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On Dec. 21, 2017, Ohio EPA added paint wastes, antifreeze and aerosol cans to the list of materials that can be managed under less-stringent universal waste (UW) requirements.

Paint and Paint-Related Waste

This category includes hazardous waste paints that meet the following three criteria: contains a pigment (can also be unpigmented), contains a binder and contains an adhesive, as well as hazardous materials contaminated with paint. Examples include, but are not limited to:

  • Used/unused paint and ink;
  • Spent solvents used in painting (combination of thinner and paint, lacquer or varnish);
  • PPE, gloves, rags and debris (contaminated with paint);
  • Booth filters, stripping and masking materials, paint sludge from water-wash curtains;
  • Cleanup from paint spills, residues and removal activities;
  • Sand blasting media (contaminated with paint).


This category includes propylene glycol or ethylene glycol, including aggregated batches of propylene glycol or ethylene glycol, used as a heat transfer medium in an internal combustion engine; heating, ventilating and air conditioning units; and electronics cooling applications, or used for winterizing equipment.

Aerosol Cans

Means a non-opening, non-refillable container that holds a substance under pressure and that can release the substance as a spray, gel or foam by means of a propellant gas. The waste codes typically associated with this waste would be ignitable and may include numerous listed commercial chemical products depending on the product in the container.


How are the Universal Waste Rules Different?

The universal waste rules are streamlined requirements for certain hazardous wastes that can be safely recycled. Under the rules, generators of universal wastes are:

  • Not required to count their UW toward their hazardous waste generator category (conditionally exempt small quantity generator, small quantity generator or large quantity generator);
  • Subject to less-restrictive on-site management requirements that are specifically tailored to each waste stream;
  • Not required to include a manifest with the UW;
  • Not required to obtain a U.S. EPA identification number (unless you store over 11,020 pounds onsite);
  • Not required to include UW on a biennial report (normally required for those facilities that generate over 2,200 pounds of hazardous waste in a calendar month); and
  • Allowed increased on-site storage time of one year for their UW.

What about transporters and handlers of universal wastes?

While universal waste handlers and transporters are not required to use a hazardous waste manifest when the universal waste is being transported in Ohio, transportation of these universal wastes must follow applicable DOT regulations. When these Ohio-specific universal wastes are transported and managed outside of the state, they must be managed under the receiving state’s regulations, which may mean that they must be transported using a hazardous waste manifest.

More information on these new rules and Ohio’s Universal Waste requirements can be found at: For questions, please contact Karen Hale at or (614) 644-2927 or attend our free Universal Waste Rule Updates webinar on June 13, 2018 to learn more.