Frequently Asked Questions
We understand that you probably have a number of questions that you would like to ask us. If you can't find what you're looking for below, please feel free to contact us or talk to a representative using our live chat feature. We will do our best to answer whatever questions you may have, as well as provide you with whatever resources you need.
We've broken these frequently asked questions down by topic for your convenience. Click a section for more detail:
Click here for Air Cycle's web-based Program Selector, or read more about recycling programs below:
EasyPak™ Pre-Paid Recycling Containers
< 150K Square Feet
This program is typically used by smaller facilities or facilities where storage is limited. The program is simple, requires little paperwork, and is a practical option for facilities nationwide.
EasyPak containers have instructions, complete with illustrations, printed on them to make recycling as EASY as possible. One price includes everything you need, the container, shipping to the recycling center via FedEx Ground, recycling fees, and certificates of recycling.
Bulb Eater® On-Site Lamp Crusher
> 150K Square Feet
The Bulb Eater not only crushes spent fluorescent lamps of any length into 100% recyclable material, but also captures over 99.99% of the vapors released.
The system, which is mounted to a 55-gallon container, can hold up to 1350 4' fluorescent lamps. This allows for relatively large quantities of lamps to be stored without using much storage space.
Nationwide Bulk Pick-ups
> 150K Square Feet
Recycling services and transportation available throughout the continental United States to help facilities properly recycle lamps, ballasts, batteries, and electronics. These wastes are palletized and shrink wrapped prior to pick-up.
Great for properties with large quantities of waste and enough available storage space for at least one pallet to be stored.
Learn more about Bulk Pick-Ups
Air Cycle is committed to providing innovative recycling solutions for companies large and small. For companies whose scale demands a more comprehensive tool, Air Cycle offers Custom Corporate Portals, which allow you to easily and effectively create, manage, and track your nation-wide recycling program.
Learn more about corporate recycling programs
In addition to corporate programs Air Cycle offers comprehensive green consulting through it's division, Greener Results. Greener Results offers a straightforward approach to assisting companies that want to become more green…and, at the same time, get credit for their efforts.
Learn More about Greener Results
When you log-In, you will see the following links in the right side bar:
Email and Address Book - View, edit, or add shipping and billing addresses for your account and manage you email address and email subscriptions.
Reports - Access live visual reporting based on the amount of waste recycled at your facility. Track progress, set goals, and email reports.
Order History - View date, status, and other details for past orders.
Track Containers - Perfect for multiple facilities, container tracking gives managers the ability to quickly determine container status.
Pickup Requests - View status, details, and recycling certificates from past pickups or request a new pickup.
If you don't have an account, click here to register.
- What is a Bulb Eater®?
- Why do people use the Bulb Eater® system?
- How does the Bulb Eater® work?
- How long does it take to crush the lamps?
- How many crushed lamps fit in a 55-gallon drum?
- How much space can I save by crushing my lamps?
- What is the difference between the Model 55 VRS and the Model 55 VRS-U Bulb Eater® systems?
- What does VRS stand for? VRS-U?
- I've seen reference to T8, T12, and T17 lamps. What is the difference?
- Is it safe?
- Sure, it makes sense to crush the lamps, but what do I do with the crushed lamps?
- How often do the filters need to be changed?
- Where do I buy extra filters?
- What is EasyPak™?
- Why choose EasyPak™ over the alternatives?
- What is the EasyPak™ Sustainable Program
- How many containers should I order?
- Do I get a discount for ordering in bulk?
- How long will it take to receive my EasyPak™ containers?
- Can I place broken lamps in an EasyPak™ container?
- Can I put UV lamps in an EasyPak™ container?
- Can I put lead acid batteries in the EasyPak™ Battery Recycling container?
- Are EasyPak™ containers safe for storage and transport?
- Why can’t I use my existing box to return my waste?
- Where can I view EasyPak™ Terms and Conditions?
- Is EasyPak™ available in all states?
