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By John L. Fetters
August 2006 -
Environmental awareness affects every area of institutional and commercial facilities, as well as most activities of maintenance and engineering departments. In recent years, such awareness has extended to lighting systems, primarily lamps and ballasts.
Managers face a host of options and decisions related to properly disposing of these products at the end of life (EOL), and developing a successful strategy starts with understanding the challenges and the resources available.
U.S. consumers dispose of more than 600 million fluorescent lamps annually. Fluorescent lamps that contain more than 0.2 milligrams per liter of mercury will not pass the toxicity characteristic leaching procedure (TCLP) from the U.S. Environmental Protection Agency (EPA).
The Universal Waste Rule (UWR) covers spent fluorescent and high-intensity-discharge lamps — mercury, metal halide, and high-pressure sodium — that have been removed after service life. The rule allows end users to handle them as universal waste.
In 1999, the UWR added hazardous-waste lamps to the existing list of universal wastes regulated under the Resource Conservation and Recovery Act (RCRA) in 1999. This action reduced the regulatory burden on generators in collecting, storing and transporting lamps that had been classified as hazardous waste. End users still must comply fully with recycling, treatment and disposal laws.
For example, end users must label waste lamps as “Universal Waste–Lamps,” not "Hazardous Waste” and must ship them to another handler or a designated facility. A small-quantity handler does not have to manifest shipments but must mark shipping containers according to U.S. Department of Transportation requirements.
Managers must be thorough, however. States can modify the UWR and add universal waste to their regulations, so managers need to check regional EPA web sites for exact regulations.
Small-diameter fluorescent lamps — T2, T5, T5HO, and compact fluorescent lamps (CFL) — can experience an EOL condition that creates a serious safety problem. The signs of the condition include melted sockets and cracked glass near the lamp base. Fire can occur if this condition persists.
What causes the problem? Lamp electrodes are coated with an emissive paste to produce electrons. At end of life, the coating on one electrode can deteriorate first, and the power to that electrode increases rapidly to maintain the supply of electrons to keep the lamp operating. This condition does not occur in larger-diameter lamps — T8 and higher — which have more space between the electrode and the bulb wall.
To prevent this EOL condition, most ballasts that operate the affected lamps feature a sensing techniques, but the best practice is to specify this feature.
Metal-halide (MH) lamps also can experience a violent EOL condition called non-passive failure. The following warning label is found on the packaging of standard MH lamps: “If the arc tube ruptures, the outer bulb might break, and pieces of extremely hot glass might be discharged into the surrounding environment, with an associated risk of property damage or personal injury.”
This condition is not normal and happens infrequently, but following these operating recommendations can prevent its occurrence:
These recommendations are available in the LSD 25-2004 document available from the National Electrical Manufacturers Association. Managers can download them at www.nema.org.
To avoid hazards created by EOL explosions, managers can specify protected lamps, which use a shroud or glass cylinder around the arc tube to prevent its glass from penetrating the outer glass envelope.
Changes to the 2005 National Electric Code require manufacturers of fixtures that use MH lamps to provide either a containment barrier to enclose the lamp or provide other safety provision, usually a special lamp holder or exclusionary socket, that only accepts an ANSI Type O lamp.
Lamp manufactures produce products that are designed to pass the TCLP test, ordinarily designated by green end caps, and they exhibit no loss of performance. Some states, including California, Maine, and New York, require recycling of all lamps except incandescent lamps. Many end users avoid liability for their lamp disposal by also recycling spent TCLP-compliant lamps, although they might not be required to.
Although the rate of ballast replacements continues to increase, there are still a significant number of magnetic ballasts installed in fluorescent fixtures. Magnetic ballasts manufactured before 1979 contain polychlorinated bi-phenols (PCB) in the dielectric of their capacitors.
