The crushing of spent mercury-containing lamps falls within the definition of treatment in §260.10 (64 FR 36466, 35477; July 6, 1999). EPA does not believe that universal waste handlers should treat universal wastes, therefore, universal waste handlers are prohibited from treating universal waste except by responding to releases as provided in §§273.17 and 273.37 (§§273.11(b) and 273.31(b)). The prohibition against treatment includes a prohibition against crushing lamps due to a concern for the uncontrolled crushing of lamps and the potential mercury emissions. EPA is concerned that uncontrolled crushing of universal waste lamps in containers meeting only the general performance standards of the universal waste rule would not sufficiently protect human health and the environment. The prevention of mercury emissions during collection and transportation was a reason EPA included mercury lamps in the universal waste program. However, some state universal waste programs may allow lamp crushing under regulatory requirements designed to control emissions of hazardous constituents, particularly mercury (64 FR 36466, 35478; July 6, 1999).
The hazardous waste lamp rule (64 FR 36466; July 6, 1999) is available at the following URL: http://www.epa.gov/epawaste/hazard/wastetypes/universal/laws.htm
May universal waste handlers crush spent mercury-containing lamps on site?
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