Ohio EPA Added 3 New Universal Wastes This Year

Posted on 11/5/2018 by Roger Marks

In late 2017, the state of Ohio added three new types of universal waste to its existing universal waste requirements. Universal wastes are not fully regulated as hazardous waste but can instead be managed under a simplified set of storage and disposal rules. 

Universal wastes recognized under the Federal RCRA regulations include lamps, batteries, mercury-containing devices, and certain pesticides.

The three new types of universal waste added in Ohio are: 
  • Paint and paint-related wastes.
  • Antifreeze.
  • Waste aerosol containers.
These three waste streams may now be managed under the universal waste standards in Ohio. To learn more about the Buckeye State’s universal waste rules, see Ohio Administrative Code (OAC) rule 3745-273-89.

Learn new and changing hazardous waste rules you must know for 2019! Reserve your seat now for Lion's RCRA Hazardous Waste Management Workshop, coming to Cleveland and Cincinnati in Fall 2019.

If you manage hazardous waste in Ohio and you’re not already managing paints, aerosols, or antifreeze as universal waste, doing so may help simplify your hazardous waste compliance responsibilities; cut costs for storage, transport, and disposal; or even change your generator status. 

Learn more about the new Ohio universal waste rules here.

How to manage universal paint and paint-related wastes in Ohio

Like with all universal wastes, there are specific management rules to follow to qualify these materials for exclusion from the full brunt of the hazardous waste regulations. For paint and paint-related wastes, these requirements are relatively basic.

Small and large quantity handlers of universal waste must manage paint and paint-related wastes in containers or tanks that comply with applicable requirements. Generators and universal waste handlers must label each container, tank, multiple-container package or hopper with words that identify the contents, e.g., Universal waste paint, waste paint, used paint.  

While facilities can continue to manage reclaimed paint as universal waste, any new wastes generated from the reclamation process must be evaluated to determine if it is hazardous waste. Ohio EPA has also created requirements for the reclamation of paint and paint-related wastes.

How to manage universal waste antifreeze in Ohio

To manage antifreeze as a universal waste, facilities must comply with the following universal waste handling requirements.

Universal waste antifreeze must be managed in dedicated containers or tanks to prevent comingling with other wastes, and those containers or tanks must comply with applicable requirements. Labels are required to identify the contents of containers or tanks holding universal waste antifreeze, e.g., Universal waste antifreeze, waste antifreeze, usedantifreeze.

The facility must develop and maintain a procedure that describes how antifreeze will be prevented from comingling with other wastes.

Antifreeze mixed with used oil after generation does not quality as universal waste. As Ohio EPA puts it, “Antifreeze that is mixed, subsequent to generation, with used oil is defined as either a used oil… or as a hazardous waste….” (Rule 3745-273-89)

Ohio EPA has also created requirements for the reclamation of universal waste antifreeze.

How to manage universal waste aerosol containers in Ohio


Non-empty aerosol cans with contents that exhibit one or more of the hazardous waste characteristics may also now be managed as universal waste in Ohio.

Aerosol cans must be accumulated in containers, a cabinet, or other unit. For leaking aerosol containers, the handler shall immediately empty the container of contents or individually overpack the leaking container with enough absorbent material to hold the leaking contents. The container, package, cabinet, or other unit must be labeled with words that identify the contents, e.g., Universal waste aerosol containers, waste aerosol containers, used aerosol containers.

Ohio EPA also lays out requirements for puncturing or crushing aerosol cans on site. Any waste material that comes out of the can during puncturing or crushing must be collected and evaluated to determine if it is a hazardous waste.

Note: Unlike other universal wastes, aerosol cans may be accumulated in satellite areas before being moved to the main universal waste storage area (or aerosol puncturing area). The only limit for satellite accumulation is that any container used has a capacity of 55 gallons or less. A cabinet can also be used to accumulate universal waste aerosol containers at satellite areas.

US EPA has its own plans to add aerosol cans to the 40 CFR universal waste management regulations under RCRA.

Manifesting Universal Wastes in Ohio

While a Hazardous Waste Manifest is not required for universal waste shipments, there is an important distinction to make about state-only universal wastes.

When transported within the state of Ohio, these three new universal wastes do not require a Manifest (DOT hazmat shipping rules apply). However, if the shipment is destined for a different state, a Manifest would be required if the destination state does not recognize the waste as universal waste.

Get more information about the new Ohio Universal Wastes here.

2019 RCRA and Hazmat Training in Ohio

Lion’s RCRA Hazardous Waste Management Workshop returns to Ohio in January 2019!
Join us in Cincinnati on September 26—27 or Cleveland on October 21—22 to meet EPA’s hazardous waste management training mandate and simplify RCRA compliance at your facility.

 Check out the full 2019 schedule here.

Online Hazardous Waste Management Training

Complete your RCRA training when you want, where you want with engaging, interactive online courses that drive home critical knowledge and skills that environmental professionals need to succeed. Train from home, from work, or from the road!

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