Spent Bulbs as Hazwaste

Q. In your reply to B.K. in the September issue of PF regarding spent bulbs as hazardous waste, I would like to emphasize the importance of one part of your response as it applies to alternative bulbs. While the use of E-lamps, Green bulbs, et al, has significantly increased over the past 10-years, there is still some misconception that all bulbs with green end caps fall below EPA mercury TCLP limits. Several years ago I attended a RCRA workshop where one of the speakers discussed his company’s conversion to a certain manufacturer’s green lamps, so as to minimize their hazardous/universal waste liabilities and overall costs.

Our company was converting to green lamps from the traditional type, so the following week I requested the technical data from the manufacturer of the specific lamps cited at the seminar (so as to have my due diligence on hand for regulatory inspections). After reviewing the data I was surprised to find that, while much lower in mercury, the manufacturer could not certify that the lamps could pass EPA TCPL limits for mercury. Subsequently, I have seen and heard of many companies over the years that have made this potentially dangerous assumption. It is for this reason that I wish to emphasize the significance of one critical word in your response “...usually fitted with green end caps and certified to pass TCLP”. Unless you have that certification on hand for your lamps, or TCLP results from a certified laboratory, you may find during your next inspection that the cost of (mis)managing your lamps has more than erased all the savings you made. D.W.

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A. D.W., thank you for your response. It is quite valuable. In fact, over the last few months, I have encountered this situation at several facilities. Fortunately, they were still handling the spent fluorescent lamps as a recycled universal waste out of habit. At one facility we found an old environmental audit report that stated the facility was “relamped” in 2002 with “green” fluorescent bulbs that could be thrown into the trash. These bulbs have green end caps and printing. However, on further investigation, we found, like you, that the bulbs did contain much lower mercury than “conventional’ bulbs, but still above the Toxicity Characteristic Leaching Procedure (TCLP) threshold for mercury.

Unless you have certification from the bulb manufacturer that the specific model lamp passes the USEPA hazardous waste criteria, one should assume that it is a universal waste to be recycled. However, there are a few states (California and New York come to mind) which mandate all spent fluorescent must be recycled no matter what their mercury content, so it is a good idea to check you state’s waste management agency website for your state’s particular requirements.