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Attachment 3 FREQUENTLY ASKED QUESTIONS ABOUT UNIVERSAL WASTE LAMPS Q What types of lamps are included in A business doesn't generate any the UW rule? other dangerous waste, but they do have a lot of fluorescent lamps that AThe rule includes,but is not limited to, get changed out—how does the UW rule fluorescent tubes,compact fluorescent, affect them? mercury vapor,metal halide,high- pressure sodium and neon lamps. The rule targets The affect of the rule on the business those lamps that are frequently used by businesses, depends on a few things. The first is institutions,government and utilities,and that are whether or not the lamps are dangerous known to have hazardous properties that may cause waste. If the lamps are dangerous waste,then the them to be a dangerous waste,such as mercury and number of lamps generated and the local regulations lead. Other types of lamps,such as incandescent, for business lamp disposal will affect that business. may also have hazardous properties,such as lead in For such a business, the quantity of dangerous waste the lamp base,that can cause them to be dangerous lamps generated is going to determine their waste and as such could be managed as universal regulatory status, If the business generates more waste. than 220 pounds of lamps at one time or during one month or accumulates more than 2,200 pounds of lamps at any time,then they would become a QWhat is the difference between a regulated dangerous waste generator unless they generator and a handler under the manage the lamps under the universal waste rule. If UW rule? the business generates less than 220 pounds of dangerous waste lamps,then they would be AUnder the universal waste rule a considered a small quantity generator(SQG)and generator of universal waste is also subject to the less stringent small quantity generator considered a handler. A handler can be regulations found at WAC 173-303-070(8). They could choose to manage the lamps as universal the generator of the lamp,ora business that receives, waste,or choose to manage the lamps as SQG collects and then sends lamps on to another handler, dangerous waste. The business should check with or to a destination facility. their local health department,solid waste agency or landfill operator for requirements. QWhat does the UW rule mean for regulated generators of dangerous A business is currently a small waste(medium quantity and large quantity generator(SQG) of quantity generators)? dangerous waste,how does the UW A rule affect them? Regulated generators of dangerous waste that also generate dangerous waste lamps A business that generates dangerous should begin managing those lamps as universal waste. The benefits of managing the waste at the small quantity generator lamps as universal waste include no counting,no level may be affected by the rule. If,in addition to other dangerous wastes they generate, manifesting,no reporting on annual reports,and a they generate or accumulate dangerous waste lamps longer accumulation time. The January 1995 policy in quantities that may push them over the SQG on fluorescent tubes is being replaced by the quantity exclusion limits,then they should manage universal waste rule, so regulated generators no those lamps as universal waste to retain their SQG longer have the option of sending their dangerous status. If a business generates dangerous wastes, waste fluorescent tubes to a Municipal Solid Waste including dangerous waste lamps,under the SQG landfill. 3-1 Attachment to Focus Sheet 00-04-020, Universal Waste Rule for Dangerous Waste Lamps