Mercury is a naturally occurring element of the earth. Increasingly,
people have become familiar with the environmental and human health
impacts associated with mercury and its compounds; however, many are
not aware that mercury is an essential component of most energy-efficient
lamps. Fluorescent light bulbs (including compact fluorescent)
and high intensity discharge (HID) lamps are the two most common types
of mercury-containing lamps. Fluorescent bulbs provide lighting
to most schools, hospitals, office buildings and stores. HID lamps
include mercury vapor lamps, metal halide and high-pressure sodium lamps,
and are used for streetlights, floodlights, parking lots, and industrial
lighting. Due to the mercury content, these lamps typically require
special handling at end-of-life.
Nationwide, over 600 million mercury-containing lamps are discarded
each year, yet the recycling rate is about 24%. Most of these
lamps are still discarded with municipal solid waste that is ultimately
landfilled or incinerated. The Association of Lighting and Mercury
Recyclers (ALMR), the National Electrical Manufacturers Association
(NEMA), and the Solid Waste Association of North America (SWANA) are
working in collaboration with the U.S. Environmental Protection Agency
(EPA) to increase the national recycling rate through an outreach and
education campaign. In order to encourage better management of
mercury from spent lamps, we are targeting outreach efforts towards
the people who can best contribute to diverting these lamps from municipal
solid waste landfills. The objective is to get enough information
to the right people so that both mandatory and voluntary recycling increases
from the current rate of 24% to 40% by 2006 and 80% by 2009. To
achieve the objective, it is necessary to change peoples behavior;
in other words, to increase compliance by changing the current disposal
pattern for mercury-containing lamps into recycling.
Targeting Disposal Decision-Makers
In order to have a significant impact on the recycling rate, disposal
decision-makers must be fully informed about the regulations regarding
mercury-containing lamps, and the opportunities available for recycling
them. Disposal decision-makers have both the authority and responsibility
to dispose of spent lamps in an environmentally safe manner that complies
with legal requirements. Disposal decision-makers include building owners
and managers of commercial, industrial, and government properties. Electrical
contractors, lighting maintenance and demolition contractors, the solid
waste industry, local governments, lighting specifiers, and partners
of the EPA Energy Star and DOE Rebuild America programs also influence
THE FEDERAL RULES
Used (also known as spent) mercury-containing lighting products
are regulated by the Environmental Protection Agency under the Universal
Waste Rule (UWR), which
is a subset of the Resource Conservation and Recovery Act (RCRA)
Subtitle C hazardous waste regulations. Most states have adopted
these rules, and several have adopted regulations that are more stringent
than the UWR.
The federal hazardous waste rules are a complex set of regulations affecting
all aspects of waste management. They are found in the Code of
Federal Regulations (40 CFR Parts 260-279). The Universal Waste
Rule is a subset of these regulations which streamlines the management
of selected common hazardous waste products. These products include
batteries, certain pesticides, thermostats, and lamps. In general,
this rule prohibits spent lamp disposal in municipal landfills.
Anyone who chooses to recycle their lamps under universal waste regulations
generally have reduced regulatory burden and costs.
If this is the option that you have chosen, it is important to know
that there are certain requirements that you must adhere to. Lamps
that are sent for recycling under the Universal Waste Rule have less
stringent requirements for storage, record keeping and transportation
as compared to the requirements of the full Subtitle C hazardous waste
regulations. Regardless of how you choose to manage your waste,
you must be thoroughly acquainted with both state and federal regulations
in order to determine how they apply to you. Please review the
RCRA and UWR Definitions (as they apply to lamps)
The following definitions are summaries of those found in the Code of
Federal Regulations (CFR) as they apply to mercury-containing lamps.
Also cited are specific sections in the CFR where official definitions
Lamp or Universal Waste (UW) Lamp - The bulb or tube portion
of an electric lighting device. A lamp is specifically designed
to produce radiant energy, most often in the ultraviolet, visible, and
infrared regions of the electromagnetic spectrum. Examples of
common universal waste electric lamps include, but are not limited to,
fluorescent, high intensity discharge, neon, mercury vapor, high pressure
sodium, and metal halide lamps. The lamp definition is found at (40
All fluorescent lamps contain some amount of mercury. Unless otherwise
marked, these lamps will likely fail EPAs Toxicity Characteristic
Leaching Procedure (TCLP) for mercury, and unless exempted, they must
be handled as a hazardous waste. Depending on date of manufacture,
some lamps that pass the TCLP test may be marked in green, either as
an etch on the glass, or as a colored base. In some circumstances
these lamps may be handled as ordinary solid waste. All mercury-containing
lamps, whether hazardous or not, will release mercury into the environment
when broken outside of a controlled recycling process. EPA encourages
recycling all mercury-containing lamps.
