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Achieving Compliance with the Universal Waste Rule Mercury Lamp Recycling Project For the Tanning Industry Prepared by the Small Business Environmental Assistance Program Mercury Lamp Recycling Workshop Introductions: Who are the Players? - SBEAP, Other Agencies and You

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Achieving Compliance with the Universal Waste RuleMercury Lamp Recycling ProjectFor the Tanning Industry

Prepared by the

Small Business Environmental Assistance Program

mercury lamp recycling workshop
Mercury Lamp Recycling Workshop


Who are the Players? - SBEAP, Other Agencies and You

(TDEC - Key Messages)

Who’s in the Audience?

workshop objectives
Workshop Objectives
  • Educate the tanning industry on the hazards of Mercury
  • Explain the Universal Waste Rule and Policy and their regulatory impacts
  • Review and encourage Best Management Practices for handling Mercury Lamp Products to reduce exposure risk and pollution
workshop objectives cont
Workshop Objectives (cont.)
  • Identify and promote options to help Mercury Lamp Recycling
  • Provide resource and assistance information
workshop topics
What are the Mercury Issues

Modes of Exposures

Health effects

Environmental Effects

Environmental Rules

- Universal Waste Rule and

- Policy

Workshop Topics
workshop topics cont

Best practices

Challenges and Benefits

Contacts and Resources

Workshop Topics (cont.)
what are the issues
What are the Issues?

Mercury Lamps and You -

What happens to my used HV Lamps?

What are the Implications and Impacts?

Open Forum: Questions and Answers

what are the issues8
What are the issues?


- Mercury is a valuable resource material, that must be handled properly when it no longer has a beneficial use.

modes of exposure
Modes of Exposure

Exposure may be caused by any of

the following:

  • Mercury gets airborne via fuel burning sources
  • Mercury exposure occurs through eating contaminated fish
  • Or even through broken lamps
modes of exposure10
Modes of Exposure

Mercury exposure may be caused by Dental fillings:

Mercury amalgams (dental fillings) may contain as much as 50% mercury, 25 % silver and 25% other material.

modes of exposure11
Modes of Exposure

The mercury vapor released may combine with other sources to create small amounts of methyl mercury, which is absorbed into blood stream.

health effects
Health Effects
  • Neurotoxicity is the Health Effect of greatest concern with mercury exposure
  • Reference Dose - Is the level of exposure without risk to health
mercury exposure can harm our health
Mercury exposure can harm our health...
  • May cause permanent kidney and lung damage, cardiac and respiratory problems.
  • Significant amounts of mercury in the

body may produce arthritis, depression, dermatitis, dizziness and fatigue.

  • Gum disease, hair loss, insomnia, head-aches, joint pain, slurred speech memory loss and muscle weakness.
  • High levels may interfere with enzyme activity, which could result in blindness and paralysis.
mercury can harm our health
Mercury can harm our health …
  • Exposure has been shown to affect women of childbearing age and is especially harmful to pregnant women and unborn children.
  • Causes delayed walking and learning ability in children
  • Methyl mercury is absorbed into the blood and goes to all tissue, including the brain.
  • It readily passes to placenta and fetal brain in unborn children. It also causes delayed walking and learning ability in children
mercury can harm our health15
Mercury can harm our health …
  • Especially children, the elderly, those with respiratory problems, and those that spend a lot of time outdoors
  • Aggravates asthma and increases susceptibility to illnesses like pneumonia and bronchitis
mercury harms our environment
Mercury harms our environment …
  • Wide spread contamination on natural resources and recreation areas
  • 238,000 miles of rivers
  • 52,000 lakes have various levels of contamination
  • Fish consumption advisories have been issued in Tennessee
mercury harms our environment17
Mercury harms our environment…
  • Contamination has occurred in ocean fish
  • Impacted species include King Mackerel, Sharks and Swordfish
your mission should you accept
Your mission - should you accept:

Avoid Mercury Exposure

get tanned but not burned
Get tanned, but not burned

Mercury, has many beneficial uses. The tanning industry uses special HV lamps that contain mercury.

However, improper disposal of mercury lamps may harm you and the environment.

environmental regulations for mercury
Environmental Regulations for Mercury

Understanding TDEC’s

Universal Waste Rule

and Policy

how is mercury regulated
How is mercury regulated? …
  • Universal Waste Rule covers the use and handling of Mercury Lamps.
  • In nearly everything we do, we leave behind some kind of wastes. Households create “household waste”.
  • Industrial and manufacturing processes create “solid” and “hazardous wastes”.
regulatory overview
Regulatory Overview …

The Resource Conservation and Recovery Act (RCRA) regulates the generation, storage, disposal, and treatment of wastes.

