Lighting Waste Management

October 1998 - TI#18403
(Revised March 2000)
Introduction
Important Terms
Governing Regulations
Managing PCB-containing Ballasts
Managing DEHP-containing Ballasts
Managing Mercury-containing Fluorescent
Light Tubes and HID Lamps
"Green" Lighting
Summary
For More Information
Document References

Introduction
Fluorescent light tubes, high intensity discharge (HID) lamps and lamp ballasts are used in almost every residence and building, as well as in outdoor areas. These types of energy efficient lights are increasingly used to replace less efficient incandescent (heated filament) lights. However, when fluorescent tubes, HID lights, and ballasts are removed, they may require management and disposal as a hazardous waste. This is because the lamps and ballasts may contain regulated hazardous materials such as polychlorinated biphenyls (PCBs), mercury, or di (2-ethylhexyl) phthalate (DEHP). The purpose of this Fact Sheet is to describe the potential hazardous components of these types of lights, discuss waste management techniques, summarize applicable regulations, and provide pollution prevention and recycling information.

Important Terms
Ballast - a device, typically located in the lamp fixture (luminaire), used to operate fluorescent and HID lamps. The ballast provides starting voltage, limits the current, and matches the line voltage to the arc voltage. Fluorescent and HID lamp ballasts contain a small capacitor that may contain high concentrations of PCBs, a possible human carcinogen. Some ballasts manufactured between 1979 and 1991 contain the PCB replacement DEHP.

Chemical Waste Landfill - a landfill permitted under the Toxic Substance Control Act (TSCA) that accepts hazardous substances and extremely hazardous waste. The facility must meet different engineering requirements than hazardous waste landfills permitted under Subtitle C (Hazardous Waste Landfills) of the Resource Conservation and Recovery Act (RCRA).

Fluorescent Lamp - a light source consisting of a tube filled with argon, along with krypton or another inert gas. When electrical current is applied, the resulting arc emits ultraviolet radiation that excites the white "phosphor" coating the inside of the lamp wall, causing the lamp to radiate visible light. Fluorescent lamps contain a small amount of mercury. Tungsten-halogen lamps contain only minimal amounts of some halogens and do not warrant any special waste disposal considerations, and therefore are not discussed in this fact sheet.

Hazardous Waste Landfill - a hazardous waste landfill is a landfill that is permitted under RCRA Subtitle C and is engineered to contain hazardous wastes. Incoming wastes are manifested by the generating facility and some incoming hazardous wastes may be subject to treatment standards.

High Intensity Discharge (HID) Lamps - a generic term referring to mercury vapor, metal halide, and high- & low-pressure sodium light sources. HID lamps contain a small amount of mercury.

Potting Material - an insulation material that fills the space between the functioning parts of a ballast and its outer covering (shell).

Governing Regulations
TSCA
The Toxic Substances Control Act (TSCA), enacted in 1976, banned the production, processing, and distribution in commerce of PCBs in the United States. Under TSCA, and subsequent amendments added in June 1998, leaking PCB-containing ballasts must be incinerated in an EPA-approved high-temperature incinerator. Non-leaking ballasts may be disposed in conventional municipal solid waste landfills. Other, more environmentally responsible disposal methods for non-leaking PCB-containing ballasts include incineration, recycling, or disposal in a chemical or hazardous waste landfill. The complete regulatory requirements governing the use and disposal of PCBs are found in Title 40 Code of Federal Regulations (CFR) Part 761, "Polychlorinated Biphenyls (PCBs) Manufacturing, Processing, Distribution in Commerce, and Use Prohibitions." The requirements of Part 761, as they pertain to PCB-containing light ballasts, are discussed in more detail later in the Fact Sheet.

DEHP-containing ballasts, as well as mercury-containing fluorescent tubes and HID lamps, are not regulated under TSCA.

CERCLA
The Comprehensive Environmental Response, Compensation and Liability Act (CERCLA) regulates the release of PCB-containing ballasts, DEHP-containing ballasts, and mercury-containing fluorescent tubes and HID lamps. "Release" means any spilling, leaking, pumping, pouring, emitting, emptying, discharging, injecting, escaping, leaching, dumping, or disposing into the environment (including the abandonment or discarding of barrels, containers, and other closed receptacles containing any hazardous substance or pollutant or contaminant). When a release exceeds the CERCLA reportable quantity in a 24 hour period, solid waste generators are required to notify the National Response Center (NRC) at (800) 424-8802. Release reporting is not required when disposal is governed by a federally enforceable permit, such as a hazardous waste permit under RCRA. The release reporting requirements of CERCLA would be in effect when:

