​Universal Waste Handler Requirements

The universal waste regulations create two groups of generators of universal waste, called handlers, based on the amount of universal waste accumulated on-site. Universal waste handlers are not just those that generate or produce universal waste, but also those who receive universal waste from other handlers. Below is a description of the two universal waste handler groups - Small Quantity Handlers of Universal Waste and Large Quantity Handlers of Universal Waste and the main requirements each must comply with. A full description of handler requirements can be found in 40 CFR Part 273 Subpart B (SQHUW) and 40 CFR Part 273 Subpart C (LQHUW.) For more information on waste specific management, universal waste lamp crushing, transporter, and destination facility requirements, please see the web pages pertaining to each topic.

Small Quantity Handlers of Universal Waste

Small Quantity Handlers of Universal Waste (SQHUW) accumulate less than 5,000 kilograms (or about 11,000 pounds) of universal waste at any one time on-site.

SQHUWs Must Comply with the Following:

  • Label or mark universal waste to identify the type of universal waste it is (See 40 CFR 273.14.)
  • Manage universal waste in a way that prevents releases to the environment.
  • Immediately respond to releases of universal waste and properly manage released waste.
  • Distribute basic waste handling and emergency information to their employees to ensure that their staff is aware of these procedures.
  • Accumulate universal waste for no more than one year.
  • Comply with export requirements for foreign shipments.

SQHUWs are not required to notify DEQ of their universal waste management activities, not required to keep records of universal waste shipments, and not required to use a hazardous waste manifest for off-site shipments of universal waste. However, DEQ recommends keeping records of universal waste management as a best management practice. Handlers must comply with US DOT hazardous materials requirements, if applicable.

Large Quantity Handlers of Universal Waste

Large Quantity Handlers of Universal Waste (LQHUWs) accumulate on-site 5,000 kilograms or more of universal waste at any one time. The designation as a LQHUW is retained for the remainder of the calendar year in which the 5,000 kg threshold was exceeded, and may be reevaluated in the following calendar year.

LQHUWs Must Comply with the Following:

  • Label or mark universal waste to identify the type of universal waste (See 40 CFR 273.34.)
  • Manage universal waste in a way that prevents releases to the environment.
  • Immediately respond to releases of universal waste and properly managed released waste.
  • Ensure that all employees are thoroughly familiar with proper waste handling and emergency procedures relative to their responsibilities during normal facility operations and emergencies.
  • Accumulate universal waste for no more than one year.
  • Comply with export requirements for foreign shipments.
  • Notify DEQ and obtain an EPA identification number if they do not already have one.
  • Maintain records of all universal waste shipments received by and sent from the facility and retain these records for three years.

Handlers are not required to use a hazardous waste manifest for off-site shipments of universal waste, but must comply with U.S. DOT hazardous materials requirements, if applicable.

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Virginia Department of
Environmental Quality
P.O. Box 1105
Richmond, VA 23218
(804) 698-4000


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