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 Introductions: Who are the Players? - SBEAP, Other Agencies and You (TDEC - Key Messages) Who’s in the Audience?
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.) • Identify and promote options to help Mercury Lamp Recycling • Provide resource and assistance information
What are the Mercury Issues Modes of Exposures Health effects Environmental Effects Environmental Rules - Universal Waste Rule and - Policy Workshop Topics
Recycling Best practices Challenges and Benefits Contacts and Resources Workshop Topics (cont.)
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 issues? Hg - Mercury is a valuable resource material, that must be handled properly when it no longer has a beneficial use.
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 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 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 • 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... • 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 … • 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 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 … • 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 environment… • Contamination has occurred in ocean fish • Impacted species include King Mackerel, Sharks and Swordfish
Your mission - should you accept: Avoid Mercury Exposure
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 Understanding TDEC’s Universal Waste Rule and Policy
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 … The Resource Conservation and Recovery Act (RCRA) regulates the generation, storage, disposal, and treatment of wastes.
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 … • 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 … • 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 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 … • 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? … 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 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 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? … 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? • 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 ... • 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 … • 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 … • 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 … • 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 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 … • 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 … • 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 … • 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 … • 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 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 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 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 Open Forum: Questions about waste & Who can help?
You Want me to What ... R E C Y C L E
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.