A Fact Sheet from PRO-ACT: Disposal of Fluorescent Light Tubes, High Intensity Discharge Lamps and Flourescent Lamp Ballasts

PRO-ACT
A Base-level Pollution Prevention Resource sponsored by HQ AirForce Center for Environmental Excellence
March 1995

Introduction

Fluorescent light tubes and lamp ballasts, and high intensity discharge (HID) lamps are found throughout our environment in residences, office buildings, commercial and industrial buildings, streets, and parking lots. They are energy efficient and virtually indispensable. Their disposal, however, can create waste which are often classified as hazardous. The purpose of this fact sheet is to provide information on the components which make the waste hazardous and on appropriate waste disposal procedures.

Federal Requirements

Fluorescent Light Tubes and High Intensity Discharge Lamps

Fluorescent light tubes and HID lamps contain mercury which is a Resource Conservation and Recovery Act (RCRA) characteristic hazardous waste (D009). The disposal of mercury-containing wastes is regulated by the Environmental Protection Agency (EPA) in Title 40 Code of Federal Regulations (40 CR), Part 261, "Identification and Listing of Hazardous Waste."

Title 40 CDR 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.

Exclude the lamps from regulation as a hazardous waste provided they are disposed in permitted municipal landfills or managed in permitted reclamation facilities; or
Aid mercury-containing lamps to EPA's Universal Waste Proposal. The Universal Waste approach is a streamlined, reduced regulatory structure designed to address the management of certain widely generated wastes currently subject to full RCRA regulations. Its purpose is to encourage conservation, improve regulatory implementation, and encourage exempt users to utilize the same disposal systems as regulated users.

The comment period for this proposed rule is 26 September 1994. Once the EPA has reviewed all comments received, the Agency will make a final decision concerning the handling of mercury-containing lamps. Until then the current rules still apply.

Fluorescent Lamp Ballasts

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 noncrystalline 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 of a black, tar-like compound.

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:

All ballasts manufactured through 1979 contain PCBs.
Ballasts manufactured after 1979 that do not contain PCBs are labeled "NO PCBs."
If a ballast is not labeled "NO PCBs," assume it contains PCBs.

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.

PCB-containing ballasts that have been damaged and are leaking must be incinerated in an EPA-approved high temperature incinerator.

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 points of 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 you 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.

Table 1. Recycling Centers for Flourescent Light Tubes, High Intensity Discharge Lamps and Fluorescent Lamp Ballasts

Tubes/Lamps MTI: (800) 808-4684
Melbourne, FL

Lighting Resources, Inc.: (714) 622-0881 or
386 South Gordon Street: (800) 572-9253
Pomona, CA 91766

Mercury Recovery Systems: (818) 301-1372
2021 South Myrtle
Monrovia, CA 91016

Mercury Technologies Corporation: (707) 745-5173
140 West Industrial Way
Bencia, CA 94510

Nine West Technologies: (201) 623-0007
Newark, NJ 07102

Quick Silver Products, Inc.: (415) 468-2000
Brisbane, CA

Recyclights: (800) 831-2852
2010 East Hennepin Avenue
Minneapolis, MN 55413-2799

Lamp Ballasts

Eastern Environmental Technologies: (203) 856-2014
Norwalk, CT

Ensquare, Inc.: (617) 969-9238
Newton Upper Falls, MA

Environmental Energy Group: (817) 383-3632
Denton, TX

FulCircle Ballast Recyclers
Cambridge, MA: (617) 876-2229
Bronx, NY: (212) 328-4667

Salesco U.S.A.: (800) 368-9005
Honolulu, HI

Transformer Services, Inc.: (603) 224-4006
Concord, NH 03302

Note: Information contained in Table 1 was obtained from "Lighting Waste Disposal" published by the EPA Green Lights Program and EPA Region IV. Air Programs Branch.

References

Lighting Waste Disposal, EPA Green Lights Program, January 1994. Dangerous Properties of Industrial Materials, Seventh Edition, Volume III, N. Irving Sax and Richard J. Lewis, Sr., 1989.
National Archives and Records Administration, Code of Federal Regulations, Protection of Environment 40 Parts 260 to 299, Revised July 1, 1993 (Washington, DC: GPO 1993).
Environmental Protection Agency, Federal Register, Part XXII, Semiannual Regulatory Agenda, FR 59 - 21095, April 25, 1994.
Environmental Protection Agency, Federal Register, Part II, 40 CFR Parts 260 et al., Hazardous Waste Management System; Modification of the Hazardous Waste Recycling Regulatory Program; Proposed Rule, FR 58 - 8102, February 11, 1993.
Environmental Protection Agency, Federal Register, Part IV, 40 CFR Parts 260, 261 and 273, Hazardous Waste Management System; Modification of the Hazardous Waste Program; Mercury-Containing Lamps; Proposed Rule, FR 59 - 38288, July 27, 1994.
Characterization of Products Containing Mercury in Municipal Solid Waste in the United States, 1970 to 2000, U.S. Environmental Protection Agency, Office of Solid Waste, Municipal and Industrial Solid Waste Division, OSW# EPA530-R-92-013, April 1992.
National Institute for Occupational Safety and Health, Centers for Disease Control, Department of Health and Human Services, letter with attachments to requester. Received July 18, 1994.
Research Triangle Institute, Management of Used Fluorescent Lamps: Preliminary Risk Assessments, Final Report, prepared for the U.S. Environmental Protection Agency, Office of Solid Waste, Characterizations and Assessment Division, Revised May 14, 1993.
U.S. Environmental Protection Agency, Region IV, Air Programs Branch, Individual State Replies, Regulations Concerning Fluorescent Lighting Ballasts and Lamp Disposal.
Syracuse Research Corporation, Toxicological Profile for Selected PCBs (Aroclor-1260, -1254, -1248, -1242, -1232, -1221, and -1016), prepared for the Agency for Toxic Substances and Disease Registry (ATSDR), U.S. Public Health Service in collaboration with the U.S. Environmental Protection Agency, June 1989.

Fact Sheet TI #0789 - March 1995

Need more information?
Call PRO-ACT
DSN 240-4214 (800) 233-4356

Return to top of this document.

Return to P2 Facts Sheets

Last Updated: April 8, 1997