Category: Laws & Regulations

Yonkers launches fluorescent bulb recycling

May 25, 2011   nlrgreen   No comments

Under the terms of an enforcement agreement with the United States Environmental Protection Agency (EPA), the City of Yonkers has initiated a program to recycle fluorescent light bulbs, as well as light ballasts and electronic waste, known as E-waste. Fluorescent bulbs contain mercury, which can be released if the bulbs are broken. By collecting and recycling these bulbs from city residents, Yonkers will be helping to reduce the release of mercury to the environment.

In 2008, EPA inspected various buildings belonging to Yonkers and requested documentation regarding the city’s spent bulb recycling efforts. After the city did not adequately respond, EPA cited the city for violating the Resource Conservation and Recovery Act, the federal law governing the treatment, storage, and disposal of hazardous waste.

Agency regulations require that spent mercury and other toxic metal-containing bulbs from business, industry and government be handled as hazardous waste, which means they must be disposed of in specially licensed facilities. As an alternative, they can be handled under simpler universal waste rules to encourage their recycling.

Under the terms of the settlement, Yonkers will begin collecting spent fluorescent bulbs, light ballasts and e-waste from Yonkers residents. The city will widely publicize the program.

via American Recycler, May 2011 | Yonkers launches fluorescent bulb recycling.

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Lamp Recycling Handler Size: Small vs. Large

April 05, 2011   nlrgreen   No comments

 

A handler accumulates universal waste (in this case lamps) but do not treat, recycle, or dispose of the waste. Knowing your size under the Universal Waste Rule allows you to know exactly what your requierments are. The EPA cites them as:

The universal waste regulations include requirements for two groups of handlers based on the amount of universal waste accumulated on site at any one time:

-A small quantity handler of universal waste may accumulate less than 11,000 pounds (5,000 kg) of total universal waste, (i.e., batteries, pesticides, mercury thermostats or mercury containing lamps) for periods up to one year.

-A large quantity handler of universal waste is one who accumulates 11,000 pounds (5,000 kg) or more of total universal waste for periods up to one year.

Small quantity handlers must ensure that any universal wastes they are accumulating are managed in a closed container that prevents the release of the universal waste or waste components. Each container must be labeled with the type of universal waste it contains. The small quantity handler may accumulate its universal waste no longer than one year from the date the waste was generated, and must maintain records demonstrating the actual generation date. Additionally, the small quantity handler must ensure all employees handling a universal waste have been provided information on proper handling and emergency procedures appropriate to the types of wastes managed. A small quantity handler must send its universal waste to another universal waste handler, a permitted facility or a foreign destination. Small quantity handlers are not required to use a uniform hazardous waste manifest or keep records of universal waste shipments.  However, it is highly recommended such records be maintained. Universal waste shipments may be transported by a contracted transporter or by the small quantity handler of universal waste.

In general, the requirements for large quantity handlers are more stringent than those of small quantity handlers of universal waste. First, the large quantity handler must receive an EPA Identification Number. Much like the small quantity handler, the universal waste must be accumulated in a closed container labeled with what it contains. Large quantity handlers may not accumulate universal wastes for more than one year and must maintain records demonstrating the date of the universal waste generation. Employees managing universal waste must be trained as to proper waste handling and emergency procedures. Shipments of universal waste from a large quantity handler must be tracked on a manifest, bill of lading, or similar type of document which must be maintained for at least three (3) years.

Get the EPA Guide: Introduction to universal waste

Need more information? Contact NLR

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What is RCRA?

March 29, 2011   admin   No comments

Enacted in 1976, The Resource Conservation and Recovery Act (RCRA) addresses how to safely manage and dispose of the large volumes of industrial and municipal waste generated nationwide. EPA’s Office of Solid Waste (OSW) administrates the program. The goals of the program include: protecting the community from the inherit hazards of waste disposal, using recycling and recovery to conserve energy, try to eliminate or reduce waste, and the clean up of any improperly disposed of or spilled waste.

The Resource Conservation and Recovery Act (RCRA) requires generators of solid wastes containing toxic constituents (such as mercury) to test representative samples of their waste before disposal to decide whether the waste is hazardous. According to RCRA, generators of used fluorescent lamps are responsible for determining whether their lamp wastes are hazardous. If you do not test used fluorescent lamps and prove them non-hazardous, assume they are hazardous and dispose of them accordingly. Using a specific type of fluorescent lamp, i.e. a “low mercury” or “environmentally friendly,” does not satisfy the requirements. Most importantly, these lamps do not eliminate your liability. They still contain mercury and according to the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), you can still be subject to superfund demands.

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What is the Universal Waste Rule?

March 29, 2011   admin   No comments

The UWR is designed to reduce the amount of hazardous waste items in the municipal solid waste stream, encourage the recycling and proper disposal of some common hazardous wastes, and reduce the regulatory burden on businesses that generate these wastes. Although handlers of universal waste must meet less stringent standards for storing, transporting, and collecting waste, the waste must comply with full hazardous waste requirements for final recycling, treatment, or disposal.

The UWR implements rules and guidelines for the collection of certain hazardous waste streams in the following categories: Lamps, Batteries, Ballasts, and Mercury Containing Devices.

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Understand the Laws & Liabilities

March 28, 2011   admin   No comments
EPA

The risks of not recycling aren’t just environmental – they’re financial. Fluorescent and other mercury-containing lamps and waste are regulated by the EPA. If you are not managing and disposing of them in accordance with hazardous waste regulations, you and your business could be subject to serious fines and superfund liability. The Federal Superfund law imposes liability upon certain parties who have engaged in disposal activities related to so-called “hazardous substances.”

Using a specific type of fluorescent lamp, i.e. a “low mercury” or “environmentally friendly,” does not satisfy the requirements. Most importantly, these lamps do not eliminate your liability. They still contain mercury and according to the Comprehensive Environmental Response, Compensation, and Liability Act (cercla), you can still be subject to superfund demands.

Used mercury-containing lamps and other items are regulated by the Environmental Protection Agency (EPA) under the Universal Waste Rule, (UWR) and in some states regulations are more stringent than the UWR.

The universal waste rule is designed to reduce the amount of hazardous waste items in the municipal solid waste stream, encourage the recycling and proper disposal of some common hazardous wastes, and reduce the regulatory burden on businesses that generate these wastes. Although handlers of universal waste must meet less stringent standards for storing, transporting, and collecting waste, the waste must comply with full hazardous waste requirements for final recycling, treatment, or disposal.

Crushed lamps and containers with excessive lamp breakage must be managed under full RCRA requirements. Only intact lamps can be managed under universal waste rule.States can have more stringent regulations than the universal waste rule. Many states have banned all mercury-containing lamps from landfills and have added other items such as electronic scrap and batteries to the regulations. If you have additional questions concerning the regulations in your state, call your local environmental agency.

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