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for first-t me submissions (RMP*Submit 2004 User's Manual (EPA550- B-04-002) ) . CALL CENTER QUESTIONS AND ANSWERS RCRA 1. Contractors as Cogenerators of Universal Waste Lamps An element ry school is in the process of remodeling and is replacing i s light fixtures with more energy-efficient lamps. This proces will generate more than 5,000 kg of spent hazardous waste lamps that will be subject to the universal waste management standards in 40 CFR Part 273. If the school hires a contractor t remove the spent hazardous lamps, who is required to comply wi h the universal waste standards in Part 273? Both the sc ool and the contractor will be subject to the universal wa to handler standards in Part 273 because they would both be cons'dered universal waste handlers. A universal waste handler is d fined as a generator of universal waste or the owner or operator f a facility that receives universal waste from other univer al waste handlers (Section 273.9) . A generator is any person, y site, whose act or process produces hazardous waste or who3e act first causes a hazardous waste to become subject to r gulation (Section 273.9) . In this case, the school used the lam s and made the determination to discard them and is thus a gener tor. The contractor that actually removes the universal wa to lamps from service is considered a handler and generator of the waste making the school and the contractor cogenerators (64 FR 36466, 36474; July 6, 1999) . As cogenerators both the school and the contractor will be jointly and severally liable as universal waste handlers. EPA recommends that when two or more parties meet the definition of generator they should mutually agree to have one party perform the generator du ies (45 FR 72024, 72026; October 30, 1980) . The generator du ies in this case are those required of a large quantity han ler of universal waste in Part 273, Subpart C, which apply to uni ersal waste handlers accumulating 5,000 kilograms or more univers 1 waste at any time (Section 273.9) . NEW PUBLICATONS How to order. NTIS Publi ations are available by calling (800) 553-6847 or (703) 605-6000, or writing NTIS, 5285 Port Royal Road, Springfield, VA 22161. Use the NTIS rder Number listed under the document. NSCEP Publica ions are available by calling (800) 490-9198 or by writing USEP /NSCEP, PO Box 42419, Cincinnati, OH 45242-0419. Use th EPA Order Number listed under the document. Call Center P blications are available by calling the Call Center at: RCRA, Superf nd & EPCRA National Toll-Free No. : (800) 424-9346 Local: (703) 412-9810