Mercury Lamp Drum-Top Crusher Study Frequent Questions1. What are drum-top crushers (DTCs)?
2. Why did we do the Mercury Lamp Drum-Top Crusher Study?
3. What does the Mercury Lamp Drum-Top Crusher Study show?
4. Should drum-top crushers (DTCs) be used in the management of fluorescent lamps?
5. Are drum-top crushers (DTCs) safe to use?
Drum-top crushers (DTCs) are devices that are designed to safely crush fluorescent lamps. DTCs fit on the top of a 55 gallon drum and crush the fluorescent lamps into the drum below. These devices are used to reduce the volume of waste lamps, so as to improve storage and handling and reduce shipping costs of waste lamps to make it easier to recycle them. They also are designed to prevent the release of mercury that is a key component of fluorescent lamps.
Hazardous waste lamps were added to the federal list of universal wastes on January 6, 2000. The preamble identifies lamp crushing as RCRA treatment and specifically prohibits the use of DTCs for management of fluorescent lamps as universal waste unless an equivalency determination is made. The purpose of the Study is to make information available to states and regions that could eventually be used to provide “a demonstration of equivalency to the federal prohibition [on treatment of universal waste without a permit]” (64 FR 36465).
This Study also demonstrated that during operation of the three DTCs that completed the Study, the operator was, at times, exposed to levels of mercury above the TLV and PEL values. Higher exposures typically occurred when a DTC had to be taken off of a drum because the drum was full. This procedure allowed the drum to be open to the room for several minutes.
The Mercury Lamp Drum-Top Crusher Study presents the findings of the DTC Device Study. EPA encourages states to review the Study carefully as they determine whether, and under what circumstances, to allow the use of DTCs.
Despite these advantages, the DTCs evaluated as part of this Study all released some mercury when used and so have the concern of creating new sources of mercury exposure. The DTC operator and any assistants handling lamps or working directly with the DTC are the most obvious new exposures. Less direct mercury exposures that could be created by DTC use include anyone working in or visiting buildings in which DTCs are used. The only way to eliminate these unnecessary indirect mercury exposures would be to keep the ventilation of the lamp crushing room completely separate from the general building ventilation system as is done at large-scale, industrial lamp recycling facilities.