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This information was prepared to address questions frequently asked by property managers regarding management of Universal Waste. Those other than property managers should consult the Universal Waste Management Regulations or call DDOE’s Hazardous Waste Program for assistance in determining how to comply.
Spent compact fluorescent light bulbs (CFLs), fluorescent light bulbs, and batteries are considered Universal Waste in the District of Columbia and must be managed in accordance with the District Department of the Environment (DDOE) regulations.
If you choose to ship your spent, intact (unbroken) lamps to an approved disposal facility or arrange for a pick-up from your facility, the waste is classified as Universal Waste. The key distinction is that the lamps are unbroken.
Crushing is the intentional breaking of fluorescent and other mercury lamps for the purpose of volume reduction. Crushing reduces the physical volume of lamps but does not recover any mercury. Drum-top crushing is done using a mechanical device that fits on top of a 55-gallon collection drum. Whole lamps are broken in the system but components are not separated, and the drum will contain hazardous mercury, phosphor powder, glass and mixed metals. Crushing lamps into drums releases mercury into the filter, which also becomes hazardous.
If you choose to use a drum-top crusher and crush your fluorescent light bulbs, a new hazardous waste determination must be made. Note that if you do not test your low-mercury lamps to prove them non-hazardous, assume they are hazardous waste and manage them according to DDOE Hazardous Waste regulations.
A battery is a device consisting of one or more electrically connected electrochemical cells designed to receive, store, and deliver electric energy. An electrochemical cell is a system consisting of an anode, cathode, and an electrolyte, plus such connections (electrical and mechanical) as may be needed to allow the cell to deliver or receive electrical energy. Regulated batteries also include an intact, unbroken battery from which the electrolyte has been removed.
As a property manager, you may also be generating other waste streams including but not limited to used oil, waste petroleum products, waste paint thinners, waste solvents, and waste pesticides. These materials may also be subject to management under the Hazardous Waste regulations.
For more information contact one of the following inspectors:
Victoria North - 202.535.1909
Lawrence Williams - 202.535.2298
Jan Walwyn - 202.671.5120