From a past attendee of one of my Training Seminars – now defunct – on May 19, 2015:

Dan,

I seem to recall hearing that the EPA does not like the telescoping boxes for used lamps.  I can only assume this is because the container may not meet the definition of “closed.” Has EPA given any written interpretation on this? Or better yet, do you know of a better method for storing 8-ft used fluorescent lamps that is better than standard 8-ft lamp boxes, is easier to access, and meets the closure rule?

Thanks,

My reply later that same day:

Both large quantity handlers and small quantity handlers of universal waste are required to identify the universal waste by one of three options:

• Universal Waste…
• Waste…
• Used…

The name of the universal waste that follows will depend on its type.  The USEPA identifies four universal waste categories, they are:

• Lamps
• Batteries
• Mercury Containing Devices
• Recalled or Cancelled Pesticides

The labeling requirements of the first three are relatively simple (eg. “Waste Batteries” or “Universal Waste Lamps” or “Used Mercury Containing Devices” &etc.).  The labeling of Recalled or Cancelled Pesticides is more challenging, if interested I recommend you read:  Identification and Management of Universal Waste (slides 50-56).

Many states have added to this list of universal wastes, however I have found the labeling requirements to remain the same as these.  Please check with your state to be sure.

You can be sure that the following examples are all a violation of Federal and State regulations:

• “Bad Batteries”
• “Spent Lamps”
• “Batteries for Recycling”
• And any other that isn’t one of the allowed options.

Since universal wastes have an on-site accumulation time limit of one year – and perhaps longer if necessary to facilitate disposal, confirm this with your state – you must indicate the date of initial accumulation in order to demonstrate the amount of time the universal waste has been on-site.

So, that’s two things that must be communicated:

1. The name of the universal waste.
2. Its date of initial accumulation.

The question remains, “How?”

Answering that question is the purpose of this article. (more…)

The universal waste regulations of the USEPA provide an option for generators of certain hazardous waste to manage them according to a lower regulatory standard:  The Universal Waste Regulations.  To take advantage of this “de-regulation” of a hazardous waste, generators need only comply with some basic regulations pertaining to its onsite management and off-site disposal.  You can learn more about the management of Universal Waste from my article:  The Universal Waste Option for the Management of Hazardous Waste.

The USEPA hazardous waste currently eligible for the Universal Waste option are:

• Lamps
• Batteries
• Mercury-Containing Devices
• Recalled or Canceled Pesticides

While states may differ in what they identify as a Universal Waste and in some of the on-site management requirements, they all agree that Universal Waste must be sent for disposal or recycling to a Universal Waste Destination Facility.  A business can not simply throw Universal Waste in the trash with its regular garbage.

**NOTE:  It may be possible for a Conditionally Exempt Small Quantity Generator of hazardous waste or a homeowner to send its Universal Waste to a Municipal Solid Waste Landfill for disposal with its regular trash or garbage.  However, this is not recommended and some states out-right ban the landfill disposal of fluorescent lamps.

Whatever your hazardous waste generator status or your status as a handler of universal waste, you and your employees will benefit from some form of my training services.  Please contact me to discuss the best training option for you:

• Training Seminars
• Onsite Training
• Webinars
• Learning Management Systems

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If you have ever handled a fluorescent lamp you know how fragile they are and how easy it is to break one.  I myself have a – rather embarrassing – memory of dropping a box of approximately thirty 4′ long lamps from the height of 1 1/2 feet.  The nearly simultaneous explosion of all of those bulbs caused the box to swell outwards (luckily it held) and then compress in on itself due to the vacuum created.  I was lucky that neither I nor anyone else was hurt.  Lesson learned.  But what about cleaning up the mess?  In order to minimize the risk of mercury exposure (or other hazards that may be present such as lead), please follow these steps: (more…)