Universal Waste Transporters

The following standards apply to transporters of universal waste.

• Applicability
• Exports
• Off-Site Shipments
• Prohibitions
• Response to Releases
• Storage Time Limit
• Waste Management
• Hazardous Waste Generator Requirements - 2002 Fact Sheet

Applicability
A universal waste transporter is any person who “engages in the off-site transportation of universal waste by air, rail, highway, or water.”

This definition is notable for what it does not say; transporters do not require any special registration or license to transport universal waste. Therefore, a person can transport universal waste in their own vehicle or use any common carrier including package delivery firms.

Check with a carrier or package delivery service ahead of time to ensure that they will accept waste mercury lamps for transport and to find out if they have any special requirements. (Section 66273.50)

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Exports
Transporters must not accept a shipment to a foreign destination if the shipment does not conform to the EPA Acknowledgment of Consent. Ensure that a copy of the EPA Acknowledgment of Consent accompanies the shipment, and that the shipment is delivered to the facility designated by the person initiating the shipment. (Section 66273.56)

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Off-Site Shipments
Transporting waste mercury lamps to a place other than a universal waste handler, a destination facility, or a foreign destination is prohibited. Therefore, waste mercury lamps can not be left at a landfill or a vacant lot for disposal. (Section 66273.55)

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Prohibitions
Universal waste transporters are prohibited from disposing of waste mercury lamps or treating them, except when responding to releases. (Section 66273.51)

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Response to Releases
Immediately contain all releases resulting from broken mercury lamps. Determine whether any of the released material is hazardous waste. If the waste is hazardous, refer to Title 22, Division 4.5, Chapter 12, Standards for Generators of Hazardous Waste. Waste consisting only of residues of leaking, broken, or otherwise damaged mercury lamps may be managed as universal waste provided that the leaking, broken, or otherwise damaged lamps are repackaged according to the standards described in the “response to releases” section under small or large quantity handlers of universal waste. (Section 66273.54)

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Storage Time Limit
Store waste mercury lamps at a transfer facility for:

• Ten days in an industrial-zoned area
• Six days in all other areas

Transporters that exceed either of these storage limits are considered to be universal waste handlers and must comply with the applicable handler requirements while storing the waste mercury lamps. (Section 66273.53)

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Waste Management
Transporters shall comply with all applicable U.S. Department of Transportation (U.S. DOT) regulations for transporting specific universal wastes. These rules apply not only to universal waste, but also to transportation of anything in the United States. (Section 66273.52)

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