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Ask the Expert Question-and-Answer Archive by Ron Joseph January, 2001 Hazardous Waste vs. Universal Waste Q. A lab employee questioned our environmental department in allowing some of the lab waste to be labeled as Universal of Paint and Paint related waste instead of hazardous waste. We throw away significant isocyanate amounts and a very small amount of chromate pigment-containing paint. We also have the usual organic solvents contained in our lab produced samples. Are these chemicals allowed as Universal Waste? A. You have probably given up on getting and answer to your question of January 26. Well, I'm not an expert in this, and I forwareded your question to a colleague. Here is his answer: RCRA regulations indicate that the "Universal" categorization applies to a specific list of hazardous wastes that the government wants to encourage "flexibility" in terms of managing. Flexibility means recycling/managing materials that would otherwise be classified as hazardous wastes (e.g., batteries, pesticides, mercury thermostats). In California, Universal Wastes are called "Special Wastes". To our knowledge, the paints in question as described which contain isocyanates and chrome are not a listed waste that is conditionally exempt from RCRA regulations. The applicable regulatory section is Title 40 Code of Federal Regulations (CFR) Section 273
Allan W. Ader, Ph.D., DABT
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