Spent Bulbs as Hazardous Waste?

Q. I am the HR manager of a medium size manufacturing plant and environmental, health, and safety issues are also my responsibility. Recently, the company that we contract to dispose of our hazardous waste contacted us about purchasing a crusher for our spent fluorescent and metal halide lamps. Currently, we place them back into the same kind of box in which we receive them and about once each year we ship them to a recycling center. While there appears to be a worthwhile savings if we use the bulb crusher, we have been under the impression that spent fluorescent and metal halide lamps are hazardous waste if they are crushed. They say it is not. Could you give us some
guidance? B.K.

A. It is good to see that you are aware of the hazardous waste potential of spent fluorescent and metal halide lamps; we have found that this is an issue that “falls between the cracks” for many facilities. The reason for their potential as a hazardous waste is that they likely contain mercury and possibly other heavy metals at concentrations that fail the Toxicity Characteristic Leaching Procedure (TCLP). In order to encourage the recycling of these materials, USEPA and the states have established “universal waste rules” that significantly reduce the regulatory burden for those who generate, handle and recycle these wastes. Specifically, if these materials, such as spent lamps, meet certain criteria, they are not regulated as a RCRA hazardous waste but as a universal waste.

The question of whether or not crushed lamps or bulbs are regulated as a hazardous waste or universal waste depends upon the state in which you are located. As stated in a guidance document, USEPA “is not allowing crushing of hazardous waste lamps under federal regulations. However, generators located in a state with an authorized universal waste program may be allowed to crush universal waste lamps, if within the state authorization process the Agency determines that a state’s program allowing generators to treat lamps under controlled or restricted conditions is equivalent (per RCRA 3006) to the federal prohibition. EPA believes that this approach both ensures protection of human health and the environment while allowing for the development of state regulatory programs that include specific standards for the safe crushing of hazardous waste lamps.”
A 2004 survey by the Association of Lighting & Mercury Recyclers (ALMR) found that the following states do allow some crushing of lamps within their Universal Waste regulations: Alabama, Colorado, Florida, Illinois, Maryland, Massachusetts, Mississippi, Missouri, Tennessee, Texas and Virginia. Use of a lamp/bulb crushing device must be permitted in the following states: California, Connecticut, Massachusetts (conditionally exempt small quantity generators are exempt from permitting), Maine, Minnesota, Missouri and Rhode Island. So for your state, the crushed lamps can still be handled as a universal waste and the bulb/lamp crusher would not need a permit.

However, if your crushed universal waste is going to be shipped into a state that regulates crushed lamps as hazardous waste, you would be required to label, transport and manifest the crushed bulbs in accordance with the receiving state’s hazardous waste requirements at the time of off-site shipment. In such a case, it may be in your best interest to send the crushed lamps to an in-state broker if no in-state recycling facility is available.

An alternative for your consideration is to use lamps that do not exceed TCLP hazardous waste levels for mercury or any other RCRA metal. These lamps, usually fitted with green end caps and certified to pass TCLP, are neither hazardous nor universal waste and can be placed with your regular trash for disposal. However, a few states, such as New York, are now mandating that even these low-mercury lamps be recycled, as they still contain mercury; other states “strongly recommend” that all fluorescent lamps be recycled.

Lastly, another consideration is the potential of mercury exposure to your employees. Mercury emissions from the crushed lamps can be in both particulate and vapor phase. In addition to HEPA quality particulate filters, we recommend that a filter system should also address vapor phase mercury using activated carbon or MERSORB® pellets. Furthermore, the bulb crusher should be in an area of excellent ventilation to further reduce potential mercury exposure, and you may even desire to perform personal or area air sampling during the crushing operation in order to document the actual mercury exposure and whether or not more engineering controls and personal protective equipment are needed.

In closing, if you decide to pursue the bulb/lamp crusher, be sure that your supplier responds to the issues described above, particularly who will receive your crushed bulbs and are they properly permitted.