Federal Regulation Affecting Fluorescent & Mercury Lamp Handling & Disposal
(From the September/October 2000 issue of Demolition, published by the NADC)
recently, federal regulations have made it difficult and expensive to
properly manage used lamps and as a result most have ended up in municipal
landfills. Now the US EPA is including fluorescent and mercury lamps in
the Universal Waste Rule (UWR).
new changes in the federal regulation are designed to reduce the amount of
hazardous waste items in landfills and encourage recycling, by minimizing
the cost and regulatory burden on generators.
Waste Rule (UWR)
EPA adopted the UWR in May 1995 (40 CFR Part 273). At that time, the
agency allowed individual states to adopt their own UWRs or other local
policies addressing lamp disposal. Most states have already adopted some
policy to prohibit lamp disposal in municipal landfills and are granting
handling exemptions to generators who recycle their lamps. In 1999, EPA
included lamps in 40 CFR 273.
UWR creates several new definitions and requirements for those who
generate or handle lamps.
who creates waste mercury lamps (a RCRA characteristic waste >0.2
mg/I TCLP). A generator is also considered a SQHUW or LQHUW depending
on how many lamps are produced in a year.
Quantity Handler (SQHUW):
a generator or third party who accumulates <5,000 kg at a time, up
to one year. No EPA registration is required. Training and information
on handling mercury lamps and emergency procedures is required. Proper
marking and labeling is required.
Quantity Handler (LQHUW):
a generator or third party who accumulates >5,000 kg at a time, up
to one year. EPA or state registration and ID# is required. Training
and information on handling mercury lamps and emergency procedures is
required. Proper marking and labeling is required.
one who transports UW lamps for <10 days. No EPA registration is
a non-permitted storage location for <10 days.
Facility: a RCRA
permitted processing, recycling or disposal facility.
Quantity Handlers, Large Quantity Handlers and Transporters are not
allowed to dispose of hazardous lamps into municipal landfills, and must
them as a fully regulated hazardous waste with all the RCRA
requirements and the HW manifest
them at a permitted Destination Facility with reduced requirements and
lower costs using a Bill of Lading
UWR Basic Principles
for households and CESQGs (<100kg/mo.). May manage lamps as a UW or
via a RCRA exemption.
all but the smallest quantities (only households and CESQGs) from
traditional municipal landfills. Requires management in permitted RCRA
landfills with strict limitations or by recycling at a permitted
Destination Facility. This is less burdensome because businesses won't
have to register with the EPA to obtain a generator ID# or do the
full regulatory compliance for hazardous waste if recycling is not
chosen. including registration with the EPA, use of the manifest and
certified HW hauler, and federal and state reporting requirements for
hazardous waste land filling at RCRA Subtitle C facility. This option
could greatly increase administrative shipping and disposal costs, as
well as increase the potential long term liability for land filling
whole lamps from the HW manifest requirements and allows the use of a
Bill of Lading (BOL) for shipment if they are sent for recycling. It
does not require the analytical testing or reporting of whole lamps
destined for recycling.
Allows the use of a common carrier instead of a certified
hazardous waste hauler for shipment to a recycling facility. This
lowers shipping costs.
Allows anyone to collect lamps provided they are taken to a
Destination Facility. Allow generators and haulers to store lamps in
any amount up to one year.
Imposes minimal training and labeling requirements on
generators and haulers.
The information on this important subject was provided by
Full Circle, Inc., a full service recycling & disposal company.
You can contact Full Circle at (800) 775-1516, firstname.lastname@example.org, or http://www.feballast.com