Tag Archives: Liability Act

Thumbs Up for Lamp Recycling!

January 11, 2012   nlrgreen   No comments
thumbs-up

Fluorescent lamp recycling for a business of any size has its positives that far outweigh not recycling and just going on with business as usual. There are positives that can be quantified, ones that can be physically seen and still others that have long reaching effects.

  • Through tracking and reporting a business can have a total of all their recycling efforts across one or multiple sites. This will allow them to be able to craft a more effective lamp recycling program by being able to pin-point which program (bulk or mail back) is right for them.
  • The bottom line. As with most things there is a charge for lamp recycling, but the cost is less than fines that can be assessed for improper management. Would a company rather pay $49 for a pre-paid recycling program that eliminates their liability or would they rather pay hundreds of dollars in fines for the same material that wasn’t recycled?
  • By collecting and correctly storing used lamps a business can reduce their liability for breakage, environmental breach, and possible employee injury
  • Recycling is both environmentally and corporate responsible. Recycling lamps keeps mercury out of our landfill and in turn out of the water and food sources that can directly impact our health
  • A lamp program can help a business increase their green image as well as convey a message of environmental stewardship to their employees and customers. Businesses can set up a company-wide recycling drive for all their employees or use their total lamp recycling numbers to quantify how much mercury was kept out of the environment. Real “Green Press” is green gold in today’s PR world.
  • Simply-Its the law and the right thing to do.

 

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The Thin Green Line

January 06, 2012   nlrgreen   No comments

Green Line

Programs like office paper, glass and can recycling are often implemented by a business’s  ”green team’ or as part of a corporate sustainability program. These programs help not only the environment but also provide a tangible aspect to a businesses green image and environmental responsibility. A corporate officer or employee can easily see the recycling bins and see what they have accomplished. However a company may not be subject to EPA fines if  the program is improperly managed or liable for incorrect storage of these items.* Would a EPA auditor say “Hey those aluminum cans and paper for shredding have no accumulation date.” or “What is your procedure to guard against environmental breach of those Snapple bottles?”. Most likely not. So when does environmental responsibility become a environmental requirement? Answer: When a company generates used lamps, batteries, ewaste, ballasts or mercury devices.

While used fluorescent lamps are taken away to the proper storage containers in the back of a  facility may not be in your face “look at us we recycle” it is still environmentally friendly and most importantly is the LAW.  Simple things such as having a universal waste recycling program, trained staff or properly stored containers with accumulation dates can help companies be compliant and reduce their liability. All of these things can be accomplished without a environmental health and safety officer or being a draw on budgets. The below are a few simple steps to successful universal waste recycling:

1) Learn & Educate-Understand your state’s regulations and specifics on universal waste
• What is Universal Waste? • RCRA Requirements • My State’s Regs
2) Assess Your Company- Take a general look at what universal waste your company produces and how often. See if you are a small or large generator3) Plan the Program- Based on the amount of waste generated see if a national mail-back program or bulk pick-up service is needed. Also look at factors beyond quantities such as ease of management, your facilities locations, or specific needs of your industry.

4) Implement & Monitor- Once you have selected the proper program be sure to implement it company-wide, educate employees, monitor progress, keep recycling records/certificates and evaluate the program yearly.

5) Have Questions or Need Assistance? Get Help-Call 877.822.4733 to discuss your company’s specific needs, implement a new program or to enhance a current one.
*depending on what state your company is in this may not be true. Check your local laws and regulations.

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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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