Achieving Compliance with the Universal Waste Rule Mercury Lamp Recycling Project For the Tanning In

1
Achieving Compliance with the Universal Waste
RuleMercury 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)
• Whos 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 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.

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 TDECs
• Universal Waste Rule
• and 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

• RCRAs 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 states 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 whats 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

• Tennessees 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 ...

• R
• E
• C
• Y
• C
• L
• E

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

• Dos and Donts about handling
• lamps.
• Handle with care
• Store in dry cool place
• Protect from breakage
• Recycle lamp tubes
• Label your containers

56
Best Practices for Mercury Lamps

• Dos and Donts about handling
• lamps.
• Dont place in dumpster
• Dont retain onsite more than 1 year
• Dont 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 businessRecycling 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, Tennessee
• 423-282-2022 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 dont get burned. - Be
  in compliance and call us if we can help

65
Resources for Tanning Shops

• Best practices checklist
• Web Sites Associations
• Technical fact sheets Brochures
• Training workshops

66
On-line Resources

• Mercury Lamps Recycle Project
  
• E-MAIL US at http//www.BGSBEAP_at_state.tn.us
• OR VISIT OUR WEB PAGE ATa
• www.tdec.net/ea/sbeapOr 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 1-800-734-3619
68
Have a Great Day !!!

• Wrap -Up - QA
• Contacts
• Workshop Evaluation(s)