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A common inquiry we receive concerns proper management of spent mercury-containing lightbulbs or “lamps” and how lamp crushers can be used in the waste management process.

Mercury is a hazardous material. All fluorescent lamps and compact fluorescent lamps (CFLs) contain elemental liquid mercury, as do high-intensity discharge (HID) lamps such as mercury vapor, metal halide, and high-pressure sodium lamps. When a lamp is broken, the mercury vaporizes into an invisible, odorless, and tasteless vapor. Inhaling mercury vapor is extremely dangerous to human health. If released to the environment, the mercury can be transformed to methylmercury, which is more toxic than elemental mercury and which bioaccumulates within food chains.

Normal handling of intact lamps presents a very low risk of mercury exposure. Repeated exposure to broken lamps or a one-time exposure to a large number of broken lamps increases the risk. The key is to protect lamps from accidental breakage and properly manage spent lamps.

Regulations

Since January of 2000, the USEPA has allowed spent mercury lamps to be managed as universal waste. A lamp generator can be a Small Quantity Handler of Universal Waste (SQHUW) or a Large Quantity Handler of Universal Waste (LQHUW) depending on the number of spent lamps accumulated at one time. See www.ecfr.gov for the federal universal waste handler requirements in 40 CFR 273 Subparts B and C. Recycling of mercury lamps is strongly encouraged. If a facility does not choose to manage their mercury lamps as universal waste, they must then be disposed of as a full RCRA hazardous waste.

In addition, some states require broken lamps to be handled according to full RCRA hazardous waste regulations. Be sure to check with your state’s environmental agency for up-to-date waste handling requirements. The National Electrical Manufacturers Association (NEMA) makes available an interactive map with links to state environmental agencies and fact sheets. You can access the map at www.lamprecycle.org. A USEPA table of links to state universal waste regulations is also available at www.epa.gov.

Sections 273.16 and 273.36 of the Universal Waste Rule discuss the general employee training requirements for small and large quantity handlers of universal waste. Specifically for mercury lamp management, the Association of Lighting and Mercury Recyclers (ALMR), with support from USEPA, developed an easy-to-use “Training Module (1-hour version) for Generators and Handlers of Fluorescent and Mercury-Containing Lamps (and Ballasts).” The document is available for download at http://almr.org/resources.html.

Lamp Crushers

Crushing is the intentional, controlled breaking of mercury-containing lamps into an appropriate storage container. Crushing itself is not recycling, but it can be part of a facility’s lamp recycling program. Crushing lamps can have several benefits: reduced risk of accidental lamp breakage during packaging and shipping of whole spent lamps; reduced handling time by eliminating the need to package and ship whole lamps; reduced storage space requirements.

A drum-top crusher is a mechanical device that is mounted on the top of a 55-gallon drum. The lamps are fed into the crusher and the crushed components are stored in the drum until ready for pickup for recycling or disposal. A 55-gallon drum typically can hold 1,000 or more crushed 4-foot lamps or the equivalent amount of other lamp types.

The lamp components are not separated during crushing, so the drum will contain mercury, phosphor powder, glass, and metals. The mercury will tend to evaporate, so an activated carbon filter is used to capture mercury vapor before it can be released to the ambient atmosphere. Dust filters and HEPA filters are also used to prevent particulate release.

Proper filter disposal depends on the specific type of crusher you use. The technical specifications for each type of crusher being considered or used should be carefully studied and understood to ensure filters are installed, checked, changed, and disposed of properly.

Monitoring and PPE

Areas in which a lamp crusher is used should be monitored for mercury vapor and mercury-containing particulates. The monitoring can be accomplished using various methods such as wipe sampling and air sampling.

At a minimum, Level D PPE should be used by employees operating the crusher or otherwise working in the immediate area. Higher levels of PPE may be required depending on the specifications of the specific crusher and area monitoring results.

We’ve talked about universal wastes on our blog before but never in much detail. Today, I’m going to break down the four categories to help explain what is included, what is regulated, and where information regarding them can be found in 40 CFR. Before reading on, remember that any state specific regulations may vary and should always be varified with local government. That said, please continue reading for more information about batteries, pesticides, mercury containing equipment, and lamps.

Universal Waste – Batteries 

BatteriesThis includes discarded primary (non-rechargeable) and secondary (rechargeable) batteries that contain elements such as cadmium, lead, or mercury, which would render them RCRA-hazardous.

