TRADEBE works closely with customers to ensure that hazardous waste shipments and packaging are in compliance with container regulatory requirements of the Department of Transportation, (DOT).
Tradebe's Fluorescent Lamp Guidelines (PDF) document is a regulatory brochure designed to aid customers in the development of programs for the proper management, (e.g., generation, packaging and shipments), of universal waste/lamps. Generators of universal waste, known as universal waste handlers, (“handlers”), are classified by the USEPA as small quantity handlers (40 CFR 273 Subpart B) or large quantity handlers, (40 CFR 273 Subpart C), based on the volume of all universal waste generated by the handler at their site.
Federal universal waste regulations apply to: batteries, pesticides, mercury-containing devices and lamps. Handlers must manage lamps in a way that prevents release of any universal waste, or component of a universal waste, to the environment. Also, handlers must accumulate lamps in a structurally sound container to protect the lamps and prevent release of any universal waste constituent such as mercury. Handlers must identify and label these containers with the type of universal waste and the date the waste was placed into the container.
USEPA regulations allow lamps to be identified as any of the following types:
- “Universal Waste—Lamp(s),” or
- “Waste Lamp(s),” or
- “Used Lamp(s)”
Note, “Bad bulbs” or “Bad lamps” are not USEPA approved types; (refer to 40 CFR 273 regulations).
• Broken lamps must be immediately cleaned up and placed in a structurally sound container.
• Lamps showing evidence of breakage, leakage or other damage must be placed in a container to avoid the possible release of mercury or other hazardous constituents to the environment.
• Universal waste/lamps cannot be accumulated for more than 1 year.
• Employees whose actions generate or responsibilities include handling waste lamps must be trained.
• Universal waste/lamps must be shipped to approved facilities.
• Records of universal waste/lamps shipments must be maintained.
Refer to USEPA 40 CFR 273 for the Federal Universal Waste Regulations. Tradebe recommends that Generators/Handlers of waste always review their state environmental regulations and guidance documents to determine the types and specific handling for their state's universal waste regulations.