FLC Universal Waste Management Plan

The purpose of this plan is to inform interested persons that Fort Lewis College is complying with Colorado Division of Public Health & Environment (CDPH&E) requirements for handling universal wastes (UW).

This plan applies to all departments and laboratories where materials identified potential as universal wastes are used.  Universal wastes in Colorado include the following materials:

  • Batteries, including nickel-cadmium, lithium, button and some alkaline 
  • Pesticides
  • Mercury-containing devices
  • Mercury-containing lighting wastes
  • Electronic devices and components
  • Aerosol cans containing hazardous materials

Fort Lewis College is a Conditionally Exempt Small Quantity Generator (CESQG) based on the definitions of the CDPH&E.  Fort Lewis College will follow the UW Small Quantity Handler (SQH) guidelines relative to training, record keeping, storage and shipping to protect the campus community and environment surrounding the campus.

The universal waste plan is intended to minimize the hazards to human health or the environment from improper handling or disposal of these wastes in landfills. Written procedures for handling universal wastes set standard practice for daily, weekly, monthly, and even annual clean-up. Well written universal waste handling procedures can yield the following benefits:

  • Lower operating costs due to cost savings of recycling.
  • More efficient time management due to organization of materials, records, data.
  • Improved control over resources and data due to better maintenance and organization of those resources.
  • Conservation of resources, since resources can be better maintained and most efficiently used.

The Environmental Health & Safety (EH&S) Department is responsible for developing and maintaining this program, for maintaining any records generated in the course of managing this program and for insuring compliance with the CDPH&E rules and regulations.  A copy of the plan may be reviewed by employees during normal business hours in EBH 227.  Fort Lewis College encourages suggestions from our faculty, staff and students for improving our universal waste plan, as the College is committed to developing and maintaining an effective plan. Goals for this plan include a better understanding of the laws, safe behavior from associates involved in handling universal wastes and active involvement in the plan from every level of the campus.

Sources of Waste

It is the intent of Fort Lewis College to assure that accumulations of universal wastes are monitored so that they are disposed of properly. Certain activities on campus generate universal waste, including the use of:

  • Mercury thermometers used in heating, ventilation and air-conditioning systems, laboratory thermometers and lab equipment
  • Fluorescent light bulbs and lamps, high intensity discharge lamps, mercury vapor lamps, metal halide and sodium pressure lamps
  • Batteries from portable, hand-held equipment; radios, smoke and fire detectors, cameras, computers and emergency lighting units
  • Pesticide containers – recalled, obsolete, banned products or damaged containers of products in use
  • Consumer electronics that have been identified as failing the EPA toxicity test for heavy metals, such as computer monitors, cathode ray tubes, and circuit boards
  • Aerosol cans containing hazardous materials, such as paint, brake cleaner or other solvents.

Handling Universal Wastes

Battery Management

Spent universal waste batteries are handled in a manner that prevents releases to the environment.   Examples include:

  • Comply with packaging requirements. 
  • Have implemented procedures to follow when handling batteries (e.g., sort battery types, mix battery types, dissemble battery packs, remove electrolyte and tape contacts to prevent shock). 
  • Place universal waste batteries that show evidence of leakage, spillage, or damage in a container that closes, is structurally sound and is compatible with the contents of the battery. 
  • Label/mark containers in the PPS yard and Chemical Storage Building to identify the type of universal waste inside as specified by the CDPH&E. 

Pesticide Management

Suspended, canceled, obsolete and recalled pesticides are handled to meet one of the following conditions: 

  • Containers remain closed, are structurally sound, compatible with the pesticide, and lack evidence of leakage, spillage, or damage that could result in further leakage under reasonably foreseeable conditions. 
  • Pesticides in containers not meeting the criteria above are re-packed in a container that does. 
  • Containers and storage cabinets are labeled and marked to identify the type of universal waste inside. 

Mercury-containing Equipment Management

Spent mercury-containing equipment is handled in a way that prevents releases of mercury to the environment.  Examples include: 

  • Place leaking universal waste mercury-containing equipment with non-contained elemental mercury in containers that do not leak and are reasonably designed to prevent the escape of mercury into the environment by volatilization or any other means. 
  • Label/mark containers to identify the type of universal waste inside.
  • Note:  mercury spill kits are stored in the Chemical Storage Building and are available  for use for cleaning up small spills – such as a broken thermometer.

