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Lamp Recycling Made Easy - Universal Waste Rule Compliance

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stack of lamps

Whether constructing or maintaining an office building, hospital or home, decisionmakers must consider environmental regulation compliance as they dispose of potentially hazardous waste.

In 1995, the Environmental Protection Agency (EPA) issued the Universal Waste Rule (UWR) to make environmental regulations for wastes, generated by large numbers of businesses in relatively small quantities, more efficient. Universal wastes are typically items that households and small businesses frequently throw into the trash, including thermostats, batteries and pesticides. Over the past six years, particular attention has been paid to the addition of mercury-containing lamps to the UWR.

The reason for the amendment to the UWR is threefold: to reduce the solid waste stream’s exposure to hazardous waste, to encourage recycling and proper disposal of common hazardous wastes and to reduce the regulatory burden on businesses that generate these wastes. The rule intends to make it easier for hazardous waste generators to “do their part.” EPA studies have shown that past deterrents to proper disposal of mercury-containing lamps included cost, inconvenience, lack of infrastructure and an absence of clear, consistent information.

According to the EPA, most fluorescent lamps contain enough mercury to fail the toxicity characteristic and, as a result, must adhere to the hazardous waste regulations set forth in the Resource Conservation and Recovery Act (RCRA).

This federal law, along with the various regulations it has spawned, creates a framework of rules that govern all aspects of waste management in the United States. States have been authorized to implement and enforce the RCRA rules, however their waste regulations must be either equal to, or more stringent than, specified federal requirements. Federal law indicates that full RCRA regulation applies to those who generate more than 100 kilograms of hazardous waste per month.

Federal law also maintains that the generators of these wastes are ultimately responsible for, and must comply with, full hazardous waste requirements for labeling, processing, treatment and final processing. In an effort to help generators eliminate any potential future environmental liability, waste management companies have developed service solutions to enable customers to remain compliant with the regulations.

The Importance of Lamp Recycling

Mercury is a neurotoxin, a substance that inhibits, damages or destroys the tissues of the nervous system.

While the severity of the hazardous health effects of exposure to mercury depend on a variety of factors, including dose, duration of exposure, route of exposure, age and health of the person and chemical form, exposure may impede neurological development, cause neuromuscular damage, emotional changes, respiratory failure and even death.

There are many kinds of lamps that contain mercury — lamps that many generators do not realize are considered hazardous waste when spent. These lamps are not uncommon and include florescent, compact fluorescent, black lights, high intensity discharge, ultraviolet and neon.

Improperly disposed of mercury-containing lamps pose an enormous threat to the safety of our environment and the health of our population. For example, when mercury- containing lamps are discarded, the mercury may find its way into the soil, air and water. One fluorescent lamp contains enough mercury to pollute more than 7,000 gallons of water beyond a safe drinking level.

Each year, 520 million lamps enter the solid waste steam — enough mercury to contaminate 3.6 trillion gallons of water.

What is a Generator Supposed to Do?

Unfortunately, for generators of mercury-containing waste, federal and state regulations are far from simple and straightforward. The most important step a generator can take is to stay informed. It is imperative to periodically check local, state and federal laws and to adhere to the strictest option available. These laws will detail the requirements for lighting removal, storage, transportation and disposal.

The EPA recommends that anyone wanting to dispose of lamps should take one of three actions. A generator could have a testing laboratory run a Toxic Characteristic Leachate Procedure (TCLP) on the lamps. This procedure identifies any waste that has the potential to leach from the solid waste and cause groundwater contamination. The generator could also obtain manufacturersupplied information about the lamps’ toxicity, which is generally not readily available to consumers. Finally, the generator could assume that the lamp is hazardous and dispose of it according to local, state or federal standards.

Once the decision has been made to properly dispose of mercury-containing lamps, generators again have several options. According to the National Electrical Manufacturers Association (NEMA), households and small quantity generators are generally exempt from the hazardous waste disposal requirements; however, many states have banned all mercury-containing wastes from being put in the normal trash.

Some municipal and state landfills may accept this kind of waste, but most have become more restrictive because of recent regulations and questions related to how much hazardous waste leaches from landfills. Most incinerators will not accept any mercury- containing waste, provided they are aware of the material. A viable option is to contact a waste management company to determine what services are offered to meet current needs.

Some lighting and electrical distributors have teamed up with recycling companies to offer lamp recycling services to customers. Generators may be able to purchase convenient recycling “kits” from your distributor for smaller quantities of lamps, or even “bulk” recycling for large re-lamp projects.

“Offering an environmentally-compliant recycling solution is a natural fit for our customers,” stated Glen C. Goedecke, Alabama Division Manager for Mayer Electric Supply Company Inc. “The solution, however, needs to be more than just offering a box”, continued Goedecke. “It needs to provide adequate levels of environmental and liability protection.”

Onyx Environmental Services (OES), for example, has developed systems that are safe for handling mercury-containing products. One such product is its Onyx- Pak, a line of prepaid packaging materials that streamline lamp recycling, especially for those lamps that contain mercury. Tested and approved in accordance with United Nations and U.S. Department of Transportation standards, recycling supplies can be delivered to their door, complete with prepaid return shipping labels.

Designed in part to meet the EPA’s goal of an 80% recycling rate for mercury containing lamps by 2009, OnyxPak, and other services like it, are a solution for organizations that want to do their part to comply, but do not have the resources or the volume to warrant a pick up service. “OnyxPak minimizes liability,” notes John McShane, Branch Manager for the Electronics Recycling Division of Onyx Environmental Services. “We’ve designed OnyxPak to make it easy to recycle as well as comply with federal, state and local disposal regulations.”

Choosing a qualified service provider is crucial to properly disposing of mercury-containing lamps and to ultimately taking the liability out of the generator’s hands. Waste generators must evaluate recycling companies based on their knowledge of the regulations, having the necessary permits and not having EPA violations. Recycling companies should also be evaluated based on indemnification and environmental track record. Indemnification protects companies from financial liability from environmental damage caused by mismanagement of waste, while a solid environmental record offers further protection and peace of mind.

When recycling a potentially hazardous lamp, being compliant with the UWR can be confusing. Waste generators should rest assured that there are places to turn for help. Four resources available to anyone include lighting manufacturers or distributors; state and local environmental agencies; the USEPA-funded Lamp Recycling Outreach Program; and environmental service/recycling companies.