What are you doing to prevent environmental problems associated with spent lamps?
Each year nearly 600 million lamps are dumped in landfills and solid waste incinerators across the nation, and energy-efficient fluorescent lamps containing mercury make up the largest number of those trashed. In the past, the Environmental Protection Agency (EPA) considered these lamps hazardous waste. But with the revisions to the Universal Waste Rules (UWR) effective January 2000, businesses now have the option to treat used mercury-containing lamps as universal waste, thus reducing the costs associated with storage, transportation, and record keeping requirements.
Past concerns. As defined by EPA guidelines, hazardous waste is any refuse material that fails the Toxicity Characteristic Leaching Procedure (TCLP) test, a laboratory test that simulates the potential leaching of hazardous wastes under conditions typically found in municipal solid waste landfills. If the concentration of mercury in water passed through a sample of crushed fluorescent lamp fragments exceeds 0.2 mg/liter, the lamp fragments are considered hazardous waste. In most cases, fluorescent lamps and lamp fragments fail the TCLP test. This designation caused problems for several plants and facilities where workers complained that managing spent lamps as hazardous wastes on-site took up too much space. Storing intact lamps also created concerns about meeting federal Resource Conservation Recovery Act-imposed storage deadlines, and shipping costs for hazardous wastes were higher than for universal wastes.
First passed by the EPA in May 1995, the UWR regulate and encourage recycling of hazardous waste nickel-cadmium and other batteries, certain types of waste pesticides, and mercury-containing lamps, including mercury vapor, metal halide, and high-pressure sodium. Since the amendment of the UWR in January 2000 to include mercury-containing lamps, facilities that use such lights no longer have to deal with the processes involved in their disposal and reclamation, making it easier and more attractive to recycle the spent lamps.
Facilities that store universal waste on-site fall into two categories: large quantity handlers (LQHUW) and small quantity handlers (SQHUW) of universal waste. An SQHUW is one that stores less than 11,000 lb of universal waste on any given day, and an LQHUW stores more than 11,000 lb. Due to the dangers involved with these materials, facilities must provide basic handling and emergency action information or training to employees who handle the waste.
There are several ways improper lamp disposal can do damage to humans, animals, and the environment. Mercury vapor from broken lamps can escape into the air and affect the central and peripheral nervous systems, lungs, kidneys, skin, and eyes in humans. Environmental problems occur when mercury seeps into the earth and settles into ground and surface waters.
The liquid form can also be ingested via fish and birds that have been exposed to large doses. Lead, which is also found in used lamps, causes severe environmental damage, and children exposed to it are more likely to have lower IQ. Yet despite the dangers associated with improper disposal, it's common to find anywhere from one to dozens of spent fluorescent tubes tossed in with regular trash at commercial waste facilities.
Many facilities refuse to comply with the lamp-disposal laws in a misguided attempt to reduce cost, but when you consider the potential fines and the lengths to which the courts will go to prosecute corporations that knowingly break environmental laws, this is not a smart strategy. So as a contractor, what can you do to make sure your customers are doing their part to reduce the levels of hazardous waste in the local landfills? When bidding a re-lamping job (Photo on page 32) or writing the specifications for bid, ask your customer (or your plant manager), “Do you want recycling with that?”
Adhering to recycling rules.
Proper recycling provides the lowest cost approach for protecting natural resources from mercury poisoning. Through the UWR, the EPA has established methods by which businesses must dispose of and recycle mercury-containing devices, including lamps. Penalties for noncompliance are stiff and enforcement of the recycling laws is increasing. Don't assume low-mercury lamps are exempt from these requirements. Ecologic lamps have less mercury, but they still have mercury and they're still toxic.
Follow these recommendations to manage the mercury hazard in fluorescent and HID lamps:
Don't crush or break the lamps.
Store mercury-containing lamps in a manner that will prevent them from breaking. Ideally, unbroken used lamps should be packed in boxes.
Don't tape lamps together. Lamps stored in this manner can break by implosion.
Store any broken lamps in a nonmetal closed container marked “Broken Mercury-Containing Lamps.” Broken lamps may be sent to a permitted recycling facility or a licensed hazardous waste facility as hazardous waste, according to federal/state hazardous waste requirements.
Ship the lamps to a permitted TSD site for recycling.
Once the lamps are out of your hands, recycling and reclamation facilities have two ways to reduce their hazard to the environment: recycling or retorting. A recycler separates component parts and handles hazardous materials per the UWR into five categories: aluminum end caps, brass, glass, mercury-rich phosphor powder, and bake-o-lite insulation.
Mercury reclamation facilities retort the lamps. When a crushed lamp and its components are heated under high temperature and vacuum, the mercury is vaporized, condensed, and extracted from the powders, glass, and metal components. Almost all of the mercury is recovered and reused.
It's important to note that not only are you responsible for following proper procedures in recycling your lamps, but the facility you send your universal waste to must be in compliance with 40CFR parts 264, 270, and 261.6(c)(2) and be properly permitted to accept the waste you're sending.
How can you best eliminate the potential for environmental damage when disposing lamps? Shop around for someone who can give you a turn-key solution to your lamp disposal needs. Ask important questions, such as what their requirements are for packaging, labeling, and pickup. If they've taken the time to pre-pare a kit to make your job easier, that's a good sign they have a customer focus.
Fitch is President, Atlantic Inland Environmental Services, Inc., Wayne, Pa.