Question: I have large amounts of fluorescent bulbs that need to be shipped out of my facility. Do I need to handle these bulbs in a certain way?
Answer: It depends on whether or not the bulbs contain a certain amount of mercury and exhibit characteristics of waste toxicity. You can test this with the Toxicity Characteristic Leaching Procedure (TCLP). You can also check with the bulb’s generator who may have already tested the bulb’s mercury levels.
If your bulbs have less than 0.2 milligrams per liter (mg/L) of mercury they aren’t subject to federal regulations. Check state and local regulations, however, which might be stricter than federal regulations.
If your bulbs contain more than 0.2 mg/L of mercury, the bulbs are considered hazardous and need to be disposed of as such. You have a choice on how to manage hazardous bulbs and lamps.
According to the Environmental Protection Agency (EPA), hazardous fluorescent bulbs and lamps can be managed under full Resource Conservation Recovery Act (RCRA) hazardous waste regulations, or they can be managed under the RCRA’s Universal Waste Rule (UWR), which is less stringent than hazardous waste regulations.
The UWR was created to reduce the regulatory burden on generators, allow them more flexibility for managing universal waste streams and encourage recycling. Under the federal UWR, spent fluorescent bulbs and lamps that are intact and are going to be recycled have relaxed regulatory requirements.
Like RCRA’s hazardous waste rules, generators of universal waste are divided into categories. Small quantity handlers accumulate less than 5,000 kg of universal waste at any time. Large quantity handlers have greater than 5,000 kg of universal waste onsite at any time. It is important to note that state regulations vary greatly when it comes to managing universal wastes, so it is best to verify whether your state follows the federal regulation or if they have enacted more stringent rules.
Under the federal regulations, small quantity handlers of universal waste must:
- Not dispose of the universal waste [40 CFR 273.11(a)]
- Prevent releases (spills) into the environment [40 CFR 273.13(d)]
- Keep the lamps and bulbs in structurally sound, closed containers [40 CFR 273.13(d)]
- Immediately clean up any broken lamps or bulbs and place the waste in a sealed container [40 CFR 273.13(d) and 40 CFR 273.17]
- Label collection containers with the words “Universal Waste – Lamp(s),” “Waste Lamp(s)” or “Used Lamps” [40 CFR 273.14]
- Train employees on proper handling and emergency response procedures [40 CFR 273.16]
Large quantity generators of universal waste have similar requirements. They are forbidden to dispose of or treat the wastes, must label containers, prevent releases, clean up any broken lamps and train employees. In addition, they must also notify the EPA of their status as a large quantity generator, obtain an EPA identification number and track shipments.
According to the Association of Lighting and Mercury Recyclers, over 670 million fluorescent lamps and bulbs are recycled or disposed of in the United States each year. Improperly disposed of lamps can easily break and release two to four tons of mercury into the environment annually. Determine whether your fluorescent bulbs and lamps are federally or locally regulated before disposing of them.