- I lost my prepaid shipping label, what should I do?
- FedEx refuses to pickup my package, what should I do?
- How long does it take to get my certificate of recycling?
- What if I can’t find my certificate of recycling?
- How do I become an EasyPak™ distributor?
- Are EasyPak™ containers recycled after they have been used?
- Where are my EasyPak™ containers sent for recycling?
- Why can't I just throw my lamps in the trash?
- Tell me more about Air Cycle Corporation's recycling program...
- What happens to the lamps once they are picked up?
- What happens to the batteries once they are picked up?
- Do I have to count every lamp before they are picked up?
- How should the waste be packaged prior to pick-up?
- Does Air Cycle provide packaging material? Boxes? Drums?
What is a Bulb Eater®?
A Bulb Eater® is a lamp crushing machine that processes, or crushes, spent fluorescent lamps into small fragments. The crushed glass is compacted into 55-gallon containers. The Model 55 VRS crushes over 1350 T8 4' lamps into one 55-gallon drum. The Model 55 VRS-U not only crushes straight fluorescent lamps of any length, but also u-shaped fluorescent lamps as well. This greatly improves storage of the lamps, handling, safety/liability issues, and fluorescent bulb recycling costs. The units are complete with filtration systems to help ensure both OSHA and EPA compliance, even for facilities disposing of large quantities of lamps.
Why do people use the Bulb Eater® system?
Facilities around the world use the Bulb Eater® lamp crushing systems to make their lamp disposal process more efficient. The systems will greatly reduce storage needs, minimize handling of the lamps, create a safer, cleaner work environment, and cut overall fluorescent bulb recycling costs.
How does the Bulb Eater® work?
- The lamp is fed into the entry tube of the machine.
- In roughly one second the lamp, whether straight or u-tube enters the machine and is crushed to pieces.
- The Bulb Eater’s filtration system pulls the contaminated air out of the drum to filter out the released powder as well the mercury vapor.
- The contaminated air goes through a two stage filtering process in the blue case. The first stage filter captures over 99% of the released dust particulate. The second stage HEPA filter acts as a polishing filter and captures over 99.99% of the remaining particulate.
- At that point the air is clean but still contains mercury vapor.
- The mercury vapor is then blown out of the blue case and through the third and final filter.
- The carbon filter not only captures the mercury vapor, but also neutralizes it by converting the vapor to a non-hazardous substance.
- Clean air comes out of the Bulb Eater® exhaust vent.
How long does it take to crush the lamps?
It takes roughly one second to crush a 4' fluorescent lamp and a fraction of a second longer for 8' lamps.
How many crushed lamps fit in a 55-gallon drum?
1350 Straight T8 4' Lamps / 875 Straight T12 4' Lamps / 475 Straight T12 8' Lamps / 450 U-Shape T12 Lamps
What is the difference between the Model 55 VRS and the Model 55 VRS-U Bulb Eater® systems?
The Model 55 VRS Bulb Eater® is an emissions controlled system able to crush straight fluorescent lamps of any length and diameter. The system has a removable entry tube for T12 fluorescent lamps that can be supplemented with entry tubes for T8 and T17 straight fluorescent lamps. The Model 55 VRS-U Bulb Eater® is also an emissions controlled system but is able to crush not only straight fluorescent lamps, but also u-shaped fluorescent lamps as well. The entry chute for the u-shaped fluorescent lamps can be removed and sealed while crushing straight lamps. This system also comes complete with a T12 straight fluorescent entry tube. T8 and T17 entry tubes are also available.
What does VRS stand for? VRS-U?
Vapor Removal System AND Vapor Removal System with U-Shape Capability
I've seen reference to T8, T12, and T17 lamps. What is the difference?
