Three things are clear about mercury in fluorescent and other lamps. One is that mercury is harmful. A second is that all spent mercury-containing lamps should be recycled. The third? A significant number of lamps from commercial and institutional facilities are being dumped in landfills, where the mercury has the potential to contaminate the environment.
The National Electrical Manufacturers Association (NEMA) estimates that 78 percent of all lamps used are “business lamps,” which includes everything but residential homes. But the Association of Lighting & Mercury Recyclers (ALMR), whose members handled about 85 percent of all recycled lamps last year, estimates that of the 150 million lamps recycled each year, the business, government and institutional sector was responsible for less than 30 percent.
Where Mercury Hides
According to a briefing prepared by the Northeast Waste Management Officials’ Association (NEWMOA), essentially all energy-efficient light bulbs contain mercury. NEWMOA divides them into fluorescent; compact fluorescent; high intensity discharge, including metal halide, ceramic metal halide, high pressure sodium and mercury vapor; mercury short arc, including mercury xenon short arc; capillary; and neon. Data for the briefing were obtained from the Interstate Mercury Education & Reduction Clearinghouse (IMERC) database. This database contains information submitted by product manufacturers in compliance with laws in Connecticut, Maine, New Hampshire, New York, Rhode Island and Vermont. Other state government members of IMERC include California, Illinois, Massachusetts, Minnesota, New Jersey, North Carolina and Washington.
Not all lamps contain the same amount of mercury. Some fluorescent lamps, for example, contain a small enough amount of mercury to pass the U.S. Environmental Protection Agency’s (EPA) test for mercury — the TCLP or toxicity characteristic leaching procedure. Lamps that test positive fall into the category of hazardous waste known as universal waste.
Compared to other types of hazardous waste, the Universal Waste Rule has less stringent requirements for storage, record keeping and transportation. Hazardous waste lamps are regulated as a universal waste to encourage lamp recycling and good lamp management, as well as to improve compliance with hazardous waste regulations.
Matt Hale, director of the EPA Office of Solid Waste, admits that, under the legal definition in the federal rules, low-mercury lamps are not considered universal waste.
“But even though some low-mercury lamps may not trigger the technical definition, it’s still a good idea to collect them safely and send them to recycling,” he says.
All states are required to adopt at least the minimum universal waste requirements of federal legislation. But some, including New York, are going further.
In New York, even low-mercury lamps that pass the federal toxicity characteristic leaching procedure must be recycled or managed by an authorized facility under legislation that became effective July 12, 2005.
The state’s Department of Environmental Conservation makes it clear that improper disposal of mercury is against the law. Violators will be subject to civil and criminal penalties and held liable for contaminated waste sites.
The federal regulations exempt smaller facilities and households from mercury lamp recycling. The federal regulations also allow facilities that produce less than 220 pounds (100 kilograms) of hazardous waste to be exempt from national rules. But whether one of those facilities is permitted to send spent lamps to municipal solid waste landfill depends on state or local regulations. And a growing number of states are becoming more stringent.
“Since February 2006, California has banned the landfill disposal of mercury lamps, regardless of how small the business is,” says Hale. “Maine and Massachusetts have similar approaches.”
Even states that do allow smaller businesses exemptions for spent mercury lamps may require additional record keeping or registration with state agencies.
Under federal regulations, facility executives may legally bury mercury lamps in hazardous waste landfills, provided they are stabilized so mercury cannot migrate out and EPA treatment standards are met. But dealing with hazardous waste can be a costly procedure, and rules are stringent.
Recycling simplifies lamp disposal, says Paul Abernathy, executive director of the ALMR. There are no reporting or analytical testing requirements, and a common carrier can be used to haul spent lamps to a recycling facility.
In addition to ALMR member companies that provide recycling services anywhere in the United States, its territories, Mexico and Canada, there also are lighting, maintenance and other building contractors that collect spent lamps.
Small users can participate in prepaid box programs. A container, labels and shipping papers are provided so when the container is full it can be sent to the recycler via ground mail shipment. Small users also may be able to take lamps to a locally operated waste facility in their community.
For facility executives faced with larger amounts of spent lamps, recyclers can arrange pick-ups. Another option is to arrange with common carriers to transport the lamps to accumulation facilities. Even trailer loads can be picked up if needed.
“It’s really pretty easy to recycle spent lamps,” says Abernathy. Because old mercury lamps are considered universal waste, they can be shipped in box programs via UPS, FedEx, other common carriers and even the postal service.
Another option for facility executives may be crushing lamps. However, not all states permit lamp crushing, and even those that do often have additional requirements. Crushing lamps is considered treating a hazardous waste.
Some states that allow lamp crushing require crushing to be done in licensed facilities where conditions can be closely monitored by state agencies.
Federal regulations do not preclude ordinary facilities from crushing spent lamps. EPA recently completed a drum-top crusher (DTC) study. The study was performed at three large-scale lamp-recycling facilities and evaluated the performance of three DTC devices.
The performances of the devices diminished over their lifetimes and under varying environmental conditions. Minor mistakes in assembly of the devices could result in leaks. Nevertheless, throughout the study, all three devices maintained mercury levels below Occupational Safety and Health Administration (OSHA) time-weighted average requirements within the containment structure and in the operator breathing zone.
The advantage of DTC devices is that several hundred crushed lamps require the space of 40 or 50 whole lamps, according to EPA’s study. Storage and shipping costs are reduced, which lowers per-lamp recycling costs.
“Crushing lamps before shipment also has the advantage of allowing the lamps to be shipped to the recycler in a well-sealed, durable container that is unlikely to release substantial amounts of mercury,” says the study.
Shipping whole lamps, of course, results in some breakage and potential mercury release, but with careful handling this can be minimized.
All DTC devices evaluated by the EPA study released some mercury when used, creating new mercury exposure situations.
“Exposure will be experienced by the DTC device operator and any assistants handling lamps or working directly with the DTC device,” says the study. “Less direct mercury exposures that could be created by DTC device use include anyone working in or visiting buildings in which DTC devices are used. To eliminate these unnecessary indirect exposures, the ventilation of the lamp crushing room would need to be separate from the general building ventilation system, as is done at industrial lamp recycling facilities.”
Rita Tatum, a contributing editor for Building Operating Management, has more than 25 years of experience covering facility design and technology.