Eases Handling and Disposal Regulations
Reduces Cost to Properly Manage & Recycle
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.
Federal Register
July 6, 1999 - Vol. 65
No. 128 pp 36465-36490
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. |