Universal Waste Handler or Handler Generally
speaking, anyone who produces, stores, collects, or accumulates universal
waste, such as mercury-containing lamps, but does not treat, recycle,
or dispose of them.
Small Quantity Handler of Universal Waste (SQHUW) -
A generator (such as a business or building owner) or third
party (such as a contractor) who accumulates less than 5,000 kg total
of universal waste (such as spent mercury-containing lamps) at a time.
No EPA ID is required. Storage time for the waste is up to one
year. Employees are required to have minimal training and information
on proper handling and emergency procedures regarding mercury-containing
lamps. Proper marking and labeling of universal waste is required.
SQHUW requirements are found at 40 CFR 273 Subpart B.
Large Quantity Handler of Universal Waste (LQHUW) -
A generator (such as a business or building owner) or third party (such
as a contractor) who accumulates more than 5,000 kg total of universal
waste (such as mercury-containing lamps) at a time. An EPA ID
is required, and state registration may also be required. Storage time
for the waste is up to one year. Employees are required to have
training and information on proper handling and emergency procedures
regarding mercury-containing lamps. Proper marking and labeling of universal
waste is required. LQHUW requirements are found at 40 CFR 273 Subpart
Universal Waste Transporter - One who engages
in the process of transporting waste lamps for 10 days or less.
A transporter may not store, accumulate, dispose, dilute or treat universal
waste lamps. No EPA ID is required. Proper marking and labeling of waste
lamps is required. Transporter requirements are found at 40 CFR 273
Universal Waste Transfer Facility - A non-permitted
storage location for 10 days or less. The transfer facility definition
can be found at 40
CFR 273.9. If storage exceeds 10 days, Handler
Destination Facility - A state or federally-permitted
processing, recycling or disposal facility. A destination facility
is subject to requirements similar to a Treatment, Storage, and
Disposal Facility (TSDF), permitting requirements, Land Disposal
Restrictions (LDR), and other provisions under Subtitle C (40 CFR 273
For more definitions and commonly used terms see the
SUMMARY OF THE UNIVERSAL WASTE RULE AND RCRA SUBTITLE C HAZARDOUS WASTE
REGULATIONS FOR BUSINESSES
Who does this rule apply to?
· Federal RCRA requirements apply
to everyone except households and Conditionally Exempt Small Quantity
Generators (CESQGs) see
glossary for definition of CESQGs.
· Although households and CESQGs
may legally dispose of waste lamps in the trash unless state policies
are more stringent (and many are), EPA encourages them to recycle their
lamps as well. See the State-by-State
Stringency Comparison Table.
Where can the waste go?
· In most cases, hazardous waste
lamps must go to a destination facility or TSDF (only lamps from households
or CESQGs are exempt) rather than to a municipal solid waste landfill.
These facilities include lamp recyclers or mercury recyclers.
Recycling waste lamps under the UWR is less burdensome because most
businesses will not have to register with the EPA to obtain an EPA ID.
How does using the UWR to recycle
· If you choose to dispose of lamps
under the more stringent full Subtitle C hazardous waste requirements,
the following applies: you must obtain an EPA ID, a HW manifest
is required for transportation, and a certified HW hauler must be used
for transportation. This option could greatly increase administrative,
shipping and disposal costs.
· If you recycle lamps under the
UWR, you are exempt from the HW manifest requirements. The UWR
allows the use of a record of shipment like a bill of lading (BOL).
It does not require the analytical testing or reporting of lamps destined
· If you recycle lamps under the
UWR, you may use a common carrier instead of a certified HW hauler for
shipment to a recycling facility. This lowers shipping costs.
· Intentional lamp breakage is
considered treatment, and treatment of lamps (e.g., drum-top
crushing) requires compliance with full Subtitle C requirements unless
your state has authorized regulations allowing lamps to be crushed under
the UWR. See the State-by-State
Stringency Comparison Table. Also see the Crushing section
of this document.
· If you recycle lamps under the
UWR, you may collect lamps without a permit. The UWR also allows handlers
such as businesses and building owners to store lamps in any amount
up to one year.
· If you recycle lamps under the
UWR, there are minimal training requirements for employees. The
labeling requirements for this waste are also less burdensome.
