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ALL CENTER QUESTIONS & ANSWERS RCRA October 30, 1980). The generator duties in this case are those required of a large 1. Contractors i is Cogenerators of quantity handler of universal waste in Part Universal WE ste Lamps 273, Subpart C,which apply to universal waste handlers accumulating 5,000 An elementary, hool is in the process of kilograms or more universal waste at any remodeling and is eplacing its light fixtures time(§273.9). with more energy- cient lamps. This process will genera a more than 5,000 kg of spent hazardous w ste lamps that will be subject to the univ sal waste management standards in 40 CF Part 273. If the school hires a contractor t remove the spent hazardous lamps, z o is required to comply with the universal z aste standards in Part 2 73? Both the school d the contractor will be subject to the unive sal waste handler standards in Part 271 because they would both be considered i niversal waste handlers. A universal waste hi ndler is defined as a generator of univers 1 waste or the owner or operator of a facili that receives universal waste from other un versal waste handlers (§273.9). A generat r is any person, by site, whose act or proces produces hazardous waste or whose act rst causes a hazardous waste to become subject to regulation (§273.9). In this cas , the school used the lamps and made the etermination to discard them and is thus a g nerator. The contractor that actually remove the universal waste lamps from service i considered a handler and generator of the aste making the school and the contr ctor in in (64 FR 36466, 36474; Ju y 6, 1999). As cogenerators, both th school and the contractor will be joi itly and severally liable as universal waste h dlers. EPA recommends that wh n two or more parties meet the definition o generator they should mutually agree to ha a one party perform the generator duties ( 5 FR 72024, 72026;