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Proper Bulb Management: Crushing vs. Non-Crushing

Fluorescent bulbs are one of those wastes that the government has allowed some specific reliefs on based on the degree of the hazard and the volume that needs to be managed. Because of these reliefs, the government has categorized them as a "universal waste." Specifically, "Universal Waste" is a general descriptive term used to describe wastes that are generated by a large, diverse population. Classifying an item as a universal waste provides flexibility from having being managed under the restrictions of the hazardous waste classification while still insuring that the item is prevented from entering the municipal trash. (http://www.epa.gov/osw/hazard/recycling/electron/mce-fs.pdf)

The environmental regulations related to the recycling of spent fluorescent lamp bulbs vary by state. With the exception of the following 10 states: CA, CT, MA, MN, MI, NH, PA, RI, VT, and WV, a facility may crush its own spent fluorescent lamp bulbs on site and send the waste material to a proper recycling firm which handles these specific types of wastes. While it should be noted, that the EPA has not officially endorsed or approved any specific manufacturer of portable or mobile crushing units, it is expected that this new technology will be reviewed by the EPA, and depending on their findings, may result in legislation changes.

Bulb Crushing
The crushing option only applies to those bulbs which do not exceed the mercury content of 0.2mg/l. Bulbs that do exceed this level of mercury are typically from an older generation of bulb technology, and cannot be legally crushed.

There are many manufacturers of bulb crushing systems which can be purchased relatively inexpensively. These systems can be operated by the generating company and their on-site that personnel, with relative ease, generally only requiring minor maintenance. A typical bulb crushing system consists of a collection container, crushing system, vapor collection multi-stage filtration, and control system.

Both straight bulbs and U shaped bulbs can be processed on these systems with a simple change of the feeder tube on the unit.

While fluorescent lamp bulb crushing systems are relatively new in the area of recycling and the legislation is not in line with the technology, It should be specific reviewed to ensure it is appropriate for that particular company and their needs. Under the proper management and usage, sites can be provided a wide range of benefits by implementing this technology. Depending upon the annual volume of spent bulbs generated and crushed, here are some of the advantages that have been realized:

• Reduction in storage space normally utilized for the storage of spent whole lamps
• Labor costs associated with collecting, handling, and boxing were reduced.
• Worker risks associated with material handling and accidental breakage minor
• Recycling costs reduced (varies by volume of spent bulbs)

Crushed bulbs can be accumulated on-site for up to one year. Storage of the crushed bulbs (full or partially full containers) that exceeds one year, shall be in accordance with State and Federal regulations as they apply to Large, Small, and Conditionally Exempt generators.

Licensed firms can complete the final stage of recycling. These firms can be contracted for drum pick up and delivery to their permitted recycling facilities.

The filter systems within the recycling units require maintenance and replacements (of filters) on a regular basis. Under certain conditions, the replacements may be sent along with the crushed bulbs for recycling.

Recycling systems typically recover each material that can be re-used. The system separates the lamps into lime soda glass, aluminum end caps, lead glass/ferro metal components, and phosphor powder, which can be retorted to the capture the mercury.

In certain states and situations, generators that utilize bulb crushing, may be subjected to increased regulatory burden. In most cases, crushed fluorescent lamps and lamp fragments fail the TCLP (Toxicity Characteristic Leaching (not Leachate) Procedure Test, which then requires that they be managed as hazardous waste.

Traditional Recycling Options

Facilities with sites located in states that do not allow crushing, or if the economic analysis does not prove to be cost-effective, the option to continue to manage (collection, transportion, and recycle) of universal waste lamps at approved recycling facilities is still available. The process to approve a site can include an audit or assessment of that site to ensure that they engage in proper management techniques, the wastes are sent to licensed disposal facilities and are recycled in the same manner.. The only caveat to this would be the options available within the site's state, regarding the recycling of the material left from the bulbs after the mercury has been released and captured by the crushing machine filters. Sites which are located within a state that allows crushing, would need to account for some recycling weight from the glass and other components. As is always the requirement, this residual waste material will need to be within acceptable levels.

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