Understanding the latest lamp disposal rules can reduce expense and potential liability.

Before July 6, 1999, federal and some state regulations made it difficult and expensive to properly manage the millions of lamps discarded each year as hazardous waste. Most states had adopted policies to prohibit lamp disposal in municipal landfills and were granting handling exemptions to users who recycle lamps.

Unfortunately, many lamps still ended up in municipal landfills, posing the hazard of mercury and lead contamination in groundwater. Fortunately, the EPA added mercury-containing lamps to the federal list of universal wastes regulated under the Resource Conservation and Recovery Act (RCRA) of 1990. Thanks to streamlined regulations regarding accumulation, storage, transport, treatment, and disposal, that act reduces the cost and regulatory burden on users who recycle.

Let’s take a look at some of the hazardous materials involved in the disposal and recycling of lamps and how you can protect yourself and the environment.

Mercury waste. Mercury is a heavy metal regulated under the RCRA waste disposal guidelines. Using the toxicity characteristic leaching procedure (TCLP), if the mercury within the waste leaches out at a rate of 0.2 mg/l or greater, the waste qualifies as a "D009" RCRA regulated waste.

You can classify mercury as an RCRA listed waste U151, when the metal is in its "unused" chemical grade form. Whether classified as a U151 or a D009, mercury is subject to the land disposal restrictions (LDR) for hazardous wastes as provided in 40 CFR Part 268.

You can treat hazardous wastes containing mercury by retort, incineration, or stabilization. Retorting (or roasting) is the preferred process for the environment, in which a thermal processing unit vaporizes mercury for subsequent condensation and recovery.

While handling any harmful waste, it’s important to know what you’re dealing with. It’s actually more harmful to inhale the vapor from a bead of mercury than to ingest the same bead. Unfortunately, mercury and mercury-contaminated materials vaporize at room temperature. Mercury is the only heavy metal that is liquid at room temperature—where it vaporizes readily into an invisible, odorless, and tasteless poison. You can control ambient mercury levels in the breathing zone if people are aware of, and trained in, mercury management. Be conscious of the hazard of unseen mercury contamination in cracks, corners, and untreated storage containers. Mercury handling requires the following protective equipment:

  • Gloves made of leather, or equivalent.

  • Safety glasses with side shields, or full-face shield.

  • Safety toed shoes or boots.

PCBs and regulation. Lamp ballasts contain an oil-filled capacitor, which may contain polychlorinated biphenyls (PCB) or di (2-ethyl hexyl) phthalate (DEHP). The U.S. EPA Comprehensive Environmental Response Compensation and Liability Act ("Superfund") classifies these as hazardous substances. Several states, including Massachusetts, Maine, Rhode Island, and California, regulate PCBs as hazardous wastes. According to data in the Toxic Substances Control Act Section 21 Petition, ballasts manufactured prior to July 1978 have more than a 50% chance of containing PCBs at 50 ppm or greater in their potting material. The US EPA is asking anyone who seeks to dispose of these ballasts in a municipal landfill to dispose of them as PCB waste. The recommended disposal method is high temperature incineration. Equipment labeled "Non-PCB" has no PCBs. If the equipment is either unmarked or poorly marked, you should assume PCB content is less than 500 ppm and dispose of it in accordance with TSCA guidelines.

Most ballasts and capacitors you encounter pose no health risk. However, even when handling ballasts or capacitors with very small amounts of PCB fluid, you must wear the correct protective equipment:

  • Gloves made of chemical resistant neoprene coated, butyl rubber, or leather.

  • Safety glasses with side shields or full-face shield.

  • Safety toed shoes or boots

The Toxic Substance Control Act (TSCA) requires you to store PCB ballasts in approved DOT drums, once you remove them from their fixtures. You should store the drums indoors. You can store them outdoors, but they must be on an impervious surface, the drum lids must be secure, and the drums must be protected from weather and vandalism.

Separate ballast by type (PCB, non-PCB). Visually check for leaking units. You must double-bag leaking PCB ballasts and place them in drums containing at least 3 in. of vermiculite. Place the other ballasts into regular drums. Properly label all drums PCB or Non-PCB, and secure the lids.

If protective equipment comes into contact with any material leaking from a capacitor, you must place it in proper containers for disposal. As was noted with the disposal of lamps, wash your hands with soap and water when beginning the work, before a break, and upon completion of the work. No tobacco materials, food, or beverages are permitted while working with lamp ballasts.

Lamp disposal. The EPA estimates that within 4 yr, landfills will no longer accept mercury-containing lamps. This means you will need to send these lamps to certified recyclers. Fortunately, many of these companies have experience with industrial users and can make the process almost transparent to you. If you follow the handling and storage guidelines, you can practice good corporate citizenship and good economics at the same time. Place lamps in lamp boxes and tape the ends shut—you do not need to place the original egg crate material back into the boxes. Be aware of the following:

  • Package broken or crushed lamps in an approved container (55 gallon drum).

  • Badly damaged boxes and wet boxes will not be accepted for transport.

  • Keep boxes in a secure, dry area.

  • Palletize lamp boxes to a maximum height of 6 ft.

  • Secure boxes to the pallet with shrink wrap or stretch film.

  • Label all pallets as Used Mercury Lamps or Universal Waste Mercury Lamps.

  • Provide the following information to schedule a pickup: contact person, date of pickup, physical address of location, and material location.

Wash hands with soap and water before a break and upon completion of the work. Again, you must avoid tobacco materials, food, or beverages while working with mercury lamps.

Violating hazardous waste regulations can trigger state and federal enforcement actions and result in significant monetary fines. If you follow the rules, though, you can not only avoid legal action, but help protect the environment as well.