EPA adds Manifesting Fees to Processing Costs

TerraCycle discusses the EPA’s updated manifesting fees going into effect September 1, 2018

EPA Logo
EPA Logo

In an effort to encourage all hazardous waste receiving facilities to adopt fully electronic manifesting, the EPA has changed the fee structure for Manifest User Fees.  Effective September 1, 2018 through September 30, 2019, hazardous waste receiving facilities will be charged based on a scale that rewards them for adopting the EPA’s fully-integrated, electronic system.  The agency will continue to accept paper manifesting, but at a higher fee.  Fluorescent lamp waste generators and other hazardous waste generators can expect to see an increase in their recycling cost as processors pass the new expense on to their customers. 

TerraCycle Regulated Waste is aware of the new fees and is working to limit the impact on responsible recyclers.  Contact your TerraCycle Regulated Waste representative directly for more information or questions.  

Household Mercury can be a Danger to Many Families

fluorescent bulb waste
Properly dispose of old lamps to prevent breakage
Compact fluorescent bulbs are the one of most inexpensive and environmentally-sound lighting options for consumers. Fluorescent bulbs are more efficient than traditional, incandescent light bulbs because they utilize less energy and last longer than comparable incandescents. While LED bulbs have decreased in price, making them a more viable option for homeowners (certain companies such as G.E. are phasing out of the fluorescent bulb business entirely), there are still millions of fluorescent bulbs in homes world-wide. The question becomes: once these bulbs burn out, what are you supposed to do with them?

The problem with fluorescent bulbs is that they contain mercury. If fluorescent bulbs are thrown in the trash they are likely to break, which is a big issue because each bulb contains at least 4 mg of mercury. This doesn’t seem so scary when you consider that a household thermometer contains 500 mg of mercury, but to put it in perspective– it is enough to contaminate two Olympic-size swimming pools.  That is why mercury can be harmful to the environment if it enters a landfill.  When the bulbs break in the natural compacting of waste on a landfill, the mercury has the opportunity to leach into the water supply.

And while it is very important to protect the environment from mercury contamination, there is danger to beware of in your own home as well. If the bulb breaks, the mercury is released as a vapor that can be inhaled and as a fine powder or liquid droplets that can settle into carpets.  If not properly cleaned up, this mercury can pose a serious health threat to children and pets.  A lot of people are aware of this danger but don’t know what to do with the bulbs, aside from not throwing them in the garbage.

So, unsure what their options are, people collect their bulbs, letting them pile up until a convenient option arises. In fact, the EPA gives the advice “Rather than disposing of them with household trash, simply store expended CFLs until easy recycling is available in your area”. Well meaning as this advice seems, these bulbs should be disposed of as quickly as possible.

While used fluorescent lamps are sitting in a box in your garage or shed, the mercury within them is still contained.  When the glass tube is intact, the mercury can be kept within them indefinitely.  The probability of you, your children or your pet accidentally coming into contact this box increases the longer the bulbs pile up.  More time sitting in storage equals greater chance of accidental breakage.  Not to mention that many of us store paints, solvents and automotive chemicals in our utility areas.  Broken bulbs could mix with other such household hazardous items in a contained area – your shed could be brewing all sorts of toxic concoctions.

Going the extra step to recycle your fluorescent bulbs correctly doesn’t have to be a huge pain. There are several convenient options available to dispose of fluorescent bulbs safely.

  • Drop off at a household hazardous waste collection area

Most municipalities and towns have designated drop-off centers where you can safely dispose of your bulbs and other household hazardous waste. And in most town this service is free or carries a very modest administrative fee. Neighbors can join forces and bring all their fluorescent bulbs over at once and split the cost if it seems too much. Your local solid waste department can provide the details on their website or by phone.

Earth 911 also provides information on recycling programs and other community programs to benefit the environment.   If you type in your zip code the site will tell you where hazardous waste drop-off areas are located and the collection schedule, if that is available in your town.


  • Drop off at a Home Depot or other hardware store

If the hazardous waste drop off in your town is too far, Home Depot offers recycling programs for CFLs.  Other hardware stores offer recycling for fluorescent lamps, batteries and used paint on a regional basis, as well.  Check with your local retailer for details.

Another option is to purchase an EasyPak CFL Recycling Box from TerraCycle. These are inexpensive way to keep your home safe from the potential  threat of mercury. The boxes are specially designed to meet crush-resistant standards and have an integrated lining that captures mercury, should a lamp break inside the box.   Once you buy an EasyPak, there is a prepaid return label included so you can send your fluorescent bulbs safely back to TerraCycle for recycling.

