Sort of a RAIN

There’s a good chance that there’s a corner of a closet in your facility where you’re keeping the old fluorescent bulbs because no one knows what to do with them. Would a $45,000 fine from the EPA make you think that tracking these bulbs might be worth adding this to the retention schedule.

The phosphor powder found inside the fluorescent lamp tubes contains mercury. That means if you are in a non-household environment, you are legally required to protect public health and the environment from the hazards of these lamps.

To ensure proper handling of all type of hazardous waste the EPA created the Resource Conservation and Recovery Act (RCRA), which governs treatment, storage, and disposal. (Did anyone know that we could be fined for keeping the old bulbs around???  Are you setting a retention schedule for this?) 

The EPA cited a Maryland company for RCRA violations involving hazardous waste stored at their facility, including fluorescent bulbs.  These violations could have been totally unintentional, and it’s possible employees weren't aware that their method of storage for these materials was in violation of the law. Should you be adding this to your records schedule? 

You can protect yourself by being aware of RCRA requirements. Old fluorescent lamps must be stored in a structurally sound container to prevent breakage, or prevent leakage for lamps that are broken. These containers must be appropriately labeled. You must also track the length of time these bulbs accumulate to ensure that they are stored on-site for no more than one year. 

I read about this in a Press Release by  e-End and it surprised me.  This firm does recycling of electronics and now fluorescent bulbs and such. ( e-End is qualified to handle all your old lamps — including fluorescent, LED, high-pressure sodium and mercury vapor. )  It seems that  RM’s might inquire how to keep your business RCRA compliant.  I hope e-End doesn’t mind me posting this but it seems there are so many new things to worry about with recycling copiers, computers, printers due to information and toxic stuff. 

To learn more about proper bulb disposal under the RCRA, visit the EPA's website at:
http://www.epa.gov/osw/hazard/wastetypes/universal/lamps/faqs.htm

Ironically the 300 million of us who install these bulbs in our home have no requirement to handle these bulbs with care. Now we can visit this web site.  Or call those guys at e-End  (www.eendusa.com if you know you have a problem or people like them.) The EPA uses that “Ignorance of the law is no excuse!” when they fine you. Mercury is bad stuff.  They should never allowed that chemical to be used in something as common as light bulbs and then failed to educate people.  I see them sticking out of dumpsters in city areas all the time.

Tracking bulbs in through purchasing and out through facilities should be an issue now.


Hugh Smith
FIRELOCK Fireproof Modular Vaults
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(610)  756-4440    Fax (610)  756-4134
WWW.FIRELOCK.COM

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