Mercury-containing Lighting Waste

There are numerous types of mercury-containing lights on campus.  These include fluorescent, neon, mercury vapor, high-pressure sodium, metal halide, and other hazardous waste lamps.  When handling spent lamps and bulbs we: 

  • Contain any lamp in containers or packages that are structurally sound, adequate to prevent breakage, and compatible with the contents of the lamps. Such containers and packages remain closed and must lack evidence of leakage, spillage, or damage that could cause leakage under reasonably foreseeable conditions. 
  • Immediately clean up and place in a container any lamp that is broken and place in a container any lamp that shows evidence of breakage, leakage, or damage that could cause the release of mercury or other hazardous constituents to the environment. 
  • Containers are closed, structurally sound, or compatible with the contents of the lamps and lack evidence of leakage, spillage, or damage that could cause leakage or reasonably foreseeable conditions. 

Electronic Devices and Components

Electronic devices and components that might fail the EPA toxicity test are collected by the Central Stores Department and shipped to a reclamation facility in the Denver area.  This process is managed by the Purchasing Department and usually occurs on a quarterly basis.  Equipment is stored in a zircon storage unit to prevent exposure to weather.

Aerosol Cans which Contain Hazardous Materials

Aerosol cans sometimes need to be discarded before they are completely empty.  This occurs for a variety of reasons, including when the spray mechanism no longer operates as designed, the propellant is spent or the product is no longer needed or used.  It is our responsibility to determine if the materials in an aerosol can are hazardous.  Aerosol cans containing hazardous materials that are still in use are not considered hazardous wastes.  If the contents of the aerosol cans are hazardous, they must be managed in compliance with the Colorado Hazardous waste regulations.  Aerosol cans that are empty or that contain materials that are not considered hazardous wastes may be managed as solid waste.

Accumulation of Universal Wastes

Although we take every precaution to prevent any spills of battery acid, pesticides, mercury or other hazardous materials, we are prepared in the event one should occur. We are careful about the containers we select to store and ship our spent batteries, pesticides, or mercury-containing equipment in and we have appropriate containment and personal protective equipment available for response personnel. 

As a CESQG we:

  • are limited to generating 100 kilograms (~25 gallons or 250 pounds) of total hazardous waste per month
  • are limited to generating no more than 1 kilogram of acutely hazardous waste per month
  • must never accumulate more than 1000 kilograms of hazardous waste on site at any one time.
  • must identify which wastes are hazardous, which are UW and ensure that the hazardous wastes are sent to a licensed facility for disposal.

Under Colorado law, we are regarded as a Small Quantity Handler.  By definition, Fort Lewis College cannot accumulate more than 5,000 kilograms of total universal waste at any one time.  As a SQH we cannot accumulate more than 35 kilograms of elemental mercury at one time. 

There is a one year accumulation time limit for UW on campus.


UW must be labeled in one of three manners.  Using spent batteries as an example the options are:

  • Waste Batteries
  • Used Batteries
  • Universal Waste Batteries

If UW is stored in an accumulation container, then only the container has to be labeled.  Waste containers must be maintained in good condition; if leaking they must be placed in an over-pack container or removed and placed into a container that is in good condition.  Any individual item showing signs of leakage must be stored in an over-pack container.


SQHs are not required to notify the CDPH&E of their UW management activities.  Representative from the federal EPA or CDPH&E have access to all records upon request.


SQHs are required to inform all employees who manage universal waste about the proper handling and emergency procedures appropriate to the types of universal waste at the facility.  Under our plan, employees will be informed of appropriate handling techniques for batteries, pesticides, and mercury-containing equipment, electronic devices and aerosol can.  Additionally, training will include methods for handling UW during maintenance activities, proper packing and storage practices before disposal, and shipping protocol. In addition, they will receive appropriate hazard communication training for the hazardous substances contained in the universal wastes found on campus.


SQHs are required to immediately containerize and manage any spills or residues from releases of UW.  Any waste generated from a spill is considered newly generated waste, and a hazardous waste determination is required.  If determined to be a hazardous waste, it must be managed as a hazardous waste and not as a UW.

Shipping Universal Wastes

In order for our recycling efforts to succeed, we must follow CDPH&E’s requirements for universal wastes being shipped to treatment/disposal facilities. The EH&S department is responsible for coordinating shipments of universal wastes.  Aspects of this process include ensuring UW is properly stored, tracking the amount of accumulated UW, retaining a licensed UW contractor for pickup and shipment, tracking receipt of shipped waste from the state approved Treatment, Storage and Disposal (TSD) facility.

Maintaining the Plan

The EH&S department is responsible for: 

  • Conducting periodic audits of storage sites on campus. 
  • Maintaining records of all inspections and reports. 
  • Updating the plan as needed by incorporating any necessary changes resulting from major changes relative campus operations or maintenance.

Updated 11/2009