This is a great option for getting rid of fluorescent bulbs safely in your own house, or even incorporating your community into the cause by having a designated spot to put bulbs for several households. By being more aware of the potential harm fluorescent light bulbs can cause, we can all keep our homes and communities safer while saving energy and protecting the environment.

Colorado State Prison System Uses BulbEater to Recycle Lamps

Correctional facilities face a number of unique challenges unheard of in other large, multiuse properties.  Combining living space, industrial operations and heightened security needs puts lighting at a priority.  Burned-out fluorescent lamps are not just a nuisance but can be a life-threatening situation.  For that reason, correctional facility managers must stay ahead of lamp replacement.  Most will seek to replace lamps before the end of their practical lifecycle which can often result in the need to dispose of hundreds, if not thousands of lamps at a time.

The EPA requires that correctional facilities recycle all spent mercury-containing lamps.  With linear and U-bend fluorescent lamps in such great numbers at these facilities, it is important to understand how to remain compliant.  Failure to do so can result in violations and fines that could have been easily prevented.

“Correctional facilities are no different than any other non-residential fluorescent lamp user to the EPA,” explains Joe Day, Account Manager at TerraCycle Regulated Waste.  “The rules governing hazardous waste apply, just the same.  They must recycle all fluorescent lamps, as well as any other mercury-containing lamps.”

A facility will fall into one of three waste generator categories, based on the amount of total hazardous waste they generate per month.

  • Very Small Quantity Generators (VSQGs) generate 100 kilograms or less per month of hazardous waste or one kilogram or less per month of acutely hazardous waste.
  • Small Quantity Generators (SQGs) generate more than 100 kilograms, but less than 1,000 kilograms of hazardous waste per month.
  • Large Quantity Generators (LQGs) generate 1,000 kilograms per month or more of hazardous waste or more than one kilogram per month of acutely hazardous waste.

The materials that are considered ‘hazardous waste’ include fluorescent and mercury-containing lamps, paint, insecticides and fertilizers, batteries, and cleaning supplies.  Keeping these waste products in storage, on-site until pick up by a registered hazardous waste hauler is not uncommon, but must follow the federal guidelines.

For fluorescent lamps, that means storing in a way that prevents accidental breakage of the lamps and potential contamination by the release of the mercury contained in the lamps.  To achieve this, some larger facilities use a drum-top lamp crusher like the Bulb Eater 3®.  A lamp crusher is a device that crushes the glass tube of the fluorescent lamp in a vacuum system that captures the mercury before it can be released into the atmosphere.  The crushing of the lamps compacts the waste volume by as much as 80%, making storage much more manageable.  With a capacity of approximately 1350 T8 fluorescent lamps per 55-gallon steel drum, storage space is well controlled by lamp crushing.

BulbEater 3 with U-Bend/CFL chute attachment

“Our combined efforts will truly make a difference not only with complying with local regulations, but also with being good stewards for the environment.”  States Dave Bechtle, Colorado Department of Corrections.  Colorado purchased Bulb Eater 3® units in 2017 for all nine state penitentiaries.

For specialty lighting, like safety-sealed fluorescent lamps, drum-top bulb crushing is not appropriate.  To properly dispose of these types of lamps, a facility can purchase EasyPak self-sealing containers or PalletPak containers for larger quantities.  It is very important to note that the EPA requires that any spent lamps being stored at a facility until shipping is able to be efficiently facilitated must be kept in containers that prevent the accidental breakage and can capture any mercury, should there be accidental release.  Corrugated boxes or fiber drums used as storage must either be lined with plastic or contain an integrated seal, like EasyPak boxes.

Drum-top crushing is not approved in all states, so it is important to speak to a lamp recycling specialist to determine the best practices in your region.  Understanding how many lamps per month or year a facility is generating will make it easy to create a recycling plan that fulfills EPA compliance standards and meets the needs of the property—both in safety and security.

Illegal disposal of fluorescent lamps can be a costly mistake

Fluorescent lamps
Fluorescent lamps illegally dumped

In 1976, the federal government passed the Resource Conservation and Recovery Act (RCRA).  The act has been amended several times, giving the EPA definitions and guidelines that provide them the ability to take action against facilities and businesses that fail to meet regulations for the health and safety of people and the environment.  An important subsection of the RCRA regulations addresses the handling of waste, and more specifically, regulated waste.

According to EPA records, over the last two years hundreds of companies and facilities have been fined for failing to comply with the EPA’s rules on the handling of universal waste.  Fines typically range from $3,000 to $9,000, but some have been recorded as high as tens of thousands for substantial violators. A check of the inspection records for several states and regions indicates that cited violators were not limited to large universal waste producers or any specific industry.  From small, public schools to major corporations, any facility that utilizes fluorescent lighting can find themselves in trouble if their universal waste is not properly managed.

