Storage Standards ■ Used lamps may be stored in drums, used mercury-containing lamps — no land-filling of any materials. Recycling Levels Generator The amount of lamps estimated to be re-turned for proper management hovers around 20-30 percent of all lamps. While businesses do better than house-holds in this regard, four out of five lamps re-moved from service in businesses and man-aged properties are not properly managed. As lamps cycle from old technologies to more efficient and longer-lived technologies, the amount of resources put into them will increase as well. These resources will need proper man-agement and should be viewed as finite and boxes or the cartons they originally came in. ■ The packaging must remain closed unless lamps are being added or removed. ■ Used lamps must be clearly labeled as: “Universal Waste Lamps” or “Waste Lamps” or “Used Lamps.” ■ All broken lamps must be stored in a sealed container separate from intact lamps. in need of proper management. The days of out of sight — out of mind are no longer. Managers and professionals need to en-sure that all lamps receive proper treatment by having them managed properly through a lighting waste handler to ensure their proper management. Eric Uram has served as a board member on the Association of Lighting and Mercury Recyclers representing the company MRT Systems AB International as their North American sales and service representative. He serves on the Sierra Club’s National Toxics Committee and is the executive director for SafeMinds, a non-profit dedicated to ending the crisis of preventable neu-rological impacts and disorders in children. Quantity Generator (CESQG). This is inclusive of all hazardous waste generated in a calendar month. Under federal regulations, this type of generator is exempt from the majority of hazardous waste regulations. However, CESQGs must ensure that their waste is sent to a permitted hazardous waste management facility, a permitted mu-nicipal or industrial solid waste facility or a recycling facility. Contact your state environmental regu-latory agency to see if your local municipal solid waste facility is permitted. While federal regulations allow some mer-cury-containing lamps to be landfilled, cer-tain states may prohibit this action. Many states apply the CESQG requirement in a more stringent manner than the federal government and in other states the CESQG requirements are not applicable at all. For example, all mercury-containing wastes are banned from landfills in the states of Vermont and Minnesota regardless of whether they are disposed of by CESQGs or households. California enacted a similar ban in Febru-ary 2006. New Hampshire does not have a CESQG exemption in its hazardous waste regulations. Therefore, you are strongly encouraged to know what is required in your state. For more information specific to your state, please contact your state or local envi-ronmental regulatory agency. Whether your state regulates more strin-gently or not, all states and the EPA encour-age the proper and complete recycling of Shifting Technology Fluorescent Powder While LFL and CFL technology continues to advance; newer, more efficient lighting tech-nologies are under development. Improvements in current LFL/CFL technology includes improving the fluorescent pow-ders used in lighting. These increase efficiency and operational characteristics making them more accept-able in all applications. These powders contain several Rare Earth Elements (REEs). These REEs have increased in value both strategically — as a need for military applica-tions and in use by our federal government — as well as a resource for other lighting and display applications built by U.S. industry. Making recycling a common practice helps ensure strategic supplies of these REEs will remain available for new products. Hg Content Lamp dosing technologies and methods have greatly improved. This allows for greater precision in the amounts of mercury introduced into lamps allowing manufacturers to ensure more uniform production and overall characteristics. Lamp recyclers continue to keep a closed-loop on the mercury needed for lamps pro-duced domestically as well as finding uses for the glass and aluminum from spent lamps. The emerging market for REEs improves the market for recycling, but this has not yet transferred into profit for recyclers. As a result, the ability to recycle lamps requires some cost assistance. At least for the time being, or until a solution is put into place requiring no-fee recycling as we are seeing in some states — including Maine and Washington — building manag-ers should look for recycling options. Light-emitting Diodes (LEDs) LEDs hold great promise once a few issues are resolved. Content issues still indicated some levels of toxic elements in production of LEDs cur-rently found in the marketplace. Problems associated with the use of lead solder as well as small amounts of some toxic metals internal to the LED are being addressed by the lighting industry. CM www.cmmonline.com 39
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