Policy

All waste batteries, lamps, and waste light ballasts generated at the University of Chicago shall be handled and disposed of in accordance with applicable regulations. 

Off-site transportation and disposal of universal waste (UW) lamps and batteries shall be facilitated by a contracted service that is licensed, bonded, and permitted as a universal waste transporter and destination facility by the Illinois Environmental Protection Agency (IEPA). 

Off-site transportation and disposal of leaking batteries and leaking ballasts containing polychlorinated biphenyls (PCBs) shall be facilitated by a contracted service which is a licensed hazardous material hauler; all hazardous waste shall be transported to a federally permitted hazardous waste treatment facility.

The IEPA recognizes the following four categories of “universal waste”:

Universal Waste Batteries
Universal Waste Light Lamps (bulbs/tubes)
Universal Waste Pesticides
Universal Waste Mercury Devices

At the University, only waste batteries and lamps containing mercury are managed as UW. 

Pesticides and mercury-containing devices are treated as hazardous waste and should be managed under the procedures outlined in the Hazardous Waste Disposal Procedures Policy.

While light ballasts do not fall under the IEPA categories for Universal Waste, procedures outlining their handling and disposal are also covered by this policy.

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Authority and Responsibility

Facilities Services – Operations is responsible for:

1. Bringing waste lamps, batteries, and ballasts to the appropriate accumulation locations for storage;
2. Ensuring each storage location has containers (drums, boxes) appropriate for storing waste materials, materials for marking containers, and spill response materials;
3. Appropriately marking each storage container;
4. Ensuring waste lamps, batteries, and ballasts are regularly picked up for disposal with no waste remaining on site for more than one year from the accumulation start date or 90-days for leaking batteries or ballasts containing PCBs;
5. Ensuring personnel who handle waste lamps, ballasts, or batteries take required “Batteries, Lamps, and Ballasts - Waste Handling” training online within 90-days of the start of employment; and
6. Maintaining a service agreement with a permitted third-party universal waste disposal company and ensuring the third-party company operates within the terms set within the service agreement.

Facilities Services – Capital Project Delivery is responsible for:

1. Ensuring all hazardous waste, including universal waste, generated from demolition or renovation projects are appropriately handled and disposed of in accordance with this policy and the Hazardous Waste Disposal policy.

Environmental Health and Safety (EHS) is responsible for:

1. Providing waste handling training to employees;
2. Signing hazardous waste manifests used for shipping leaking batteries or ballasts containing PCBs;
3. Retaining copies of hazardous waste manifests for three years from the date of shipment;
4. Conducting periodic audits of UW storage locations on the University of Chicago campus; and
5. Annually reviewing the Batteries Lamps and Ballasts Waste Handling policy and making appropriate changes.

Building/Facility Managers are responsible for:

1. Ensuring waste lamps, batteries, and ballasts are brought to the appropriate storage location;
2. Providing each storage location with containers (drums, boxes) appropriate for storing waste materials, materials for marking containers, and spill response materials;
3. Appropriately marking each storage container;
4. Ensuring waste batteries, lamps, and ballasts are regularly picked up for disposal with no waste remaining on site for more than one year from the accumulation start date or 90-days for leaking batteries or ballasts containing PCBs;
5. Ensuring personnel who handle waste lamps, ballasts, or batteries take required “Batteries, Lamps, and Ballasts - Waste Handling” training online within 90-days of the start of employment;
6. Ensuring spills/releases from broken bulbs or leaking ballasts or batteries are immediately cleaned following the appropriate spill response procedures; and
7. Contacting EHS to arrange for an immediate hazardous waste pick up for leaking PCB-ballasts or lead-acid batteries.

Employees who handle waste batteries, lamps, and ballasts are responsible for:

1. Taking “Batteries, Lamps, and Ballasts - Waste Handling” training;
2. Handling/packaging waste batteries, lamps, and ballasts according to this policy; and
3. Immediately cleaning up any small releases from broken lamps or leaking batteries/ballasts and immediately reporting large spills to the University Police Department at 773.702.8181.

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Procedures

All handling, packaging, labeling, and storing of waste batteries, lamps or ballasts shall be done in accordance with the procedures listed below:

Batteries - Identification

There are many types of batteries but the most common are:

• Single-use alkaline batteries
• Rechargeable batteries
  • Lead-Acid
  • Nickle-Cadmium (NiCAD)
  • Nickle-Metal Hydride (NiMH)
  • Lithium/Lithium-Ion

Alkaline

Used alkaline batteries do not contain hazardous materials and are safe to dispose of in the general trash.  These batteries are non-rechargeable and widely used in households or small electrical devices (e.g. AA, AAA, C, D, 9V, select button batteries).

While the University does use a vendor that recycles alkaline batteries, the energy use associated with de-manufacturing and transporting these batteries for recycling often outweighs the environmental benefits. To help reduce the environmental impacts of used batteries please consider changing from single-use alkaline batteries to rechargeable batteries that may be recharged hundreds of times.

