From: Art Coleman (email@example.com)
Date: Fri Jan 16 1998 - 10:10:47 CST
I assume you are referring to mercury or fluorescent lamps. As Kirk Nofzinger stated, Ohio EPA, OPP, has a mercury lamp/ballast fact sheet and list of commercial lamp recyclers - a joint effort between OPP and the Division of Hazardous Waste Management (DHWM).
Ohio regulates lamps discarded by a business under its hazardous waste program. There are two management alternatives for discarding mercury-containing (and incandescent) lamps. A business may either dispose of its lamps or recycle them. If the lamps are disposed of, the owner/operator of the business must first determine whether or not the lamps are hazardous wastes. If they are hazardous, the business must dispose of them at a hazardous waste facility that is permitted to handle the lamps. If the lamps are not hazardous wastes, the lamps can be dispose of as non-hazardous wastes. [There is anecdotal information that some used fluorescent lamps may have significant amounts of mercury embedded in the glass. The glass may pass the TCLP test (for mercury) because the mercury is inaccessible to the extraction fluid, but the glass may pose exposure and environmental contamination issues if it is subsequently processed by certain methods]. If the lamps are recycled, Ohio does not consider the lamps
to be hazardous wastes at the point of generation through recycling States vary in regards to how they regulate mercury lamps.
Ohio strongly encourages businesses to recycle their lamps and to use energy-efficient lighting. We offer the following tips to the regulate community on recycling mercury lamps:
(1) Crushing lamps - Although crushing lamps to facilitate their consolidation and transportation may be cost-effective, some recyclers may not accept broken lamps or charge an extra fee. Currently, Ohio does not require a hazardous waste permit to crush lamps, provided they are recycled and the lamp crushing unit is equipped with an emission control system that captures gases and particulates and, the toxic constituents (e.g. mercury) from the spent or used emission control media (e.g. activated carbon) are recycled.
(1) Segregate lamps - This is especially important if the generator decides to get the lamps tested to determine whether they are hazardous wastes. Mixing lamps of different characteristics or brands complicates the process of obtaining a representative sample and may result in inconclusive or inaccurate results. Most of the major lamp manufactures provide MSDSs on their lamp products. Most of them have web sites for downloading information on their products. It is wise to maintain copies of product specifications on file. I caution, however, that lamp generators that rely exclusively on MSDSs in characterizing their lamps should carefully evaluate the lamp specifications data. Be aware that some analytical or testing laboratories may use different preparation procedures, although the actual TCLP test (an analytical test to determine whether a waste displays the hazardous waste characteristic of toxicity) has specific procedural guidelines that must be followed, by regulation. Also, the recyclin
g unit at the facility may only be capable of handling specific types of lamps. For example, the unit may not be able to handle incandescent lamps because of the difficulty in separating metal filament fragments from the glass. Some fiberglass manufacturers cannot except metal-contaminated glass because it clogs their glass extruders.
(3) Use Reputable Recyclers - Check out their compliance history, if any. Most of the commercial lamp recyclers in Ohio initially contacted the Agency to discuss the feasibility of setting-up a lamp recycling facility in Ohio. Find out what services they offer and what they are doing with the lamps (e.g. technology, storage, turnover, down time, record keeping, tracking, annual report, personnel training, efficiency, etc.). If they send recovered lamp components to another recycler, you may want to find out what the recycler is doing with the components. You may want to directly contact the recycler for verification or details. Some prospective customers visit or audit the site. How clean and efficient is the recycling technology? Does the process generate large quantities of wastes? If so, how are the wastes handled? Is the technology widely used and accepted, or is it new and unproven? Does the recycler have a transportation network? If so, are the transporters trained in handling mercury
lamps or hazardous materials? Most commercial recyclers offer a certificate of completion or destruction which is an assurance to the customer that the recycler has followed the proper protocol.
(4) In order to minimize breakage, it is best to store discarded lamps in a designated location or area that is restricted to authorized personnel. The storage area should have the appropriate signs posted. A tracking log or inventory should be maintained.
If you desire additional information or clarification, feel free to contact me or the Technical Support Unit (TSU).
Art Coleman, Ohio EPA, DHWM
P.O. Box 1049
Columbus, Ohio 43216-1049
(FAX (614) 728-2345
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