Campus Resources

Department of Health, Safety & Environmental Compliance

Universal Waste


Saint Joseph ’s University (SJU) will consider its environmental responsibilities in making universal waste decisions. SJU will purchase materials (when possible) that are:

batteriesRecyclable. If not recyclable, disposed of safely

  • Non-toxic or minimally toxic, preferably biodegradable
  • Highly energy-efficient
  • Made from raw materials that have been obtained in an environmentally sound, sustainable manner
  • Subject to minimal or no environmental damage during normal use or maintenance
  • Shipped with minimal packaging (consistent with care of the product), preferably made of recycled and or recyclable materials


Universal Wastes are wastes that do meet the regulatory definition of hazardous waste, but are managed under special, tailored regulations. These wastes include:

  • batteries
  • pesticides
  • lamps/fluorescent bulbs
  • mercury-containing equipment/thermostats


Waste should be stored in a manner which prevents discharge into the environment. For example, batteries should be stored so that acids will not enter the environment. Lamps should be protected from breakage and exposure to the environment.

The number of Universal Waste storage areas should be limited, preferably one per building. Identification of new Universal Waste locations must be reported to the Director, Safety, Health and Environment within 30 days of installation.


Labeling of all Universal Waste is required immediately when stored. Storage is permitted only in designated areas marked “For storage of Universal Waste Only”. Labels must include the following words:

1) Universal Waste

2) Waste description

3) The date first stored.

See attachment A for example Universal Waste Label

Labels must be placed on each waste item or on the container holding multiples of the same items.. Universal Waste Labels can be easily ordered or printed for specific wastes by the stockroom.

Specific item labeling and storage requirements


  • All used lamps will be stored in a separate closed container. Containers will be dated when first used. Example: A carton of spent fluorescent bulbs should be labeled “Universal Waste-Fluorescent Bulbs-00/00/00 (Month/Day/Year) when the first bulb is stored in the carton.
  • A preventive maintenance work order will be issued to all zone mechanics every 60 days to remove used containers.
  • All used lamp containers will be sealed and transferred to the Sullivan Garage on a regular basis for pick up by the waste disposal contractor.


  • All Facilities Management personnel will return used batteries to the Overbrook stockroom before replacement. Batteries will be separated and stored in sealed containers.
  • A preventive maintenance work order will be issued every 60 days to the Stockroom Manager to move used batteries to Sullivan Garage for scheduled pickup.


  • Pesticides use is outsourced to a contract exterminator.
  • The Facilities grounds crew does not use pesticides.
  • The Fieldhouse pool uses bromine which is installed by Main Line Pools. The Aquatics Director must have a current pesticide license. A copy of this license is available in the pool area.

Mercury Containing Device:

  • The Facilities Department has replaced most mercury thermostats with pneumatic or

Electronic devices. If a mercury thermostat switch or other device is encountered, the Associate Director for Facilities Management should be contacted for removal and transfer to the approved Science Center location for recycling.


Personnel with Universal Waste responsibilities will perform a monthly inspection to:

  • Confirm that all items/containers in Universal Waste Storage locations are properly labeled.
  • Inspect buildings to insure that Universal Waste is not stored in areas not designated for this purpose
  • Check that dumpsters do not contain Universal Waste

All of the above inspections will be documented and include:

  • the area description
  • a checkmark that the area is acceptable/unacceptable
  • if unacceptable, a description of the problem identified
  • action taken to address the problem

Forms should be signed and returned to supervision for filing and access by Director, Safety, Health and Environment.


Transfer of Universal waste from building storage areas to the disposal contractor pick-up location will be arranged by the building Facilities representative. This transfer is recommended no more than 90 days from the start date of accumulation.  Universal waste should be removed from the campus pick-up location no later than 6 months from the date of generation.

The University’s contract terms and conditions require contractors to dispose of all waste according to EPA guidelines.

Waste Battery Disposal Policy:

The Facilities Department l accepts most types of batteries for disposal with the exception of alkaline batteries. This includes Alkaline, Lithium, Mercury, Nickel Cadmium (NiCad) and Nickel Metal Hydride


Alkaline (carbon-Zinc): These are common non-rechargeable batteries that most people use. Alkaline batteries are not regulated as hazardous waste and can be disposed of in the regular trash or sent to be recycled.

Lead-Acid batteries: These include automotive and smaller gel-cell batteries commonly use in emergency lighting systems. Lead-Acid batteries contain regulated amounts of lead and must be recycled.

Lithium Batteries: These batteries come in a variety of shapes and sizes, and are commonly used in computer clocks, cameras, watches, and other equipment.

Mercury batteries: These are usually small and button shaped. Mercury batteries contain regulated amounts of mercury and should be handled as hazardous waste. These batteries are no longer available in the United States although they may still be found in older equipment.

Nickel-Cadmium: These are the most common rechargeable batteries and are commonly found in cellular phones, and other types of rechargeable equipment. NiCd batteries contain regulated amounts of cadmium and should be handled as hazardous wastes.

Nickel Metal Hydride: These are rechargeable batteries that are commonly used in cordless hand tools and other types of equipment.

Pickup of Universal Waste is coordinated by the Director, Health and Safety/Environmental Compliance Officer at 610-660-3037

Attachment A—Sample Universal Waste Label