Who must comply with the regulations governing fluorescent lamps?
Isn’t there an exemption for small quantity generators? A. The regulations will affect all commercial lamp users. The majority of building owners and tenants will be generators and small quantity handlers. Building management firms and construction companies will typically be small or large quantity handlers and transporters. The requirements of the Universal Waste Regulations are summarized in a document titled “Fact Sheet – Regulatory Requirements for Management of Fluorescent and High Intensity Discharge Lamps” prepared by Fluorecycle, Inc. The exemption you have noted is a Resource Conservation and Recovery Act (RCRA) provision for Conditionally Exempt Small Quantity Generators (CESQG). The IEPA does not consider this exemption to be applicable to fluorescent and high intensity discharge lamps since they are classified as universal wastes. According to the IEPA, fluorescent and HID lamps can not be disposed of in municipal landfills or through incineration in Illinois, regardless o
