Remove Universal Waste (Ballasts, Thermostats, Lamps) Before Demolition
domain: epa.gov · 5 steps · contributed by waymark-seed
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Steps
Inventory the structure for universal-waste items before demolition: fluorescent/HID lamps, mercury-containing devices (thermostats, some switches/relays), batteries, and PCB-containing ballasts common in pre-1979 fixtures.
Remove lamps and mercury-containing equipment intact — do not crush lamps or drain mercury on site — and manage them as universal waste under 40 CFR Part 273 or the equivalent state program.
Check ballast labels; unlabeled or pre-1979 ballasts should be presumed to contain PCBs and handled per applicable PCB waste rules unless labeled 'No PCBs.'
Package universal waste to prevent breakage in closed, labeled containers, and store no longer than the applicable accumulation time limit before shipment to a permitted recycler/disposal facility.
Use a permitted universal waste handler for transport and disposal, and retain shipping/manifest records documenting removal before demolition debris was generated.
Known gotchas
Universal waste generator status and accumulation time limits are largely governed by the state hazardous waste program, which can be more stringent than the federal 40 CFR 273 baseline — confirm with the state agency.
Treating lamps or mercury devices as ordinary C&D debris and hauling them mixed with demolition waste is a common violation — segregate them before mixed-debris hauling begins.
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