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Lamp Recycling Contractors Might Be Able to Help |
Any contractor
who works in a building can assist owners with lamp recycling.
Collection and recycling services can be a new profit center for
contractors, or offered as a value-added service for better
customer relations.
Federal and state rules allow lamp generators, such as building
owners and contractors to collect and accumulate lamps for
recycling with reduced regulatory burden. According to the
National Electrical Manufacturers Association, most states in
the
U.S. have adopted a less burdensome set of regulations for
dealing with hazardous waste lamps and several other hazardous
waste items.
These regulations are known as the Universal Waste Rule (UWR).
If lamps are sent for recycling under the UWR, there are less
stringent requirements for storage, record-keeping and
transportation as compared to managing them under the full
Subtitle C hazardous waste requirements.
The major exposure to mercury in lamps arises from lamp
breakage. As the old lamps are removed from their sockets, they
should be carefully packed to avoid breakage. Federal rules
suggest using the cartons supplied with the new lamps for this
purpose; alternatively, the lamp recycling service may be able
to provide larger containers that will minimize the labor and
handling involved. States have different requirements regarding
the number of broken lamps that can be included in a shipment of
universal waste lamps. Careful handling of waste lamps will,
therefore, minimize disposal costs.
The Association of Lighting and Mercury Recyclers (ALMR)
estimates there are about 500 million lamps per year that are
not being recycled, but should be recycled. This is a huge
opportunity for contractors. Once people realize how easy it is
to get lamps recycled, more and more contractors can improve
their bottom line by offering this service. ALMR also encourages
you to set up recycling programs for the spent
mercury-containing lamps in your own facilities.
If contractors choose to recycle lamps under the less
burdensome Universal Waste Rule, then the following applies:
Contractors can be considered “handlers” under the UWR.
Universal waste handlers are divided into two categories by the
amount of universal waste they produce. Each category has
slightly different requirements:
Small Quantity Handler of Universal Waste (SQHUW): A generator
(building owner) or third party (contractor) who accumulates
less than 5,000 kg total of universal waste (such as spent
mercury-con-taining lamps) at a time. No EPA ID is required.
Storage time for the waste is up to one year. Employees are
required to have minimal training and information on proper
handling and emergency procedures regarding mercury-containing
lamps. Proper marking and labeling of universal waste is
required. SQHUW requirements are found at 40 CFR 273 Subpart B.
Large Quantity Handler of Universal Waste (LQHUW): A generator
(building owner) or third party (contractor) who accumulates
more than 5,000 kg total of universal waste (such as
mercury-containing lamps) at a time. An EPA ID is required, and
state registration may also be required. Storage time for the
waste is up to one year. Employees are required to have training
and information on proper handling and emergency procedures
regarding mercury-containing lamps. Proper marking and labeling
of universal waste is required. LQHUW requirements are found at
40 CFR 273 Subpart C.
Universal Waste Transporter: One who engages in the process of
transporting waste lamps for 10 days or less. A transporter may
not store, accumulate, dispose, dilute, or treat universal
waste lamps. No EPA ID is required. Proper marking and labeling
of waste lamps is required. Transporter requirements are found
at 40 CFR 273 Subpart D.
Both SQHUWs and LQHUWs are exempt from the Subtitle C hazardous
waste (HW) manifest requirements. A record of shipment is
required for LQHUWs, and may take the form of a bill of lading (BOL)
or other shipping document. In both cases, shipments can be made
through a common carrier, instead of a certified hazardous waste
hauler. No analytical testing or reporting of lamps is needed
for recycling.
In summary, the following applies:
• Accumulation- can be for up to one year;
• Transportation- can be done via common carrier; and
• No permitting is required.As a contractor, if you offer lamp
recycling to your customers, and you do not accumulate or store
spent lamps in your own facilities, you are not typically
subject to hazardous waste regulations.
Crushing
Under federal regulations, intentionally breaking lamps
(crushing) is considered “treatment.” Those who treat lamps
(e.g., by drum-top crushing) are subject to full Subtitle C
regulations rather than the UWR regulations.
However, certain authorized state programs allow both whole and
intentionally crushed lamps to be managed under the UWR.
Handlers that choose to intentionally crush lamps must do so in
accordance with authorized state programs. For more information
specific to your state, please consult the State-by-State
Stringency Comparison Table at www.nema.org.
Lighting Specifiers
Specifiers should include end-of-life considerations when
lighting is chosen for buildings. In addition to life-cycle
costs of lamps, energy savings and fixtures, mercury lighting
disposal/recycling costs should be considered in the overall
economics of using energy-efficiency lighting.
Remember, owners and contractors are responsible for regulatory
compliance. Specifiers can assist by getting information to the
decision-makers. Any lighting retrofit will likely generate a
large number of waste lamps. These lamps may contain some
combination of mercury, cadmium, antimony and lead. Contractors
and owners should pay close attention to proper disposal of this
waste.
The services of a competent, properly licensed, recycling
service for both lamps and ballasts is highly recommended for
any retrofit project. It should be noted that the most
significant environmental enforcement actions concerning
incorrect handling of waste lamps and ballasts have involved
lighting retrofits.
In the U.S., if the lamps classify as hazardous waste, it is
the responsibility of the owner to manage the waste correctly;
and contractors involved may share that legal responsibility.
Contractors can charge a fee to collect lamps, and arrange for
recycling through an authorized recycler who can provide a
certificate verifying that the lamps were recycled. This
certificate can be passed along to the generator, (i.e.,
building owner). Containers for waste lamps are available
through recyclers. ❑
A list of recyclers can be found at www.almr.org or
www.lamprecycle.org. |
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