Q. Can businesses collect employees’ batteries to add to the batteries generated on site for recycling?

A. Assuming that the business is in compliance with the universal waste rules applicable to a handler of universal waste batteries, the business can accept waste batteries from employees and add them to the waste batteries generated onsite and managed as universal waste. A universal waste handler is a generator of universal waste or the owner or operator of a facility that receives universal waste from other universal waste handlers, accumulates universal waste, and sends universal waste to another universal waste handler, to a destination facility, or to a foreign destination.

The universal waste provision at 40 CFR 273.8 allows “persons” (e.g. a business) to “commingle” household waste with the same type of universal waste and manage them under the universal waste regulations. The employees’ batteries meet the definition of household waste found at 40 CFR 261.4(b)(1): “any material (including garbage, trash and sanitary wastes in septic tanks) derived from households (including single and multiple residences, hotels and motels, bunkhouses, ranger stations, crew quarters, campgrounds, picnic grounds and day-use recreation areas)”. Consequently, the business can collect the employee’s household waste batteries, add them to the batteries generated at the facility, and send them to a destination facility for recycling, treatment, or disposal.