The diameter of a lamp is measured in eighths of an inch and expressed as a "T" number, such as T8 (equals 8/8's or one inch) and T12 (equals 12/8's or an inch and a half diameter). T17 lamps, while uncommon, are 17/8's or 2 and an eighth inches in diameter. This designation is given in lamp catalogs and sometimes printed on the lamp itself. For example, one of the most common 4' lamps is an F40T12/CW. The Bulb Eater® systems come standard with an entry tube fitted for T12 lamps. T8 and T17 entry tubes are also available.
Is it safe?
Yes. In fact, studies show that it is actually safer to package lamps by using Bulb Eater® lamp crushing systems than boxing the lamps intact. This is because the Bulb Eater® captures over 99.99% of the mercury vapor released during crushing. While there is a small amount of mercury vapor released, the overall mercury exposure is significantly less than when managing the same quantity of lamps intact and dealing with the accidental breakage of the lamps. No one intends to break the lamps while handling them, but unfortunately when handling tubes of glass up to 8' long accidental breakage is unavoidable. Based on EPA studies that show an accidental breakage rate of 3% (which based on our industry knowledge we believe to be low), our customers are considerably safer crushing their lamps with our controlled emissions systems. Due to the potential for mercury vapor exposure, our emissions-controlled lamp crushing machines have been tested for OSHA safety compliance by outside testing laboratories (test results available). These tests show that the operator experiences well under both Federal and State OSHA mercury vapor exposure levels. In fact, our most recent emission study showed non-detectable levels of mercury vapor emissions even after crushing 1500 lamps! Also, please note that the State of Illinois Environmental Protection Agency has inspected Air Cycle Corporation's facility and also the Bulb Eater® machines. In fact, the State of Illinois Environmental Protection Agency uses the Bulb Eater® to safely package their lamps prior to recycling.
Sure, it makes sense to crush the lamps, but what do I do with the crushed lamps?
Contact Air Cycle to have the drums picked up and transported to one of our contracted recycling facilities to be recycled. This is the preferred method of the Environmental Protection Agency and is the most cost efficient option. Depending on your state regulations, you may be able to exclude this waste from your hazardous waste totals. Contact Air Cycle today for a customized fluorescent bulb recycling quote!
How often do the filters need to be changed?
The filters need to be replaced on a scheduled basis. The first Stage filter bag is changed twice per drum. The second Stage filter cartridge is changed at least every 10 full drums. When changed, the filters can be placed on top of the crushed glass inside the drum (depending on applicable regulations). The filters are sent for recycling with the crushed lamps in the drum. The 3rd Stage premium-grade activated carbon filter is rated for over a million lamps. Based on these figures, most facilities will never need to change this filter. Should this activated carbon filter become saturated, the filter can be recycled.
Where do I buy extra filters?
Filters can be purchased online or by calling 800-909-9709.
What is EasyPak™?
EasyPak™ is a pre-paid recycling program for lamps, ballasts, batteries, electronics and thermostats. One price includes a container, shipping to the recycling center, recycling costs and a certificate of recycling.
Place your order online, or over the phone by calling toll-free 888-640-6700.
Why choose EasyPak™ over the alternatives?
Aren’t all pre-paid container programs the same? No!
EasyPak™ offers the latest in recycling technology and innovative features. In addition to the essentials – a quality product, a fair price, and great customer service – every EasyPak™ customer has access to the following online features:
- Recycling Reports - Access live visual reporting based on the amount of waste recycled at your facility. Track progress, set goals, and email reports.
- Automatic Re-ordering - Return a full container for recycling, and a replacement container will automatically be shipped to you.
- Certificates of Recycling - Download certificates of recycling from your personal account 24/7. Stay in compliance at all times.
- Container Tracking - Perfect for multiple facilities, container tracking gives managers the ability to quickly determine container status.
What is the EasyPak™ Sustainable Program?
The EasyPak™ Sustainable Program is the most innovative and efficient method to recycle spent lamps, ballasts, batteries and electronics.
First, figure out what kinds of waste you have at your facility(s) and select recycling containers accordingly. Once you receive your EasyPak containers, fill them up and ship them back with the included pre-paid shipping label.