  • Disposing of one pound or more of PCBs in a 24-hour period. Approximately 12 to 16 PCB-containing ballasts will contain about one pound or more of PCBs. This notification requirement applies only to non-leaking ballasts since disposal of leaking PCB-containing ballasts is governed under TSCA.
  • Disposing of one hundred pounds or more of DEHP in a 24-hour period. Approximately 1,600 DEHP-containing ballasts will contain about one hundred pounds or more of DEHP.
  • Disposing of one pound or more of mercury in a 24-hour period. Approximately 11,000 four-foot T12 mercury-containing fluorescent lamps will contain about one pound or more of mercury.
In addition, under CERCLA, persons disposing of hazardous substances may be held liable for response costs if there is a release or threat of a release of a hazardous substance into the environment. All generators may incur this liability for disposing of PCB, DEHP, or mercury-containing wastes in a dumpster, local landfill, or other facility. CERCLA liability is a possibility should the wastes become a source of environmental contamination requiring cleanup under Superfund.

RCRA
The Resource Conservation and Recovery Act (RCRA) regulates the management of non-hazardous and hazardous solid waste. Solid waste generators are responsible for identifying and characterizing their hazardous waste streams and managing them in accordance with RCRA. Fluorescent light tubes and HID lamps are not listed RCRA hazardous wastes. However, mercury (found in fluorescent light tubes and HID lamps) is a characteristic hazardous waste due to its toxicity. Therefore, mercury-containing fluorescent light tubes and HID lamps may constitute a hazardous waste stream.

DEHP is listed as EPA Hazardous Waste No. U028 when it is an unused commercial chemical product being discarded or is intended to be discarded. However, the DEHP in lighting ballast capacitors is considered "used" and therefore no longer meets the listing description. By definition then, DEHP as found in lighting ballasts is not itself a listed hazardous waste.

Although not listed hazardous wastes, ballasts and capacitors destined for disposal, regardless of their chemical makeup, may be regulated as a RCRA hazardous waste if they meet any of the characteristic hazardous waste criteria in Title 40 CFR Part 261 Subpart C, "Characteristics of Hazardous Waste."

PCB containing ballasts are regulated under TSCA, as discussed above, and are not addressed under the requirements of RCRA.

The Universal Waste Rule
On 11 May 1995, the EPA adopted the Universal Waste Rule (Title 40 CFR Part 273). The rule established streamlined management practices for universal wastes and provides relief from the full regulatory aspects of RCRA. Additional information on the Universal Waste Rule is contained in the PRO-ACT Fact Sheet "Universal Waste Rule" (currently under revision).

In July 1999, the EPA added spent lamps to the federal list of universal wastes, and the revised universal waste regulations became effective 6 January 2000. The Universal Waste Rule defines lamps as "the bulb or tube portion of an electric lighting device." Examples of common universal waste lamps include spent fluorescent, high intensity discharge, neon, mercury vapor, high pressure sodium and metal halide lamps.

Although the rule provides less stringent practices for storage, handling, and transportation; universal wastes are still considered hazardous and must be disposed of properly. Because not all States have adopted the Universal Waste Rule as a part of their program, generators should consult regional, State, and local regulations regarding proper management.

Managing PCB-containing Ballasts
Proper management and disposal of PCB-containing ballasts includes:
  1. understanding federal, state and local requirements;
  2. identifying ballasts containing PCBs; and
  3. identifying and removing leaking PCB-containing ballasts.
According to the EPA, all ballasts manufactured prior to July 1978 have a greater than 50% chance of containing PCBs at 50 parts per million (ppm) in their potting material. Ballasts manufactured after July 1978 are required to bear a "No PCBs" label indicating that they do not contain PCBs. In considering how best to manage lighting ballasts manufactured prior to July 1978, the EPA offered two suggestions to generators in the preamble to the June 1998 TSCA Amendments (63 FR 35383). First, the EPA suggests that generators assume that all of these ballasts contain PCBs at 50 ppm or greater in their potting material and dispose of them as PCB waste (discussed below). The second recommendation is for generators to conduct a survey of ballast manufacturers and types, and then develop a random sampling plan for each manufacturer and type to analyze the ballasts. Currently, the Office of the Air Force Civil Engineer (HQ USAF/ILEVQ) is considering these suggestions and is formulating an Air Force-wide policy on the disposition of lighting ballasts manufactured prior to July 1978. PRO-ACT will publish this policy in our CrossTalk publication as soon as it becomes available.

