Message
for Distributors
We encourage you to review the
Message for All
OVERVIEW
Any electrical distributor who sells energy-efficient lighting for buildings
can assist owners with lamp recycling. This presents distributors with
a new business opportunity. A take-back program, where the distributor
collects and sends the spent lamps to a recycling company can be a new profit
center, offered as a value-added service for better customer relations. Distributors
can establish relationships with lamp recyclers and can physically handle
lamps or set up “box programs” so customers can ship directly to
recyclers. Any recycler found at www.almr.org
can supply details on box programs. Since building owners and contractors
are your key customers, it is important for you to have an understanding of
the regulations that apply to these customers.
FEDERAL AND STATE RULES
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.
If distributors choose to recycle lamps under the less burdensome
Universal Waste Rule, then the following applies:
Distributors offering recycling services may be considered “handlers”
under the UWR if they accumulate spent lamps in their own facilities.
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 (distributor) 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 regarding 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 (distributor) 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 exempt from the full 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
· No permitting is required
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.
For more information on crushing, please see the “Message
for All.” .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, consult the State-by-State
Stringency Comparison Table.
As a distributor, if you offer lamp recycling “box programs” 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.
A box program involves setting up an arrangement for your customers to purchase
a lamp storage box for which the transportation and recycling costs are prepaid.
LIGHTING RETROFITS
As a distributor, you are frequently involved in the sale of efficient lamps
for retrofits. Any lighting retrofit will generate a large number of waste
lamps. These lamps may contain some combination of mercury, cadmium,
antimony and lead. Environmental considerations call for everyone involved
in a lighting retrofit project to 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. While distributors have no specific legal responsibility
for end-of-life management of the lamps they sell (except for lamps in their
own facilities), distributors can be influential in assisting customers with
recycling options.
OTHER JURISDICTIONS
The Canadian provinces have similar concerns about environmentally responsible
lamp disposal. Lamp recyclers are also available in Canada. The www.lamprecycle.org
website has information on lamp disposal and recyclers in Canada. Mexico
has passed a version of the U.S. UWR, which includes mercury-containing lamps.
Implementation is the responsibility of the 31 states. Details are not yet
available.
LAMP BREAKAGE
While lamp breakage is of some concern to distributors (primarily if you receive
shipments with broken lamps into your warehouse), the parties most concerned
with this issue are your customers, the contractors and owners.
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.
For more information specific to your state, consult the State-by-State
Stringency Comparison Table. We also encourage you to set up recycling
programs for the spent mercury-containing lamps in your own facilities.
SETTING UP RECYCLING SERVICES
Recycling services are provided by Association of Lighting and Mercury Recyclers
(ALMR) member companies anywhere in the United States and its territories,
Mexico and Canada. Services are available to large lamp users, small businesses,
contractors, municipal government agencies and they are also available to
households and the public through household waste collection programs.
Either directly or through a network of transportation and solid waste contractors,
material can be picked up in any U.S. community. There are also a number
of lighting, maintenance and other building contractors who will collect spent
lamps and get them recycled for their customers.
Lamp collection programs can be designed for all generators:
| • | Small users can participate by using a “box program”, where a container is provided and when full it can be sent to any recycler via ground mail shipment. This is a prepaid program and labels and shipping papers are provided. |
| • | For larger users, recyclers can arrange milk-run pick-ups and common carriers will transport lamps to accumulation facilities throughout the country, where they are consolidated for shipment to destination facilities. |
| • | For very large generators, materials can be picked up in trailer loads as needed. |
| • | There are numerous collection locations around the country that ship large quantities of lamps to recycling “Destination Facilities” (state authorized recyclers) every day. |
| • | Recyclers typically provide customers with collection/shipping services and containers for lamps. They will also arrange all aspects of getting lamps recycled for anyone who is interested. |
| • | Individuals and small users can also take lamps to any locally operated household waste facility in their community. For a list of community programs see www.earth911.org. |
“Lamp Recycling. The Responsible Thing To Do.”©
For
more information visit
www.lamprecycle.org
or
www.almr.org