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Universal Waste Management in Tennessee

Universal waste is a specific subset of hazardous waste subject to less stringent management requirements than regular hazardous waste. Certain types of batteries, lamps (lightbulbs), pesticides, and mercury-containing equipment are potentially eligible for the less stringent universal waste requirements.

In Tennessee, hazardous waste generators and handlers may elect to manage non-hazardous items in these categories as universal waste. For example, a non-hazardous battery can be managed as a universal waste battery in order to reduce the regulatory burden on trying to separate or identify non-hazardous waste materials from hazardous waste materials. Universal waste management requirements in Tennessee closely mirror the federal universal waste management requirements.

Questions and answers on universal waste management and issues can be found in RCRA Online on the U.S. EPA website.

More federal guidance on universal waste can be found at epa.gov/hw/universal-waste.

A key difference between federal and state universal waste regulations is that Tennessee permits the utilization of lamp (bulb) crushers. Strict standards apply to operators of lamp crushers. Standards for lamp crushers are found at the end of Rule 0400-12-01-.12 in paragraph (8).

Another key difference from the federal regulations is that universal waste destination facilities in Tennessee are subject to a state annual maintenance hazardous waste fee per Rule 0400-12-01-.08(4)(c). See the Hazardous Waste Forms page for more information on this fee.