The City of Yonkers, New York, under a December 21. 2010 Consent Agreement (“Agreement”) with the United States Environmental Protection Agency (“EPA”), has initiated a recycling program to properly handle its residents’ spent fluorescent light bulbs.
An EPA inspection of various Yonkers buildings in 2008 led to a City citation for violating the Resource Conservation and Recovery Act (“RCRA”), which governs the storage, treatment, and disposal of hazardous waste. Under RCRA, mercury-containing bulbs, such as fluorescent bulbs, must be handled as hazardous waste and, therefore, must be disposed of in a special licensed facility. Alternatively, if the bulbs are properly recycled they can be handled under universal waste rules, which greatly simplifies the accounting of their disposal and lifts other federal requirements.
Under the Code of Federal Regulations, a Small Quantity Universal Waste Handler accumulates less than 5,000kg of universal waste on site at any one time whereas a Large Quantity Universal Waste Handler accumulates 5,000kg of universal waste or more on site at any one time. 5,000kg is roughly the equivalent of 18,000 4’ linear T12 fluorescent bulbs or 27,000 4’ linear T8 fluorescent bulbs. The City of Yonkers is defined under the Agreement as a Small Quantity Generator, that is, a generator of less than 1,000kg of universal waste per month. This is roughly the equivalent of 3,600 4’ T12 fluorescent bulbs or 5,400 4’ linear T8 fluorescent bulbs.
Fluorescent light bulbs are encouraged by EPA because they are more energy efficient than incandescent bulbs thereby saving energy and reducing greenhouse gas emissions. However, they contain mercury which, if released, can cause a variety of health problems including damage to the nervous system. By instituting this recycling program, Yonkers will create significant health benefits to its residents.
Under the Agreement, Yonkers will begin collecting fluorescent bulbs, light ballasts and electronic waste from its residents at the City Recycling Center at 735 Saw Mill River Road, Yonkers, New York. According to the EPA, Yonkers has been compliant with the enforcement Agreement.
Universal Waste Handlers as well as generators should take caution from EPA’s action against the City of Yonkers. In addition to requiring the implementation of this disposal program and the associated costs, Yonkers was assessed a fine and a rigorous penalty schedule was established in the event it does not timely comply with the requirements under the Agreement. Based on its success with the City of Yonkers, EPA may be inclined to seek similar remedies against Universal Waste Handlers, both Small Quantity and Large Quantity.
For more information on the proper handling of fluorescent light bulbs visit EPA’s website.