cathode ray tubes

USEPA Revises Regulations Regarding the Export of CRTs

On June 18, 2014 the USEPA made revisions to its regulations regarding the export of Cathode Ray Tubes (CRTs).  Those persons involved in the export of CRTs for reuse or recycling – eg. electronic collectors and recyclers – must review these revised regulations to ensure compliance.

CRTs may be a toxic hazardous waste for lead

Many older TVs and monitors contain CRTs that are a toxic hazardous waste for lead

A cathode ray tube (CRT) is the glass video display component of an electronic device (usually a computer or television monitor). CRT funnel glass generally contains high enough concentrations of lead that the glass is regulated as hazardous waste when disposed.

In an earlier revision (2006) to the regulations of the Resource Conservation and Recovery Act (RCRA) the USEPA created an exclusion from regulation as a solid waste for CRTs if certain conditions are met (review the RCRA Exclusion From Regulation for CRTs at 40 CFR 261.4(a)(22)).  This June 18, 2014 publication is a revision to the export requirements for those regulations.

Specifically, the rule:

(1) Adds a definition of “CRT exporter” to eliminate potential confusion over who is responsible for fulfilling CRT exporter duties, including submitting the export notices.
(2) Requires information on all interim and final destinations for CRTs exported for recycling to provide more complete information to receiving countries.
(3) Requires annual reports from exporters of used CRTs sent for recycling to provide EPA more accurate information on the total quantity of CRTs exported for recycling during a calendar year.
(4) Replaces the one-time notice for used CRTs exported for reuse with an expanded, periodic notice to improve tracking, and thus better management, of these CRTs.
(5) Requires that normal business records maintained by exporters of used CRTs for reuse be translated into English upon request.

Refer to the USEPA Webpage for Cathode Ray Tube (CRT) Regulations for more information.

Use caution when selecting your CRT recycler:

Cathode Ray Tube Recycler Fined by AZ DEQ

Criminal Penalties for CRT Recycler

Criminal Penalties for Michigan CRT Recycler 

Without the use of the above referenced RCRA exclusion, your CRTs may be required to be managed as a hazardous waste.  The knowledge of this exclusion – and others, see below – is critical for anyone who generates a hazardous waste or – as in the case of CRTs – generates something that could be a hazardous waste.

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Please contact me for a free RCRA Training consultation or any questions you may have about the hazardous waste regulations of the USEPA.

Cathode Ray Tube Recycling Facility Fined by Arizona DEQ

The Bullet:

Dlubak Glass, based in Blairsville, PA will pay a fine of $120,000 to the Arizona Department of Environmental Quality for violations of the Resource Conservation and Recovery Act (RCRA) regulations.

Read the ADEQ press release:  Arizona DEQ fines glass recycler

ADEQ in Arizona

The ADEQ regulates hazardous waste in Arizona

 Who:

Dlubak Glass, based in Blairsville, PA operates a cathode ray tube recycling facility in Yuma, AZ.  Violations were found and civil penalty assessed by the Arizona Department of Environmental Quality.

What:

“During an inspection ADEQ inspectors found broken CRT glass throughout the five-acre facility and stained soil in several locations. The stained soil also was observed extending about 20 feet into an orchard adjoining the Dlubak property. Samples taken on the property found levels of lead as much as 75 times more than the maximum federal and state exceedance level of five milligrams per liter.

In addition, the broken glass was stored in open, unlabeled cardboard containers and washing activities were conducted on an outdoor concrete pad. State regulations require that all CRT storage and processing activities be conducted within a building with a roof, floor and walls.”

Dlubak Glass was assessed a penalty of $120,000 for the above violations.

Where:

The Dlubak Glass facility where the violations occurred is located at 19538 S. Avenue 1 East in Yuma, AZ.  Dlubak Glass has other plants located in Pennsylvania, Ohio, Kentucky,Texas, and Oklahoma.

When:

Date of initial inspection was not indicated in the ADEQ press release.  The date the decision was announced was March 7, 2014.

Why:

“Their unlawful management of hazardous waste put employees and the environment at risk,” said ADEQ Director Henry Darwin. “But they hired environmental consultants, changed their operating procedures and did the soil cleanup in reaching a resolution in the case.”

Cathode ray tubes are found in many older computer monitors and televisions.  If recycled properly they are excluded from the definition of a solid waste and are therefore subject to little or no regulation.  However, the exclusion hinges on proper recycling of the CRTs which was not the case here.  If improperly managed during recycling CRTs may release lead and other harmful pollutants into the environment.

How:

As a state with an authorized hazardous waste program, the Arizona DEQ has the authority to inspect, investigate, and assess fines of facility’s found to be in violation of state regulations.  The state regulations of the ADEQ are designed to protect the health and safety of the environment and people of Arizona.

Conclusion:
If you generate a hazardous waste it is important that you conduct an audit of the facilities that receive your waste for treatment (eg. recycling) storage or disposal.  It is especially important if you are using a conditional exclusion from regulation for your waste that depends upon its proper recycling by the TSDF.

Not sure of your hazardous waste generator status?

Take this short survey

You must also provide initial (within 90 days) and annual training for all facility personnel if you are an LQG of hazardous waste.  Confused?  Call me for a free consultation on the regulations of the USEPA, ADEQ or the USDOT.