If you generate used or spent lamps at your facility and wish to crush them as a means to reduce the volume and related transportation and disposal costs, you must consider the applicable regulations of the Resource Conservation and Recovery Act as enforced by both the USEPA and your state.  In an earlier article I summarize the options available to a facility that generates spent or used lamps and wishes to consider crushing them prior to off-site disposal.

If you intend to crush lamps with a Drum Top Crusher (DTC), either as a form of hazardous waste treatment or as a universal waste management activity allowed by your state, you must also consider OSHA’s regulations regarding employee exposure to airborne mercury.  A study published by USEPA in August of 2006 reported on the mercury emissions from four different DTC’s, the study’s conclusions:

• Measurable concentrations of mercury were detected in the air, but all three of the devices usually maintained mercury levels below the OSHA permissible exposure level (PEL) within the structure and in the operator breathing zone.
• DTC devices must be operated optimally to achieve low exposures.  Emissions were higher with even minor mistakes in DTC assembly or operation.  An external mercury monitor and alarm were usually needed to determine when mercury was not being contained.
• The risk of mercury exposure is increased when full drums are being replaced with empty ones and the full drums are being fitted with shipping lids.
• Performance of DTC’s may change over the lifetime of the device.

If crushing your lamps makes financial sense for you and you wish to pursue it further, I recommend you review the USEPA guidance document:  Fluorescent Lamp Recycling (EPA530-R-09-001) as it contains helpful information regarding the use of DTC’s.

While initially attractive, in my opinion the crushing of lamps by most facilities in most states is not worth the added regulatory burden.  However, this is something you must decide for yourself.  I hope the information presented in this article will assist you in your decision.  Please don’t hesitate to contact me with any questions about Universal Waste, hazardous waste, or the transportation of hazardous materials.