifically defined under the hazardous waste regulations
as a non-refillable container that:
• contains a gas compressed, liquified, or dissolved under pressure, for which the sole purpose
is to spray a liquid, paste, or powder, and
• is fitted with a self-closing release device which allows the contents to be ejected by the gas.
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Examples of products commonly dispensed using aerosol cans include:
• maintenance products (degreasers and cleansers)
• beauty products (hair sprays and perfumes)
• surface coating products (paints and varnishes)
• personal care products
• pharmaceutical products (inhalers), and
• pesticides (ant or wasp sprays)
Although EGLE does not consider empty aerosol cans a reactive hazardous waste, some states do
and most solid waste vendors require special waste approvals for aerosols due to the explosion
hazard they present when compacted.
Unused aerosol cans become a waste on the date the universal waste handler decides to discard it.
Used aerosol cans become a waste when discarded and not empty. Non-empty aerosol cans that
contain pesticides may be managed as universal waste.
When managed as universal waste, the universal waste handler regulations require handlers to
manage aerosol cans in a way that prevents a release of any component of universal waste to the
environment. Universal waste aerosol cans must be accumulated in a container that is structurally
sound, compatible with the contents of the aerosol cans, and lacks evidence of leakage, spillage, or
damage that could cause leakage. Containers must be protected from heat sources (e.g., open
flames; lightning; smoking; cutting and welding; hot surfaces; frictional heat; and static, electrical,
and mechanical sparks).
Leaking or damaged aerosol cans must be either packaged in a separate closed container,
overpacked with absorbents, or immediately punctured and drained.
Individual aerosol cans or aerosol can storage containers must be labeled with the words “Universal
Waste—Aerosol Cans,” “Waste Aerosol Cans,” or “Used Aerosol Cans.”
Handlers may sort aerosol cans by type, mix intact cans into one container, remove nozzles to reduce
risk of accidental release, and puncture and drain empty aerosol cans if the cans are recycled and
residual liquids are properly characterized and managed.
Handlers that puncture universal waste aerosol cans must also meet the following requirements
specified under the universal waste regulations:
Puncturing and draining must be conducted using a device specifically designed to safely
puncture aerosol cans and effectively contain the residual contents and any emissions.
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Handlers must develop and follow a written procedure detailing how to safely puncture and drain
aerosol cans. This procedure must address proper assembly, operation, and maintenance of the
puncturing unit, segregation of incompatible wastes, and proper waste management practices to
prevent fires and releases. Handlers must maintain a copy of the puncturing device
manufacturer’s instructions onsite and ensure employees operating the device are trained in the
proper procedures.
Puncturing must be performed in a manner designed to prevent fires and releases into the
environment. This includes, but is not limited to, locating the equipment on a solid, flat
surface in a well-ventilated area.
The contents from the waste aerosol can or puncturing device are immediately transferred to a
container or tank that meets requirements of hazardous waste rules that apply to the site’s
generator status or the liquid industrial by-products generator requirements.
Handlers must determine if the contents from the emptied aerosol cans are hazardous waste.
Any hazardous waste generated from puncturing the cans is subject to all hazardous waste
regulations, and the handler is considered the generator of the hazardous waste.
Handlers must have a written procedure for cleaning up spills or leaks of the contents of the
aerosol cans. A spill cleanup kit must be provided, and all spills or leaks must be cleaned up
promptly.
Universal waste generators may also puncture and drain non-empty universal waste aerosol cans,
but secondary universal waste handlers cannot unless they are a universal waste destination
facilities licensed under the hazardous waste regulations. Air permitting and hazardous waste
licensing is required in some cases prior to installing aerosol can puncturing process equipment. For
details on additional regulations that apply to puncturing beyond the universal waste rules, please
see the aerosol can puncture guide.