As soon as we receive your shipment at our recycling facility, our system will automatically trigger a new order to replace your used container(s). We will bill you for replacement containers using the purchase order or credit card of your choice.
The Sustainable Program ensures that you always have containers in stock and never need to worry about placing another order. When you Sign Up, you also get instant access to unique online features, like Recycling Reports, Certificates of Recycling, and Container Tracking.
Learn more about the EasyPak™ Sustainable Program here.
How many containers should I order?
It depends on the amount of waste you generate. It usually helps to order one more container than you need, that way you'll always have one on-site while the other is being shipped back. Each container has a waste limit specified in the product details section.
Do I get a discount for ordering in bulk?
Yes. If you order 5 or more of any single container, you'll receive free ground shipping. When ordering large volumes (20 containers or more) call 888.640.6700 and ask about special pricing.
How long will it take to receive my EasyPak™ containers?
Typically, all containers are shipped within 3 to 5 business days.
Depending on your distance from our distribution center, you should receive your container(s) in 5 days or less.
Can I place broken lamps in an EasyPak™ container?
EasyPak™ containers are intended for the transport, and recycling of intact fluorescent lamps. However, in the event that a lamp breaks in the container or in transit, our recyclers will still accept it for processing.
Can I put UV lamps in an EasyPak™ container?
You may recycle UV lamps only if it contains solid mercury amalgam.
If you are unsure of the type of mercury inside the lamps, please do not ship it in the EasyPak™ container. Failure to comply will put your company at risk and violate our terms and conditions.
Can I put lead acid batteries in the EasyPak™ Battery Recycling container?
No. EasyPak™ battery recycling containers are intended for dry cell batteries only.
Various types of dry cell batteries include alkaline, nickel, cadmium, nickel metal hydride, iron, zinc carbon, and silver, as well as AA, AAA, C, D, and 9-volt.
Are EasyPak™ containers safe for transport?
Yes. EasyPak™ containers have been tested and UN Certified at Advanced Packaging Technology Laboratories, Inc., an independent testing laboratory.
Containers are deemed compliant with applicable sections of 49 CFR pertaining to the safe transport of dangerous goods - Packaging Group III. EasyPak™ lamp recycling boxes have been subjected to repetitive shock vibration tests, stacking tests, free fall drop tests, and water absorption tests.
Why can’t I use my existing box to return my waste?
Packaging and labeling requirements vary by state, and standard boxes are often not suitable for shipping Universal Waste.
In addition, our transportation partners require the contents be shipped following specific guidelines which require additional containment such as VaporShield®. Shipping with UN and transporter approved EasyPak containers provide compliance with shipping regulations and minimize risk and liability for you.
Where can I view EasyPak™ Terms and Conditions?
Is EasyPak™ available in all states?
While EasyPak™ is available in most states nationwide, it is currently not available in Alaska, Hawaii, Maine or Puerto Rico. If you have questions regarding EasyPak™ service and your state regulations, please visit our regulations page , or contact an EasyPak™ representative at 888-640-6700.
I lost my prepaid shipping label, what should I do?
Call 888-640-6700 to speak with an EasyPak representative. Be prepared to describe the container, its contents and your location.
The shipper refuses to pickup my package, what should I do?
You may be calling the wrong number. Please make sure you are calling our toll-free number at 888-777-6040. To schedule a pickup online, click here, fill out the pickup information, and click “Schedule Pickup”.
How long does it take to get my certificate of recycling?
You will typically be able to access your certificate of recycling 1 week after you ship your EasyPak™ container. Recycling certificates can be downloaded as a PDF from your account menu online. Login to your account now to access certificates.
What if I can’t find my certificate of recycling?
When logged in to your account, find Recycling Certificates in your account menu and click “Open Search Form”. Enter your containers full tracking number in to the appropriate field and click “Find”.
If you don’t have your tracking number, contact an EasyPak™ representative by calling 888-640-6700.
