By Rob Arner
According to the National Electrical Manufacturers Association (NEMA), there are an estimated 600 million fluorescent lamps discarded in the United States each year, of which only about 10–20% are recycled.1 The lamps that are thrown away may break because of their fragile nature. However, this causes only a small amount of mercury to be released into the atmosphere since most of the mercury is not in a vapor state.2
As an illustration of the nature of the problem, one truckload of four foot intact non-reduced mercury fluorescent lamps (approximately 30,000 lamps) contains approximately one pound of mercury.3 On average, 600,000 to 750,000 square feet of office space contains approximately 30,000 lamps—with each lamp having a life-span of approximately five years.
Mercury's toxic effects and persistence in the environment have led to dramatic efforts to reduce and eliminate further pollution from this metal. However, despite recent progress (mercury use dropped 74% from 1980 to 1993), mercury still maintains the number-one ranking on the U.S. EPA's list of the 19 most persistent, bioaccumulative, and toxic metals targeted for control and eventual elimination.4 Mercury is the most frequent cause of fish advisories in the United States, represented in 60% of all water bodies with advisories.
The Universal Waste Rule
Until recently, all hazardous wastes were regulated uniformly under the Resource Conservation and Recovery Act (RCRA). The RCRA defines which materials are considered solid wastes and then identifies which are hazardous and subject to hazardous waste requirements. On May 11, 1995, the U.S. EPA finalized streamlined requirements for collecting certain widely dispersed hazardous wastes under the "Universal Waste Rule" because their diffuse nature made them difficult to monitor, particularly if the rules were lengthy or complex. U.S. EPA concluded that there was enough evidence that spent mercury-containing lamps are a high source of mercury in the municipal solid waste stream. These findings, along with heightened concern about mercury in the environment, led to the inclusion of waste lamps in the Universal Waste Rule.
Under the Universal Waste Rule, the users of fluorescent lamps must:
- characterize spent lamps using the TCLP test5 to determine hazardous waste classification for appropriate disposal;
- recycle the lamps by a reclaimer; or,
- dispose of spent lamps in hazardous waste landfill.
Under RCRA, Conditionally Exempt Small Quantity Generators (CESQGs), who generate less than 100 kg/mo (220 pounds) or less than 1000 kg of hazardous waste, are exempted from RCRA hazardous waste requirements.
Management of mercury-containing lamps under these regulations is based on a "recycling presumption." That is, in order to qualify for reduced management requirements the lamps must be collected or managed for recycling/reclamation. Lamps that are to be "disposed of" rather than legitimately recycled/reclaimed are subject to full regulation as hazardous wastes if they exhibit a hazardous waste characteristic.
Current management paths
Although the Universal Waste Rule establishes specific criteria for dealing with spent fluorescent lighting, the question that arises is whether or not these regulations are actually being implemented.
How fluorescent lighting is managed directly correlates with the risk of releasing mercury into the environment as well as the eventual cost to the lighting generator. The management paths for lamps are:
- mercury reduction through procurement practices;
- lamp recycling;
- lamp incineration; and,
- lamp landfilling.
Mercury reduction through procurement practices
Mercury reduction through procurement practices can be achieved in two ways—through the procurement of more energy efficient lighting and through the procurement of TCLP compliant lamp types.
The adoption of more energy-efficient lighting can have a dramatic effect on overall emissions—including mercury and greenhouse gases from fossil-fuelled power generation. The procurement of TCLP-compliant lamps with lower mercury doses will also minimize disposal emissions.6 Most conventional linear fluorescent lamps are available in TCLP compliant types and should be purchased whenever possible, provided that performance adjusting for output and life outweighs their non-TCLP equivalents. In addition, improved lamp types are constantly being introduced, which have better life cycle costs. These lamps may be considered for new construction or major renovation where it can be shown that the combination of light output and life results in overall reductions in mercury-bearing and/or solid waste, or where improved life cycle costs justify disposal by recycling.
Ninety percent of the total fluorescent market in the United States is shared approximately equally between Philips Lighting, OSRAM Sylvania, and General Electric. Each manufacturer offers a range of TCLP-compliant products, and innovative, improved performance products. Competitive bids may be obtained to assure the least cost for equivalent products. Bids may also include performance warranties, and some manufacturers offer enhanced warranties when lamps and ballasts are purchased from the same source.
Some procurement officials have problems with reduced mercury (TCLP-compliant) lamps in the older ballasts that were made for 40W lamps. The Energy Policy Act of 1992 banned the sale of most 40-watt T12 lamps. Some are still available, but the predominant wattage is now 34-watts. Some vintage 40-watt ballasts have a tendency to fail when the higher current 34-watt lamps are used. Ballasts manufactured within the last 15 years should have no problems with properly designed and manufactured 34-watt TCLP compliant lamps. Retrofitting with T8/electronic may be a preferred approach.
The definition of a lamp recycler stretches from firms that simply crush lamps (a lamp processor that separates the glass, metal, and the mercury, and then disposes of the mercury in a hazardous waste landfill) to firms that provide full service separation and complete mercury reclamation. However, a true lamp recycler performs a complete in-house mercury reclamation (distillation). Although less expensive than incineration or disposal in a hazardous waste landfill, only an estimated 10–20% of mercury lamps are recycled nationally. The cost to recycle a typical 48-in. fluorescent tube is from between 20 to 40 cents depending on the volume of lamps and pick-up requirements. Although the demand for lamp recycling is not large at the present time, it is expected to grow.
Time to change
The purchase of reduced-mercury lamps and/or recycling of spent lamps to be encouraged to all. Those who handled mercury lamps have the legal responsibility for proper disposal of mercury containing lamps, or face non-compliance.
Local and State government can be particularly effective by playing a leadership role in reduced mercury lamp purchasing and information transfer between regulatory agencies at all levels and the industry. Also these governments represent one of the largest groups of generators and potential recyclers and should encourage model cooperative purchasing contract to both buy reduce mercury lamps and develop innovative cooperative lamp recycling programs in-house.
Other types of public/private partnerships and incentives can be explored to insured that mercury lamps handling is properly addressed. It is time for us to shed new light on reducing mercury pollution.
- Walitsky, Paul. Manager of Environmental Affairs, Phillips Lighting Co. Personal communication, 8/99, cites 15 to 20%. Other communications have cited as low as 10%.
- Battye, McGeough, and Overcash, "Evaluation of Mercury Emissions from Fluorescent Lamp Crushing," EPA-453/D-94-018, February, 1994.
- The National Electrical Manufacturers Association notes in its August 20, 1999 review letter that "For lamps manufactured in 1994 and disposed of in 1999, you need about 20,000 lamps to contain one pound of mercury. For lamps manufactured in 1999 and disposed of in five years, you need 40,000 lamps to contain one pound of mercury. This already includes TCLP compliant lamps."
- U.S. EPA. Background Information on Mercury. http//www.epa.gov/glnpo/bns/mercrcse/merc/_srce.html. Date accessed: 4/5/99
- One of the requirements of the Universal Waste Rule is that generators must determine whether their product is a hazardous waste or simply a solid waste. The test used by the U.S. EPA to determine this is the Toxicity Characteristics Leaching Procedure (TLCP). For mercury, the total amount of mercury in the sample must not exceed 0.2 mg/l. More information can be obtained at (http://es.epa.gov/techinfo/facts/pro-act5.html).
- For instance, Philips Lighting maintains that its ALTO fluorescent lamps have a mercury content nearly 80% lower than average fluorescent lamps and that if all lamps were ALTO lamps, that approximately 12 to 13 tons of mercury would be removed from the waste stream each year.