regulatory overview24
Regulatory Overview …
  • RCRA’s goals are to:
    • Protect us from the hazards of improper waste disposal
    • Conserve energy and natural resources by recycling and recovery
    • Reduce or eliminate waste
    • Clean up waste, which may have spilled, leaked, or been improperly disposed of
types of waste
Types of waste …
  • There are three types of wastes. Solid waste, hazardous waste, and special waste.
  • Hazardous waste comes in many shapes and forms such as solid, liquid, and gas
  • How do we know we have hazardous waste? Hazardous waste are either listed or they exhibit any of four characteristics: ignitable, corrosive, toxic, or reactive (flammable).
tell me more
Tell me more …
  • Universal wastes are hazardous waste which are regulated under the state’s Universal Waste Rule
  • Universal waste includes items such as waste batteries, agricultural pesticides, thermostats and tanning lamps.
a definition and more
A definition and more…
  • A lamp, also referred to as “universal waste lamp,” is defined as the bulb or tube portion of an electric device. Common universal waste electric lamps include, but are not limited to, fluorescent, high intensity discharge, neon, mercury vapor, high pressure sodium, and metal halide lamps.
goals of the regulation
Goals of the regulation …
  • Universal waste regulation:
    • Ease regulatory burdens on businesses.(far less regulations than normal hazardous waste)
    • Promote proper recycling, treatment, or disposal
so what s a generator
So what’s a Generator? …

Generator means any person, by site, whose act or process produces hazardous waste identified or listed in Rule 1200-1-11-.02 or whose act first causes a hazardous waste to become subject to regulation.

tell me more30
Tell me more …
  • There are two main types of handlers for universal waste.
    • Small Quantity Handler of Universal Waste (SQHUW) that accumulate less than 5000 kg (11000 lbs) of waste at any one time.
    • Large Quantity Handler of Universal Waste (LQHUW) that accumulate More than 5000 kg of universal waste at one time
tell me more31
Tell me more …
  • Two other types Universal waste handlers are:
    • Households - (Are Exempt)
    • Conditionally Exempt Small Quantity generators of hazardous waste (CESQHW) that meet the conditions for exemption. - Rule 1200-1-11.02(1)(e)(1) and 40 CFR 273.8 (a)(2).
should labels be used
Should Labels be used? …

Labeling or marking a Universal waste lamp:

A container in which the lamp or crushed lamps are contained, must be labeled or marked clearly with any one of the following phrases: “Universal Waste – Lamp(s)”, or “Waste Lamp(s)”, or “Used Mercury Lamp(s)”, or placing “Crushed”, as appropriate, on the label

will i need an id number to ship lamps
Will I need an ID number to ship lamps?
  • Environmental Protection Agency (EPA) Identification Number is required for (LQHUV). (SQHUW) is not required to have an EPA Identification Number.
  • Manifest are not required for SQHUW and LQHUW. LQHUW must keep basic shipping records. However, changes are proposed and SQHUW will be required to also keep records.
more about shipping lamps
More about shipping lamps ...
  • Shipments of universal waste must only be sent to other handlers and destination facilities or a permissible foreign destination.
  • Destination Facility- a facility that treats disposes of or recycles universal waste.
so where do the lamps go
So where do the lamps go …
  • Universal Waste Transfer Facility
    • any transportation-related facility including loading docks, parking areas, storage areas and other similar areas where shipments of universal waste are held during the normal course of transportation for ten days or less.
more about universal waste
More about Universal Waste …
  • Universal Waste Transporter
    • a person engaged in the off-site transportation of universal waste by air, rail, highway, and/or water
  • Waste management
    • a Small Quantity Handler of Universal Waste must manage lamps in a way that prevents releases of any universal waste to the environment as follows:
handling waste lamps
Handling waste lamps …
  • The handler of universal waste must secure lamps in a closed container or package that is structurally sound, adequate to prevent breakage, and compatible with lamp contents.
handling waste lamps38
Handling waste lamps …
  • The handler must also immediately clean up and place in an adequate container any lamp that is broken or that shows evidence of breakage, leakage, or damage that could cause the release of mercury or other hazardous constituents to the environment.
provide training to employees
Provide training to employees …
  • Employee Training - a small quantity handler of universal waste lamps must inform all employees who handle or have the responsibility for managing universal waste.
  • The information must describe proper handling and emergency procedures appropriate to the type of universal waste.
what if a lamp breaks
What if a lamp breaks …
  • Response to releases
    • A handler of universal waste lamps must immediately contain all releases and other residues from universal waste.
    • A handler of universal waste lamps must determine whether any material resulting from release is hazardous waste, and if so, must manage the waste according to hazardous waste rules.
making the right stops
Making the right stops …
  • Transporter
    • A facility that transports universal waste from one handler to another handler, or to a destination facility.
  • Destination Facility
    • A facility that recycles, treats, or disposes of universal wastes.
environmental policy
Environmental Policy …
  • Tennessee’s guidelines for Universal Waste
    • Households are Exempt
    • 15 or fewer lamps per month - OK to landfill, but we recommend recycling. Applicable only to small quantity generators of hazardous waste
    • Over 15 lamps/month - Generators must Recycle
environmental policy43
Environmental Policy …
  • Policy requires generators of Universal Waste to verify that used lamps are not hazardous, if disposed of instead of recycled.
    • Some lamps may be non-hazardous, check with your supplier and/or manufacture.
    • Know your options before you purchase lamps. Otherwise, you may have to test.
environmental policy44
Environmental Policy …
  • If test verifies that lamps are non-hazardous - Can lamps go to the landfill?

