Lamp Recycling Contractors Might Be Able to Help

Building Services Management

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-containing 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 regard¡ing 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 ex¡empt 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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