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Universal Waste Compliance Guidelines for Electronic Lamps

INTRODUCTION AND SCOPE

Arizona State University (ASU) uses a large amount and variety of electronic lamps.  The spent lamps are considered by the Environmental Protection Agency (EPA) to be hazardous and used lamps are known as universal wastes.  Examples of common electronics lamp that are universal wastes include intact fluorescent, high intensity discharge, neon, mercury vapor, high-pressure sodium, metal halide lamps, and incandescent lamps.  The hazardous constituents of concern in electronic lamps are the heavy metals used in manufacture, e.g. mercury and lead.  The EPA regulates universal wastes under the Resource Conservation and Recovery Act , which is the same law that defines hazardous waste. This rule streamlines the hazardous waste regulation requirements for hazardous waste lamps.  Handlers of universal wastes are subject to less stringent standards for storing, transporting, and collecting these wastes than those handlers of chemical hazardous wastes.  The EPA has concluded that regulating spent electronic lamps as a universal waste under 40 CFR Part 273 will lead to better management of these lamps and will facilitate compliance with hazardous waste requirements.  If electronic lamps are not handled correctly, EPA and state regulators will consider unmanaged lamps to be a hazardous waste.

Universal Waste Used Lamps Handling and Employee Training (40 CFR 273.16)  

I.  Proper Handling of Mercury Containing Lamps

1. Carefully remove lamp from light fixture.

2. Place the lamp into the cardboard box or sleeve from which it arrived.  (Cardboard drums are also provided for this purpose.)

3. Fold over end flaps and close with appropriate tape.

4. Mark the container appropriately with the words “Used Mercury Lamps” and generation date.

5. Carefully move the filled and labeled container to the campus accumulation point for this waste in a manner designed to prevent breakage of lamps (Call Hazardous Waste Management at 965-3899 or 965-8554 for pick up of container).

II.  Emergency Procedures - Immediately upon breakage, all lamp debris must be properly collected, packaged and disposed of as hazardous waste.

1. Don proper personal protective equipment (Latex gloves).

2. Using appropriate technique to minimize dust generation, collect all glass, metal, and phosphor (white dust) debris into a sturdy plastic bag.

3. Decontaminate all surfaces with a rag wet with vinegar and place used rag into the sturdy plastic bag.

4. Place plastic bag into an rigid container.

5. Seal container

6. Label and mark container with an ASU Hazardous Waste tag.

7. Call Hazardous Waste Management at 965-3899 or 965-8554for pick up of container

Definitions

• Universal Waste Handler:

1.       A generator of universal waste: or

2.       The owner or operator of a facility that receives universal waste from other universal waste handlers, accumulates universal waste and sends universal waste to a destination facility.

• Generator of Universal Waste/Hazardous Waste:  Any person whose act or process produces hazardous waste identified or listed in Part 261 of 40 Code of Federal Regulations or whose act first causes a hazardous waste to become subject to regulation.  

• Small Quantity Handler of Universal Waste:  A Universal Waste handler… who does not accumulate 5,000 kilograms or more total of universal waste (batteries, pesticides, or thermostats, calculated collectively) at any one time.

• Large Quantity Generator of Universal Waste:  A universal waste handler who accumulates 5,000 kilograms or more total of universal waste (batteries, pesticides, or thermostats, calculated collectively) at any one time.  

• Universal Waste:  Fluorescent, high intensity discharge, neon, mercury vapor, high-pressure sodium, and metal halide lamps, as well as batteries, pesticides, and thermostats.  

Contacts

The telephone or email contacts for hazardous waste pickups, or the universal waste process:

• Henry Walsh, Environmental Programs Manager , (480) 965-8554, henry.walsh@asu.edu  

• Jeffrey Bender, Hazardous Waste Supervisor, (480) 965-3534
  
• David Lopez, Hazardous Waste Specialist, (480) 965-0758, dalopez@mainex1.asu.edu 
  
• Stephen Scheufler, Hazardous Waste Specialist, (480) 965-0647, stephen.scheufler@asu.edu

If none of the above are available, questions or unusual emergency assistance requests should be directed to the main Risk Management department phone number at (480) 965-1823, or through the ASU Police at (480) 965-3456.

Mailing Address: PO Box 873804, Tempe, Arizona 85287-3804
Contact Email: EHS@asu.edu
Phone: (480) 965-1823
FAX:  (480) 965-0736