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Management of Used Fluorescent, High Intensity Discharge and Miscellaneous
Lamps as Universal Wastes
This information is presented as a public service and is not intended to be
legal advice. Please consult environmental and legal professionals.
----Follow The EPA Link below for The Federal Register Notice---- |
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- The US EPA has added mercury containing
lamps to the federal list of universal wastes regulated under the Resource
Conservation and Recovery Act (RCRA) of 1990.
- This reduces the cost and regulatory
burden on generators who recycle due to streamlined regulations regarding
accumulation, storage, transport, treatment & disposal.
- Until July 6, 1999, federal and some
state regulations made it difficult and expensive for generators to
properly manage the 600 million lamps discarded each year as hazardous
waste. Most ended up in municipal landfills which posed dangers for the
public health and environment due to mercury and lead contamination of air
and groundwater. Most states had already adopted policies to prohibit lamp
disposal in municipal landfills and were granting handling exemptions to
generators who recycle lamps.
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- Requires full regulatory compliance for
hazardous waste if recycling is not chosen.
- Optional for Households and
Conditionally Exempt Small Quantity Generators (less than 100 kg/mo). May
manage lamps as Universal Waste or via RCRA exemption.
- Exempts whole lamps from shipment on
Hazardous Waste Manifest and allows shipment using a Common Carrier Bill
of Lading if lamps are destined for recycling.
- Does not require the analytical testing
or reporting of whole lamps destined for recycling.
- Adds hazardous waste lamps to the
federal universal waste rule (waste lamps that are hazardous due to
exhibiting one or more of the characteristics of hazardous waste) which
includes incandescent and neon lamps.
- Small and large quantity handlers of
universal waste lamps are prohibited from diluting or treating universal
waste lamps except by responding to releases.
The prohibition against treatment includes
a prohibition against crushing. EPA feels that uncontrolled crushing of
universal waste lamps in containers meeting only the general performance
standards of the universal waste rule would not sufficiently protect human
health and the environment.
- Reduces record keeping, training and
emergency requirements. Most businesses won’t have to register with the
EPA to obtain a generator ID or do reporting.
- Increases storage time of waste lamps
up to one year.
Imposes minimal training and labeling requirements on generators and
handlers.
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- Anyone who creates a waste mercury lamp
(a RCRA characteristic waste >0.2mg/l TCLP). A generator is also
considered a Small Quantity Handler or a Large Quantity Handler depending
on how many lamps are produced in 1 year.
Contractors who remove universal waste
lamps from service are considered handlers and co-generators of the waste.
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- Small Quantity Handler (SQHUW)
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Generator or third party
who accumulates less than 5,000 kg at a time, up to 1 year.
No EPA registration required. Training and information on handling mercury
lamps is required. Proper marking and labeling is required.
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- Large Quantity Handler (LQHUW)
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Generator or third party
who accumulates more than 5,000 kg at a time, up to 1 year. EPA or state
registration and ID# is required. Training and information on handling
mercury lamps is required. Proper marking and labeling is required.
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- A non-permitted storage location for
less than 10 days.
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- A RCRA permitted processing, recycling
or disposal facility such as Earth Protection Services, Phoenix, AZ.
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The
information above represents EPSI's interpretation of the Universal Waste
Rule.
Environmental / legal professionals should be consulted for
additional interpretations. |