How do I become an EasyPak™ distributor?
Contact an EasyPak™ representative for more details by calling 888-640-6700.
We offer volume discounts and marketing materials that make selling easy. We would be delighted to have you join our growing nationwide network of EasyPak™ distributors!
Are EasyPak™ containers recycled after they have been used?
Yes. Once the contents of a container have been processed for recycling, the empty buckets and boxes are recycled. Your entire purchase is 100% recyclable!
Where are my EasyPak™ containers sent for recycling?
All EasyPak™ containers are processed at permitted recycling facilities located in the Unites States of America. Containers will be shipped to the facility closest to your location.
How can I get more information on the machines and/or this recycling service?
Why can’t I just throw my lamps in the trash?
Lamps contain mercury and in most cases are considered hazardous. The Environmental Protection Agency regulates the management of spent lamps. Most states do not allow hazardous lamps to be disposed in solid waste landfills.
Tell me more about Air Cycle Corporation's recycling program...
Air Cycle Corporation offers a fluorescent bulb recycling program throughout North America for crushed lamps, as well as intact lamps, ballasts, batteries, and computer hardware. We pride ourselves in offering aggressive pricing to our customers. A toll-free number is available for scheduling or questions. All facilities are properly permitted and provide documentation that the recycling was completed within applicable EPA regulations.
What happens to the lamps once they are picked up?
The lamps are transported to a permitted facility to be processed. The lamps are recycled in machines designed to break down the lamp and then separate the glass, metal, and mercury. Once the glass is clean of the mercury it can be reused as well as the metal and mercury. After the lamps are processed, a Certificate of Recycling will be issued for your records to document that your lamps were properly recycled by a permitted facility. More details on the recycling process can be found here.
What happens to the batteries once they are picked up?
All waste recycled through Air Cycle Corporation is processed at fully-permitted facilities within the United States. Batteries undergo a process of inspection, sorting, sizing, recovery, and separation of final products. More deatils on this process can be found here.
Do I have to count every lamp before they are picked up?
No. Waste from your bulk recycling pickup will be accurately counted by the recycling facility and you will be billed accordingly.
How should the waste be packaged prior to pickup?
Intact Lamps – All lamps must be packaged in a manner to "minimize" breakage. The OEM box is the most popular method of packaging. If the OEM box is not available, fiber drums are a simple alternative. Because they have lids, fiber drums provide a time advantage to boxing and taping. All lamps must be free of foreign material, including tape (on the actual lamp) and paper sleeves.
Crushed Lamps – Crushed lamps must be sealed in a steel 55-gallon drum complete with locking ring and lid. There cannot be any extraneous material such as wire, trash, or liquids in the drum or it will be returned.
Ballast - Non-leaking ballast should be packaged in a 55- gallon steel drum with locking ring and lid. These drums must also be free of any other foreign material. Leaking ballast should be placed in a plastic bag or a similar material to prevent contaminating the non-leaking ballast, and placed in a separate pail or drum.
Batteries - All batteries should be separated and packaged in a manner that will minimize spilling during transport. The most popular container is a 5-gallon pail. 55- gallon drums also work well if the quantity of materials can justify this size. Larger lead acid batteries should be palletized and shrink- wrapped with slip sheets between each row of batteries. Also, all holes must be plugged to reduce the leaking of acid.
Computer - There is no exact way to package computers. The simplest way is to use Gaylord boxes with lids. Because these are not always available, palletizing and shrink- wrapping is the next best alternative. Smaller components can be placed in any kind of box or secondary containment.
Does Air Cycle provide packaging material? Boxes? Drums?
Air Cycle can provide boxes, fiber drums, or steel drums throughout North America.
Why is mercury an environmental concern?
Mercury is a metallic element that can accumulate in living tissue. In sufficient concentrations, mercury may cause adverse health effects. Sources of mercury in the environment from human activity include coal-burning power plants, batteries, and fluorescent and HID lamps.
