COMMONWEALTH OF MASSACHUSETTS
MASSACHUSETTS DEPARTMENT OF TRANSPORTATION
HIGHWAY DIVISION
STANDARD OPERATING PROCEDURES
SUBJECT: Universal Waste Management at MassDOT
Highway Division Facilities
EFFECTIVE:
9/29/10
ISSUED:
9/29/10
S.O.P.NO. ENV-01-07-1-000
Page 1 of 2
SUPERSEDES:ENV-01-07-1-000,
Dated 8/13/08
DISTRIBUTION:
A
AUTHORIZED:Signature on
original
PURPOSE
To provide guidance for the handling and disposal of items, such as certain batteries, pesticides, or
fluorescent lights, which are now designated by the Department of Environmental Protection (DEP) as
“Universal Wastes” (ref 310 CMR 30, DEP Policy # BWP-95-005, BWP/DHW-92-01.
RESPONSIBILITY
It is the responsibility of the District Maintenance Engineer (DME) or their designee to ensure that this SOP
is adhered to.
The Environmental Management System Compliance Coordinator (ECC) is responsible for arranging for the
removal of the waste and reporting any findings from their facility inspection to the District Maintenance
Engineer.
The waste will be sent to a licensed facility that will accept the waste for treatment, disposal, or recycling.
Private contractors working for MassDOT, unless otherwise specified in their contract, are responsible for
the removal, proper handling and recycling of any universal waste they generate, such as spent fluorescent
bulbs, etc.
DEFINITION
Universal Wastes are wastes which the Environmental Protection Agency (EPA) and/or the Department of
Environmental Protection (DEP) have determined need special management. These include:

Batteries
-Used Batteries, primarily nickel cadmium (NiCad) and button batteries
-Mercury containing batteries banned from domestic sale
-Used consumer products containing rechargeable batteries which
cannot be easily removed.

Pesticides (Only if unused or recalled by the manufacturer)

Mercury Containing Devices
-Thermostats
-Switches
-Thermometers
-Fluorescent Light Bulbs
COMMONWEALTH OF MASSACHUSETTS
MASSACHUSETTS DEPARTMENT OF TRANSPORTATION
HIGHWAY DIVISION
STANDARD OPERATING PROCEDURES
SUBJECT: Universal Waste Management at MassDOT
Highway Division Facilities
EFFECTIVE:
9/29/10
ISSUED:
9/29/10
S.O.P.NO. ENV-01-07-1-000
Page 2 of 2
SUPERSEDES:ENV-01-07-1-000,
Dated 8/13/08
DISTRIBUTION:
A
AUTHORIZED:Signature on
original
POLICY
As a generator of Universal Waste, MassDOT is a handler of this waste stream. In order to comply with the
Federal and State regulations regarding this waste MassDOT must take measures to prevent releases of any
universal waste, or a component of that waste, into the environment. This means that MassDOT Highway
Division must store the waste in a manner consistent with our hazardous waste practices. The following
guidelines will be followed:

Store the waste in a container that is marked or labeled appropriately, Clearly label or mark, for
example:
UNIVERSAL WASTE
Mercury Containing Lamps
08/09/10




Be sure to include type of material and the date that the accumulation started.
Maintain an inventory system, and
Store the waste in a specific accumulation area.
Universal Waste can only be stored for one year from the time of generation.
RELEASE RESPONSE:
A Universal Waste can become a Hazardous Waste if the hazardous elements are released. The hazardous
elements of a Universal Waste are contained in the component, such as in a battery casing, or in a fluorescent
lighting tube. If these components are damaged or broken the hazardous elements can become mobile and be
released into the environment. When this occurs the material ceases to be classified as Universal Waste, and
becomes Hazardous Waste. In the event that this occurs, you will need to follow the SOP for Hazardous
Waste.
CAUTION
DO NOT ATTEMPT TO CLEAN-UP SPILLED MERCURY FROM A BROKEN THERMOSTAT.
MERCURY IS EASILY ASBSORBED THROUGH THE SKIN CAUSING DAMAGE TO THE
CENTRAL NERVOUS SYSTEM; MERCURY VAPORS (AS WITH A BROKEN FLUORESCENT
BULB) CAN BE INHALED CAUSING DAMAGE TO THE LUNGS. SPILLED BATTERY
ELECTROLYTE CAN CAUSE BURNS TO THE SKIN WITHOUT SPECIAL CLEAN-UP EQUIPMENT.
USE THE CALL DOWN SHEET TO REPORT THESE TYPES OF SPILLS AND AWAIT
INSTRUCTIONS.