Health Department Guidance Toolkit Methods for encouraging responsible disposal of mercury-containing devices A Covanta SEMASS & Center for EcoTechnology Program HEALTH DEPARTMENT GUIDANCE TOOLKIT Methods for encouraging responsible disposal of mercury-containing devices • A Covanta SEMASS & Center for EcoTechnology Program Covanta SEMASS, owner of the waste-to-energy facility in West Wareham, MA, where your community’s trash goes, is working with the Center for EcoTechnology (CET), a nonprofit environmental organization, to implement greater recycling of mercury-containing devices with the help of health departments like yours. On May 1, 2008, the Massachusetts Mercury Management Act was passed. This act prohibits the disposal of mercury-containing devices, including all fluorescent lamps (bulbs), as trash. Boards of Health/Health Departments can play an important role in educating and regulating permitted businesses on mercury-containing devices. By working with Covanta SEMASS and CET, you can help businesses comply with the Massachusetts Mercury Management Act, prevent mercury from entering the waste stream and provide an opportunity for municipalities to serve local businesses. This document provides an overview of why mercury-containing devices need to be recycled, what a Health Department can do and supporting materials to achieve these initiatives. Item One. Why Recycle Mercury-Containing Items? Mercury is a neurotoxin found in fluorescent lamps and some household items. When mercurycontaining devices are thrown in the trash, mercury is released into the environment and can accumulate in people and wildlife, especially fish. Those especially susceptible to the negative effects of mercury are children, pregnant women, nursing mothers and women of child bearing years. Mercury pollution is a local problem and Massachusetts residents have been cautioned to limit eating fish caught in certain lakes and rivers due to elevated mercury levels. The amount of mercury in a small thermometer, 1 gram, is enough to contaminate a 20 acre lake, and render fish unfit to eat! Item Two. What can Health Departments do? How do Health Departments help prevent the release of mercury into the environment? Health Departments permit various business types who may be using fluorescent lamps or mercurycontaining devices in their facilities. Modify the Permitting Process for Facilities Permitted by the Health Department One option for encouraging greater recycling of mercury-containing devices is to change the permit renewal requirements for facilities permitted by the Health Department. For a facility’s permit to be renewed, Health Departments can request that a business report the name of the recycler for its mercury-containing devices. With help from CET and Covanta SEMASS, Health Departments can include educational materials on recycling mercury-containing devices with permit renewal paperwork. In addition, Health departments can require proof of proper disposal of mercurycontaining devices. By requesting proof of proper disposal or certificate of recycling, Boards of Health can ensure compliance with new regulations and with state law. A sample of a permit renewal letter is included in this document. 508-291-4450 • 141 Cranberry Highway, W. Wareham, MA 02576 • www.covanta.com Health Departments conduct annual inspections of permitted businesses and manage permit renewal requirements. On some permit forms, a description of proper trash and recycling procedures is already required. Modify the Inspection Process for Facilities Inspected by the Health Department Health agents that inspect permitted facilities can add a question about lamp recycling to their inspection checklist and look for proof of fluorescent lamp recycling programs and responsible waste diversion. For example, as fluorescent bulbs in fixtures are examined for safety sleeves, the inspector could inquire about their recycling process. Similar to the permitting process, health inspectors can request proof of proper disposal or a certificate of recycling prior to giving a facility a passing inspection. A guide on what types of mercurycontaining products can/should be recycled is included at the end of this document. Partnerships with Transfer Stations, Health Departments and Covanta help keep businesses in compliance. As a contracted community with Covanta SEMASS, mercury devices collected for recycling at the town transfer station or mercury shed are recycled at no cost. When small businesses have access to these collection areas, they keep mercury out of the waste stream and this system provides an opportunity for municipalities to serve local businesses at no cost to the community. Take Advantage of Free Technical Assistance to Foster Communication and Recycling Programs Health Departments are eligible for free technical assistance from Covanta to facilitate communication between their departments and Transfer stations. When take-back programs are established at town transfer stations, Health Departments can play a role in referring community residents to participate in these programs. Health Departments can also be instrumental in encouraging communities to have a thorough process for collecting mercurycontaining devices from properties in the town, which can be centrally housed at transfer stations prior to free recycling pick-up. Some towns have collections through Health Departments. Take Advantage of Free Recycling and Educational Resources to Foster Recycling Programs Covanta SEMASS arranges free recycling for all mercury-containing devices collected through Health Departments. Health Departments can utilize the resources available to them, such as lists of permitted businesses, large commercial property owners, and healthcare facilities, to initiate targeted mercury recycling programs. Health Departments can take advantage of these connections to sponsor or coordinate one-day business collection events. Health Departments can also disseminate information and resources they receive for free (from Covanta and CET) to residents, businesses, and town employees about mercurycontaining device handling, clean-up, and recycling. 