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BoReTech)e 3.0 MANAGEMENT OF SPECIFIC WASTES FLUORESCENT LIGHT TUBES AND HID LAMPS Certain spent fluorescent light tubes, high intensity discharge (HID) lamps, and mercury -containing lamps (e.g., fluorescent, high pressure sodium, mercury vapor, and metal halide lamps) must be managed as universal waste. Universal waste lamps include most (but not all) fluorescent tubes, HID lamps, sodium vapor lamps, and any other lamps which exhibit a characteristic of a hazardous waste. First, contact the lamp manufacturer to request a written claim that the lamps are not hazardous (basically, mercury -free). If they cannot make that claim, then you must follow the requirements for "small quantity handlers" of fluorescent lamps that are found in 40 CFR 273. Fluorescent lamps are conditionally exempt from classification as hazardous wastes provided that they are managed in compliance with the standards of 40 CFR 273. A summary of these requirements is found below. Incandescent light bulbs would not be expected to exhibit a characteristic of a hazardous waste and, consequently, are not be subject to regulation as hazardous wastes. Labeling and Containers: • Contain any lamp in containers or packages that are structurally sound, adequate to prevent breakage, and compatible with the contents of the lamps. Such containers and packages must remain closed and must lack evidence of leakage, spillage or damage that could cause leakage under reasonably foreseeable conditions. It is preferred to store lamps in the containers in which the new lamps came. • Each lamp or a container or package in which such lamps are contained must be labeled or marked clearly with one of the following phrases: "Universal Waste-- Lamp(s)", or "Waste Lamp(s)", or "Used Lamp(s)". Label lamps with the date that they are generated (section 273.14). This date is the date that a universal waste is discarded after being "used up", or when the generator decides to discard the universal waste. The regulations contain several options for labeling. The intent of the label is to assist emergency response personnel or an inspector to identify the universal waste, and for an inspector to determine from the label if all universal wastes are being shipped offsite within the one year time period. Disposal and Transportation of Spent Lamps • Do not dispose of universal waste with regular nonhazardous solid waste. • Handlers of universal waste are prohibited from sending universal waste to a place other than another universal waste handler, a destination facility, or a foreign destination. Universal wastes may be sent to one of three types of destination: Boretech Hazardous Materials & Hazardous Waste Management Operations Plan Page 121