Spent Bulbs as Hazwaste Part II

Q. In your reply to DW in the January issues (“Spent Bulbs as Hazwaste”), you stated that New York and California mandates that all spent fluorescent bulbs are to be recycled no matter their mercury content.

That statement is partially true. In New York there is an exemption for small businesses. It is found in New York State’s Mercury-Added Consumer Products Law Title 21 Section 27-2113 paragraph three.

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Just thought you might like to inform your readers that there are exemptions for small businesses and they may want to check the consumer laws in their own states for similar exemptions.

Below is a copy of the law that references the disposal requirements and below that is the exemption I referenced above:

27-2105. Disposal.

1. No person shall knowingly or intentionally dispose of a mercury-added consumer product in solid waste or otherwise dispose of such a product except by separated delivery thereof to a solid waste management facility or hazardous waste management facility permitted or authorized pursuant to title seven or nine of this article.

27-2113. Exemptions.

3. The provisions of subdivision one of section 27-2105 of this title shall not apply to mercury-containing lamps
discarded by a small business if such small business discards no more than fifteen mercury-containing lamps per month. For the purposes of this subdivision “small business” means any business which is resident in this state, independently owned and operated, not dominant in its field, and employing not more than one hundred individuals.

From the research that I have done, even though the regulation states that all bulbs are to be disposed of a universal or hazardous waste, a law gives the small business an exemption and talways supersedes the regulation. R.D.

A. Thanks R.D. for your particular insight into New York’s laws on this issue.