From the archives of the Enforcement and Compliance Listserv for Hazardous Waste Generators

Oct. 1, 2010

Unbroken mercury-containing lamps managed as universal waste

Unbroken mercury-containing lamps can be managed as a universal waste. If you chose to manage your unbroken mercury-containing lamps as hazardous waste please see information below. Unbroken bulbs that are managed as universal waste can be shipped using a common carrier and a standard bill of lading. Generators may also self-transport their own bulbs to an authorized destination facility. Typically the bulbs can be transported using the description: UN3077 (UNIVERSAL WASTE) FLUORESCENT BULBS, 9, PGIII; however; specialty bulbs that contain certain metals or gases may not be able to use that description. You should always check with your bulb manufacturer for correct and current shipping description. 

Although the Universal Waste Rule eases restrictions on the transportation requirements for universal waste lamps, self-transportation of used lamps still must comply with the U.S. Department of Transportation requirements including packaging, labeling and marking of containers. The lamp recycler you choose may provide boxes designed to reduce breakage during transport to a recycling or disposal facility; however, be certain that the boxes provided are properly labeled "Universal Waste-Lamp(s)" or "Waste Lamp(s)" or "Used Mercury Lamp(s)."

Broken mercury-containing lamps or mercury-containing lamps not managed as universal waste

Mercury-containing lamps that are crushed or broken cannot be shipped as universal waste. These broken bulbs are hazardous waste and the hazardous waste transportation requirements apply. These requirements include but are not limited to: proper packaging, labeling and marking of containers; the use of a Uniform Hazardous Waste Manifest; and the use of a licensed hazardous waste transporter.  The description on the hazardous waste manifest is typically RQ, UN3077 HAZARDOUS WASTE SOLID (MERCURY), 9, PG III; however, specialty bulbs that contain certain metals or gases may not be able to use that description. You should always check with your bulb manufacturer for correct and current shipping description. Don’t forget that bulb crushers are not allowed in the state of Missouri and every effort should be made to avoid breaking bulbs. Broken bulbs expose employees, the public and the environment to mercury which can be harmful even at low levels.

A transporter is allowed up to 5 percent breakage of mercury-containing lamps during transportation; however, this does not mean generators can send broken bulbs as universal waste. The 5 percent  accidental or incidental breakage only pertains to breakage that occurs during shipment or as a result of shipment. When facilities generate broken bulbs they must manage and transport the broken mercury containing lamps as hazardous waste and must use a Uniform Hazardous Waste Manifest.

To learn more about universal hazardous waste bulbs, visit our website.

August 27, 2010

Waste Fluorescent Light Bulbs

What is the proper shipping description for a generator's waste fluorescent bulbs? Typically most fluorescent bulbs do not contain large amounts of mercury and can not be classified as "Mercury contained in manufactured articles, 8, UN2809, PG I". Instead, generators should use the shipping description "Hazardous waste, solid, n.o.s. (D009), 9, NA3077, PG III". You may want to check previous manifests or bills of lading for the shipping description that you are using. If you or your environmental contract have chosen a different shipping description for shipping waste fluorescent bulbs now may be the time to rethink that decision.

Lithium Batteries in Storage and in Transportation

Lithium batteries can lead to dangerous fires if  batteries short out against each other or a battery short-circuits with something else. Lithium batteries are especially problematic because once a fire starts it is difficult for fire fighters to extinguish the fire because of the heat and gasses produced. It is important to prevent lithium batteries from short-circuiting by taking special precautions while lithium batteries are in storage and transportation including:

  • Packing each battery separately using non-conductive materials (not cardboard, paper, or metal as the primary segregation). Plastic bags or bubble wrap work well for this.
  • Separating batteries from other batteries, devices, or conductive materials. Do not store lithium batteries directly together or with other batteries. Do not store your lithium batteries in direct contact with metal containers such as a drum.
  • Cover battery terminals or connectors with non-conductive caps, tape, or other appropriate means. These coverings should be sturdy enough to last through transportation. Remember, even non-waste lithium batteries can be an ignition source and must be separated from ignitable hazardous waste or protected against shorting out.

For more information on the transportation of lithium metal and lithium ion batteries please see the International Air Transportation Association's Guidance Document on Transport of Lithium Metal and Lithium Ion Batteries. To review topics that have been previously covered by the listserv, please visit our archive. If you would like to unsubscribe, please visit our website. If you know of anyone else who would like to be added to this listserv, they can visit our website to sign up.

