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.
“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.