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quantity exclusion limits, then they may manage the Will on-site lamp crushing to reduce lamps as SQG dangerous waste. The business volume space be allowed under the should check with their local health department, UW rule? solid waste agency or landfill operator for requirements. No,Ecology did not include an on-site lamp crushing management option in the final universal waste rule. During the Are manufacturers making lamps rule development,it was determined that the as- Athat are non-dangerous waste? proposed performance-based lamp crushing standards were not enough to ensure that The major lamp manufacturers are uncontrolled releases of mercury and other producing lamps that pass both the hazardous constituents would not occur from the use federal Toxicity Characteristic Leaching of lamp crushing units currently on the market. Procedure(TCLP)test and Ecology's static acute Because of this,Ecology could not ensure that fish toxicity test for state criteria. Check with the handlers would be crushing lamps properly and in a lamp manufacturer,your local lamp distributor,or way that did not release mercury or other hazardous lighting contractor for more information on specific constituents into the environment. To address this lamp models. issue,Ecology would need to add layers of complexity to the universal waste rule in explaining such requirements as engineering controls and QCan those non-dangerous waste maintenance schedules. Adding more complex lamps be managed as solid waste or language and requirements would conflict with the do they need to be managed as purpose of the universal waste management system. univerAsal waste? The universal waste rule only requires What happens if a universal waste that dangerous waste lamps be lamp handler mismanages universal managed as universal waste. Lamp wastes? models that have been shown to be non- dangerous waste would be eligible for disposal The universal waste rule is a subset of the to a Municipal Solid Waste landfill, subject to full dangerous waste regulations,and a local regulations and landfill operator approval. handler that mismanages universal waste is subject to enforcement. A handler that receives Of course,the non-dangerous waste lamps still universal waste from others and mismanages the have recyclable components, including glass waste would be held liable for the actual regulatory and the aluminum end caps and metal bases. violation,but the other handlers would also be Additionally,these types of"green" lamps still responsible for that mismanagement under our state contain mercury, and pass the TCLP not simply cleanup law,the Model Toxics Control Act. Since because of the lower mercury content,but universal wastes are still dangerous wastes,persons because there are other unique lamp components remain liable under dangerous waste and cleanup or additives that aid in binding up the mercury regulations for remediation of any releases from so that it doesn't leach during the TCLP test. universal waste management. The manufacturers have all stated that removal of the unique components or additives will Can a handler of universal waste generally cause these lamps to fail the TCLP. lamps self-transport universal As always, Ecology recommends recycling over wastes to another handler or disposal. destination facility? • 3-2 Attachment to Focus Sheet DO-04-020, Universal Waste Rule for Dangerous Waste Lamps