Regulatory Requirements for Management of Fluorescent and High Intensity
House Bill (HB) 2164 became law on August 19, 1997,exempting only householders. This law designates
fluorescent and high intensity discharge (HID) lamps as universal waste,
a category of hazardous wastes, because of their mercury content. This designation
dramatically changed your allowable management practices for these lamps.
Most notably, as universal waste lamps, they no longer must be disposed of in hazardous waste landfills as long as they are properly recycled or pass the TCLP test. The universal waste designation allows the lamps to be handled with less paperwork and licensing. While they may not be disposed of in municipal landfills or incinerators in Illinois unless they pass TCLP testing, they are easier to process to a recycler for destruction.
HB 2164 required the Illinois Environmental Protection Agency to propose
revisions to Title 35, Part 733
of the Illinois Administrative Code for management of lamps. The
revisions to these regulations, which are often called the Universal
Waste Regulations, were promulgated as final on April 2, 1998. Under
the regulations, lamps which are characteristically hazardous because
of mercury content become a universal waste as soon as they are permanently
removed from service, i.e., when a spent lamp is removed from a fixture.
The regulations identify “roles” in the subsequent management
of the lamps and standards applicable to these roles. You, as the
building owner or tenant, will be involved in one or more of these
roles, as explained below.
WHAT IS/ARE YOUR ROLE (S) IN THE LAMP MANAGEMENT
The regulations identify generators, handlers (small and large
quantity), transporters, and destination facilities. Which
hats you wear depends on what involvement you have in the lamp management
process. As the building owner or tenant you are a universal waste generator.
If you remove the lamps you are also a handler, either a small or large
quantity handler. If you subsequently transport the material off-site then
you are also considered a transporter. It is unlikely that building owners
or tenants would be a destination facility, unless you enter the lamp recycling
business. A building management company or a contractor that re-lamps or
removes lamps from a building also takes on roles in this process. An outside
company that removes lamps is a handler. If the company transports the lamps
off-site, they are a transporter.
So, what do you need to do as a generator, handler, and/or transporter?
Fortunately, the universal waste designation is intended to minimize your
regulatory requirements. As noted, you can no longer dispose of spent lamps
in municipal landfills or incinerators in Illinois, regardless of the number
of lamps you generate. The most viable option is to “dispose”
of the lamps by recycling. The regulatory requirements for properly
managing the lamps to a recycler are briefly summarized below.
Generators do not have specific regulatory requirements per the Universal
Waste Regulations. However, generators may also be handlers as described
above. Furthermore, and more importantly, generators ultimately have responsibility
for ensuring their lamps are properly managed/destroyed. IE
Cradle to grave responsibility.
Universal waste handlers must:
Handlers are allowed to crush lamps only on the
generator’s site for volume reduction. There are requirements for
the type of crushing equipment, ambient air mercury concentrations in the
crushing area, training of personnel involved in the crushing, and quarterly
reports to the IEPA on the crushing activity. The regulation prohibits
handlers from gathering lamps from various generator sites and crushing
them at a central location. i.e. Lamps must be crushed at the site from
which they were generated (removed from the fixture).
- Handle lamps in a manner that prevents releases (breakage).
- Put unbroken lamps in containers that minimize breakage and put
broken lamps in packaging that prevents mercury vapor releases.
- Immediately contain any releases and manage released material as
a hazardous waste unless it is determined not to be hazardous.
- Label all lamp containers.
- Only ship the lamps to another universal waste handling facility
or a universal waste destination facility such as Fluorecycle, Inc.
- If the facility is a large quantity handler, notify the Illinois
Environmental Protection Agency (IEPA) of the handling activity
and obtain a USEPA Identification Number.
Transporters must transport the lamps only to a universal waste handling
facility or a universal waste destination facility such as Fluorecycle,
Inc. Transporters are allowed to crush lamps for volume reduction under
the same restrictions noted for handlers, i.e. only on the generator site.
The destination facility must render all hazardous components of the lamps
into directly re-useable products. For example, a process that simply separates
the lamp components into end caps, glass, and mercury-containing phosphor
powder is not recycling. The Fluorecycle, Inc. facility incorporates a distillation
process to remove the mercury from the phosphor powder so it can be sold
directly to a mercury manufacturer for use in new mercury-containing devices.
Fluorecycle, Inc. is a state-of-the-art lamp recycling facility using
Swedish manufactured equipment. This facility meets or exceeds all
regulatory requirements. We have worked closely with the IEPA, to
ensure our facility not only complies with the letter of the regulations,
but also with IEPA’s intent and vision of a recycling program.
Our efforts have been instrumental in helping the IEPA define their
lamp management policy.
We would like to work with you to set up your lamp management program
and to become your lamp recycling facility.
call us at 815-363-4411 to discuss how we can help you with your lamp