NEMA members have implemented a nationwide labeling program for mercury-containing
fluorescent and HID lamps, and their packaging, to ensure that consumers
receive consistent and clear information on the proper disposal of spent
lamps with each product they purchase.
The lamp package includes the following information, with the toll-free
number being manufacturer-specific:
Hg - LAMP CONTAINS MERCURY
IN ACCORD WITH DISPOSAL LAWS
or call 1-800-XXX-XXXX,
Until recently, regulations made it difficult and expensive to recycle
used lamps. Now the EPA has included mercury-containing lamps
in the Universal Waste Rule, a federal regulation that reduces the cost
and regulatory burden of recycling.
Lamps are fragile and can easily break. The regulations distinguish
between accidental breakage that occurs during normal transport and
intentional breakage or crushing. (See Crushing in the next section
of this document.) While there is no specific amount of breakage that
is considered accidental, less than 5% is generally acceptable.
Anyone who chooses to recycle lamps under the UWR should take standard
precautions to minimize breakage, such as using the boxes from new lamps
to store old ones in. More specific guidance on this is available
EPA provides the following breakage advisory:
Handling of Small Numbers of Broken Fluorescent Lamps
Broken Lamp Handling Practices: If
a lamp breaks in your home, close off the room to other parts
of the building. Open a window to disperse any vapor that
may escape, and leave the room for at least 15 minutes.
Carefully scoop up the fragments with a stiff paper (do not
use your hands) and wipe the area with a disposable paper towel
to remove all glass fragments. Do not use a vacuum as
this disperses the mercury over a wider area. All fragments
should be placed in a sealed plastic bag and properly disposed
of. For proper disposal instructions, see the Message
for Environmental Groups.
Universal Waste Rule Requirements: Under the EPA Universal
Waste Rule, a lamp that does not pass the TCLP test and is broken
must be cleaned up and placed in a container. The container
must be closed, structurally sound, compatible with lamps, and
lacking any evidence of spillage. This advice is applicable
to any mercury-containing lamp. In some states, universal
waste status is lost when lamps are broken and they must be
handled as a full hazardous waste. It is important to
check with your local, state, or federal office for the latest
update in regulatory status or go to www.lamprecycle.org.
Health Effects: No adverse effects are expected from
occasional exposure to broken lamps.
General Overview of Crushing
Crushing is the intentional breaking of fluorescent and mercury lamps
for the purpose of volume reduction. Crushing reduces the physical
volume of lamps but does not recover any mercury. In order for lamps
to be managed under the Universal Waste Rule, treatment
by handlers or transporters is not allowed. Under federal regulations,
crushing is considered a type of treatment. Generally, anyone
who treats their lamp waste is not considered a handler
under the UWR and is subject to full Subtitle C hazardous waste requirements.
This includes manifesting and reporting compliance items that add costs
to shipping lamps. Crushing is not recycling, but it can be a step in
the treatment process when the crushed material is further treated by
a recycling process that includes retorting. Under no circumstances
can the crushed lamps be landfilled as municipal solid waste.
Certain authorized state programs allow both whole and intentionally
crushed lamps to be managed under the UWR. Handlers that choose
to intentionally crush lamps must do so in accordance with authorized
state programs. For more information specific to your state, consult
the State-by-State Stringency
What is Drum-Top Crushing?
Drum-top crushing is done using a mechanical device that fits on top
of a 55-gallon collection drum. Whole lamps are broken in the
system but components are not separated, and the drum will contain hazardous
mercury, phosphor powder, glass and mixed metals. Crushing lamps
into drums releases mercury into the filter. This filter medium
also becomes hazardous.
National Crushing Study
At this point, intentional crushing is controversial. There are
no clear national guidelines, accountability or health and safety monitoring
requirements. EPA has embarked on a study to determine what the
national minimum standards should be. The ALMR cooperated with
EPA in developing standards to eliminate any abuses of the rules.
Until this is complete, we simply urge caution and suggest people check
with their state agencies.
MERCURY LAMPS AND WATER ISSUES
In the context of The Safe Drinking Water Act and The
Clean Water Act, along with their enacting regulations, there
may also be environmental concerns about water quality from the discharge
of mercury from broken lamps. While there is no significant research
in this area, preliminary evidence suggests that mercury from spent
lamps may impact water quality when they are broken in solid waste containers
where rainfall leaks out. No one knows how many containers there
are, how many will have tops open when it is raining or exactly how
many lamps will break in any container, but we do know that there are
still over 500 million mercury-containing lamps per year put into some
type of solid waste container and managed as municipal solid waste.
