Small Quantity Handlers

The following standards apply to small quantity handlers of universal waste.

• Applicability
• Accumulation Time Limits
• Employee Training
• Exports
• Labeling
• Notification
• Off-Site Shipments
• Prohibitions
• Recordkeeping
• Response to Releases
• Waste Management

Applicability
A small quantity handler of universal waste has less than 5,000 kg (11,000 lbs or 5.5 tons) of universal waste on hand at any one time. Virtually all businesses that generate universal waste, but do not accept waste from other generators, are small quantity handlers. (Section 66273.10)

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Accumulation Time Limits
You may not accumulate lamps for longer than one year from the date the first waste lamps were generated or received unless specific conditions are met. Waste mercury lamps may be accumulated for more than one year if the sole purpose of accumulating such quantities is necessary for proper recovery, treatment, or disposal.

Demonstrate the length of time that the waste mercury lamps have been accumulated from the date they were generated or received by:

• Placing the waste mercury lamps in a container marked or labeled with the date that the first waste lamp was generated or received.
• Maintaining an onsite inventory that identifies the dates on which all waste mercury lamps were generated or received.
• Maintaining an onsite inventory system that identifies the earliest date that any waste mercury lamp in a group of waste lamps, or a group of containers of waste lamps, was generated or received.
• Placing the waste mercury lamps in a specific accumulation area and identifying the earliest date that any item in the area was generated or received.
• Any other method which clearly demonstrates the length of time that the waste mercury lamps have accumulated from the date that they became waste or were received. (Section 66273.15)

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Employee Training
Train all employees who handle or manage waste mercury lamps. The training content should describe proper handling and emergency procedures. (Section 66273.16)

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Exports
Waste mercury lamps shipped to a foreign destination, other than OECD countries require the consent of the receiving country, and must be in conformance with the EPA Acknowledgment of Consent. Provide a copy of the EPA Acknowledgement of Consent for the shipment to the transporter who will be exporting the shipment. (Section 66273.20)

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Labeling
Items containing waste mercury lamps must be labeled or marked clearly with one of the following phrases:

• Universal Waste – Lamp(s)
  or
• Waste Lamp(s)
  or
• Used Lamp(s) (Section 66273.14)

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Notification
The Department of Toxic Substances Control (DTSC) and the United States Environmental Protection Agency (U.S. EPA) do not require notification small quantity handlers’ universal waste handling activities. (Section 66273.12)

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Off-Site Shipments
Transferring waste mercury lamps to anyone other than a recycling facility or another universal waste handler is prohibited. A handler of universal waste is any business that accumulates waste lamps for shipment to a recycler. Packaging, labeling, and placarding shipments in must be in compliance with the transportation requirements of the U.S. Department of Transportation (U.S. DOT). (Section 66273.18)

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Prohibitions
Disposing of, or treating, waste mercury lamps is prohibited, except when responding to releases. (Section 66273.11)

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Recordkeeping (Tracking Universal Waste Shipments)
Keep records of all waste mercury lamp shipments. These records are vital for demonstrating compliance with the regulatory standards.

• Receipt of shipments: Keep a record of each waste mercury lamp shipment received. The record may take the form of a log, invoice, manifest, bill of landing, or other shipping document. It must include the name and address of the originating universal waste handler, the quantity received, and the date of receipt.
• Shipments off-site: Keep a record of each waste mercury lamp shipment sent to other facilities. The record may take the form of a log, invoice, manifest, bill of landing, or other shipping document. It must include the name and address of the shipment recipient, the quantity sent, and the date of shipment.
• Record retention: Retain records of received waste mercury lamp shipments and shipments sent to other facilities for at least three years from the date of receipt or departure. (Section 66273.19)

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Response to Releases
Immediately contain all releases resulting from broken mercury lamps. Clean up broken, leaking, or damaged waste mercury lamps and place them in an airtight container. (Section 66273.17)

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Waste Management
Manage waste mercury lamps in a way that prevents releases to the environment.

• Contain waste mercury lamps in a structurally sound box or container that remains closed and lacks evidence of leakage, spillage, or damage.
• Immediately clean up broken, leaking, or damaged mercury lamps and place them in an airtight container.
• Remove waste mercury lamps from fixtures in a manner designed to prevent breakage. Practice ladder safety and wear good leather gloves. (Section 66273.13)

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For questions about content, please contact the Regional Assistance Officers at (800) 72-TOXIC
(800-728-6942) or go to http://www.dtsc.ca.gov/ContactDtsc/Regulatory-Assistance-Officers.cfm