Universal Waste Series – Common Mistakes Managing Used Lamps

Universal waste regulations allow the company to not count the designated waste as hazardous as long as the company complies with Chapter 40 of the Code of Federal Regulations (CFR) §273. “Used Lamps” is the first of a series of 4 The Record articles providing common mistakes and best practices to avoid having to count universal waste as hazardous waste.

The universal waste standards streamline the hazardous waste management standards for wastes that are commonly generated in relatively small quantities. There are three intended outcomes from the streamlined regulations according to the United States Environmental Protection Agency (U.S. EPA) website:

• Promote the collection and recycling of universal waste
• Ease the regulatory burden on retail stores and other generators that wish to collect these wastes and transporters of these wastes
• Encourage the development of municipal and commercial programs to reduce the quantity of these wastes going to municipal solid waste landfills or combustors

General universal waste management requirements

• One-year storage limit for universal waste accumulation
• Universal waste must be stored in structurally sound containers that are compatible with the waste and prevent breakage, spillage, or damage
• Universal waste containers must contain a label containing the phrases “Universal Waste” and the specific universal waste type. The start date of universal waste accumulation also needs to be included on the label
• Employees must be trained on applicable waste handling and emergency procedures
• Universal waste releases must be immediately contained
• Universal waste that meets the definition of hazardous materials per the U.S. Department of Transportation (U.S DOT) must contain the proper hazardous materials label and proper shipping paperwork per 49 CFR 172. U.S DOT hazardous material training must also be completed by any employee involved in the transportation of hazardous materials
• Track and maintain records of all universal waste shipments
• Universal waste must be sent to a universal waste destination facility

Handlers of universal waste can be classified as a small quantity handler (accumulates < 5,000 kg of universal waste at any one time) or a large quantity handler (accumulates > 5,000 kg of universal waste at any one time). A large quantity handler of universal waste must notify the Regional Administrator (or State Agency where the state has primacy) and have received a U.S. EPA identification number before exceeding the 5,000 kg accumulation storage limit. 

Used Lamp management

In 40 CFR §273.9, lamps are defined as “the bulb or tube portion of an electric lighting device”. Common types of lamps include fluorescent, high intensity discharge, neon, mercury vapor, high pressure sodium, and metal halide lamps. A used lamp becomes a waste when it is discarded, and an unused lamp becomes a waste once it is determined to be discarded.

What are common used lamp management mistakes?

• Not having a dedicated and commonly known storage area for universal waste
• Exceeding the one-year storage limit for used lamp accumulation
• Maintenance practices such as taping used lamps together or storing used lamps in the same container with new lamps
• Storing used lamps in the same area as new lamps without clear storage delineation
• Storing used lamps outside of a storage container
• Failing to label or appropriately label storage containers (using improper labels or not including the accumulation start date) for used lamps
• Failing to keep containers storing used lamps completely sealed unless used lamps are being added to the container (this includes even small openings in containers such as bankers boxes)
• Assuming LED lamps are exempt from universal waste regulations
• Cleaning up broken used lamps without proper PPE, or in a manner that increases the likelihood that hazardous constituents are released to the environment
• Using a lamp crusher
• Not completing the DOT hazardous material training if shipping universal waste that meets the definition of hazardous materials

How can I avoid common used lamp management mistakes?

• Pick a dedicated and commonly known universal waste storage area that allows for proper storage and is reasonably close to the source of universal waste generation
• Include detailed instructions for proper used lamp management in an annual universal waste training program. Also include the location of the universal waste storage area and which personnel are responsible for managing the universal waste program
• Develop a Standard Operating Procedure for used lamp management and distribute to applicable personnel. Review and update the SOP routinely
• Have a consistent inspection program that provides detailed corrective actions to employees responsible for used lamp management
• Keep track of supplies such as boxes, tape, and labels
• Schedule pick-ups at intervals that avoid exceeding the one-year storage limit
• Stay up to date on newer lamp technologies such as LED lamps
• Complete the U.S. DOT hazardous material training and complete the refresher training within the three-year requirement

If you have any questions about universal waste or specifically “Used Lamps”, please reach out to me at agolding@all4inc.com or Karen Thompson at kthompson@all4inc.com. ALL4 is here to answer your questions and assist your facility with all aspects of hazardous and universal waste management.