Rechargeable (Nickel-Cadmium, Nickel-Metal Hydride, Lithium, Lithium-Ion)

Batteries such as lithium (Li), lithium-ion (Li-Ion), nickel-cadmium (Ni-Cad), and nickel-metal hydride (NiMH) batteries are used in a wide variety of consumer products such as rechargeable tools, laptop and tablet computers, and phones.  

Please note:  Thin lithium "button" batteries used in small electronic devices are not rechargeable but should be collected for recycling.

Rechargeable (Lead-Acid)

           

Lead-acid batteries commonly come in two forms, sealed batteries found in equipment such as backup power supplies, and flooded batteries such as those used in automobiles and groundskeeping equipment. 

These batteries contain concentrated acid and the heavy metal lead are considered hazardous.  Lead-acid batteries are usually larger than other types of batteries and are very heavy for their size. 

Because lead-acid batteries are too large to fit in battery collection containers they should not be brought to the campus collection sites.

Batteries Disposal

Damaged or mishandled batteries can be a significant fire risk. Prior to adding batteries to collection containers, all battery terminals shall be taped off or each individual battery shall be bagged or packaged to prevent battery terminals from touching adjacent batteries/metal surfaces and causing electrical shorts or sparks. 

Alkaline

• Place in general trash; or
• Drop off at battery recycling locations and follow the procedure above to protect battery terminals.

Lead-acid batteries

• FS employees may drop off at the Facilities Services building at 5225 S Cottage Grove Ave.; or
• Other employees may contact the Facilities Services Service Center at 773.834.1414 to request a pick-up.

Damaged/Leaking Batteries

• Contact EHS at 773.702.9999 or  to arrange for a hazardous waste pick up; or
• Research staff may also use the online Environmental Health and Safety Assistant (EH&SA) platform to enter a chemical waste pick-up request for these items.

Rechargeable or Lithium Button Batteries

Follow the taping/bagging procedure described above and bring batteries to one of the following battery collection locations:

• Anatomy (Mail Area)
• Campus North Residence Hall (Mail Room)
• Edelstone (Lobby)
• Edith Abbott Hall (Lobby)
• Gordon Center for Integrative Science (West Lobby)
• Granville-Grossman Residence Hall (1^st Floor Mail Area)
• Henry Hinds Laboratory for Geophysical Sciences (Dock)
• Keller Center (Student Kitchenette 0002)
• Max Palevsky Residence Hall (Lobby)
• Michelson Center for Physics (South Entrance)
• Swift Hall (Basement Corridor)
• UC Press Building (Lobby)
• William Eckhardt Research Center (Lobby)
• Zoology (Outside Rm 114)
• Harper Memorial (Outside 2nd FL Dean of the College Suite)

Note: EHS is not responsible for the creation or maintenance of the battery collection locations above.  This list is subject to change, and some locations may no longer host a battery collection container.

Batteries - Storage

Batteries from the many collection locations around campus shall be picked and consolidated into drums at the Facilities Services building at 5255 S Cottage Grove Ave. by FS employees.  

All collection containers of used batteries (tubes and drums) should be marked with:

• The words “Universal Waste – Batteries”
• The accumulation start date (the date batteries were first added to the container)
• All battery collection containers shall be emptied and the batteries shipped for disposal within one year of the accumulation start date. 

Lamps - Identification

The EPA defines a lamp, as the bulb or tube portion of an electric lighting device. A lamp is specifically designed to produce radiant energy most often in the ultraviolet, visible, and infra-red regions of the electromagnetic spectrum.

Examples of common universal waste electric lamps include, but are not limited to: fluorescent, high-intensity discharge, neon, mercury vapor, high-pressure sodium, ultraviolet (UV), and metal halide lamps.

Because they may contain mercury or lead, used lamps are considered to be hazardous waste and may not be disposed of in the general trash*.

*Note: Incandescent and LED bulbs do not contain hazardous materials and may be disposed of with the general trash.

Lamps - Disposal

Intact Lamps

When you are finished using a lamp, it should be placed inside of a rigid container to protect it from accidental breakage. 

• Contact Facilities Services Service Center at 773.834.1414 or online at facilities.uchicago.edu/services/service-request/ to request a pick-up of used lamps.

Broken Lamps

• Follow the procedures outlined in the Spill Response Section of this policy and then contact EHS at 773.702.9999 or safety@uchicago.edu to schedule a waste pick up.

Used Lamps - Storage

Lamps collected from campus buildings shall be placed into a collection container, box or drum and shall be kept closed when not actively adding lamps to the container.

All containers must be marked with:

• The words “Universal Waste – Lamps” 
• The accumulation start date (date lamps were first added to the container)
• All containers must be shipped for disposal within one year of the accumulation start date.

Ballasts - Identification

A lamp ballast is a device designed to limit the amount of current in an electrical circuit.  Inductive ballasts used in fluorescent lamp fixtures are used to prevent electrical current from rising to a destructive level.

