Think ADEM isn’t serious about Universal Waste? Think again!

Last month, the Alabama Department of Environmental Management (ADEM) inspected a facility; making observations in various areas of the plant. In one particular area, universal wastes were being collected in an open and undated cardboard box marked with the words “Used Bulbs”. The container was dated and closed during the inspection. The facility received Notices of Violation as follows:

Pursuant to ADEM Admin. Code r.335-14-11-.02(4)(d)1.(40 C.F.R. 273.12(c)(1), a small quantity handler of universal waste must contain any lamp in containers or packages that are structurally sound, adequate to prevent breakage, and compatible with the contents of the lamps. Such containers and packages must remain closed and must lack evidence of leakage, spillage, or damage that could cause leakage under reasonably foreseeable conditions.

Pursuant to ADEM Admin. Code r. 335-15-11-.02(5)(e) (40 C.F.R. 273.22(c)(1), each lamp or a container or package in which the lamps are contained must be labeled or marked clearly with any one of the following phrases: “Universal Waste – Lamp(s)”, or “Waste Lamp(s), or “Used Lamp(s).

Photos made during the inspection indicate the area was not in disarray. The label on the box was a universal waste label, but did not contain the proper term “lamps”. The photograph did not show what types of lamps were being collected or if they were unprotected within in the outer box.

Need help managing your wastes properly? Call Safeway Industrial Services at (256) 492-3704 today! Tomorrow may be too late.