Title: Reading Assignments
Course: WGF 107 DEVELOPMENT > Section: Content

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Sub-Title | Lamp Regulations & Disposal
Content
Overview of Regulations

Fluorescent and other high-intensity-discharge (HID) light sources generally require care in their handling and disposal. Fluorescent light sources, HID, and mercury vapor lamps all require various amounts of mercury to

operate (ranging from 3 mg to over 100 mg, or about the tip of a ballpoint pen to a small bearing). Care is needed during the unpacking, installing, or replacing process for these light sources, as they can break if dropped or mishandled.

Mercury, especially in larger quantities, is considered a hazardous material, and the EPA and states regulate its disposal and handling. In general, state waste disposal regulations take precedence over federal regulations. Additionally, some county disposal regulations are even more stringent than a state’s regulations.

On July 6, 1999, EPA added hazardous waste lamps to the federal list of “universal wastes.” Hazardous waste lamps are any lamps that are characteristically hazardous, as determined by the TCLP (Toxicity Characteristic Leaching

Procedure). This includes fluorescent, high intensity discharge, neon, mercury vapor, high-pressure sodium, and metal halide lamps, if they are characteristically hazardous (that is, as confirmed by the TCLP test results).

The new rule became effective on January 6, 2000. Options for managing lamps include managing them as hazardous waste, managing them under the universal waste rule, or using a type of lamp that is not hazardous. “Universal wastes” are also hazardous wastes; however, they have less stringent requirements for storage, transport, and collection. Universal wastes are regulated

under 40 CFR 273 and other state codes.

Federal regulations currently allow a conditionally exempt, small-quantity generator (someone generating less than 220 pounds of hazardous waste/month) to dispose of its waste in a municipal waste landfill. Newer lamps on the market have lower levels of mercury and thus are not considered hazardous waste. If the lamps pass the TCLP, they are not hazardous waste and may be disposed in a municipal waste landfill. Manufacturers are required to disclose whether or not their lamps pass the TCLP tests, and indicate the amount of mercury present in a lamp in product catalogues and consumer packaging.

If a collection and recycling system already exists in the building for linear fluorescent lamps, it can be easily expanded to include CFLs. If, however, a collection

and recycling program does not exist for either linear or compact lamps, then it should be considered and included as part of a comprehensive user and occupant outreach and education on energy efficiency (especially to help address user-supplied devices and programs to provide CFLs to occupants). A list of fluorescent lamp recyclers is generally available from the state departments of environmental protection, or from the resources listed below. Generally, a collection area or areas will be needed and designated for spent (and broken) lamps, and a location will be needed to set aside for collection and storage in between recycling pick-ups. (See also the chapters on Recycling and Special Waste Programs and Resident Education.) Information from the EPA on CFL cleanup can be found at: http://www.epa.gov/cfl/cflcleanup.html .
Links/Uploads | Building Upgrade Manual (ENERGYSTAR®) – Whole Building Design Guide http://www.wbdg.org/ccb/STAR/energystar_bldgupgrademanual.pdf
Attributions | Image courtesy of Content courtesy of Green Seal (Building O&M Manual – Chapter 4), and