Fluorescent Lamps

Improper handling or disposal of used fluorescent and high density discharge lamps damages the environment. When broken, these lamps release mercury and other metals that damage the environment. In addition, when used lamps are collected as municipal waste and disposed in a solid waste landfill the possibility exists that the mercury they contain may be released into the landfill's leachte and then potentially migrate out the the landfill.

Used fluorescent and HID lamps may be classified as hazardous waste due to their mercury content and are thus regulated under the Resource Conservation and Recovery Act (RCRA). These regulations provide for management of hazardous wastes. In Illinois, the newly amended Universal Waste Rule encourages recycling or proper disposal of waste lamps. The Illinois Pollution Control Board amended the Illinois Universal Waste Rule (on April 2, 1998) to cover lamps that meet the definition of hazardous waste. Wastes in this special category of hazardous waste are called "universal" because they are broadly generated. Pesticides, thermostats and batteries also can be classified as universal wastes.

The Illinois Universal Waste Rule encourages hazardous waste lamps to be properly collected, and subsequently recycled or disposed of.

In Illinois, commercial and industrial facilities may follow the Universal Waste Rule described in this fact sheet (and in state regulations) or you may follow RCRA requirements for hazardous-waste handling, storage, treatment and disposal. You must choose one of these options.

Households may dispose of their used lamps as municipal waste. However the Illinois EPA strongly encourages households to manage their used lamps in accordance with the guidance in this fact sheet. Specifically, households should take their used lamps to a household hazardous waste collection or one of the recyclers listed in this fact sheet.

In order to manage these lamps properly, you may:

• accept the lamp maker's written claim the lamps are not hazardous;
• assume they are hazardous;
• have them tested.

Managing waste lamps under the streamlined requirements of the Illinois Universal Waste Rule:

• Eliminates permits for universal waste handlers and transporters;
• Eliminates manifests (except when lamps are transported through or are treated or disposed in states not recognizing waste lamps as universal waste);
• Eliminates their contribution to your total volume of hazardous waste;
• Increases the time you may store waste lamps;
• Reduces record keeping, training and emergency preparedness requirements.

If you generate universal waste or receive it for consolidation, you are a universal waste handler. If you treat, dispose, recycle or transport such wastes, you are not a universal waste handler.

Handlers who transport waste lamps are subject to all regulations affecting transporters. (Transport means moving wastes off-site.)

Accumulating less than 11,000 pounds of universal waste at a time makes you a small-quantity handler; more than 11,000 pounds makes you a large-quantity handler. (It takes about 17,000 48-inch lamps to equal 11,000 pounds.)

Handlers and transporters are prohibited from disposing, treating, recycling or diluting waste lamps. Instead they must:

• Send lamps to a facility that accepts universal-waste lamps for recycling, treatment or disposal; a list of recyclers is available from the Illinois EPA.
• Minimize breakage and immediately clean up broken or damaged lamps;
• Prevent release of lamp fragments and residues. (The Illinois EPA recommends storing broken lamps in nonmetallic packaging because mercury tends to accumulate on other metals.)

Individual waste lamps or containers must clearly state one of the following:

• "Universal Waste Lamps"
• "Waste Lamps"
• "Used Lamps"

For up to one year (or longer if they can demonstrate more time is needed to collect quantities necessary for proper recovery, treatment or disposal). Handlers must record on each lamp or lamp container the date lamps became waste.

In-house training differs between small- and large-quantity handlers:

• Small-quantity handlers shall inform all employees who handle or manage universal waste of proper handling and emergency procedures;
• Large-quantity handlers shall ensure all employees are thoroughly familiar with these procedures.

Large-quantity handlers must record each shipment of universal waste in a log, invoice, manifest, bill of lading or other shipping document, and include:

• name and address of receiving facility;
• quantity and type of each waste;
• shipping date.

Records must be kept for at least three years from date of shipment. Small-quantity handlers are not required to keep records.

Universal waste handlers and transporters may crush waste lamps only to reduce their volume, and only at the site where waste lamps are generated, provided:

• Crushing occurs in a closed system designed and operated to prevent mercury emissions from exceeding 0.1 milligrams per cubic meter, measured on a time-weighted average over an eight-hour period, as rated by the crusher's manufacturer;
• The Illinois EPA is notified of crushing activities quarterly, using the Agency's Notification of Universal Lamp Crushing Activity Form;
• Crushing occurs in a well-ventilated and -monitored area, to ensure compliance with applicable OSHA exposure limits;
• Employees crushing lamps are thoroughly familiar with emergency procedures and proper handling of mercury waste;
• Crushed lamps are stored in closed, nonleaking containers;
• Spilled or leaked materials are transferred immediately to closed containers.

Crushing may pose health and environmental risks if mercury vapors are released. Also, lamp recyclers may prefer whole lamps to crushed ones.

Transporters may store universal waste at a universal-waste transfer facility for no more than 10 days without becoming a universal waste handler subject to additional requirements. Transporters may take universal waste to only a universal waste handler, a universal-waste transfer facility or a universal-waste destination facility.

Universal waste handlers or transporters need not obtain hazardous waste management permits, but must manage these wastes in compliance with state regulations.

Mercury-containing lamps discarded by households are not subject to hazardous waste rules and can be accepted by municipal-waste landfills; however, the Illinois EPA recommends you take these lamps to household-hazardous-waste collection centers. (Call your county recycling coordinator to find the center nearest you.)

For further information regarding the management of universal wastes and other hazardous wastes in Illinois, there are several additional resources available:

• Federal Universal Waste Webpage
  
• Federal Final Rule on Hazardous Waste Lamps
• Illinois Universal Waste Management Regulations

If you still have questions, please call the Illinois EPA's Bureau of Land Permit Section, at 217-524-3300.

View this list of fluorescent lamp recyclers.