The program in Florida for mercury-containing lamps and devices came about as the result of the Solid Waste Amendments of 1993, from which Section 403.7186, F.S. was promulgated. At the beginning, guidance was issued by the Department for the management of mercury-containing lamps going to mercury recycling facilities. On May 10, 1995, rules were promulgated under Chapter 62-737, F.A.C. (pdf) for the management of MCLs and MCDs and the permitting of mercury recovery and reclamation facilities in Florida. These rules were later amended on May 20, 1998, so that they would be in synchrony with the US EPA’s Universal Waste Rule (UWR).

Photo: An example of crushing and separation equipment used in the first step of the lamp recycling process. Note that the equipment is enclosed and operates under negative air pressure with the process air routed through redundant carbon filters to remove mercury vapor.

Two mercury recovery facilities (pdf), one of which also has mercury reclamation capabilities, have been permitted under Chapter 62-737, F.A.C. As a result of Florida’s disposal prohibitions on MCLs and these facilities’ efforts to market their services, more than 25% of the MCLs estimated to have been discarded in Florida in 1997 and 1998 was managed at these facilities for the recovery and reclamation of the mercury they contained. Due to the competition between these facilities, the prices charged generators for their services have dropped substantially. In addition, one of the facilities participates in a State of Florida contract to provide MCL recycling services to state and local governmental agencies. This has resulted in great savings in recycling costs for state and local agencies. As a result of the Universal Waste Rule and the development of a nationwide market for MCL recycling services, however, the Department is looking at more cost-effective ways for these facilities to achieve the mercury recovery standards (pdf) set out under Chapter 62-737, F.A.C.

The UWR framework provides incentives for generators of MCLs and MCDs to manage these wastes under Chapter 62-737, F.A.C., for recycling as opposed to their management as hazardous wastes under RCRA through disposal. Only transporters and other non-generator handlers are required to register (using the registration form listed above) with the Department unless they are solely participating in a reverse distribution program as described below. A MCL and MCD handler facility, including a generator, needing to accumulate 5,000 kilograms (kg) or more of all universal wastes (including hazardous waste batteries, etc.) must also notify and receive an EPA/DEP ID number before accumulating such quantities, if it does not already have one per the large quantity handler requirements under the Universal Waste Rule . Other requirements (see 62-737.400(3)(a)3.), including a $1,000 registration fee, apply to non-generator handler facilities and to transporter transfer facilities storing MCLs or MCDs off the transport vehicle, if either accumulates 2,000 kg or more of MCLs or 100 kg of MCDs at any one time. There is also an exemption from registration for transporters (see 62-737.400(3)(a)1.) collecting MCLs from generators of ten or less MCLs per month provided the transporter does not accumulate more than 400 lamps at any one time. The Department maintains a list of registered handlers of mercury containing lamps and devices.

Photo: A drum-top lamp crusher with a mercury vapor recovery system. Operator should use appropriate personal protective equipment.

*The Department has received and is reviewing and researching additional information concerning the use of drumtop crushing equipment. The following information on the use of drumtop crushing equipment will be updated as appropriate based upon the results of this review.*

Drum-top lamp crushing equipment is used to reduce the volume of mercury-containing lamps (usually fluorescent lamps). While this may reduce storage space and transportation costs, these savings may be outweighed by employee safety problems, possible uncontrolled mercury emissions and higher recycling costs. Crushing poses employee health and environmental risks if mercury vapors are released during crushing operations, especially if crushing operations are performed in a small, closed, unventilated room. Since mercury is tasteless, odorless and colorless, the release of mercury vapor may not be noticed unless a portable mercury analyzer is used. Mercury may adhere to the drum, the container, or the metal end caps causing mercury contamination and increased costs for recycling or disposal especially under humid conditions or longer storage times. Because of these potential problems, the Department strongly recommends a thorough and ongoing evaluation of drumtop crusher worker safety.

However, use of this equipment by the generator of the lamps (as distinguished from another company that is hired to crush a generator’s lamps) is allowed as long as

• the lamps are destined for recycling;
• the crushed lamps immediately enter the final accumulation container from the drum-top crushing equipment; and
• crushing is done in compliance with the 4 requirements specified in paragraph 62-737.400(6)(b), F.A.C.

Another company that is hired by the generator is generally not allowed to use drum-top crushing equipment to crush a generator’s lamps under this regulation. Non-generator facilities need to be permitted as hazardous waste facilities if they are installing volume reduction equipment for the purpose of crushing hazardous waste mercury-containing lamps. Please contact the Department for additional guidance.

In mid-2002 and on more than one occasion, the Department had been advised that some prospective Florida users were under the impression that the “glass” resulting from the crushing of lamps with one of these devices can be disposed in a solid waste landfill. As a precaution, letters were written to all known manufacturers of drum-top crushing equipment (Company #1, Company #2, Company #3) to explain that Florida regulations governing the use of such equipment for crushing fluorescent lamps do not allow disposal of the crushed lamps in any Florida landfill. These manufacturers were advised to make sure their sales representatives conveyed the correct information on Florida regulations to potential buyers of their equipment.

Photo: When opening the drum or changing the drum liner, the Department recommends a respirator with mercury filters to protect the worker from exposure to mercury vapor.

In addition, this Chapter contains a rule to encourage the implementation of reverse distribution programs whereby manufacturers and distributors, including corporations or government agencies, register with the Department and provide for the collection and proper management of their MCLs or MCDs from their subsidiary facilities in accordance with this Chapter’s provisions. Only the sponsor of a reverse distribution program is required to register with the Department. All participating transporters and handler facilities that are listed in the reverse distribution program and that are not conducting other MCL or MCD transport or handler activities are not required to register with the Department. This rule has been used by one large corporation in Florida already to ease the management of MCLs at its subsidiary facilities. In addition, a trade association made up of mercury thermostat manufacturers is operating a reverse distribution program for mercury thermostats under these provisions.

Finally, the issue of properly managing light ballasts has come up as a result of the regulation on MCLs. In Florida any PCB wastes containing greater than 50 parts per million of PCBs is prohibited from disposal at MSW disposal facilities per Rule 62-701.300(5), F.A.C. (pdf). The management of PCB-containing and other light ballasts is further addressed on the second page of the fact sheet for Managing Spent Fluorescent and High Intensity Discharge (HID) Lamps (pdf). The EPA give guidance on the management of lighting ballasts in the LIGHTING WASTE DISPOSAL - Lighting Upgrade Manual.

Photo: A fluorescent lighting ballast which contains PCBs (polychlorinated biphenyls). Unless the ballast is stamped or labeled “No PCBs,” assume that it contains PCBs.