ANTIFREEZE
Antifreeze is a mixture of water, coolant, and additives. It is used to protect engines and other
equipment against overheating and corrosion and also from freezing in low temperatures. It is also
used as a deicing agent for airplanes. The two most common coolants used in antifreeze are ethylene
glycol and propylene glycol. Most antifreeze is nonhazardous and may be managed as a liquid
industrial by-product. However, sometimes antifreeze becomes a hazardous waste because it contains:
• Regulated concentrations of lead or cadmium that leached from a radiator.
• Regulated concentrations of benzene from gasoline that leaked into the antifreeze.
• Listed solvents from over-spraying aerosol products such as brake and carburetor cleaners that
get into the antifreeze.
• Other hazardous wastes that were missed with the antifreeze.
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If a company assumes or specifically knows its antifreeze is hazardous and manages it as a universal
waste, it must be managed to meet the universal waste handler requirements, in addition to the
requirements for managing liquid industrial byproducts. Containers and tanks must be labeled with
words "Universal Waste Antifreeze," "Waste Antifreeze," or "Used Antifreeze.” The containers must be
kept closed, except to add or remove universal waste. The containers must be structurally sound,
compatible with the antifreeze, and lack evidence of leakage, spillage, or damage that could cause
leakage under reasonably foreseeable conditions. Storage tanks must meet additional requirements in
40 C.F.R. part 265, subpart J, except for 40 C.F.R. §§265.197(c), 265.200, and 265.201, which
includes, but not limited to:
• Professional engineer certifications required for new tank systems and integrity assessments of
existing tank systems.
• Inspections at least once each operating day.
• Secondary containment.
• General operating requirements.
Any spills must be immediately clean up, properly characterized and disposed.
BATTERIES
A battery is a device with one or more electrically connected electrochemical cells that is designed to
receive, store, and deliver electric energy. An electrochemical cell is a system that consists of an
anode, a cathode, an electrolyte, and any connections that are 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. An unused battery becomes a waste when the
handler decides to discard it. Batteries must be managed in a way that prevents releases to the
environment. Batteries that show evidence of leakage, spillage or damage that could cause a leakage
must be placed in a container that is closed, structurally sound, compatible with the contents of the
battery, and lacks evidence of leakage, spillage or damage that could cause a leakage.
Handlers are allowed to conduct the following activities with batteries that are intact:
• Sort batteries by type.
• Mix battery types in one containers.
• Discharge batteries to remove the electric charge.
• Regenerate used batteries.
• Disassemble batteries or battery packs into individual batteries.
• Remove electrolyte.
• Remove batteries from discarded consumer products.
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If a handler removes electrolytes from universal waste batteries, the handler must determine if the
electrolyte exhibits a characteristic of hazardous waste. If it exhibits a characteristic of hazardous waste,
it is a newly generated waste and not a universal waste and must be managed as a hazardous waste.
Universal waste batteries (e.g., each battery) or a container in which the batteries are contained must
be labeled with any of the following: “Universal Waste-Battery(ies)” or “Waste Battery(ies)” or “Used
Battery(ies).”
Lead acid batteries are banned from disposal in Michigan’s landfills and incinerators and are normally
handled under Rule 804 of the Part 111 rules, instead of the universal waste rule. Under Rule 804, the
company must characterize the waste batteries and meet LDRs including having the one-time
notice/certification on file. The LDR does not apply to VSQGs. When being recycled, the battery volume
is not included when determining generator category. It is not necessary to use hazardous waste
manifests when shipping the used lead acid batteries to a recycler, nor hire a permitted and registered
hazardous waste transporter. In addition, there is no time limit in the state regulations on how long you
may store the lead acid batteries before shipping. There may be local ordinances that have time limits
or other requirements. Shipments need to meet the US DOT transportation requirements unless it
meets an exception in 49 CFR 173.159.