Federal requirements for managing and disposing of PCB-containing ballasts are different for ballasts that are leaking vs. ballasts that are not leaking. Therefore, it is very important to determine if PCB-containing ballasts are leaking before they are removed from use.

For leaking PCB-containing ballasts, the ballast and all parts the leaking material contacts are considered PCB wastes and are subject to TSCA requirements. Leaking PCB-containing ballasts and associated contaminated wastes must be incinerated at an EPA-approved, high-temperature incinerator. The TSCA Information Hotline, (202) 554-1404, can answer questions regarding the proper removal, packing, storage, transportation, and disposal of leaking PCB-containing ballasts and other PCB wastes.

Under TSCA, non-leaking PCB-containing ballasts may be disposed of in municipal solid waste (MSW) landfills. EPA recommends packing and sealing the intact ballasts in 55-gallon drums. However, it is important to note that state and/or local governments may have additional, more stringent requirements for disposing of PCB-containing light ballasts. Additionally, some MSW landfills may refuse to accept non-leaking PCB-containing ballasts, or ballasts that are not labeled "No PCBs." Finally, although the EPA had initially proposed to limit the number of PCB-containing light ballasts that generators could dispose of in MSW landfills to 25 per year, this limitation was not included in the final rule amendments promulgated in June 1998. The EPA did caution however that generators who dispose of PCB-containing ballasts in MSW landfills could be subject to liability under CERCLA if the landfill should ever become a Superfund site. Generators of PCB-containing ballasts are encouraged to consult with state and local officials, and MSW landfill operators, prior to disposing of known, non-leaking PCB-containing ballasts.

Generally, there are three methods for disposing of non-leaking PCB-containing ballasts that are considered to be more environmentally responsible than disposal in municipal solid waste landfills. They are:

  • High temperature incineration - this method destroys the PCBs, permanently removing them from the waste stream and limiting future generator liability under CERCLA.
  • Recycling - with this method, recyclers remove the PCB-containing ballasts, which are subsequently incinerated or landfilled. Usable materials, such as metals, are then reclaimed for secondary uses.
  • Disposal in Chemical or Hazardous Waste Landfill - this disposal method neither eliminates PCBs from the waste stream nor limits potential future generator liability under CERCLA. However, the waste is disposed in a more controlled and monitored environment than municipal solid waste landfills.
Managing DEHP-containing Ballasts
DEHP containing ballasts are found in the same types of fixtures as PCB containing ballasts, but are not specifically regulated under TSCA. Proper management and disposal of DEHP-containing ballasts includes understanding federal, state and local requirements and identifying ballasts containing DEHP. DEHP may be found in ballasts designed for the following lighting fixtures: 1) four-foot fluorescent fixtures manufactured between 1979 and 1985; 2) eight-foot fluorescent fixtures manufactured between 1979 and 1991; and 3) HID fixtures manufactured between 1979 and 1991. To determine if ballasts contain DEHP, contact the manufacturer or send a sample capacitor to a laboratory for testing.

Generally, there are four methods for disposing of DEHP-containing ballasts. They are:

  • High temperature incineration - this method destroys the DEHP, permanently removing it from the waste stream and limiting future generator liability under CERCLA.
  • Recycling- with this method, recyclers remove the DEHP-containing capacitors which are subsequently incinerated or landfilled. Usable materials, such as metals, are then reclaimed for secondary uses.
  • Disposal in Chemical or Hazardous Waste Landfill - this disposal method neither eliminates DEHP from the waste stream nor limits potential future generator liability under CERCLA. However, the waste is disposed of in a more controlled and monitored environment than municipal solid waste landfills.
  • Municipal Solid Waste Landfill - since the DEHP has been used, it is not a hazardous waste and can be discarded as solid waste. This landfill method neither eliminates DEHP from the waste stream nor limits potential future generator liability under CERCLA.
Managing Mercury-containing Fluorescent Light Tubes and HID Lamps
Proper management and disposal of mercury-containing fluorescent light tubes and HID lamps includes understanding federal, state and local requirements and determining whether the waste stream is hazardous. Generators of used fluorescent light tubes and HID lamps are responsible for determining whether the waste stream is hazardous. This is done either through generator knowledge or by testing. For information on applying generator knowledge, see Title 40 CFR Part 262.11(c)(2). To test whether a waste stream is hazardous, generators must use the Toxicity Characteristic Leaching Procedure (TCLP). If TCLP is not used to test the waste stream, EPA recommends it be assumed hazardous and managed accordingly. The RCRA Hotline, (800) 424-9346, can answer specific questions regarding RCRA and universal waste regulations on waste identification, storage, transportation and disposal. Small quantity generators of used fluorescent light tubes and HID lamps may qualify for a conditional exemption, thereby excusing them from RCRA identification, storage, treatment and disposal requirements.