According to the Cornell Law School, the EPA has the authority to inspect and levy fines for failure to properly handle hazardous waste under Code of Federal Regulations (40 CFR Part 273, Subpart A – General).  Fluorescent lamps, batteries, pesticides and mercury-containing equipment are specifically defined as “Universal Waste” by the EPA, and are subject to heightened scrutiny because of the potential danger to the environment when not properly disposed of or recycled.

For example according to the EPA’s Enforcement and Compliance History Online (ECHO) website, two universities in the Upstate region of South Carolina were recently fined in excess of $12,000 combined for RCRA violations.  A retail chain store in Kentucky was fined $3,750 by their state DEP when the federal EPA recorded the violation.  Additionally, the management team at that Kentucky store was required to attend an Enforcement Conference with the EPA.  But perhaps the most notable financial penalty for improper disposal of hazardous and universal waste in the last year is the $27.84 Million Home Depot agreed to pay to California.

Fortunately, fines and citations are easily preventable, if you work with a registered, reputable hazardous waste handler.  A certified universal waste recycler can provide facility management with a clear record of their waste’s proper handling and will provide a Certificate of Recycling Compliance for future reference.  Having an understanding of your recycler’s downstream procedures can be the difference between an uneventful inspection and a disciplinary action.

The most recent federal budget slashes the EPA funding by 23%, causing a large reduction in staff.  This might mean more pressure on inspectors to find actionable violations.  With less direct budgetary funding, it could also mean the EPA will be looking to increase the financial impact of fines and violations to help defray the cost of other important programs.  It becomes all the more important for a business or facility to have the necessary documentation of compliance.

TerraCycle EasyPak fluorescent lamp recycling box


Depending on the amount of universal waste a facility is producing, there are good options for EPA-compliance.  A smaller facility that isn’t producing much hazardous waste, say 100 kilograms (220 lbs.) or less a month, is considered a very small quantity generator (VSQG).  Setting up a box and store program for their fluorescent lamps, like an EasyPakTM box, will most likely be enough to remain compliant.

A mid-sized or larger facility could fall into either the small quantity generator (SQG) or large quantity generator (LQG) category.  Depending on a number of factors, such as the number of waste lamps generated each month and available storage space, a facility might consider a drum-top bulb crusher like the BulbEater3L® for their compliance needs (check local regulations for approval).  For very large quantities of waste lamps, a facility can set up a bulk pick-up to clear their property of potentially hazardous lamps.

The key is to get ahead of the violations before the EPA comes to inspect a facility.  No manager wants to have to spend money on a fine, plus find themselves under greater scrutiny when a situation is easily preventable.  The solutions cost a fraction of the fines the EPA can levy and prevent the embarrassment of citation.

TerraCycle Regulated Waste Announces Addition of Medwaste Recycling

TRENTON, N.J., (August 8, 2018) – Medical waste (in the form of used sharps) has become the latest difficult-to-recycle recycling program at TerraCycle, as the company continues to add waste streams to its product list.  Utilizing EPA-approved sterilization technology, the company has developed a system that provides contaminant exposure protection and high-efficiency material recovery.

The regulated waste division of TerraCycle has created a sharps container and shipping carton system available in a variety of sizes.  The puncture-resistant sharps containers are approved for use by both UPS and the US Postal Service when shipped within the corresponding carton.  Sizes range from a 1.4-quart container for home use to a commercial 28-gallon system.  Like its Zero Waste Box programs, the medwaste boxes are postage-prepaid—the customer simply fills the sharps container, boxes it and calls UPS or USPS for a pickup.

Recycle the materials from used sharps safely and securely.

“This is an exciting addition to the regulated waste offerings at TerraCycle,” explains Bobby Farris, General Manager of TerraCycle Regulated Waste, “We’re providing a real alternative to incineration for medwaste customers who want to see the materials recycled.”

According to the World Health Organization, as much as 90% of all medical waste is incinerated, even though only 15% of it is actually considered biologically hazardous.  Originally, it was thought that destroying medical waste through incineration destroyed the known pathogens, but more recent science suggests the process exposes the environment to potential contaminants in the form of microscopic particulate emitted in the process exhaust.  Furthermore, the resulting ash and byproducts are not easily recouped for recycling or reuse and are often landfilled.

To protect the population and environment, the EPA has begun to promote the use of “Alternative Treatment and Disposal Technologies for Medical Waste.”   By utilizing commercial steam disinfection (autoclave) of medical waste and then processing the sharps to separate metals, plastics and glass, TerraCycle is able to reclaim valuable materials and divert waste from the landfill.  The system provides better, more measurable elimination of biohazards and lessens the linear use of resources.