Achieving Compliance with the Universal Waste Rule Mercury Lamp Recycling Project For the Tanning Industry Prepared by the Small Business Environmental.

Achieving Compliance with the Universal Waste Rule

Mercury Lamp Recycling ProjectFor the Tanning Industry

Prepared by the

Small Business Environmental Assistance

Program

2

Mercury Lamp Recycling Workshop

Introductions:

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

(TDEC - Key Messages)

Who’s in the Audience?

3

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

4

Workshop Objectives (cont.)

Identify and promote options to help Mercury Lamp Recycling

Provide resource and assistance information

5

Workshop Topics

What are the Mercury Issues Modes of Exposures

Health effects Environmental Effects Environmental Rules

- Universal Waste Rule and - Policy

6

Workshop Topics (cont.)

Recycling

Best practices

Challenges and Benefits

Contacts and Resources

7

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

8

What are the issues?

Hg- Mercury is a valuable resource

material, that must be handled properly when it no longer has a beneficial use.

9

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

10

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.

11

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.

12

Health Effects

Neurotoxicity is the Health Effect of greatest concern with mercury exposure

Reference Dose - Is the level of exposure without risk to health

13

Mercury exposure can harm our health...

May cause permanent kidney and lung damage, cardiac and respiratory problems.

Significant amounts of mercury in thebody 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.

14

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

15

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

16

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

17

Mercury harms our environment…

Contamination has occurred in ocean fish

Impacted species include King Mackerel, Sharks and Swordfish

18

Your mission - should you accept:

Avoid Mercury Exposure

19

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.

20

Environmental Rules

21

Environmental Regulations for Mercury

Understanding TDEC’s

Universal Waste Ruleand Policy

22

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”.

23

Regulatory Overview …

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

24

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

25

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).

26

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.

27

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.

28

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

29

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.

30

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

31

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).

32

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

33

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.

34

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.

35

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.

36

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:

37

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.

38

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.

39

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.

40

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.

41

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.

42

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

43

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.

44

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.

45

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.

46

Environmental Rules for Mercury

Open Forum:

Questions about waste&

Who can help?

47

Need a Break?

- Take Ten

48

Recycling Waste Lamps

49

You Want me to What ...RECYCLE

50

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.

51

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.

52

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.

53

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.

54

Mercury Lamp Recycling

Best Practices

Are you in Compliance?

Protect your used Lamps

If it breaks, you should know what to do.

55

Best Practices for Mercury Lamps

Do’s and Don’ts about handling

lamps. Handle with careStore in dry cool placeProtect from breakageRecycle lamp tubesLabel your containers

56

Best Practices for Mercury Lamps

Do’s and Don’ts about handlinglamps.

Don’t place in dumpsterDon’t retain onsite more than 1

yearDon’t breath dust or vapors if

broken

57

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

58

Cost to Recycle -

Should be part of costto do business

Recycling mercury lamps offers an environmentally sound alternative to expensive hazardous waste disposal

59

Contacts for Recyclers

Southeast Recycling Technologies, Inc.906 Chase Drive Johnson City, Tennessee423-282-2022 or 1-800-592-3970

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

60

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

61

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

62

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

63

Recycling Mercury Lamps

Open Forum:Questions about

recycling&

Who can help?

64

Summary

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

66

On-line Resources

Mercury Lamps Recycle Project

E-MAIL US at [email protected] OR VISIT OUR WEB PAGE AT:

www.tn.gov/environment/apc/sbeap

Or Call 1-800-734-3619

Recycling Associations http://www.alma.org

http://www.lamprecycle.org

67

Tennessee Small Business Environmental Assistance Program

(SBEAP)

CALL US TOLL FREE AT:CALL US TOLL FREE AT:

1-800-734-36191-800-734-3619

68

Have a Great Day !!!

Wrap -Up - Q&A

Contacts

Workshop Evaluation(s)