Summary of Northeast State's Policies Regarding Use of Drum Top Crushers

State

Drum Top Crusher Regulations and
Policies

CESQG
Exemptions?

Contact for More
Information

Connecticut

No crushing without a permit

No exemption for
CESQGs.

Ross Bunnell

ross.bunnell@po.state.ct.us
(860) 424-3274

Maine

No crushing allowed.

No exemption for
CESQGs

Stacy Ladner

Stacy.a.ladner@maine.gov
207 287-2651

Massachusetts

Crushing of lamps is allowed as a "recycling"
activity under the Massachusetts Universal
Waste rule (a streamlined set of hazardous
waste requirements, 310 CMR 30.1034), but
the process must separate the crushed material
into its component parts (end-caps, glass and
mercury/phosphor powder) so that each can
be recycled. A drum-style crusher that does
not separate the crushed material into
component parts for recycling does not satisfy
the requirements of this regulation and will be
subject to the Massachusetts hazardous waste
licensing requirements. Generators who
operate drum-style crushers that do not
comply with the recycling requirements or are
not properly permitted or licensed may be
subject to enforcement action.

Yes, CESQGs are
exempt from the
treatment
prohibition and
may use DTCs
without a permit.

James Paterson

j ames ,paterson@state .ma. us

617-556-1096

New Hampshire

Use of a DTC is considered hazardous waste
treatment and requires a permit.

No exemption for
CESQGs

Paul Lockwood
plockwood@des. state.nh.us
603 271-2956

New Jersey

Crushing by generators allowed, (with an Air
Pollution Control Permit); third parties need a
Class D recycling center approval and an Air
Pollution Control permit from New Jersey
Department of Environmental Protection.

CESQGs that are
crushing the bulbs
prior to beneficial
use or reuse, or
recycling or
reclamation are
exempt from the
treatment permit
requirement.

Zafar Billah

zafar.billah@dep. state.nj .us
609-292-9880

New York

Lamps being managed under the Universal
Waste Rule may not be crushed. Crushing is
considered a form of hazardous waste
treatment, and under ordinary hazardous
waste generator regulations, hazardous waste
lamps may be crushed only if the process is
exempt from hazardous waste treatment
regulations (6 NYCRR 373-1.1(d)(1)).
Common exemptions that might apply to
crushing lamps are: on-site treatment by a
CESQG; the first step of a recycling process,
if the lamps will be directed to a mercury
recycler, or treatment in the tank or container
in which the lamps are stored. Generators
wishing to use one of the latter two
exemptions should seek specific guidance
from the Waste Determination & Analysis

Yes, CESQGs are
exempt and may
crush lamps
following
hazardous waste
regulations.

John Miccoli

jdmiccol@gw.dec.state.ny.us
518-402-8633


-------


Section. The crashed lamps are usually
considered hazardous waste for mercury, and
sometimes for lead, and must be handled and
disposed of in accordance with normal
hazardous waste requirements.





Rhode Island

No crashing allowed.

No exemption for
CESQGs

Bev Migliore
bmigliol@dem. state, ri.us

401 222-4700 x7503

Vermont

No crashing allowed.

No exemption for
CESQGs

Peter Marshall

peter.marshall@state.vt.us

802-241-3868


-------