Recycling Fluorescent Lamps:Why, How, and What Happens

If You Don’t!

Presented byTom Griffin

Sustainability & Green Program Development

Green Assessments Waste Stream Auditing Hazardous & Universal

Waste Management and Compliance

Environmental Management Systems & ISO14001

Staff Training & Consumer Education

LEED Advisory Services Green PR Services -

Program Participation, Recognition, & Awards

Voluntary Program Development & Management

Green Events Management & Staffing

Green Products & Technologies

Sustainability Consulting Services

My Background & Role Tom Griffin, Division Director

• Sustainability Programs• Green Assessments & Waste Audits• Voluntary Programs Development & Coordination• Regulatory Compliance for Air Cycle Corporation

» Fluorescent lamps contain mercury

Regulations protect the environment, protect workers, and protect your company.

Why Recycle Lamps?

What’s In A Lamp?

» Weights vary according to size, make, etc…

A typical T8 weighs approx. 3-4 lbs. Glass – 95-98% Aluminum, lead oxides, trace metals – 2-3% Phosphor – 1-2% Mercury - .002-.02% (3-20+mg)

What’s In A Lamp?

What is Mercury?» Liquid metal, useful in switches, gauges, thermometers and the like because it expands and contracts with changes in temperature and other variables.

• Lamps• Switches & Gages• Manometers• Barometers• Thermostats• Batteries• Thermometers• Dental Amalgams• Medications / Vaccines• Lab Chemicals• Bougie Tubes & Sphygmomanometers

Where is Mercury?

How Does Mercury Enterthe Environment?

How Does Mercury Enterthe Environment?

How Does Mercury Enterthe Environment?

How Does Mercury Enterthe Environment?

How Does Mercury Enterthe Environment?

» It is a neurotoxin» Elemental mercury» Direct prolonged exposures» Exposures by eating seafood» METHYLMERCURY

The Real “Dangers” of Mercury…

High exposures to mercury may cause:

Human Health Effects

• Trembling hands & numbness or tingling in their lips, tongues, fingers or toes

• Fatigue, joint pain & mental instability

• Speech, hearing problems

» Deposition in water» Anaerobic conditions» Accumulation in the food chain

MethylmercuryNeurotoxin

[CH3Hg]+

The Conversion to Methylmercury

Minamata Bay

The Mercury Life Cycle

• Nearly 530 million spent mercury containing lamps are put in trash each year

• Estimated that 2 - 4 tons mercury released annually from broken lamps

Health Impacts fromImproper Lamp Disposal

» Protect the environment» Protect people» Stay regulatory- compliant» Part of effective “green” program

If You Recycle Lamps…

» Negative impacts on environment, staff, and public

» Out of compliance – regulatory issues arise

» Poor message to staff and customers

If You Don’t…

How Do I Recycle Lamps?

» Drum-top crushing of lamps

» Mail-back shipping of intact lamps

» Bulk pickup of intact lamps

Options for Every Facility

• Convenient!• Great for small

quantities• Also recycle batteries,

ballasts, and e-waste

Prepaid shipping of intact lamps to a recycling facility for processing

Mail-Back Recycling

• Certified UN-compliant and ISTA® Transit Tested Certified

• Brown craft cardboard is 100% recyclable

VaporShield® is a specially treated box that contains mercury vapor and replaces the box and bag system, speeding the loading process.

VaporShield®

• Ships directly to permitted lamp recycling facilities

• Mercury and all lamp materials recovered

• Recycling certificates with weights

Mailing of Intact Lamps

Bulk Pickup of LampsPickup and transport of large quantities of intact lamps for recycling

• Recycle unlimited quantities of waste

• Flexible scheduling for recycling on as-needed basis

• Perfect for locations where lamp crushing not available

Drum-Top Lamp CrushingCrushing of spent lamps into a drum for pickup and shipment for recycling

• Most efficient lamp recycling method for large operations

• Storage, space, & handling benefits

• Improved environmental program

Fines

Bad PRHazards

Your Facility

Safe and efficient lamp recycling programs for any size facility!

Bulb Eater®

Bulk Pickup

EasyPak™

Your Facility

Fines

Bad PRHazards

Bulb Eater®

Bulk Pickup EasyPak™

Your Facility

www.AirCycle.com800.909.9709

How is it Recycled?

Lamp waste is shipped to permitted facilities to safely extract mercury and recycle ALL materials

How is it Recycled?

