By a strict definition, they’re hazardous. Fluorescent lamps contain mercury, and almost all fluorescents fail the U.S. EPA’s toxicity test for hazardous wastes. Fluorescent lamp ballasts manufactured into the mid-1980's contain polychorinated biphenyls (PCBs), a carcinogen; most of these ballasts are still in service.

Batteries can contain any of a number of hazardous materials, including cadmium (nickel-cadmium batteries), the explosive lithium (lithium-ion batteries), and lead (lead-acid batteries). Some household non-rechargeable batteries still in use also contain mercury, although mercury has been phased out of batteries that are in wide circulation.

According to a strict reading of the characteristics established by the U.S. EPA and state environmental agencies, all of these items are hazardous wastes when disposed of, and should therefore be subject to the whole onerous spectrum of handling, transportation, and disposition requirements that have been established for toxins, carcinogens, mutagens, explosives, and other wastes that are threatening to health and the environment.

But they’re generated by almost every company, and every household, in the country (hence the name "universal"). If they were defined as a hazardous waste, that would make practically every company in the U.S. a hazardous waste generator, with the accompanying burden of reporting, recordkeeping, handling, and management requirements (not to mention outrageous waste management costs). And it would flood state and federal agencies with mountains of paperwork and information to track, sort, store (and ultimately throw away).

Recognizing that the full hazardous waste approach would be overkill for batteries and fluorescents, the U.S. EPA created the "universal waste" regulatory category in the mid-1990's, and it’s been adopted since then by almost all states. The universal waste requirements are straightforward. First, batteries and fluorescents are banned from disposal in landfills and incinerators (as they should be). But, as long as they are handled, packed, and transported in a way that prevents their breakage and possible release to the environment, and are recycled through a licensed facility, they are exempt from definition and regulation as a hazardous waste. Instead, they are subject to a much less onerous (and much less costly) set of requirements specifically crafted to ensure their convenient, but safe, management, transportation, and ultimate disposition.

From a generator’s standpoint, the Universal Waste Regulations for fluorescents and batteries have three facets: 

1. handling and packaging
2. transportation
3. ultimate disposition

Wuf provides all three as follows.

Fluorescents and batteries need to be handled and packaged in a way that prevents breakage and potential release of hazardous materials, on your site and throughout the chain of custody to the ultimate disposition facility. Wuf can provide packaging for all types of fluorescents (4' and 8' straight tubes, U-tubes, and others), delivered to your dock, and straightforward handling and packaging procedures that will prevent spills and breakage and their associated cleanup costs.

Handling and packaging needs for batteries are different — batteries need to be handled and packed to prevent short-circuits (a fire risk) and minimize transportation costs. Again, Wuf can provide appropriate packaging materials and instructions designed to minimize handling requirements and costs and eliminate possible liabilities associated with mis-packaged materials.

The Universal Waste transportation requirements are not onerous. Because they are not defined as hazardous wastes, universal wastes do not need to be accompanied by a hazardous waste manifest, or shipped by a hazardous waste transporter.

Even so, transportation is where many generators lose a lot of money, and many recyclers make their margins.

The problem with transporting universals is volume. Fluorescents are too light to make a cost-effective load. You rarely generate a truckload, which leaves you at the mercy of less-than-load freight rates, or even higher on-call or "convenience" rates charged by some shippers and recyclers. Batteries are the opposite — too heavy and too bulky to cube out an efficiently loaded box trailer.

Wuf offers several solutions. If you are using Wuf to handle both electronics and universals, we’ll put them on the same truck, and cross-dock them to the correct end markets. You’ll save money on both sets of materials. We can set up scheduled route pickup. Or if you’re doing a major re-lamp, we can spot a full or "pup" trailer on your site, reducing your handling and storage overhead, and securing full-load transportation when the trailer is cubed out.

The Universal Waste regulatory requirement is that all Universals must be handled by a licensed recycler. And there are only a few licensed recyclers in the Northeast. They know each other’s prices, they know each other’s services, and unless you’re Fleet Bank or United Technologies you have precious little leverage to bargain on price or any other aspect of their service.

Wuf provides that leverage. Because we represent multiple accounts, our combined tonnage allows us to negotiate and pass along better prices than individual generators can secure on their own. In addition, our recyclers interact with Wuf as a single "super customer," instead of dozens of small accounts. They realize savings in marketing, customer management, and accounting — another reason for the low prices Wuf can pull down and pass along.

We also handle account maintenance details like assuring that vendor permits and insurance coverages are up-to-date, handling paperwork, and securing certificates of recycling. Again, because of the volume represented through our multiple accounts, we can secure more prompt attention and better service than individual generators on their own, with benefits that are measured in reduced overhead, reduced accounting costs, and reduced stress.