Not all bulbs are created equally
In the last post I summarized requirements for universal waste. One waste stream that falls into this category are bulbs (lamps). Did you know that not all lamps need to be managed as universal waste that, in fact, some are not even classified as hazardous waste or universal waste? Under federal law, lamps that exhibit the characteristic of toxicity are considered hazardous and can be managed under the universal waste regulations discussed in the previous post. Lamps that typically carry the toxicity characteristic for mercury are: metal halide, fluorescent, neon, HID, and mercury vapor. Although low-mercury bulbs have significantly lower mercury content than fluorescent bulbs, they often are 10 to 20 times higher than the 0.2 milligrams per liter (mg/L) limit. Many bulbs may pass the Toxicity Characteristic Leachate Procedure (TCLP) evaluation for mercury (have less than 0.2 mg/L) but not for other metals such lead, nickel, arsenic and silver. If a lamp fails the TCLP procedure for any of the contaminants listed in 40 CFR 261.24 it is considered hazardous and a generator/handler has the option to manage it as universal waste. Lamps that may fail for contaminants other than mercury include incandescent and LED lights–the level of contaminants depends a lot upon manufacturing process. EPA requires management as hazardous waste unless the lamp has been tested to prove otherwise. If your company generates a large amount of bulbs it may be cost beneficial to conduct a TCLP analysis with a local laboratory to determine if they are indeed hazardous. If the bulbs are not hazardous, labeling, tracking of accumulation times, and training are not required and can relieve a significant regulatory burden from the company. Whether hazardous or not recycling is highly recommended as the preferred method of disposal. Find out more information on lamp recycling in these resources:
Earth 911
Lamp Recycle
EPA FAQs on Lamp Recycling
Do you have any other resources to share on lamp recycling? If so join the conversation and leave a comment below.