How is it Recycled?

Environmental Regulations & Lamp Recycling

What Happens If You Don’t?

$$ Fines $$

What Happens If You Don’t?» Negative impacts on

environment, staff, and public» Out of compliance –regulatory

issues arise» Poor message to staff and

customers» Fines

$$ Fines $$

Environmental Regulations& Lamp Recycling

» “Cradle to Grave”» Determination of HW» Treatment, Storage, & Disposal» Recordkeeping» Generator Status

Subtitle C: Hazardous Wastes40 CFR Parts 261-269

» Hazardous materials that can be recycled» Decreased recordkeeping & handling requirements

Subtitle C: Universal Wastes40 CFR Part 273

Universal Waste

Lamps to Be

Recycled

Lamps & ballasts Electronic wastes Batteries

Subtitle C: Universal Wastes40 CFR Part 273

Used oil, etc… Pesticides Mercury-containing

equipment

Universal Wastes

» Very little recordkeeping» Labeling is important» Generator responsible for seeing that

materials are “properly recycled!” » Otherwise…HAZARDOUS!

Intact Lamps Crushed Lamps (in 9 states)

Reduced regulatory requirements Generator status Handling, storage, and shipping

Lamp Disposal Options:

Universal Waste Recycling!

Crushed LampsUniversal Waste in 9 States

ColoradoFloridaIllinoisMarylandMontanaNew MexicoTennesseeTexasVirginia

EPA ID # not required No manifests required Labeled: “Universal Waste – Lamps

to be Recycled” Must be handled according to

manufacturer’s specifications Responsible for “proper recycling” Certain additional state requirements

Crushed Lamps: Universal

Crushed Lamps (allowed in 35 states)

Lots of Benefits RCRA hazardous waste

regulations apply Generator status Handling, storage, and shipping

Lamp Disposal Options:

Recycling As Hazardous

Crushed LampsHazardous Waste in 32 States

AlabamaAlaskaArizonaArkansasDelawareD.C.GeorgiaHawaiiIdahoIndianaIowaKansasKentuckyLouisianaMassachusettsMichigan

MississippiNebraskaNevadaNew JerseyNew YorkNorth CarolinaNorth DakotaOhioOklahomaOregonSouth CarolinaSouth DakotaUtahWashingtonWisconsinWyoming

Generator status and requirements RCRA – Subtitle C /TSD-permitted facilities Shipping manifests often required EPA ID # often required Additional requirements for SQG and LQG Additional state requirements Recycling certificates

Crushed Lamps: Hazardous

Lamp Recycling OptionsDisposal / Waste Determination

• Hazardous Waste• Non-Hazardous Waste

• Low-Mercury Lamps• Possible benefits for generator status

Determination: The Case of Lamps

• Low-mercury lamps pass TCLP• TCLP Testing (0.2mg/l)• Landfill bans (0.025mg/l)

•Hazardous? Hazardous waste disposalSubtitle C-permitted facility…still must berecycled!

Crush and ship for recyclingMail or ship to recycle intactX Improper disposal

Environmental Regulations & Lamp Disposal Options

» Violations» Fines…$$» Worker exposure

to mercury» Bad PR

Improper Lamp DisposalLamp Disposal Options:

» Common Misconceptions…• Conditionally Exempt• Dilution is the Solution• Low Mercury Lamps

Lamp Disposal Options:

Improper Lamp Disposal

» Exposures to workers and the public

Lamp Disposal Options:

Improper Lamp Disposal

» Bad public relations…

Lamp Disposal Options:

U.S. EPA Files $111,199 Complaint Against College for Hazardous Waste Violations ….including improper management of spent lamps.

U.S. EPA Fines Iowa company $54,786 for hazardous waste violations including…improper labeling and management of spent lamps.

NYC fined for improper lamp disposal. U.S. EPA has reached an agreement with New York City requiring it to pay $50,000 in penalties and launch a comprehensive program to properly manage old light bulbs and computer monitors…... US EPA issues fines for

lamp disposal violations …has agreed to pay a $49,725 penalty and to voluntarily ensure that its approximately 75 stores throughout New York, New Jersey and Puerto Rico remain in compliance with the requirements for the handling of spent light bulbs.

Improper Lamp Disposal

Presented byTom Griffin

Recycling Fluorescent Lamps:Why, How, and What Happens

If You Don’t!