CONSUMER ELECTRONICS
Consumer electronics are devices run by electricity containing circuit boards commonly found in offices
and homes such as computers, printers, fax machines, telephones, printers, televisions, etc. Cathode
ray tubes (CRTs) from equipment like computers and televisions may be handled as either consumer
electronics or electric lamps universal waste. Consumer electronics include intact devices. Dismantled
electronics do not qualify for management as a universal waste.
Consumer electronics must be managed in a manner that prevents breakage or a release by containing
the consumer electronics in packaging that will prevent breakage during normal handling conditions.
Handlers must properly contain, classify, and dispose of releases of consumer electronics and their
residues.
The outer packaging or a container must be labeled with the words “Universal Waste Electronics” or
“Universal Waste Consumer Electronics.”
Handlers may do any of the following under the universal waste regulation:
• Repair electronics for potential redirect reuse.
• Remove other universal waste, e.g., batteries from the electronics.
• Remove individual modular components for direct reuse.
• Wipe hard drives to destroy data.
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To find recyclers, search the Recycled Materials Market Directory for electronics or see the EGLE list of
registered electronic recyclers at Michigan.gov/EGLEEWaste. Many electronic waste ‘recyclers’ are
actually universal waste handlers that resell refurbished equipment and components. However, if a
recycler is processing electronic waste, please contact the Materials Management Division District
Office to discuss operations to determine if additional permits are needed.
DEVICES CONTAINING ELEMENTAL MERCURY
A thermostat is a temperature control device that contains elemental mercury in an ampule attached to
a bimetal sensing element and includes mercury-containing ampules that have been removed from the
temperature control device. Other device containing elemental mercury include mercury thermometers,
vehicle switches, and sphygmomanometers.
A used thermostat, mercury switch, or other device containing only elemental mercury as its hazardous
waste constituent becomes a waste on the date it is discarded. An unused device becomes a waste on
the date the handler decides to discard it.
The universal waste regulations do not apply to mercury that was removed from devices or ampules
(e.g., mercury collected in a container). Facilities will need to manage that mercury under the
hazardous waste rules that apply to their generator status.
Mercury-containing equipment with non-contained elemental mercury or that shows evidence of
leakage, spillage, or damage that could cause leakage must be placed in a container that is closed,
structurally sound, compatible with the contents of the device, lacks evidence of leakage, spillage or
damage that could cause leakage or releases of mercury or other hazardous constituents to the
environment, and reasonably designed to prevent the escape of mercury into the environment by
volatilization or any other means.
Handlers may remove mercury-containing ampules from if the following conditions are met:
Ampules are removed and managed in a manner designed to prevent breakage.
Removed the ampules only over or in a containment device.
A mercury clean-up system is readily available to immediately transfer any mercury resulting
from spills or leaks to a container.
Any mercury resulting from spills or leaks from broken ampules are immediately transferred from
the containment device to a container.
The area in which ampules are removed is well ventilated and monitored to ensure compliance
with OSHA exposure levels for mercury.
Employees removing ampules are thoroughly familiar with proper waste mercury handling and
emergency procedures.
Removed ampules are stored in closed, non-leaking containers that are in good condition.
Removed ampules are packed in the container with packing materials adequate to prevent
breakage during storage, handling, and transportation.
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If the handler removes the original housing that holds mercury in devices that do not contain ampules,
the handler must immediately seal the original housing to prevent a mercury release and follow the
ampule management requirements discussed above.
Handlers must determine if mercury clean-up residues resulting from spills or leaks or any solid waste
generated as a result of the removal of mercury-containing ampules or housings exhibit characteristics
of hazardous waste. If these materials exhibit a characteristic of hazardous waste, they must be
managed in compliance with all hazardous waste rules that apply to their generator status. The handler
is considered the generator of the mercury residues, and/or other spill clean-up waste.
Universal waste mercury-containing equipment (i.e., each device), or a container in which the
equipment is contained, must be labeled, or marked clearly with “Universal Waste - Mercury-Containing
Equipment,” or “Waste Mercury-Containing Equipment,” or “Used Mercury-Containing Equipment.”