Generally, there are two methods for disposing of used mercury-containing fluorescent light tubes and HID lamps discarded as hazardous waste. They are:

  • Recycling - recycling separates the toxic substances (e.g., mercury) from the glass, aluminum, and other lamp components. All materials, including the mercury, may be reused in manufacturing other products. Recycling can be accomplished on-site or at an off-site recycling service provider.
  • Disposal in Chemical or Hazardous Waste Landfill - this landfill method neither removes mercury from the waste stream or limits potential future generator liability under CERCLA. However, the waste is disposed of in a more controlled and monitored environment than municipal solid waste landfills. Mercury-containing fluorescent light tubes and HID lamps generated in small quantities, or determined by TCLP not to be hazardous, may be disposed of in municipal solid waste landfills.
"Green" Lighting
Three lighting manufacturers currently offer lamps with low mercury content, which pass the current federal EPA Toxicity Characteristic Leading Procedure (TCLP). Since these lamps are TCLP-compliant, they may be disposed of in the solid (non-hazardous) waste stream; however, recycling of these items is still preferred.

Although, these low mercury content lamps pass the federal TCLP, some States enforce stricter regulations/limits than those set by federal standards. Also, it is still the responsibility of the end user to ensure the lamps are disposed of in accordance with local, State, and federal regulations. Consultation with State and local regulators is required to ensure proper waste management.

The Defense Logistic Agency (DLA) has several low mercury content lamps stock listed. For additional information on low mercury content lamps visit, the DLA web site at http://www.dscp.dla.mil/gi/general/lightcat.htm or contact PRO-ACT at DSN 240-4215.

Summary
Fluorescent light bulbs and HID lamps (including their ballasts) are energy efficient, pollution reducing devices. EPA encourages their use as well as their proper management. The two primary management concerns are the disposal and/or recycling of 1) PCB-containing ballasts and 2) mercury-containing lamps/tubes. Successful management includes an understanding of the products in use, as well as an understanding of federal, state and local requirements regarding their proper handling and disposal. In some cases, it may be possible to go beyond regulatory requirements and manage wastes in an even more environmentally responsible manner. Rather than disposing of these wastes in Municipal Solid Waste Landfills, disposal through high-temperature incineration, recycling, or chemical or hazardous waste landfilling may be chosen. In addition to being more environmentally responsible, these disposal methods may also reduce or eliminate potential future generator liability under CERCLA.

For More Information
More information about the use and proper management of fluorescent light tubes and HID lamps and lamp ballasts is available from the following sources:

Ms. Nancy Carper, DSN 240-4964, Headquarters Air Force Center for Environmental Excellence (HQ AFCEE). Ms. Carper is available to provide solid waste recycling technical assistance.

Ms. Cindy Hood, DSN 240-5663, HQ AFCEE. Ms. Hood is avaiable to provide regulatory compliance and pollution prevention assistance.

EPA's Energy Star Buildings Green Lights Program hotline may be contacted at (888) 782-7937, or visit their WWW site at: http://www.epa.gov/greenlights.html. The EPA Green Lights Program, Lighting Upgrade Manual, is available at http://www.epa.gov/buildings/esbhome/tools/lighting.html. The chapter of Lighting Waste Disposal provideds an overview of issues relating to the disposal of lamps and ballasts. It provides an extensive list of information sources including EPA Regional Offices, State Solid Waste and Hazardous Waste Agencies, EPA-approved disposal locations (incinerators and landfills), and reycling resources.

DLA's "Energy Efficient Lighting Catalog" provides information on low mercury content lamps and can be viewed at http://www.dscp.dla.mil/gi/general/lightcat.htm. For additional information contact the DLA customer support lighting number (800) DLA-BULB or PRO-ACT at DSN 240-4243 or (800) 233-4356.

Document References
"Lighting Waste Disposal," US EPA Publication EPA 430-B-95-004, February 1997.

Brandes, William F., Waste Identification Branch, US EPA, letter to Mr. Mitchell Dong, President, FulCircle Ballast Recyclers, June 8, 1994.

Title 40 CFR Part 761, "Polychlorinated Biphenyls (PCBs) Manufacturing, Processing, Distribution in Commerce, and Use Prohibitions."

Title 40 CFR Part 262, "Standards Applicable to Generators of Hazardous Waste."

"Disposal of Polychlorinated Biphenyls (PCBs); Final Rule," 63 FR 35383, 29 June 1998