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Bulb Eater® Manual
Mercury Information
Controlled Crushing Regulations
Crushing lamps with the Bulb Eater
®
is considered “controlled crushing” and is regulated under both federal
and state hazardous and universal waste regulations. The federal universal waste regulations do not authorize
on-site crushing of fluorescent lamps but do allow the states to write rules that will permit crushing on-site. The
States of Colorado, Florida, Maryland, Montana, New Mexico, Tennessee, Texas, and Virginia have all passed
rules that allow persons to crush lamps on-site under the universal waste regulations.
In states that allow crushing and classify crushed lamps as universal wastes, persons can generally store
their waste lamps on-site for up to one year, can ship waste lamps off-site with a bill of lading rather than a
hazardous waste manifest, and need not include their lamps when calculating their hazardous waste totals.
Under state and federal hazardous waste regulations, controlled crushing is considered treatment. The
hazardous waste rules typically require a person who treats wastes to obtain a permit. Federal and most state
hazardous
waste rules, however, exempt from the permit requirement persons who treat their wastes “within a
drum, tank, or container.” (See 40 CFR 262.34).
Air Cycle Corporation believes The Bulb Eater
®
systems fall squarely within this exemption and many states
have acknowledged in letters to Air Cycle Corporation that the accumulation tank exemption applies to The
Bulb Eater
®
systems. You should be aware, however, that the States of California, Maine, Massachusetts
(SQG and LQG generators), Connecticut, Rhode Island, Missouri, Vermont, New Hampshire, West Virginia,
Minnesota, Pennsylvania, Michigan, and New Jersey have more narrow exemptions to the permitting
requirements (permits are often more easily obtained in Michigan and New Jersey). It is Air Cycle’s
understanding that persons within the states not listed above as requiring a permit or as regulated under
universal waste regulations are authorized to crush lamps within general hazardous waste regulations. Air
Cycle Corporation suggests you contact representatives of those states before proceeding with on-site
crushing. Please note that regardless of whether the lamps are managed as universal or hazardous wastes,
you must properly dispose of the crushed lamps preferably by shipping the crushed lamps to a permitted
recycling facility.
Air Cycle Corporation will continue to work with state lawmakers and the Association of Lighting and Mercury
Recyclers to promote legislation, which will authorize persons to crush lamps under universal waste
regulations. Air Cycle Corporation and its customers know that persons are able to safely crush their lamps to
reduce volume, minimize handling, cut costs, and create a safer work environment by managing their crushed
lamps under either universal waste regulations or existing state hazardous waste regulations. For more
information on regulations in your state, please visit
www.aircycle.com/resources/state-regulations
.
Why is mercury an environmental concern?
Mercury is a metallic element that can accumulate in living tissue. In sufficient concentrations, mercury may
cause adverse health effects. Sources of mercury in the environment from human activity include coal-burning
power plants, batteries, and fluorescent and HID lamps.
Small amounts of mercury are a necessary component in fluorescent and HID lamps, but when a lamp is
broken, crushed, or dispensed in a landfill or incinerator, mercury may be released to the air, surface water, or
groundwater. Considering this, it is a good policy to keep the mercury in fluorescent and HID lamps out of the
solid waste stream by recycling.