A universal waste mercury-containing thermostat or container containing only universal waste mercury-
containing thermostats, must be labeled, or marked clearly with “Universal Waste - Mercury
Thermostat(s),” or “Waste Mercury Thermostat(s),” or “Used Mercury Thermostat(s).”
LAMPS
A lamp is the bulb or tube portion of a lighting device specifically designed to produce radiant energy,
most often in the ultraviolet, visible, and infrared regions of the electromagnetic spectrum. Common
lamps include fluorescent, high intensity discharge, sodium vapor, mercury vapor, neon, and
incandescent lamps, light emitting diode, and cathode ray tubes (CRTs) from computers and televisions.
A company may choose to handle CRTs as consumer electronics or electric lamp universal waste in
Michigan.
Used lamps become waste on the date the handler permanently removes it from its fixture. Unused
lamps become waste on the date the handler decides to discard it.
Lamps must be managed in manner that prevents releases to the environments and must be stored in
packages that are structurally sound, adequate to prevent breakage, compatible with the contents of the
of the lamps, closed, and lack evidence of leakage, spillage, or damage that leakage or releases of
mercury or other hazardous constituents to the environment.
Handlers must immediately clean up and place any lamp that is broken in packaging and place any
lamp that shows evidence of breakage, leakage, or damage that could cause the release of mercury or
other hazardous constituents to the environment in packaging that is structurally sound, adequate to
prevent breakage, compatible with the contents of the of the lamps, closed, and lack evidence of
leakage, spillage or damage that leakage or releases of mercury or other hazardous constituents to the
environment. Broken lamps generally cannot be handled as universal waste in Michigan. Additionally,
many recyclers only want to handle unbroken/uncrushed lamps. If you are managing lamps as a
universal waste and experience incidental breakage while handling, if the container remains intact and
closed, preventing any release, contact your universal waste handler to determine whether they can
UNIVERSAL WASTE – GUIDANCE
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accept your waste and any additional requirements you must take to ensure proper handling upon
receipt.
Individual lamps or storage containers must be labeled with the words “Universal Waste Lamp(s)” or
“Waste Lamp(s)” or “Used Lamp(s).”
Do not crush or break the lamps. Operating a lamp crushing device (sometimes called drum top
crusher) requires a permit from the Air Quality Division and there are additional hazardous waste
requirements. Once the lamps are broken, they cannot be managed as universal waste.
PESTICIDES
A pesticide is a substance or mixture of substances intended for preventing, destroying, repelling, or
mitigating any pest, or intended for use as a plant regulator, defoliant, or desiccant.
Recalled, suspended, and cancelled pesticides, and unused pesticides that have not been recalled but
are collected and managed as part of a waste pesticide collection program may be managed as a
universal waste. Recalled, suspended, and cancelled pesticides become a waste on the first date on
which the generator agrees to participate in the voluntary or mandatory recall and the person
conducting the recall decides to discard it. An unused pesticide becomes a waste on the date the
generator decides to discard it.
When managed as universal waste, handlers must manage pesticides in a way that prevents a release
or any component of universal waste to the environment. Universal waste pesticides must be contained
in one or more of the following:
• A container that is closed, structurally sound, compatible with the pesticide, and lacking
evidence of leakage, spillage or damage that could cause leakage.
• An overpacked container that is closed, structurally sound, compatible with the pesticide, and
lacking evidence of leakage, spillage or damage that could cause leakage.
• A tank that meets the requirements of 40 CFR part 265 subpart J.
• A transport vehicle or vessel that is closed, structurally sound, compatible with the pesticide; and
lacking evidence of leakage, spillage or damage that could cause leakage.
A container (or multiple container package unit), tank, transport vehicle or vessel in which recalled
universal waste pesticides are contained is labeled or marked clearly with the label that was on or
accompanied the product as sold or distributed and the words “Universal Waste—Pesticide(s)” or
“Waste Pesticide(s).”