Small amounts of mercury are a necessary component in fluorescent and HID lamps, but when a lamp is broken, crushed, or dispensed in a landfill or incinerator, mercury may be released to the air, surface water, or groundwater. Considering this, it is a good policy to keep the mercury in fluorescent and HID lamps out of the solid waste stream by recycling.
How do I know if my waste is hazardous?
All generators of waste, except households, are responsible for determining if their waste is hazardous under current state and federal regulations. Hazardous wastes can either be included on specific lists or exhibit hazardous characteristics. This determination can be done by knowledge of the waste or by testing the waste. The Toxicity Characteristic Leaching Procedure (TCLP) is the test used to determine if a waste exhibits a toxicity characteristic. Wastes found to be hazardous are subject to the hazardous waste management regulations.
Persons who generate wastes are responsible for determining whether their wastes are hazardous. One common method for determining whether a waste is hazardous is the Toxicity Characteristic Leaching Procedure (TCLP) test. The TCLP test is a laboratory test that simulates the potential leaching of hazardous wastes under conditions typically found in municipal solid waste landfills. If the concentration of mercury in water that is passed through a sample of crushed fluorescent lamp fragments exceeds 0.2 mg/liter, the crushed lamp fragments are classified as a hazardous waste. (See test method 1311 in "Test Methods for Evaluating Solid Waste, Physical/ Chemical Methods," EPA Publication SW846 for more information about the TCLP procedures.)
In most cases, standard fluorescent lamps and lamp fragments fail the TCLP test and are considered hazardous wastes. Facilities should treat the spent lamps and lamp fragments as hazardous wastes unless they test the spent lamps and fragments and determine that the wastes are non-hazardous. Facilities should manage the spent lamps as hazardous waste according to applicable federal, state, and local requirements.
New low-mercury lamps have been introduced into the market. While these lamps may pass the TCLP test and be considered non-hazardous, some states - like Minnesota and Vermont - still prohibit persons from disposing of even these non-hazardous lamps in a solid waste landfill. You may want to talk with a State EPA representative to find out how you may handle spent lamps in your state.
Please note that regardless of whether the State in which you are located allows you to dispose of lamps in your dumpster with other non-hazardous trash, the lamps do contain mercury and mercury vapors are released into our environment when you throw lamps in the trash. Typically, the lamps break in the dumpsters, during transportation or in the landfill and release mercury into the air or groundwater. These hazardous releases are a risk to surrounding communities.
Facilities that throw their spent lamps in the trash thinking they are saving money may be mistaken. Throwing spent lamps in the trash may result in the person being held responsible for the cleanup of a remote and costly Superfund site. Because of the potential liability under Superfund, Air Cycle Corporation believes facilities that decide to recycle their spent lamps are making a smart decision that benefits not only the environment but also the bottom line.
What are Universal Wastes?
Universal wastes are specific hazardous waste streams that facilities can choose to manage in an alternative manner in place of the more complex hazardous waste requirements. These wastes are typically generated by many facilities and are often not properly managed under hazardous waste regulations.
Universal Wastes include:
Lamps – Including fluorescent, high intensity discharge (HID), sodium vapor, mercury vapor, neon, and incandescent lamps Batteries – Including spent dry cell and lead-acid batteries Pesticides – Including certain suspended, canceled, or unused pesticides Devices containing elemental mercury – Including thermostats, switches, thermometers, manometers, barometers, and various medical devices
Does Quantity Matter?
Yes. RCRA (hazardous waste) requirements differ according to the amounts of hazardous waste generated per month by the facility. There are three main categories of hazardous waste generators:
Conditionally Exempt Small Quantity Generators (CESQG's) are persons who generate 220 lbs. or less of all hazardous wastes combined (not just lamps!). These generators are exempt from most of the hazardous waste regulations, which include transportation, treatment, and disposal requirements. They must not, however, store more than 2200 lbs. of hazardous waste on site at any time and must dispose of their hazardous waste in facilities that are permitted or authorized to accept hazardous or non-hazardous wastes. Many states acknowledge CESQG exemptions for paperwork, but not for disposal. Many states do not allow CESQG to dispose of hazardous waste in a solid waste landfill.