Examples are nickelcadmium (Ni-Cad), sealed lead-acid, or mercury-oxide batteries. Lead-acid batteries (such as automotive batteries) that are generated, transported, or collected to be reclaimed, or regenerated, but not reclaimed where stored, under provisions of 40 CFR 266, Subpart G, “Spent Lead-Acid Batteries Being Reclaimed,” do not need to be managed as universal waste. However, waste lead-acid batteries not managed, or eligible for management, under 40 CFR 266, Subpart G, are subject to the Universal Waste Rule requirements. Lead-acid batteries that are stored at facilities that reclaim them are subject to RCRA regulation as specified in 40 CFR 266.80(b).

Many commonly generated waste batteries, such as dry cell zinc-carbon and alkaline (“long life”) batteries, typically do not contain appreciable amounts of the hazardous elements of concern, and hence would not be required to be managed as universal waste. However, they may be managed along with universal waste batteries, and this is encouraged in the interest of diverting them from less desirable disposal destinies such as incineration or disposal in solid waste landfills.

Universal Waste – Pesticides

PesticidesSeveral classes of discarded pesticides that would otherwise be regulated as characteristic or listed hazardous waste may be eligible for management under the Universal Waste Rule:

(a) Stocks of unused suspended or canceled pesticides that are subject to a voluntary or mandatory recall under the section 19(b) of the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA), or a voluntary recall by a registrant of a pesticide that is not in compliance with FIFRA;

(b) Stocks of other unused pesticide products that are collected and managed as part of a waste pesticide collection program.

Pesticides not subject to the prescribed recalls may have to be managed as hazardous waste when discarded. Farmers managing and disposing such pesticides in accordance with the hazardous waste exclusion in 40 CFR 262.70, and complying with prescribed disposal instructions, are not subject to the Universal Waste Rule. Recalled or unused pesticides are not considered waste until a decision to discard them has been made. However, they remain subject to the requirements of FIFRA.

Universal Waste – Mercury Containing Equipment

mercury thermometerThis category was added to the Federal Rule at 40 CFR 273 on August 5, 2005.  It includes devices, items, or articles which contain elemental mercury that is integral to their functions and which would otherwise be regulated as a hazardous waste when discarded by virtue of exhibiting the toxicity characteristic (TC) for mercury (hazardous waste code D009).

Some examples of such items include mercury-containing thermostats (formerly a separate universal waste category in the original rule), thermometers, barometers, mercury switches, and certain types of meters, regulators, and gauges, in which elemental mercury is contained in ampules or otherwise enclosed and can be managed intact. This category does not include cathode ray tubes or other types of electronic equipment in which elemental mercury is not integral to function, nor does it include mercury waste that is generated as a byproduct through the process of manufacturing or treatment.

Universal Waste – Lamps

lampsThis category was added to the Federal Rule at 40 CFR 273 on July 6, 1999. The universal waste lamp category is slightly broader than its predecessor in that it includes lamps that are hazardous for any characteristic, not just for mercury. However, fluorescent light bulbs remain the most common item in this category of universal waste. This category does not include associated light fixture components such as ballasts.

Hazardous waste lamps become subject to this rule if they are hazardous waste under 40 CFR 261, and when they are permanently removed from a fixture or determined to be discarded.

A note about crushing: In adopting the Federal category of universal waste lamps, the Indiana rule has added a prohibition against intentionally breaking or crushing waste lamps that are managed under the reduced requirements of the Universal Waste Rule.

This is a consequence of the interpretation that crushing of hazardous waste bulbs is treatment, which is explicitly prohibited under the Universal Waste Rule (40 CFR 273.11(b) and 273.31(b)). The only circumstance where hazardous waste lamps may be crushed is when they are managed as fully regulated hazardous waste (rather than as universal waste) which is treated (i.e., crushed) in tanks or containers by the generator of the waste under the implied generator treatment allowance in 40 CFR 262.34, and in conformance with all applicable hazardous waste management standards. Check with local government to find regulations like this applicable in your state.

On January 1, 2013, the prohibition of the export of elemental mercury becomes effective as required by the Mercury Export Ban Act of 2008 (MEBA) which prohibits the export of elemental mercury from the United States to other countries.

Use of mercury in the world market has continued as a result of the free trade of commodity grade elemental mercury. Much of this mercury is used in “artesian” gold mining operations in countries without health and environmental standards found in the United States. The U.S. Congress intended to reduce mercury availability worldwide by banning the export of U.S. mercury. The export ban will result in a surplus of commodity mercury exceeding domestic demand. A provision in MEBA requires the U.S. Department of Energy (DOE) to provide for the long-term storage of the surplus produced domestically from mercury recycling programs and companies.

