Fluorescent Lamp Recycling

On July 6, 1999, the United States Environmental Protection Agency (EPA) added hazardous waste lamps to the federal list of "universal wastes" in 40 CFR 273 and became effective on January 6, 2000. Hazardous waste lamps are characteristically hazardous when they fail the Toxicity Characteristic Leaching Procedure (TCLP). This includes, but is not limited to: fluorescent, high-intensity discharge, neon, mercury vapor, high-pressure sodium, and metal halide lamps. Fluorescent lamps are hazardous because they contain mercury.

The Universal Waste Rule of 1995 was designed to reduce the amount of RCRA hazardous waste being disposed of in municipal waste landfills, to encourage recycling and proper management of some common hazardous wastes and to reduce the regulatory burden on businesses currently managing these materials as hazardous waste. Universal wastes are hazardous wastes; however, they have less stringent management requirements. This change in federal regulations has been adopted into the Pennsylvania Hazardous Waste Management regulations by reference under 25 Pa Code 260a.1. Universal wastes are regulated under 40 CFR 273 and 25 Pa. Code 266b.

Pennsylvania regulations do not allow for very small quantity generators to dispose of their waste in a municipal waste landfill (see 25 Pa. Code 262a.14(a)). This means that all hazardous fluorescent lamps must be managed as universal waste or manifested as hazardous waste. Lamps from households are not subject to hazardous waste regulations as they are excluded per 40 CFR 261.4(b)(1).

The intentional crushing or breaking of spent mercury-containing lamps, including the use of drum top crushing (DTC) devices, falls within the definition of treatment in accordance with 40 CFR 260.10 and 25 Pa. Code 260a.10. This treatment activity is prohibited by both the federal and Pennsylvania state universal waste regulations. This activity is also not authorized under Pennsylvania’s permit-by-rule regulation for generator treatment in accumulation containers, tanks and containment buildings, 25 Pa. Code 270a.60(b)(2). Human health and the environment can not sufficiently be protected by the generator accumulation unit standards when crushing mercury- containing lamps. For these reasons, DTC devices are prohibited without a full hazardous waste treatment permit issued in accordance with 25 Pa. Code Chapters 260-270 and 40 CFR Parts 260-270. Keeping lamps intact until they reach a qualified permitted destination facility for recycling prevents mercury exposure to workers and the environment.

Information for Proper Disposal of Compact Fluorescent Light Bulbs

Household Hazardous Waste Collection Programs

LampRecycle.org

There are newer lamps on the market that have lower levels of mercury and may not be hazardous waste. If the lamps pass the TCLP, they are not characteristically hazardous and may be disposed of in a municipal waste landfill.

You may obtain a copy of the Hazardous Waste Lamp Rule in the Federal Register.