… Well not exactly. It may be considered a special waste and additional approvals may be required.

environmental policy45
Environmental Policy …
  • If lamps are non-hazardous, it may still be a special waste and the following conditions must be met:
    • Approval letter from Division of Solid Waste Management.
    • Approval from an Official of the Landfill - who agrees to accept special waste.
environmental rules for mercury
Environmental Rules for Mercury

Open Forum:

Questions about waste


Who can help?

the big picture
The Big Picture ...
  • Technologies were developed in the US to reclaim mercury from spent lamps in 1989
  • Recycling rate 10 -12 % in 1990 thru 1999. After regulations began to drive the recycling market, it rose to about 20% and in 1999, EPA announced lamps were added to the Universal Waste Rule.
the big picture51
The Big Picture ...
  • Currently about 22.4% of lamps are recycled.
  • In the last 3 years recycling capacity has been significantly increased to meet anticipated demands.
  • About 78 % land disposal (non-recycling) rate of roughly 520 million lamps per year.
the big picture52
The Big Picture ...
  • Amount of lamps going to landfills are still too high.
  • National Goal is to increase recycling to 40% in the next two years. And upwards to 60% within 4 years.
tennessee industry profile
Tennessee Industry Profile
  • 1,000 Tanning shops with larger shops having about 15 tanning beds. Beds contain 24 - 30 lamps each.
  • Tanning beds are re-lamped 2 to 4 times per year.
  • Tanning salons generate about 2.5 million lamps per year.
mercury lamp recycling
Mercury Lamp Recycling
  • Best Practices
  • Are you in Compliance?
  • Protect your used Lamps
  • If it breaks, you should know what to do.
best practices for mercury lamps
Best Practices for Mercury Lamps

Do’s and Don’ts about handling


Handle with care

Store in dry cool place

Protect from breakage

Recycle lamp tubes

Label your containers

best practices for mercury lamps56
Best Practices for Mercury Lamps

Do’s and Don’ts about handling


Don’t place in dumpster

Don’t retain onsite more than 1 year

Don’t breath dust or vapors if broken

mercury lamp recyling best practices benefits
Mercury Lamp Recyling: Best Practices - Benefits
  • Cleaner, Safer Tanning Shop
  • Healthier work environment, with potentially fewer sick days
  • Reduced potential for mercury exposures
  • Waste reduction

Cost to Recycle - Should be part of costto do businessRecycling mercury lamps offers an environmentally sound alternative to expensive hazardous waste disposal

contacts for recyclers
Contacts for Recyclers

Southeast Recycling Technologies, Inc.

906 Chase Drive

Johnson City, Tennessee

423-282-2022 or 1-800-592-3970

Also you may contact the vendor who sold the lamps for a return pick-up

why you should recycle
Why you should Recycle
  • Lower costs
  • Similar or better performance
  • Easier to meet regulatory requirements
  • Reduced pollutant emissions
  • Better worker protection and satisfaction
  • Cleaner, healthier work environment
why you should you recycle cont
Why you should you Recycle (cont.)
  • Increases overall Recycling in the State
  • Efficient, affordable control technologies
  • Responsible care and product stewardship for mercury products
  • Reduces harm to the environment
  • Avoid environmental fines and liabilities for improper management
what is cost of recycling
What is cost of Recycling?
  • National average cost to recycle varies by region
  • Tennessee recycling costs for UV lamps range from .10 to .15 cents per foot bulb depending on pick-up arrangement.
  • Typically, there are pricing breaks for

large quantities

recycling mercury lamps
Recycling Mercury Lamps

Open Forum:

Questions about recycling


Who can help?

  • Understand the Hazards of Mercury and your environmental responsibilities
  • Review Best Management Practices for handling Mercury Lamps and of course recycle your Lamps
  • Relax - Get tanned, Just don’t get burned. - Be in compliance and call us if we can help
on line resources
On-line Resources
  • Mercury Lamps Recycle Project
  • E-MAIL US at
  • OR VISIT OUR WEB PAGE AT:a Call 1-800-734-3619

  • Recycling Associations
tennessee small business environmental assistance program sbeap
Tennessee Small Business Environmental Assistance Program (SBEAP)



have a great day
Have a Great Day !!!
  • Wrap -Up - Q&A
  • Contacts
  • Workshop Evaluation(s)