Jan. 22, 2009

Universal Waste in Missouri

Last month we started discussing the regulations that make Missouri unique. Most states have modified the federal universal waste rules and which wastes are covered by the rule varies from state to state. The universal waste rules were written to give businesses the option of managing certain hazardous wastes with less regulation. In Missouri, universal wastes include certain batteries, thermostats, mercury containing lamps, and pesticides collected by a compliant universal waste pesticide program. For more specific information, see our fact sheet and state regulations and federal regulations

Advantages of managing universal wastes under the universal waste rule include:

  • simplified labeling requirements
  • storage on site for one year, or longer if it is solely to accumulate sufficient quantities necessary for proper recovery, treatment, or disposal,
  • universal waste does not count towards your hazardous waste generator status or level,
  • there are no hazardous waste fees or taxes on universal wastes,
  • you are not required to have an EPA generator identification number,
  • you may accept universal waste from other generators,
  • you may use shipping papers or bills of lading rather than the uniform hazardous waste manifest,
  • small quantity handlers (those who accumulate less than 11,000 pounds at any one time) have no record keeping requirements,
  • you may self-transport using the less stringent universal waste transporter requirements, and
  • you are not required to use a licensed hazardous waste transporter, although U.S. Department of Transportation regulations may still apply to the material and mode of shipment.

Of course universal waste, as with all hazardous waste, must not be disposed of into the environment. Universal waste may not be diluted or treated without a Missouri Resource Recovery Certification or hazardous waste treatment permit. Mercury containing lamps, including fluorescent bulbs, may not be broken or crushed without certification or permit. In Missouri, on-site bulb crushing or drum top bulb crushers are NOT allowed. For more information on fluorescent bulbs, see our fluorescent bulb fact sheet. Your business may chose to manage universal hazardous waste as ordinary hazardous waste if your business does not want to manage universal wastes separately.

May 31, 2007

Labeling or Marking Universal Waste

As with satellite containers, universal waste also has labeling options.

  • For mercury switches, in Missouri the label should read "Universal Waste-Mercury Switch(es)", or "Waste Mercury Switch(es)" or "Used Mercury Switch(es)";
  • For batteries, the label should read "Universal Waste-Battery(ies)", or"Waste Battery(ies)" or "Used Battery(ies)";
  • For thermostats, the label should read "Universal Waste-Mercury Thermostat(s)", or "Waste Mercury Thermostat(s)" or "Used Mercury Thermostat(s)";
  • For lamps, the label should read "Universal Waste-Lamp(s)", or "Waste Lamp(s)" or "Used Mercury Lamp(s)";
  • For pesticides, the label should read "Universal Waste-Pesticide(s)", or"Waste Pesticide(s)".

Remember, hazardous waste pesticides may only be managed as a universal waste as long as they are sent to a Missouri approved universal waste pesticide collection program, to a Certified Resource Recovery Facility, or to a Universal Waste Destination Facility.

Dec. 4, 2006

Fluorescent Bulbs

Almost every business generates some type of fluorescent bulb. Most fluorescent bulbs contain mercury vapor that, when released, is dangerous to inhale. So, how must businesses handle their fluorescent bulbs? Businesses have two options, they can manage the bulbs as a universal waste or as a hazardous waste. Most businesses choose to manage their bulbs as a universal waste because the universal waste laws are less stringent. To review the advantages of managing your bulbs as a universal waste, see our listserv topic below.

Some companies offer devices for on-site bulb crushing, however, use of such devices is not allowed in Missouri. The U.S. Environmental Protection Agency recently released a study entitled "Mercury Lamp Drum-Top Crusher Study." In summary, the EPA discovered that even properly working bulb crushing machines release some mercury, and if the drum is poorly designed, mercury levels above the Occupational Health and Safety Administration's Permissible Exposure Limits may occur. Visit the US EPA document entitled "Mercury Lamp Drum-Top Crusher Study" to learn more.  For more information on properly managing your waste fluorescent bulbs and a list of bulb recyclers, visit Fluorescent Bulbs.

July 5, 2006

What is Universal Waste? Universal wastes are specific types of hazardous waste that are defined in Missouri's Universal Waste Regulations (see 10 CSR 25-16.273). Another way to think of it is that hazardous waste is the broad category and universal waste is a special subset of that broad category. Universal waste is typically items that are common, widespread, and exhibit only a low level hazard or can be easily managed. In Missouri, universal waste includes batteries, pesticides, thermostats, and hazardous lamps (fluorescent, metal-halide, High-Intensity-Discharge, and mercury containing lamps). For more specific information, please review our Universal Waste Rule in Missouri technical bulletin -- PUB2058.  The U.S. Environmental Protection Agency, recognizing the difficulty associated with following hazardous waste regulations for such common items, developed the universal waste rules. Universal waste rules allow businesses to manage universal waste in a less-stringent manner, yet still protects workers and the environment from exposure to that hazardous waste. Some of the advantages to managing your qualifying waste as a universal waste include:

  • you may accumulate universal wastes on-site for one year;
  • you may self-transport universal waste to an authorized destination facility or Missouri Certified Resource Recovery if you meet universal waste transporter requirements;
  • small quantity universal waste handlers (less than 11,000 pounds at any one time) need not keep records of universal waste received or shipped, large quantity universal waste handlers do have some record keeping requirements;
  • the transporter, rather than the universal waste handler, can prepare the shipping papers;
  • hazardous waste generator fees do not apply to universal waste;
  • no quarterly or annual reporting to the Missouri Department of Natural Resources is required;
  • universal waste is counted separately from your total hazardous waste generated, thus universal waste does not increase your hazardous waste generator status.

For information about fluorescent lamps and recyclers, please visit our Fluorescent Bulbs page.

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