PHARMACEUTICALS
Pharmaceuticals are chemical formulations used in the diagnosis, cure, mitigation, treatment, therapy,
or prevention of disease in humans or animals. A pharmaceutical becomes a waste when it can no longer
be administered to a patient and must be discarded.
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Universal waste pharmaceuticals must be accumulated in a manner that prevents release. They must
be placed in containers that remain closed, except to add or remove waste and the containers are to be
labeled with the words “Universal Waste Pharmaceuticals.” The container must be structurally sound,
compatible with the waste, and lack evidence of leakage, spillage, or damage that could cause leakage
under reasonably foreseeable circumstances. If a container does not meet these conditions, it is to be
overpacked in a container that does meet these conditions. Incompatible pharmaceuticals must be
segregated by adequate distance to prevent the contact of incompatible materials. If a release of
pharmaceuticals or component of pharmaceuticals occurs, the release must be immediately cleaned up
and properly characterized for disposal. Spill and clean-up waste cannot be managed as a universal
waste pharmaceutical.
Universal waste pharmaceutical handlers can disassemble packaging and sort pharmaceuticals.
Michigan is the only state with pharmaceuticals designated as a universal waste type. Consequently,
when managing universal waste pharmaceuticals in Michigan, they can be documented on a shipping
document and transported within Michigan by an authorized liquid industrial by-products transporter to
another universal waste handler. If the shipping only contains solid pharmaceuticals, no documentation
is required and an EGLE permitted and registered transporter is not required. However, when shipping
universal waste pharmaceuticals out of state, both solids and liquids, the shipment must be
documented on a uniform hazardous waste manifest and transported by a permitted and registered
hazardous waste transporter to a licensed hazardous waste disposal facility. Michigan recommends
noting in Box 14 of the manifest that the shipment was managed as a universal waste when managed
in Michigan. This helps verify that the weight of the shipment is not included when making a generator
category determination.
On February 22, 2019, the United States Environmental Protection Act issued new federal hazardous
waste rules for managing hazardous waste pharmaceuticals in healthcare. The federal rulemaking
prohibits healthcare providers nationally from sewering hazardous waste pharmaceuticals for disposal
as of August 18, 2020. Michigan has until February 22, 2022, to adopt the other mandatory
provisions in the rules into Michigan’s hazardous waste rules and abandon the designation of
pharmaceuticals as a universal waste. Until the federal rules are formally adopted and become
effective, pharmaceuticals may be managed as a universal waste in Michigan.
For additional information on handling pharmaceuticals now, and after Michigan adopts the new federal
rulemaking, please see the following resources:
• Handling Unwanted Pharmaceuticals and their Containers in Healthcare
• Recorded Webinar on Existing and Proposed Pharmaceutical Waste Regulations
• Webinar Notes Reflecting Proposed and Final Federal Rules for Pharmaceutical Waste
• Notice on Sewer Ban for Hazardous Waste Pharmaceuticals under New National Rules for
Healthcare
• MHA Healthcare Pharmaceutical Waste Management Guide
• MHA Guide Example Pharmaceutical Posting
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ADDITIONAL ASSISTANCE
For additional assistance, contact the Environmental Assistance Center at 800-662-9278 or
EGLE-[email protected] and ask to for the hazardous waste program staff in your county.
This publication is intended for guidance only and may be impacted by changes in legislation, rules, policies,
and procedures adopted after the date of publication. Although this publication makes every effort to
teach
users how to meet applicable compliance obligations, use of this publication does not constitute the rendering
of legal advice.
EGLE does not discriminate on the basis of race, sex, religion, age, national origin, color, marital status, disability,
political beliefs, height, weight, genetic information, or sexua
l orientation in the administration of any of its
programs or activities, and prohibits intimidation and retaliation, as required by applicable laws and regulations.
To request this material in an alternative format, contact EGLE-[email protected] or call 800-662-9278.
