Mercury-Containing Equipment Categorized as Universal Waste

Mercury-containing equipment is categorized as universal waste by RCRA. The elemental mercury in a device must be "integral to the function" of the device. This means that the mercury in the device cannot be a result of either of the following:

• An accidental occurrence of mercury in the device
• Contamination of the device from an external source of mercury

If the mercury in a device is from one of these sources, instead of being there for the functionality of the device, then it cannot be managed as universal waste.

Some examples of devices that contain mercury include the following:

• Thermostats
• Thermometers
• Barometers
• Blood pressure manometers and sphygmomanometers
• Flow meters
• Mercury light switches
• Mercury regulators
• Pressure relief and water treatment gauges
• Gas safety relays
• Bilge pump float switches in pleasure boats

Not all equipment that contains mercury is considered to be universal waste. The RCRA universal waste regulations do not apply to handlers of the following devices:

• Mercury-containing equipment that is not yet waste according to 40 CFR 261
• Mercury-containing equipment that is not a hazardous waste according to the characteristics stated in 40 CFR 261
• Mercury-containing equipment from which the components that contain mercury have been removed

To learn more about RCRA visit our RCRA Hazardous Waste Safety Online Training web page.