Air Cycle Corporation is the manufacturer of the Bulb Eater®, and the nation’s leading producer of drumtop lamp crushing machines with more than 6,000 units in operation nationwide.  We consider our machine to be the standard for the industry in terms of its safety features as numerous third-party studies have confirmed that the machine easily complies with OSHA’s standards for mercury emissions and often has non-detectable emissions during regular use.  Our users benefit from reduced storage needs, decreased labor associated with managing intact lamps, and from the cost savings of more efficient shipping and recycling.  The use of our device improves overall regulatory compliance as it facilitates storage, consistent participation because of it's ease of use and fun factor, and it avoids the breakage of intact lamps that are routinely broken while being stored and shipped for recycling.    

We support the Virginia Department of Environmental Quality in its efforts to more fully define the operational requirements of lamp crushing, especially in the case of destination recycling facilities.  Our company has created a nationwide network of lamp recyclers to service our customers, and we fully understand the safety and regulatory concerns that must be in place when processing large quantities of lamps. 

With regards to lamp crushing units, we also support the development of clear regulatory guidance related to their use and operation.  Again, we have designed our device to exceed air quality emissions standards.  And we strive to fully educate all of our customers on the importance of properly maintaining and safely operating the device, as well as their regulatory responsibilities related to storage and shipping.  We support guidance that reinforces these measures.  

However, we would recommend against regulatory requirements that cause any undue burden or add additional costs to the operator.  Our typical users crush only 2000-4000 lamps a year (average 40-80 per week).  Any unnecessary requirements such as air permits, registration fees, reporting, and air quality monitoring would discourage the economical use of these devices. 

Thank you for your consideration of our comments and for including us in this review process. 

Sincerely,

Scott Beierwaltes, CEO

Air Cycle Corporation