After January 1, 2013 storage will be at a select few commercially operated facilities that are granted permission to store beyond the one-year limit typically imposed by land ban regulation. Long-term storage of elemental mercury will eventually be conducted at a facility constructed and operated by the Department of Energy (DOE). Under MEBA, the DOE is allowed to assess a storage fee that can be increased annually. The location, design, and long term storage fees associated with the DOE facility have not been determined by the federal government.

What does MEBA mean for Heritage Environmental Services, LLC customers?

Heritage will continue to transport and accept mercury containing materials as Universal Waste or Hazardous Waste in its many forms; elemental, contained in devices and products such as fluorescent light bulbs, amalgams, contaminated debris and soil, mercury salts, and aqueous solutions containing mercury. Once collected and/or concentrated, Heritage sends this material to retort facilities for further processing which is a requirement under the land disposal restrictions imposed by Resource Conservation and Recovery Act for mercury containing waste material exceeding 260 mg/Kg of mercury. Retort results in mercury being converted back to its’ elemental form, which as previously mentioned, is primarily exported out of the United States. As a result, most all mercury managed by Heritage is affected by MEBA to one extent or other.

What are the known impacts at this time?

  • Providers to Heritage of retort and other processing services have indicated that they will be imposing storage fees for any elemental mercury received after December 31, 2012. These fees are of indefinite duration.
  • Treatment prices for hazardous waste streams containing mercury or devices contaminated with mercury will increase beginning on January 1, 2013, because elemental mercury produced by the retort process will be subject to the export ban. While we cannot fully quantify the price increases at this time, we will provide updates based on your mercury-containing waste streams as soon as possible and/or provide information as you interact with your Account Representatives and Account Coordinators.
  • It is possible that recycling activities associated with mercury containing materials may no longer be considered recycling under EPA regulatory programs.

What is unknown to Heritage?

  • The date that the DOE will have completed construction and begin operation of the long-term storage facility.
  • The fees imposed by the DOE for long term storage of elemental mercury now and into the future.

What are some of the common materials likely affected by MEBA?

  • Elemental mercury
  • Elemental containing devices; switches, barometers, relays, thermometers.
  • Elemental mercury containing medical devices.
  • Fluorescent lights, CFL, and mercury vapor bulbs
  • Batteries
  • Amalgams and alloys
  • Chemical compounds and solutions such as; Oxides, chlorides, and nitrates.
  • COD test reagent
  • Pharmaceuticals containing mercury
  • Fungicides and disinfectants
  • Laboratory reagents and waste
  • Spill related debris and soil

*Despite being exempt from the ban, many of these materials will be subject to higher prices for treatment beginning in 2013.

Have you heard the term “universal wastes?” I’ll admit, the first time I did I didn’t know what it meant. For me, the word “universal” really made it seem like it could be anything. Luckily for all of us, I have since learned what it really means.

The EPA has designated four specific wastes that are known as “universal wastes.” These are batteries, pesticides, mercury-containing equipment (like old thermometers), and lamp bulbs.

Both the EPA website and 40 CFR detail the universal waste definitions of each of these waste types. Additionally, they provide regulations that generators of these wastes must adhere to. For reference, these are the EPA definitions of each of these waste types:

  • Batteries – “Battery means a device consisting of one or more electrically connected electrochemical cells which is 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. The term battery also includes an intact, unbroken battery from which the electrolyte has been removed.” [1]
  • Pesticides – “Pesticide means any substance or mixture of substances intended for preventing, destroying, repelling, or mitigating any pest, or intended for use as a plant regulator, defoliant, or desiccant…” [2] There are some exceptions which can be seen in detail on the EPA website here.
  • Mercury-containing Equipment – “Mercury-containing equipment means a device or part of a device (including thermostats, but excluding batteries and lamps) that contains elemental mercury integral to its function.” [3]
  • Lamp Bulbs – “fluorescent light bulbs and other mercury-containing bulbs…” [4]

As mentioned above, each of these waste types has specific federal regulations associated with it (and possible individual state regulations). The links back to the EPA site will take you to more information about the regulations set out in 40 CFR.

Additionally, a good place to start out with your company is to ensure that all employees are properly trained in universal waste handling regulations and that there is a clear understanding of the different regulations. Doing this will help your company avoid potentially dangerous and costly universal waste violations.