Small Quantity Generators (SQG) are persons who generate 220 to 2200 lbs. of hazardous waste per month. These generators must keep proper records of the waste, report to EPA, and follow accumulation requirements. These generators can store up to 6 months without a storage permit.
Large Quantity Generators (LQG) generate more than 2200 lbs. of hazardous waste per month. These generators are subject to the full hazardous waste management requirements. These generators cannot store hazardous wastes on site for more than 90 days (3 months) without obtaining a storage permit.
There are 2 categories of Universal Waste handlers:
- Small Quantity Handler - Generator who accumulates less than 11,000 lbs. of universal waste (batteries, pesticides, thermostats, or lamps) at any time.
- Large Quantity Handler - Generator who accumulates more than 11,000 lbs. of universal waste (batteries, pesticides, thermostats, or lamps) at any time.
Universal Waste Storage Limits:
Both Small and Large Quantity Generators of Universal Waste can generally store their Universal Waste for one year. (For more information please contact your state Environmental Protection Agency or Air Cycle Corporation.)
How is controlled crushing regulated?
Controlled crushing of lamps is regulated under both federal and state hazardous and universal waste regulations. The federal universal waste regulations do not authorize on-site crushing of fluorescent lamps but do allow the States to write rules that will permit crushing on-site. The States of Illinois, Florida, Virginia, Tennessee, Texas, Colorado, Maryland and Montana have all passed rules that allow persons to crush lamps on-site under the universal waste regulations. Air Cycle Corporation is working with several States and expects these States to pass rules within the next year, which allow lamp crushing under universal waste rules.
In States that allow crushing and classify crushed lamps as universal wastes, persons can generally store their waste lamps on-site for up to one year, can ship waste lamps off-site with a bill of lading rather than a hazardous waste manifest, and need not include their lamps when calculating their hazardous waste totals.
Under state and federal hazardous waste regulations, controlled crushing (which is what the Bulb Eater® systems do) is considered treatment. The hazardous waste rules typically require a person who treats wastes to obtain a permit. Federal and most state hazardous waste rules, however, exempt from the permit requirement persons who treat their wastes "within a drum, tank, or container." (See 40 CFR 262.34).
Air Cycle Corporation believes The Bulb Eater® systems fall squarely within this exemption and many States have acknowledged in letters to Air Cycle Corporation that the accumulation tank exemption applies to The Bulb Eater® systems. You should be aware, however, that the States of California, Maine, Massachusetts, Connecticut, Rhode Island and Missouri have more narrow exemptions to the permitting requirements. Air Cycle Corporation suggests you contact representatives of those States before proceeding with on-site crushing.
If your State does not allow crushing under its universal waste regulations, then you typically may manage crushing under your state's hazardous waste regulations as a process exempt from the general permitting requirements. Please note that regardless of whether the lamps are managed as universal or hazardous wastes, you must properly dispose of the crushed lamps preferably by shipping the crushed lamps to a permitted recycling facility.
Air Cycle Corporation will continue to work with State lawmakers, the National Electrical Manufacturing Association and the Association of Lighting and Mercury Recyclers to promote legislation, which will authorize persons to crush lamps under universal waste regulations. Air Cycle Corporation and its customers know that persons are able to safely crush their lamps to reduce volume, minimize handling, cut costs, and create a safer work environment by managing their crushed lamps under either universal waste regulations or existing state hazardous waste regulations.
How do I get more information on these regulations?
Customers are always welcome to contact customer service at Air Cycle Corporation for further information concerning federal and state regulations. Air Cycle has a database of contact names at both federal and state environmental protection agencies, as well as guidance papers from many states that are available to our customers. We are more than willing to help you learn more about applicable regulations.
Do you have a question not listed?