How is controlled crushing regulated?

Controlled crushing of lamps is regulated under both federal and state hazardous and universal waste regulations. The federal universal waste regulations do not authorize on-site crushing of fluorescent lamps but do allow states to write rules that will permit crushing on-site. The states of Illinois, Florida, Virginia, Tennessee, Texas, Colorado, Maryland and Montana have all passed rules that allow persons to crush lamps on-site under the universal waste regulations. TerraCycle Regulated Waste is working with several states and expects more states to pass rules within the next year to allow lamp crushing.

In states that allow crushing and classify crushed lamps as universal waste, persons can generally store their waste lamps on-site for up to one year, can ship waste lamps off-site with a bill of lading rather than a hazardous waste manifest, and do not need to include their lamps when calculating their hazardous waste totals.

Under state and federal hazardous waste regulations, controlled crushing (which is what the Bulb Eater systems do) is considered treatment. The hazardous waste rules typically require a person who treats wastes to obtain a permit. Federal and most state hazardous waste rules, however, exempt from the permit requirement persons who treat their wastes "within a drum, tank, or container." (See 40 CFR 262.34).

TCRW believes The Bulb Eater® systems fall squarely within this exemption and many states have acknowledged in letters to TCRW that the accumulation tank exemption applies to The Bulb Eater systems. You should be aware, however, that the states of California, Maine, Massachusetts, Connecticut, Rhode Island and Missouri have more narrow exemptions to the permitting requirements. TerraCycle Regulated Waste suggests you contact representatives of those states before proceeding with on-site crushing.

If your state does not allow crushing under its universal waste regulations, then you typically may manage crushing under your state's hazardous waste regulations as a process exempt from the general permitting requirements. Please note that regardless of whether the lamps are managed as universal or hazardous wastes, you must properly dispose of the crushed lamps preferably by shipping the crushed lamps to a permitted recycling facility.

TerraCycle Regulated Waste will continue to work with state lawmakers, the National Electrical Manufacturing Association and the Association of Lighting and Mercury Recyclers to promote legislation, which will authorize persons to crush lamps under universal waste regulations. TerraCycle Regulated Waste and its customers know that persons are able to safely crush their lamps to reduce volume, minimize handling, cut costs, and create a safer work environment by managing their crushed lamps under either universal waste regulations or existing state hazardous waste regulations.