Estimates indicate that about one-half of these old ballasts have a potting compound contaminated by leaking PCB capacitors. This environmental problem requires the attention of technicians in recycling magnetic ballasts, especially those with date codes of 1979 or earlier. Some manufacturers used capacitors containing another toxic substance, DEHP, in ballasts produced after 1979.
Recycling is the best way to dispose of magnetic ballasts. The process allows the reuse of copper and aluminum wire, steel laminations, and steel cases, and it disposes of capacitors and potting compound as hazardous waste in high-temperature incinerators.
As electronic ballasts fail, managers should treat them as electronic waste. Many lamp and ballast recyclers are expanding their businesses and being certified to accept electronic waste. Recyclers that accept both lamps and electronic ballasts are a good place to dispose of screw-base CFLs with electronic bases.
Universal waste handlers and transporters can crush spent lamps to reduce their volume but only at the site where the lamps are generated. Crushing must take place in a well-ventilated, monitored closed system that is designed and operated to prevent mercury vapors from exceeding 0.1 milligrams per cubic meter.
Even when organizations comply with the UWR, crushing can pose health risks if it releases sufficient mercury vapors. When crushing lamps, workers must store them in closed, non-leaking containers, and they must notify the regional EPA. Employees who handle universal-waste lamps must receive training and be completely familiar with emergency procedures. Many facilities send spent lamps to recyclers intact, since some recyclers will not take broken lamps.
Under the UWR, a broken lamp that does not pass the TCLP test must be cleaned up — not using a vacuum cleaner — and placed in a container. The container must be closed, structurally sound, compatible with lamps, and lacking evidence of spillage. These rules apply to all lamps except incandescents.
In some states, broken lamps lose their universal-waste status, and workers must handle them as full hazardous waste. Again, managers should check with local, state or federal agencies for the latest update on regulatory issues or visit www.lamprecycle.org.
Properly cleaning up spilled mercury and providing adequate ventilation can minimize risks to workers. The EPA has determined that breaking one fever thermometer is unlikely to threaten a worker’s health. Since an average 4-foot fluorescent tube contains about 8 milligrams — or nearly 100 times less mercury than a typical 700-milligram fever thermometer — lamp breakage would appear to cause virtually no risk of harm.
CFLs normally contain even less mercury than 4-foot linear fluorescent tubes. The legal requirements for disposal, however, might be quite different.
Facilities recycling small amounts of universal waste can take advantage of prepaid boxes with packing labels some recyclers provide. The boxes help end users comply with regulations with minimal effort. End users can use prepaid boxes to ship fluorescent and HID lamps, ballasts and batteries by submitting an online form with billing to a credit card.
Several electrical distributors offer “reverse distribution” of lamps by offering lamp take-back programs. A major benefit of such programs is that distributors receive orders for lamps they would not have received if they didn’t offer a recycling service. Distributors have taken a variety of approaches, ranging from acting as a broker to picking up spent lamps from customers.
For details, go to www.newmoa.org/prevention/mercury/lamprecycle/electrical_distributors.cfm.
Managers must be aware of safety conditions and regulatory requirements when dealing with spent lamps and ballasts. Given the rising environmental awareness affecting facilities, the issue is certain to become even more complex and challenging.
John L. Fetters, CEM, CLEP, is president of Effective Lighting Solutions in Columbus, Ohio.
A myth persists regarding the phosphor coating inside fluorescent lamps. Many end users mistakenly believe this coating is dangerous and contains phosphorous. At one time, heavy metals were bound to the phosphor, but manufacturers have not used them for 15 years. Chemically, the phosphor coating is an inert substance, chloro-fluor-phosphate. At the end of lamp life, however, mercury can adhere to the coating, requiring careful handling of broken tubes.
According to the National Electrical Manufacturers Association, a five-year study of new lamp phosphor by the Industrial Hygiene Foundation of the Mellon Institute found no significant adverse effects on humans by ingestion, inhalation, or eye or skin contact.
— John L. Fetters