Small quantity generators may manage their batteries and mercury containing thermostats under either the Universal Waste Rule or in accordance with the SQG requirements.  However, if SQG of household hazardous waste batteries and thermostats are commingled with universal waste from medium of large quantity generators, the commingled waste is considered hazardous waste and must be managed as universal waste.

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