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Disposal of Fluorescent Light Tubes, High Intensity Discharge Lamps and Fluorescent Lamp Ballasts
March 1995 - TI#0789A |
Title 40 CFR 261 defines four characteristics which can make a waste hazardous: ignitability, corrosivity, reactivity, and toxicity. Mercury has the characteristic of toxicity. This means if a representative sample of a waste containing mercury is analyzed using the EPA's Toxicity Characteristic Leaching Procedure (TCLP), and the mercury content of the leachate is equal to or exceeds 0.2 mg/L, the waste is classified as hazardous.
Currently, fluorescent light tubes and HID lamps are neither listed nor excluded as hazardous wastes under EPA regulations. Prior to disposal, tubes and lamps can be handled and stored safely without being managed as hazardous waste. They can also be disposed in any municipal solid waste landfill, as long as the waste does not fail the TCLP and become classified as hazardous. However, once the waste containing the fluorescent light tubes and HID lamps is declared hazardous, it must be handled as such with all the accompanying regulations and procedures.
There are several exemptions to these requirements. Lamps generated as household waste are exempt from regulation as hazardous waste. Conditionally exempt small quantity generators (generate 100 kg or less of hazardous waste per month) are also exempt from RCRA hazardous waste regulations.
In 1991, EPA initiated a voluntary energy conservation program called "Green Lights" to encourage pollution prevention through the use of energy efficient lighting. Energy efficient lighting, however, requires the use and eventual disposal of fluorescent light tubes and HID lamps. To encourage participation in the Green Lights program, the EPA is proposing to reduce unnecessary regulatory burdens arising from current requirements to manage used fluorescent light tubes and HID lamps as hazardous waste.
On 27 July 1994, the EPA published, in the Federal Register, a proposed rule to modify the management of waste mercury-containing lamps. The EPA proposed two possible alternatives.
Fluorescent Lamp Ballasts
The Toxic Substances Control Act (TSCA), in 1976, banned the production of PCBs in the United States because there was evidence they accumulate in the environment and are a human health hazard.
The following guidelines should be used to determine if your ballasts contain PCBs:
PCB- containing ballasts that have been damaged and are leaking must be incinerated in an EPA-approved high temperature incinerator.
Fluorescent lamp ballasts may contain polychlorinated biphenyls (PCBs). PCBs are a family of man-made chemicals that contain 209 individual compounds. Their composition can vary from mobile oily liquids to white crystalline solids to hard non-crystalline resins. They were used widely as coolants and lubricants in transformers, capacitors, and other electrical equipment. In fluorescent fixtures, PCBs were usually found in ballasts either within small capacitors or in the form a black, tar-like compound.
The EPA regulations governing the use and disposal of PCBs are found in 40 CFR Part 761, "Polychlorinated Biphenyls (PCBs) Manufacturing, Processing, Distribution in Commerce, and use Prohibitions." PCB-containing ballasts that are intact and are not leaking can be disposed in a municipal solid waste landfill in properly packed and sealed 55-gallon drums. The Green Lights program, however, recommends use of high-temperature incineration, a chemical or hazardous waste landfill, or recycling as responsible waste management.
State Requirements
Before disposing of fluorescent light tubes and lamp ballasts, and HID lamps, Air Force personnel can contact their state regulatory agency since the appropriate procedures can vary from state to state. You may contact PRO-ACT for a list of state fluorescent light tube pointsof contact or contact your base environmental coordinator for more information. Table 1 contains a list of recycling centers for fluorescent light tubes and lamp ballasts, and HID lamps.
For More Information
If your desire more information on the disposal of fluorescent light tubes and lamp ballasts, and HID lamps or on the Green Lights program, you can contact PRO-ACT at DSN 240-4214 or (800) 233-4356. Our fax number is DSN 240-4254.
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Table of Recycling Centers Recycling Centers for Fluorescent Light Tubes, High Intensity Discharge Lamps and Fluorescent Lamp Ballasts |
| MTI (800) 808-4684 Melbourne, FL |
Lighting Resources, Inc. (714) 622-0881 or (800) 572-9253 386 South Gordon Street Pomona, CA 91766 |
| Mercury Recovery Systems (818) 301-1372 2021 South Myrtle Monrovia, CA 91016 |
Mercury Technologies Corp. (707) 745-5173 140 West Industrial Way Benicia, CA 94510 |
| Nine West Technologies (201) 623-0007 Newark, NJ 07102 |
Quick Silver Products, Inc. (415) 468-2000 |
| Recyclights (800) 831-2852 2010 East Hennepin Avenue Minneapolis, MN 55413-2799 |
| Eastern Environmental Technologies (203) 856-2014 Norwalk, CT |
Ensquare, Inc. (617) 969-9238 Newton Upper Falls, MA |
| Transformer Services, Inc. (603) 224-4006 Concord, NH, 03302 |
Environmental Energy Group (817) 383-3632 Denton, TX |
| FulCircle Ballast Recyclers (617) 876-2229 Cambridge, MA (212) 328-4667 Bronx, NY |
Selesco U.S.A. (800) 368-9005 Honolulu, HI |