Batteries- All batteries that designate as hazardous waste should be managed as universal waste except for spent lead-acid batteries (typically automobile batteries).  Spent lead-acid batteries may continue to be managed under the existing lead-acid battery exemption at WAC 173-303-520.

   Generators are encouraged to segregate their batteries by type because all batteries are not managed in the same way.  For instance, nickel cadmium batteries can be recycled to recover their metal content.  A recycler may not accept them if they are mixed with alkaline or other batteries.

   Other types of batteries include alkaline, mercuric-oxide, alkaline-manganese, zinc-carbon, button cell mercuric-oxide, silver-oxide, and lithium.  These should all be managed under the universal waste requirements.  Consumer products that contain difficult-to-remove rechargeable batteries should also be managed as universal waste.

   Are alkaline batteries a hazardous waste?

  Alkaline batteries have been shown to designate for their mercury content and also for the state-only criteria as solid corrosive waste.  The mercury content in batteries has been decreasing due to changes in manufacturing, but the alkaline batteries continue to designate as a solid corrosive waste.  A generator can always test batteries to determine whether they designate.  However, alkaline batteries should be managed as universal waste unless test results show that they are not hazardous.

   Mercury-containing Thermostats- Thermostats that contain mercury should be managed as universal waste.  This does not include all mercury switches.  A thermostat is a temperature control device that contains metallic mercury in an ampule attached to a bimetal sensing element.  Ampules removed from these thermostats should also be managed under the universal waste requirements.  Other types of mercury switches must be managed according to all applicable dangerous waste requirements.

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