FY2002 OSWER Innovation Pilot Results Fact Sheet
oEPA
Developins an Innovative Policy to
Facilitate the Use of Drum-Top Crushing
Devices for Mercury Containing Lamps
The Environmental Protection Agency's Office of Solid Waste and Emergency
Response initiated a series of innovative pilot projects to test ideas and
strategies for improved environmental and public health results. This series of
fact sheets highlights the innovative approaches, results, and environmental
and economic benefits from the pilot projects that may be replicated across
various sectors, industries, communities, and regions.
PROJECT DESCRIPTION/INNOVATION
EPA's Office of Solid Waste and Emergency Response awarded
an Innovation grant to EPA Region 3 to conduct an empirical
study evaluating the release of mercury emissions from drum-
top crushing (DTC) devices when processing fluorescent bulbs,
DTC devices are designed to fit on the top of a 55 gallon drum
in order to prevent the release of mercury vapors while crushing
the fluorescent lamps into the drum below. In partnership with
the states in Region 3, DTC device manufacturers, and the
Association of Lighting and Mercury Recyclers, EPA collected
data that helped frame policy discussions and develop awareness
and educational tools on the safe use of DTC devices for
recycling mercury-containing lamps, This project showcased an
innovative approach of addressing the challenge of promoting
mercury lamp recycling through its unique collaboration with
federal, state and industry partners,
BACKGROUND
The increasingly widespread use of energy-efficient, fluorescent
lamps has had tremendous environmental benefits. However,
mercury, a toxic chemical, is an essential component of
fluorescent lamps. When lamps are broken, whether during
storage, transport, disposal or crushing, a substantial portion
of the mercury in the lamp is released as mercury vapor. If
the mercury vapor is not controlled or contained, it could be
easily inhaled, which is a health hazard for exposed individuals.
Additionally, mercury released from broken lamps is persistent
in the environment, where it can be chemically transformed to
methyl mercury, which is more toxic than elemental mercury.
When lamps are disposed in a landfill, rather than recycled, a
substantial percentage of the lamps are broken and virtually
all of the mercury contained in the lamps is released into the
environment. This is a similar issue when lamps are broken
during collection, shipping or handling.
Lamps can be recycled either by sending whole, boxed lamps to
a recycier or by using a DTC device, These devices are used to
•	The DTC devices all released some mercury
emissions when used.
•	Use of a poorly designed device could result in
mercury exposures above regulatory standards.
•	The study results helped frame policy discussions
and develop awareness and educational tools on
the safe use of DTC devices for recycling mercury-
containing lamps.
reduce the volume of waste lamps so as to improve storage and
handling, and reduce shipping costs associated with fluorescent
lamp recycling, Each method of recycling has potential benefits
and draw-backs.
Recycling fluorescent lamps with DTC devices has been
inconsistently regulated due to the lack of a clear national
strategy for controlling the mercury emissions from these devices.
This project would generate the additional data needed to help
EPA develop an effective national policy and an educational
strategy on the safe use of DTC devices for recycling mercury-
containing lamps.
PROJECT SUMMARY
In 2002, EPA Region 3 partnered with the States of Delaware,
Maryland, Pennsylvania, Virginia, and West Virginia; DTC device
manufacturers; and the Association of Lighting and Mercury
Recyclers, to design and conduct the Mercury Lamp Drum-Top
Crusher Study, The objective was to evaluate the ability of
DTC devices to contain mercury released when lamps are
crushed and to prevent worker exposure to adverse levels of
airborne mercury.
The study examined the performance of three DTC devices
at separate commercial lamp recycling facilities over a five

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month period. Over the course of the study, the three devices
each crushed approximately 5,500 lamps inside constructed
enclosures under a variety of environmental and
operational conditions.
RESULTS
More than 200 air samples were collected and indicated
a release of mercury vapor from all DTC devices during
crushing operations. Operator exposure only remained below
the regulatory exposure limits when the DTC devices were
operated optimally. The study also demonstrated an increased
risk of mercury exposure when full drums were replaced with
empty ones, an operation inherent in the use of a DTC device.
Additionally, minor mistakes in DTC device assembly can
significantly affect its ability to capture mercury. For example,
a leak on one device notably raised mercury levels in the
operator's breathing zone and caused mercury concentrations
to exceed the regulatory exposure limits for the area sample
collected near the leak. It was also determined that mercury
vapor can exceed established levels even if the lamps being
crushed in the DTC device (i.e., low-mercury lamps) are not
identified as hazardous wastes.
The pilot study illustrated that the mercury released during
DTC device use would inevitably create some new mercury
exposure situations, primarily for DTC device operators and
anyone else handling lamps or working directly with the DTC
device. Appropriate administrative and engineering controls
are warranted to help control exposure to mercury during DTC
operation. If engineering controls are not feasible or inadequate
to control mercury exposures, the use of personal protective
equipment such as respiratory protection may be necessary.
Study results also demonstrated the importance of using a two-
person team to perform the drum changes in order to minimize
potential mercury releases and exposure potential.
The findings of the pilot study were later incorporated into the
Mercury Lamp Drum-Top Crusher Study published by EPA in
2006. This report provides information on mercury emission
control effectiveness, compliance assurance for DTCs, safety
practices for crusher use, and the potential for mercury
releases from DTCs in use and during non-operational periods.
Lead and Sponsor: U.S. EPA Region 3
Other Partners:
•	Association of Lighting and Mercury Recyclers
•	Drum-top crushing (DTC) device manufacturers
•	State of Delaware
•	State of Maryland
•	State of Pennsylvania
•	State of Virginia
•	State of West Virginia
OSWER Innovation Projects:
www.epa.gov/oswer/iwg/pilots
Mercury Lamp Drum-Top Crusher Study:
www.epa.gov/osw/hazard/wastetypes/universal/drumtop/
Information on Spent Mercury-Containing
Lamp Recycling:
www.epa.gov/bulbrecycling
2010 UPDATE
The pilot project and subsequent Mercury Lamp Drum-Top
Crusher Study helped EPA develop awareness and educational
tools on the safe use of DTC devices for recycling mercury-
containing lamps like the Fluorescent Lamp Recycling Report
published in February 2009. This report provides information to
businesses interested in recycling their spent mercury-containing
lamps including best management practices (BMPs) for the
storage of spent fluorescent lamps and the use of DTCs for
compacting waste lamps. These BMPs are based on the results
of EPA's study of these devices and are intended to promote the
safest possible use of DTCs for those who choose to use them.
A PQA United States
Environmental Protection
' m Agency
OSWER Innovation Pilot Results Fact Sheet— January 2011
Developing an Innovative Policy to Facilitate the Use of
Drum-Top Crushing Devices for Mercury Containing Lamps

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