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Fluorescent Light Tubes as Hazardous Waste

  • Mercury-containing lamps may be hazardous waste under the TCLP rule under RCRA and if so, must be managed as a hazardous waste unless they are a household or are generated by an exempted small quantity generator.
  • A relatively high percentage of these lamps, when spent, exhibit the characteristic of toxicity.
  • Generators of more than 100 kg of hazardous waste per month are required to fully comply with federal hazardous waste regulations.
  • Generators of mercury-containing lamps will be required to meet a treatment standard for lamps as hazardous debris.
  • May increase the number of large quantity generators on months when mass relamping occurs.
  • Limit of 100 kg of hazardous waste per month which would be about 350 mercury-containing lamps.

Green Light Program

  • Subtitle C regulations may discourage participation in energy efficient lighting programs.
  • Green Lights including Universities.

Background into mercury as a hazardous waste and in light tubes

  • Mercury lamp tubes account for 3.8% of the 643 metric tons of mercury discarded in MSW landfills per year.
  • TC limit for Hg 0.2 mg/l
  • Less than 0.01% of the mercury in MSW landfills leaches from the landfill.
  • The average mercury content of a standard 4-foot, 1.5 inch diameter, cool white fluorescent lamp was reduced by 14% (48.2 mg/lamp to 41.6 mg/lamp), and is expected to further decrease from 41.6 mg/lamp to 27.0 mg/lamp by 1995.
  • Average municipal waste combustors (14% of municipal waste) mercury emissions factors range from 70 to 90 percent of the mercury input (98 Mg/year).
  • EPA's preliminary analysis indicates that mercury that would leach out of landfills would not all necessarily travel far enough through the ground water to contaminate drinking water wells, depending on the distance to the well. A certain percent will combine with other substances in the soil to form solid substances and remain in the soil. Therefore the regulatory limits for mercury, if reassessed using the MINTEQ model, when completed, might be higher than the current limits because mercury may be less mobile than the current TC rule indicates. However, these studies are still ongoing.
  • Municipal waste combustors...alternative is not considered in any situation.

Mercury release from fluorescent light tubes

  • 6.6 % of mercury could be released in the air from a lamp broken during the collection, storage, and transportation of mercury-containing lamps in garbage trucks.
  • Requirements could include packaging that would be required to meet a performance standard of minimizing breakage for unbroken spent lamps.
  • EPA expects that packaging in which new replacement lamps are shipped from the manufacturer would frequently be reused to store and transport removed used lamps.
  • Another option could be to impose a prohibition on intentional breakage of spent lamps by generators.
  • Standards should be imposed to protect against mercury releases during crushing or the subsequent management of crushed lamps.

Methods for collection, storage, and transportation

  • At the same time, a management requirements included in special collection system regulations could be designed to minimize hazards posed in collection of these wastes (e.g. special packaging could be required to minimize breakage).
  • Proposed quantity limit...about 35,000 lamps roughly corresponds to a full truck load of packaged fluorescent lamps, the agency is suggesting a 35,000 limit.
  • Lamps are not stored for greater than one year.
  • This approach requires that the manifest system be used for shipment from the last collection point to a destination facility, but that no manifests or other records be required for shipments from generators to consolidation points, between consolidation points, or from generators to destination facilities.

EPA options into handling fluorescent light tubes

  • The first approach is a conditional exclusion from regulation as hazardous waste.
  • If EPA concludes, after considering data from the public comment on this proposal, that the risk from mercury release from mercury-containing lamps is not significant enough to warrant subtitle C regulation, the Agency may choose to finalize a conditional exclusion. However, if EPA concludes, after considering data received in public comment that the risk from mercury release from lamps is significant, the Agency may choose to keep mercury-containing lamps in subtitle C, under the universal waste management system.
  • EPA believes that with adequate State oversight, mercury-containing lamps can be safely recycled and the mercury reclaimed from them.
  • The Agency believes that spent lamps may appropriately be considered "universal wastes" in that they are generated in a wide variety of settings, are generated by a wide number of generators, and are present in significant volumes in the municipal waste stream.

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