QUESTIONS & ANSWERS

Regulatory needs for Management of Fluorescent and High-Intensity Discharge Lamps

Chicago Lamp use has worked with the Illinois Environmental Protection Agency (IEPA) whereas developing our Lakemoor, Illinois facility. Our efforts with the IEPA on the primary lamp use facility within the State have helped form the IEPA’s lamp management policies.
The primary rules governing spent fluorescent and high-intensity discharge (HID) lamps are contained in Title thirty-five Illinois body Code half 733 (35 IAC 73). These rules, typically known as the Universal Waste rules, are somewhat obscure and subject to interpretation. we’ve raised the variety of queries and mentioned several problems with the IEPA. Following are queries and answers which will be of explicit interest to you.

Q. World Health Organization should adjust to the rules governing fluorescent lamps? Isn’t there associate degree exemption for little amount generators?

A. The rules can have an effect on all business and governmental lamp users, solely households are exempt. the bulk of building homeowners and tenants are generators and tiny amount handlers. Building management companies and construction firms can usually be little or great quantity handlers and transporters. the wants of the Universal Waste rules are summarized in an exceeding document titled “Fact Sheet.

The exemption you’ve got noted could be a Resource Conservation and Recovery Act (RCRA) provision for not absolutely Exempt little amount Generators (CESQG). The IEPA doesn’t think about this exemption to be applicable to fluorescent and high-intensity discharge lamps since they’re classified as universal wastes. in keeping with the IEPA, fluorescent and HID lamps cannot be disposed of in municipal landfills or through burning in Illinois, no matter amount, unless they pass the TCLP take a look at.

Q. World Health Organization is that the generator? Is it the building owner? the tenant? the management company that removes the lamps?

A. The building owner or tenant (if the tenant maintains the lighting) is that the generator. The building owner or tenant remains the generator if he/she hires a contractor to get rid of lamps as a part of maintenance or demolition. The contractor could be a universal waste handler during this situation.

Q. World Health Organization has liability for the lamp management and “disposal.”

A. Lamp generator, handlers, transporters, and destination facilities are to blame for specific needs delineate within the Universal Waste rules. Ultimately, the generator retains liability for guaranteeing his/her lamps are managed in accordance with the rules. it’s thus extraordinarily vital that the generator ensures the destination facility being employed is correctly permissible, will de jure issue a certificate of destruction, associate degreed recycles the lamps in an environmentally accountable manner in accordance with applicable rules.

Q. Do spent lamps must be manifested?

A. No. a part of the rationale for designating these mercury-containing lamps as universal wastes are to cut back the regulative needs for the lamp users. having the ability to ship spent lamps while not a manifest is associate degree example of the reduced needs.

Q. Am I able to crush lamps to save lots of storage space? Is crushing an honest idea?

A. A The generator, universal waste handlers or transporters are allowed to crush lamps on the generator’s web site just for volume reduction. needs for crushing instrumentality, personal coaching, allowable emissions from the crushing units, and record keeping and reportage are per thirty-five IAC 733. Crushed lamps should still be destroyed and recycled at a destination facility.

Crushing at a generator’s web site might or might not create economic sense. The generator or handler should assess whether or not the price of the crushing, (apparatus, labor, & processing) and meeting regulative needs are just supported the space for storing saved.