508-291-4450 • 141 Cranberry Highway, W. Wareham, MA 02576 • www.covanta.com Additional Resources Below is a list of free benefits provided to your Health Department and community as a contracted member of Covanta SEMASS. You can find samples of various documents such as a permit renewal notice to be used as a template and a guide for what items should be recycled at the end of this packet. Perks to Health Departments: Free technical assistance to educate and supply Heath Department staff with tools to regulate mercury-containing products at permitted businesses Free technical assistance to facilitate communication between Health Departments and Transfer Stations, schools or other town departments Free recycling of all mercury-containing products collected by the Health Department or Department of Public Works Rebates for thermometer and thermostat recycling or exchange programs, by arrangement with SEMASS Free containers and sealable bags for the collection of mercury-containing devices Free posters and signage for your office Item Three. Supporting Materials 508-291-4450 • 141 Cranberry Highway, W. Wareham, MA 02576 • www.covanta.com 508-291-4450 • 141 Cranberry Highway, W. Wareham, MA 02576 • www.covanta.com Template for Permit Renewal Letter for FOOD ESTABLISHMENTS. [INSERT TOWN NAME/INSIGNIA] [INSERT BOH CONTACT INFORMATION] [INSERT DATE] To: All Permit Holders From: [BOARD OF HEALTH DIRECTOR] Re: Permit Renewal for 20XX Enclosed please find the application necessary for renewing your permit. Please complete the application in its entirety and return it with your payment to the Board of Health, [INSERT ADDRESS FOR BOH]. You must include: 1. A copy of your current menu. 2. A copy of the person in charge’s certificate in Food Protection Management (required as of 10/21/2001 in accordance with 105 CMR 590.003 (A)) 3. A completed certificate of recycling (required in accordance with 310 CMR 30 prohibiting disposal of mercury containing items in trash) As with every year, we are requiring your permits be posted in your establishment in view by the public. All permit applications must arrive at the Board of Health office by [DATE]. Please note that a late permit fee of [LATE FEE] will be assessed for those who choose not to renew their permit by the deadline. If you do not renew your permit by the expiration date, you will be operating without a valid permit and will be subject to fines. Thank you for your time and attention to this matter. [INSERT BOARD OF HEALTH DIRECTOR] [INSERT TITLE] 508-291-4450 • 141 Cranberry Highway, W. Wareham, MA 02576 • www.covanta.com Sample Notification Letter of Renewal Process Changes Month Date, Year Dear Business Owner: As part of the renewal process this year, we are asking you to please fill out the enclosed form in regards to the disposal of your used bulbs. Disposing of the fluorescent bulbs in the trash is prohibited by state federal regulations (310 CMR 30), the Massachusetts Mercury Management Act and enforced by the Massachusetts Department of Environmental Protection (DEP). Feel free to contact us about consolidating bulbs for recycling with the town collection services. Pick-ups for used bulbs at the town collection station are free of cost. Otherwise, you can connect with Complete Recycling Solutions (CRS), the preferred recycling vendor for Covanta SEMASS, about establishing a recycling program. CRS can be reached at this toll-free number: (866) CRS9797. We will renew your license this year when we receive your renewal forms. We ask that you merely answer the questions regarding the use and disposal of your bulbs in addition to the usual renewal information (name, address, etc.) We are considering having a requirement for next year (20xx renewal) that you show proof (by means of a receipt) that you have properly disposed of the tanning bulbs using an approved recycler. Thank you for your consideration with regard to this request. If you have any questions, do not hesitate to call me at . Sincerely, , [Appropriate Title 508-291-4450 • 141 Cranberry Highway, W. Wareham, MA 02576 • www.covanta.com Fluorescent Bulbs and Mercury Items Recycling Form According to the Massachusetts Mercury Management Act- all fluorescent bulbs and mercury containing items must be recycled. http://www.mass.gov/eea/docs/dep/toxics/laws/hglawfax.pdf Fluorescent bulbs can be recycled through access to town programs, utilizing mail back programs or arranging with a service provider for pickups. Fluorescent bulbs can be kept on site for 1 year. Reference: Universal Waste Regulation http://www.mass.gov/eea/docs/dep/recycle/hazardous/univrule.pdf Recyclers of Fluorescent Bulbs & other Universal Wastes: This list was generated from the Massachusetts State Contract, CommBuys. Complete Recycling Solutions 866-CRS-9797 1075 Airport Road, Fall River www.crsrecycle.com Environmental Integrity Co 413-420-0035 Valley Mill Road, Holyoke www.eic-llc.net New England Disposal Technologies 508-234-4440 83 Gilmore Drive, Sutton www.nedtinc.com Veolia Environmental Solutions 508-584-1634 90 Pleasant Street, West Bridgewater www.veolianorthamerica.com -------------------------------------------------------------------------------Please fill out this section with your Universal Waste Recycler information: Account Holder Information Your Business Name: Street Address (where equipment was installed) City State Name of Universal Waste Recycler Address Estimated Annual Quantity Zip Code Phone City State Zip Code