When can an MRW facility crush CESQG / HHW fluorescent lamps?
Many Moderate Risk Waste (MRW) facilities collect fluorescent lamps from conditionally exempt small quantity generators (CESQGs) as well as from households. Some MRW facilities are exploring the idea of crushing lamps on-site prior to sending them off-site for final management. CESQG and Household Hazardous Waste (HHW) are regulated differently. CESQGs have different options to manage their waste lamps. CESQGs can choose to direct their waste lamps to the following types of facilities: • Universal Waste (UW) destination facility as UW [WAC 173-303-070(8)(b)(iii)(H)]. • MRW facility as MRW [WAC 173-303-070(8)(b)(iii)(C)]. • Facility for management as dangerous waste (DW).
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