Universal wastes may not be satellite accumulated.  The key distinction between satellite accumulation and accumulation of universal waste pertains to the accumulation start date.  For universal waste, the generator must mark or label the container to document the first date of accumulation of an item at each location.  Universal wastes can only be accumulated for one year from that date.  Similarly to satellite accumulation, the location, or number of locations (points of generation), at which universal wastes are accumulated is not limited.

Universal Waste Rule for Batteries and Mercury Containing Thermostats, #98-40