TerraCycle discusses the EPA’s updated manifesting fees going into effect September 1, 2018
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.
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.
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.
Air Cycle Corporation is pleased to announce that we have entered into a distribution agreement with JARSHIRE Waste and Recycling located in Slough, UK to represent us in the United Kingdom.
In addition to providing broad waste services in the UK, they have developed a mobile Material Recycling Facility (MRF) that is typically deployed on drilling rigs. Our Bulb Eater® technology will be seamlessly incorporated into their existing MRF concept, which also typically includes bailing equipment, compactors and other volume reduction technology.
“JARSHIRE had tried a few other bulb crushers supplied in the past, but we were then recommended to use Air Cycle from one of our customers who had bought other equipment from us in the past, and they said they had also used Air Cycle and other suppliers of Bulb Eaters and that Air Cycle’s unit was the best on the market for quality, price and after sales. We are delighted to be representing Air Cycle.” – Nick Jobson: JARSHIRE
Why include The Bulb Eater®?
The Bulb Eater® crushes spent fluorescent lamps of any length into 100% recyclable material and captures over 99.99% of the vapors released. The system, which is mounted onto a 55-gallon container, can hold up to 1359 4-foot fluorescent lamps.
The Bulb Eater® will help your company:
Eliminate storage hassles – Reduce your needed storage space for lamps, The Bulb Eater® lamp crusher crushes all length lamps.
Reduce handling – Save roughly 20 hours of labor per 1000 lamps by crushing rather than boxing the lamps!
Create a safer work environment – The 0.001% emission rate from the Bulb Eater® lamp crushing system provides for less mercury vapor emission.
Cut costs – By pre-crushing the lamps, facilities are able to save money on their lamp recycling costs.
“We’ve had much success simplifying our recycling program using the Bulb Eater 3 we especially like the new features including the ability to crush our ever-increasing Compact Fluorescent lamps. Great Value.” – Brandon Goulet, Markley Group
Air Cycle is committed to improving the efficiencies of your recycling programs. Save time, money, and valuable storage space with our services. If you are in the UK and are interested in the services provided by Air Cycle, contact us today! For more information on our other international distributing, click here.