At some point all of these lamps break. Most breakage occurs in
the container, as opposed to at the landfill, simply because glass is
so fragile. When these containers are also exposed to moisture
from rain or other sources and they leak, or when they are washed out,
mercury can enter the environment. Studies have shown that when
fluorescent lamps break in containers the mercury can hover for days,
and eventually migrate downwind and back onto the land. Indirectly,
this mercury can also get into water.
We know that this is a source of mercury pollution that can easily be
controlled when recycling is chosen. For a more complete and technical
discussion of the relationships between mercury from lamps and water
regulatory standards see the Mercury section at www.almr.org.
STATE REGULATIONS AND PROGRAMS
In the last few years most states have added lamps to their local regulatory
policies to make it easier to recycle and keep mercury out of landfills,
incinerators and the environment. State policies differ and local requirements
should be checked, but fundamentally all governmental policies now encourage
recycling at authorized facilities. Please review the State-by-State
Stringency Comparison Table.
9 RECYCLER SELECTION CRITERIA
It is incumbent upon you to select a recycling contractor that will
best serve your needs while at the same time give you the assurance
that your waste lamps are properly managed to minimize your liabilities.
To assist, we have provided some general criteria for selecting your
Pricing - Pricing represents the recyclers ability to service
you and your customers and meet your needs, while at the same time being
price competitive. While pricing is key, as with many things,
you usually get what you pay for. It is suggested that you question
pricing and get more than one quote for your needs.
Service - Important items include responsiveness, timeliness, program
flexibility and customization, the personnel you will be working with,
whether there will be intermediates, the capabilities of the firm and
the equipment they will be using.
Risk Management - Recyclers, as Destination Facilities, are obligated
to reduce or eliminate pollution risks for their clients. In order
to remove the mercury characteristic from the waste, recyclers must
comply with numerous federal and state regulations. Important
factors for evaluating recyclers include: 1) whether they meet
insurance requirements for general and pollution liability, 2) the financial
health of the company, 3) what indemnities or other assurances they
offer clients, 4) their environmental record and compliance history,
5) the existence of government permits and approvals for facility operation
or transportation, 6) operations and safety procedures and records,
7) vapor control technology and monitoring records, 8) hygiene and medical
surveillance information, 9) the status of a facility closure plan,
10) facility audit reports, and 11) the availability of key regulatory
These items may seem extensive and your evaluation may seem daunting,
but you are entrusting your hazardous waste to a third party and you
need assurances. You are encouraged to ask potential recycling
contractors about any of these items. It is perfectly acceptable
to ask for references or to check with the state agency that regulates
recycling facilities for compliance histories.
ABOUT THE LAMP RECYCLING OUTREACH PROJECT
Recycling. The Responsible
Thing To Do.”©
The Responsible Thing to Do was chosen by ALMR (in conjunction
with NEMA and SWANA) as the slogan for the Mercury Lamp Recycling Outreach
Project. This is a national outreach and education campaign that
was funded in 2002 by the United States Environmental Protection Agency.
The Association of Lighting and Mercury Recyclers is a non-profit organization
representing members of the lighting and mercury recycling industry,
and serving as an educational and informational resource to government,
business and the public. ALMR began in 1999 and its members currently
recycle about 80% of the mercury lamps that are diverted from the municipal
NEMA, the National Electrical Manufacturers Association, is the leading
trade association in the United States representing electronic product
manufacturers. Founded in 1926 and headquartered near Washington,
D.C., its 400 member companies manufacture products used in all walks
of life, including the generation, transmission and distribution, control,
and end-use of electricity. Annual shipments of these products
total in excess of $100 billion.
For 40 years, SWANA, The Solid Waste Association of North America, has
been the leading professional association in the solid waste industry.
SWANAs mission is, to advance the practice of environmentally
and economically sound management of municipal solid waste.
SWANA serves over 6,800 members, and thousands more solid waste professionals
with technical conferences, certifications, publications and a large
offering of technical training courses.
or contact NEMA at www.nema.org for additional information and resource
directories of services available.
www.almr.org or contact
the Association of Lighting and Mercury Recyclers (email@example.com) for
more information on how to set up a lamp recycling program.
contact SWANA for more information on how the solid waste industry is
diverting waste lamps into recycling.
or contact the U.S. EPA for more information on the Universal Waste
 The Universal Waste
Rule (UWR) (40 CFR Part 273) See Federal Register July 6, 1999, Volume
64 Number 128, pp 36465-36490. You are encouraged to visit www.lamprecycle.org
for general information and EPAs links related to the regulations.