Lamp crushing is the intentional breaking of fluorescent and other mercury lamps for the purpose of volume reduction. Drum top crushers (DTC) reduce the physical volume of lamps but do not recover any mercury. Crushing is not recycling, but it can be a step in the process when the crushed material is further treated by a recycling process that includes retorting. Generators that choose to intentionally crush lamps must do so in accordance with all state regulations. Intentionally crushed lamps should be managed as hazardous waste and often require manifests and a more stringent chain of custody.
EverLights does not recommend the use of Drum Top Crushers. DTC can release mercury into the air and pose a health threat to the operators and building occupants if the crusher is not operating properly. An EPA study advises against the use of Drum Top Crushers and advises against their use in schools, hospitals, and others facilities with sensitive populations. For these reasons, Everlights supports the ALMR Drum Top Crushing Standards. [PDF ATTACHMENT] These units should also be registered with the state EPA for one location and should not be transported as a mobile treatment unit.
For companies who do choose to crush lamps, the following conditions should be followed for both small and large quantity handlers:
A) The lamps must be crushed in a closed system designed and operated in such a manner that any emission of mercury from the crushing system must not exceed 0.1 mg/m3 when measured on the basis of time weighted average over an eight-hour period;
B) The handler must provide notification of crushing activity to the Agency quarterly in a form as provided by the Agency. Such notification must include the following information:
i) Name and address of the handler;
ii) Estimated monthly amount of lamps crushed; and
iii) The technology employed for crushing, including any certification or testing data provided by the manufacturer of the crushing unit verifying that the crushing device achieves the emission controls required in subsection (d)(5)(A) of this Section;
C) The handler immediately transfers any material recovered from a spill or leak to a container that meets the requirements of 35 Ill. Adm. Code 722.134, and has available equipment necessary to comply with this requirement;
D) The handler ensures that the area in which the lamps are crushed is well-ventilated and monitored to ensure compliance with applicable OSHA exposure levels for mercury;
E) The handler ensures that employees crushing lamps are thoroughly familiar with proper waste mercury handling and emergency procedures, including transfer of mercury from containment devices to appropriate containers; and
F) The crushed lamps are stored in closed, non-leaking containers that are in good condition (e.g., no severe rusting, apparent structural defects, or deterioration), suitable to prevent releases during storage, handling, and transportation. Click for Info