Universal Waste Lamps and Environmental Compliance

News & Views

THE UNIVERSAL WASTE CHECKLIST

If you select an answer in BOLD print, you are in violation!

1. Are you throwing any lamps in your trash dumpster?
YES  NO

2. If you answered YES to number 1, do you have documentation that your lamps are nonhazardous, such as up-to-date, comprehensive testing data from the manufacturer, or results of other lab testing?
YES  NO

If you answered NO to question 2, you may be illegally disposing of hazardous waste. Stop this practice and learn how to evaluate your lamps.

If you answered YES to questions 1 and 2, you do not have to go any further. However, remember that you bear the responsibility to have documentation on site to prove that your lamps are nonhazardous.

3. Do you put your used lamps in a container that is structurally sound, compatible with the contents of the lamps and designated to prevent breakage?
YES  NO

4. If a lamp breaks inside the container, will the container prevent a leak?
YES  NO

5. Are used lamp containers kept closed?
YES  NO

6. Are containers labeled “Used Lamps”, “Universal Waste Lamps”, or “Waste Lamps”? 
YES  NO

7. Have you informed employees who handle used lamps about how to handle them safely and what to do if there is an emergency (such as a break or leak)?
YES  NO

8. Can you show through container labels or records how long you have been storing used lamps at your facility?
YES  NO

9. Are you storing any used lamps on-site for more than one year?
YES  NO

10. Do you have more than 11,023 pounds (5,000 kgs.) of used lamps or other universal wastes at your business?
YES  NO

11. Do you send used, unbroken lamps to one of the following:
a.) a universal waste handler (another business that is a generator);
b.) an Ohio facility that has a permit to treat/dispose/recycle lamps; or
c.) an out-of-state facility that is authorized to treat/dispose/recycle lamps? (Note: Check with your handler about sending them a broken lamp.)
YES  NO

12. Do you crush any used lamps? (Note: Crushed lamps must be managed under hazardous waste rules!)
YES  NO

This completes the Universal Waste Checklist. For assistance with these regulations, with laboratory analysis, or with transportation and recycling of lamps, please call or email our Customer Service Coordinator, Ms. Dreama Mecklenburg. dmecklenburg@compliancetechnologies.biz/cti

 

Published by Stephen Kovatch

Senior Client Manager  Stephen J. Kovatch focuses on assisting clients in establishing corporate regulatory compliance programs in the areas of air, water, and waste management. Mr. Kovatch also provides direction to industrial facility owners who are active in the transaction of contaminated property by defining objectives, coordinating soil and water sampling protocols, risk assessment, and remedial / cleanup activities. He frequently represents clients in property sales negotiations and regulatory agency and insurance proceedings.

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