Ballasts manufactured prior to 1979 may contain polychlorinated biphenyls (PCBs).  PCBs have been demonstrated to cause a variety of adverse health effects on humans and animals; including cancer, effects on the immune system, nervous system, endocrine system, and reproductive system.

Due to the potential health hazards associated with light ballasts, they are managed as potentially hazardous waste.

Ballast Disposal

Ballasts shall only be removed from lighting equipment by trained Facilities Services employees.  

Non-PCB Ballasts and Intact PCB Ballasts

• Facilities Services coordinates disposal through a third-party vendor. Since Non-PCB ballasts and intact PCB Ballasts are exempt from many hazardous waste regulations no official waste manifest or shipping documents are required.
• If you’d like to dispose of used Non-PCB ballasts or intact PCB ballasts or to have ballasts removed from light fixtures, contact Facilities Services Service Center at 773.834.1414 or online at facilities.uchicago.edu/services/service-request/ to request a pick-up and/or removal.

PCB ballasts (Leaking or Not-intact)

• If you have PCB containing ballasts that are not intact or are leaking, contact EHS to arrange for a hazardous waste pick up at 773.702.9999 or safety@uchicago.edu  

Used Ballast Storage

Non-PCB ballasts shall be stored separately from PCB-containing ballasts.   Both PCB and Non-PCB ballasts shall be stored inside of closed drums supplied by a third-party waste vendor. Further information on PCB ballast storage and disposal regulations is available at: www.epa.gov/sites/production/files/2015-08/documents/ballastchart.pdf

Non-PCB ballast drums shall be clearly labeled with:

• The words “Ballasts – Non PCB”

Drums with non-leaking ballasts containing PCBs are considered are hazardous and must be marked with:

• The words "Ballasts - PCB"
• A PCB warning label
• The accumulation start date

E-Waste Recycling

University of Chicago ITS provides e-waste recycling services to all campus employees.  Further information can be found on their site at: https://uchicago.service-now.com/it?id=its_sc_cat_item&sys_id=6064c888139cb60027255eff3244b0dc

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Spill Response

Do NOT attempt to clean up a spill if any of the following conditions apply:

• The spill is an unknown agent;
• The quantity spilled is greater than one liter;
• A secondary emergency situation exists (e.g., fire); or
• You have not taken the appropriate training (see Training section below).

Leaking Batteries

Clean up the spill following the procedure:

• Put on gloves, eye protection, and long sleeves;
• Contain the leak by using absorbent pads;
• Neutralize any acid from lead-acid batteries by spreading sodium bicarbonate or an acid spill neutralization powder on the leak;
• Place any damaged batteries, absorbent pads, and contaminated PPE in a leak-proof container;
• Label the container as hazardous waste and list the contents;
• Report the spill to your supervisor and if you are in a research location, notify your designated Laboratory Safety Specialist and the Office of Research Safety at 773.834.2707; and
• Non-research staff should contact EHS at 773.702.9999 or safety@uchicago.edu to arrange for a waste pick up.
• Research staff should use the online Environmental Health and Safety Assistant (EH&SA) platform to submit a chemical waste pick-up request.

Broken Lamps

Clean up broken lamps by following the procedure below:

• Put on protective gloves and eye protection;
• Pick up broken glass with tongs or dustpan and place inside of a plastic bag;
• After all debris has been swept up, take off gloves and place them in the bag;
• Seal the bag and place it inside of a cardboard box or other rigid container; and
• Put in a waste pick up request with EHS at 773.702.9999 or safety@uchicago.edu

Leaking Ballasts

If you encounter a leaking ballast, follow the procedure below:

• Put on protective gloves and eye protection;
• Remove ballast and place inside a secure leak-proof container;
• Most ballasts leaks are of a highly viscous material that does spread beyond the ballast itself, however, if the ballast has leaked onto other materials collect them along with the ballast and place them into a container;
• Depending on the type of ballast, label the container as “Leaking Non-PCB Ballast” or “Leaking PCB Ballast; and
• For leaking non-PCB ballasts notify Facilities Services to have the ballast taken for disposal, for leaking PCB ballasts notify EHS at 773.702.9999 or safety@uchicago.edu to request a waste pick up.

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Training

All campus employees who handle, package, or ship waste batteries, lamps, or ballasts shall take the University’s “Batteries, Lamps, and Ballasts - Waste Handling” training and Hazard Communication training available via the EHSA Online Training Module.

EHS employees responsible for signing hazardous waste manifests for leaking batteries or PCB shipments are required to complete Hazardous Waste Generator training on an annual basis, and Department of Transportation Hazardous Materials Transportation training every three years.

Reviewed: May 2023

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Regulatory Citations

Title 40 of the Code of Federal Regulations (CFR) in part 273

Title 35 of the Illinois Administrative Code Part 733

TSCA Federal Storage/Disposal Requirements for Fluorescent Light Ballasts

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