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Recycling Programs for Fluorescent Lamps Can Help You Meet Stringent Regulations

Grainger Editorial Staff

If you are currently tossing your mercury-containing lamps in the trash bin, you may want to stop, step back and think again. It’s been all over the news recently—energy-efficient lamps, compact fluorescents (CFLs) and the threat of mercury waste. Since CFL's contain mercury, tossing them in the trash could place you at risk for fines, penalties and financial liability for environmental cleanups down the road.

As a result of the growing concern over the health effects of human exposure to highly toxic mercury, increased legislation and regulations have been proposed or adopted at federal, state and local levels over the past few years. These regulations address a number of issues, including banning the sale of certain mercury-containing products, enacting product-labeling legislation, establishing disposal bans and establishing education and collection programs for mercury and mercury-containing products.

Expect 2010 to be busier than ever as states continue to push legislation on mercury management. In recent years, a number of states such as California, Massachusetts, and New York have enacted legislation designed to strengthen and improve regulatory programs that manage lighting and electronic waste. In addition to the three states listed above, Maine, Minnesota, Connecticut, Rhode Island and Florida have enacted more stringent requirements than the Federal Universal Waste regulation. Other states are considering similar legislation. From complete land bans to increasing recycling rates, regulations and bills vary, so knowing the specific rules in your state and locality is very important.

The increased legislation at the state level is an indicator of the need for businesses to work with a reputable environmental services provider. Ultimately, waste generators are financially responsible for the proper management of their waste. Your environmental services provider should continually monitor what's happening from a regulatory standpoint in order to offer you solutions. This is important because the way waste is managed today could change tomorrow. A true service company assists its customers with understanding potential changes.

Depending on the types and quantities of materials you generate, and the jurisdictions in which you operate, it could be illegal for you to dispose of mercury-containing lamps with the rest of your solid waste.  More and more organizations are turning away from the dumpster and setting up programs to recycle mercury-containing devices and lamps. Through recycling, the mercury in the lamps is diverted from the solid waste stream and recovered for re-use, along with the other lamp components (glass and metal).  In short, waste is turned into a resource.

Mercury:  Why it’s a Problem
Exposure to elevated levels of mercury can cause health problems, particularly to the nervous system. Mercury makes its way into the food chain primarily as a result of airborne particles settling on the land and in water bodies through precipitation. Though the percentage of the total mercury entering the environment that is attributable to disposal of spent lamps is relatively small, this waste source is one of the easiest to control through recycling.

The Requirements:  What Are You Supposed to Do?
Wastes, such as spent lamps that contain certain levels of mercury, are regulated as “hazardous waste” under the federal Resource Conservation and Recovery Act (RCRA).  This law, and the regulations stemming from it, creates a framework of rules governing all aspects of waste management in the US.  Though it is a federal law, most state governments have been authorized to implement and enforce the RCRA rules.  State waste regulations must be either equal to, or more stringent than, federal requirements.

The Universal Waste Rule (UWR) establishes reduced requirements for managing common, widespread wastes such as mercury-containing lamps, batteries, thermostats, and pesticides.  The goal is to make it easier for organizations to “do the right thing” with these wastes.  Many states have identical requirements as the federal rule, but others have “done their own thing,” so you must check with your state environmental agency to determine what your responsibilities are. Under federal and state “Superfund” hazardous waste cleanup laws, there are no “TCLP (Toxicity

Characteristic Leaching Procedure) compliant” or “small quantity” exemptions from the liability for future site cleanup if mercury contamination shows up at a disposal facility where your mercury-containing lamps have been legally sent.

Getting Help
Regulations and recycling can be a bit confusing, but there are places you can turn to for help.  Five key resources are available to help you get started:

If you decide to set up a recycling program to comply with relevant regulations or to help protect your facility from future liability, you will need to select an environmental company to provide a safe, efficient, and environmentally sound recycling program.  Many companies offer this type of service, but when it comes to the a recycling company, “often you get what you pay for.”  In selecting a company, you should proceed with caution and make sure your selected partner actually processes not only the lamps, but also the mercury and also offers a variety of services for large or small quantities of both.

Risk Management
Your evaluation of a potential recycling company should include an assessment of the risk management features it brings to the table.  The two primary risk management features are a strong indemnification provision and a solid environmental track record.  An indemnification provision in your service agreement will help protect you from financial liability for environmental damage caused by any mismanagement of your facility's waste by your recycling company.  You should expect an environmental service company to agree to indemnify you, but you must take a look at what financial resources are available to support the obligation.   The indemnification obligation may be in part covered by insurance, so you need to evaluate the types and amounts of coverage the company carries, as well as the quality of the issuing insurance companies. In addition to insurance protection, you should examine the financial condition of the company to be sure that you are partnered with a company that is financially healthy.

Your risk management review should also include the environmental record of any potential recycling vendor. You should inspect permits or licenses, operating procedures, health and safety plans, waste tracking/chain of custody procedures, facility closure plans, and regulatory compliance history.  Fully funded closure plans should be in place to cover the costs of any cleanups of the recycling facilities in the event that the company goes out of business.  These plans offer you further protection from potential future financial liability.  Facility audits and background checks with state and local environmental and safety agencies are helpful in identifying a provider's strengths and weaknesses.

Grainger can help you solve the disposal problem for environmentally hazardous lamps, dry-type batteries and ballasts. For small quantities, Grainger offers a selection of convenient recycling kits. For large-volume requirements, including lamps, ballasts, batteries and electronics with mercury, Grainger can provide you with the expertise to help you develop a customized disposal program.  When you recycle with Grainger, you receive a certificate of reclamation that documents your compliance. With this service, you'll be assured of adherence to environmental regulations on disposal of materials containing mercury, lead, and other harmful materials.

If you follow these basic, common-sense practices, you should be able to implement a lamp recycling program that is good for the environment and good for your organization.
Article courtesy of Veolia ES Technical Solutions, L.L.C.

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The information contained in this article is intended for general information purposes only and is based on information available as of the initial date of publication. No representation is made that the information or references are complete or remain current. This article is not a substitute for review of current applicable government regulations, industry standards, or other standards specific to your business and/or activities and should not be construed as legal advice or opinion. Readers with specific questions should refer to the applicable standards or consult with an attorney.

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