The Situation
Recently, a dealership was heavily fined for improper disposal of fluorescent lamps. With the best of intentions, a porter came in on the weekend and took 150 of the dealership’s used fluorescent lamps to a public roundup at a community college. He was not aware that regulations in his area prohibited small and large quantity generators (a common classification for dealerships) from taking universal waste to public events, which are intended for households only. He was greeted by a representative from the county’s hazardous waste division and given a citation on the spot for illegal disposal of hazardous waste. He was then informed that the agency would come to the dealership to perform a full hazardous waste compliance inspection. Regardless of the dealership’s good intentions for disposal, ultimately they were heavily fined for violating regulations.
Lessons Learned
Universal wastes commonly found at dealerships include fluorescent and HID light bulbs, electronic devices, mercury containing equipment, non-empty aerosol cans, and small alkaline batteries. These items are regulated because they contain mercury, lead, cadmium, copper and other substances that are hazardous to human health and the environment.While most dealerships are recycling these wastes, they are unclear about the additional labeling, storage, disposal, and recordkeeping requirements that can expose the dealership to liability.
State and local laws vary between jurisdictions, but a general rule of thumb is to maintain accurate labeling practices in correct storage containers. Labels should include descriptions of the waste products as well as generation dates. Most state regulations don’t permit wastes to accumulate for more than a year, so don’t let stuff pile up in the back room. Remember that containers need to be compatible with their contents. Keep accurate records. Make sure that your subcontractors are accurate in their reporting, and that your records are also up to date.
Get more details about this topic in the May KPA Newsletter on Monday (click here to subscribe).
