Property and building managers either contract for or perform maintenance for indoor and outdoor lighting as one of their required duties.
With recent energy efficiency requirements moving everyone to use next-generation lighting — compact and linear fluorescent lamps (LFL/CFL) indoors, as well as high-intensity discharge lamps (HIDs) in outdoor lighting — all locations should have a plan for tracking the end-of-life management of spent lamps.
Every lamp using fluorescent technology requires the inclusion of some level of mercury to function.
Most lamps also have some lead in them from solder used in their construction.
With either mercury or lead, this content requires proper management for any lighting to keep these materials out of the environment.
If it is understood that any broken fluorescent lamp requires special handling in cleanup and disposal, then all lamps — no matter what claims are made about their toxicity characteristics — should be handled in a way ensuring no mercury is released to the environment.
Appropriate management requires collection and transfer to a licensed recycler to complete proper end-of-life recovery, disposal and/or reuse of materials.
In other words, all lamps should be handled as universal waste, not household waste.
In order to comply with your obligations as a building or property manager, state or federal regulations under the Resource Conservation and Recovery Act (RCRA) need to be followed.
The RCRA Universal Waste Rule (UWR) and Subtitle C hazardous waste regulations regulate businesses managing and disposing of fluorescent lamps and other mercury-containing lighting (HIDs, etc.) and devices (i.e. thermostats).
Property managers should store used lamps to minimize any breakage.
Any releases to the environment from broken lamps must be contained immediately and handled properly.
All employees should be trained on proper lamp management — including all emergency procedures in case of breakages or spills.
If you’re thinking of disposing of your lamps as non-hazardous materials as some lighting companies promise, every batch of lamps shipped must be tested to comply with RCRA requirements.
If not tested, you must assume they are hazardous waste and handle them accordingly.
Some states require that all mercury-containing lamps be recycled or managed as a hazardous waste, regardless of the mercury content, so check local regulations to avoid problems.
Small Quantity Handlers
According to the U.S. Environmental Protection Agency website regarding lamps, a small quantity handler of universal waste must manage lamps in a way that prevents releases of any universal waste or component of a universal waste to the environment, as follows:
- A small quantity handler of universal waste must contain any lamp in containers or packages that are structurally sound, adequate to prevent breakage and compatible with the contents of the lamps. Such containers and packages must remain closed and must lack evidence of leakage, spillage or damage that could cause leakage under reasonably foreseeable conditions.
- A small quantity handler of universal waste must immediately clean up and place in a container any lamp that is broken and must place in a container any lamp that shows evidence of breakage, leakage or damage that could cause the release of mercury or other hazardous constituents to the environment. Containers must be closed, structurally sound, compatible with the contents of the lamps and must lack evidence of leakage, spillage or damage that could cause leakage or releases of mercury or other hazardous constituents to the environment under reasonably foreseeable conditions.
Conditionally Exempt Small Quantity Generator
A generator or location that produces no more than 100 kg (220 pounds) of hazardous waste, or no more than 1 kg (2.2 pounds) of acutely hazardous waste, per calendar month is a Conditionally Exempt Small Quantity Generator (CESQG).
This is inclusive of all hazardous waste generated in a calendar month.
Under federal regulations, this type of generator is exempt from the majority of hazardous waste regulations.
However, CESQGs must ensure that their waste is sent to a permitted hazardous waste management facility, a permitted municipal or industrial solid waste facility or a recycling facility.
Contact your state environmental regulatory agency to see if your local municipal solid waste facility is permitted.
While federal regulations allow some mercury-containing lamps to be landfilled, certain states may prohibit this action.
Many states apply the CESQG requirement in a more stringent manner than the federal government and in other states the CESQG requirements are not applicable at all.
For example, all mercury-containing wastes are banned from landfills in the states of Vermont and Minnesota regardless of whether they are disposed of by CESQGs or households.
California enacted a similar ban in February 2006.
New Hampshire does not have a CESQG exemption in its hazardous waste regulations.
Therefore, you are strongly encouraged to know what is required in your state.
For more information specific to your state, please contact your state or local environmental regulatory agency.
Whether your state regulates more stringently or not, all states and the EPA encourage the proper and complete recycling of used mercury-containing lamps — no landfilling of any materials.
The amount of lamps estimated to be returned for proper management hovers around 20-30 percent of all lamps.
While businesses do better than households in this regard, four out of five lamps removed from service in businesses and managed properties are not properly managed.
As lamps cycle from old technologies to more efficient and longer-lived technologies, the amount of resources put into them will increase as well.
These resources will need proper management and should be viewed as finite and in need of proper management.
The days of out of sight — out of mind are no longer.
Managers and professionals need to ensure that all lamps receive proper treatment by having them managed properly through a lighting waste handler to ensure their proper management.
Eric Uram has served as a board member on the Association of Lighting and Mercury Recyclers representing the company MRT Systems AB International as their North American sales and service representative. He serves on the Sierra Club’s National Toxics Committee and is the executive director for SafeMinds, a non-profit dedicated to ending the crisis of preventable neurological impacts and disorders in children.