Recycling Fluorescent Lamps:
Why, How, and What Happens
If You Don’t!
Presented by
Tom Griffin
Sustainability Consulting Services
 Sustainability & Green
Program Development
 Green Assessments
 Waste Stream Auditing
 LEED Advisory Services
 Green PR Services Program Participation,
Recognition, & Awards
 Hazardous & Universal Waste
Management and Compliance
 Voluntary Program
Development &
Management
 Environmental Management
Systems & ISO14001
 Green Events Management
& Staffing
 Staff Training & Consumer
Education
 Green Products &
Technologies
My Background & Role
Tom Griffin, Division Director
•
•
•
•
Sustainability Programs
Green Assessments & Waste Audits
Voluntary Programs Development & Coordination
Regulatory Compliance for Air Cycle Corporation
Why Recycle Lamps?
» Fluorescent lamps contain mercury
 Regulations protect the environment,
protect workers, and protect your
company.
What’s In A Lamp?
What’s In A Lamp?
» Weights vary according to size,
make, etc…
A typical T8 weighs approx. 3-4 lbs.




Glass – 95-98%
Aluminum, lead oxides, trace metals – 2-3%
Phosphor – 1-2%
Mercury - .002-.02% (3-20+mg)
What is Mercury?
» Liquid metal, useful in switches, gauges,
thermometers and the like because it expands
and contracts with changes
in temperature and other
variables.
Where is Mercury?
• Lamps
• Switches & Gages
• Manometers
• Barometers
• Thermostats
• Batteries
• Thermometers
• Dental Amalgams
• Medications / Vaccines
• Lab Chemicals
• Bougie Tubes & Sphygmomanometers
How Does Mercury Enter
the Environment?
How Does Mercury Enter
the Environment?
How Does Mercury Enter
the Environment?
How Does Mercury Enter
the Environment?
How Does Mercury Enter
the Environment?
The Real “Dangers”
of Mercury…
» It is a neurotoxin
» Elemental mercury
» Direct prolonged exposures
» Exposures by eating seafood
» METHYLMERCURY
Human Health Effects
High exposures to mercury may cause:
• Trembling hands & numbness or tingling
in their lips, tongues, fingers or toes
• Fatigue, joint pain & mental
instability
• Speech, hearing problems
Neurotoxin
Methylmercury
» Deposition in water
» Anaerobic conditions
» Accumulation in the food chain
[CH3Hg]+
The Conversion to Methylmercury
Minamata Bay
The Mercury Life Cycle
Health Impacts from
Improper Lamp Disposal
• Nearly 530 million spent mercury containing
lamps are put in trash each year
• Estimated that 2 - 4 tons
mercury released annually
from broken lamps
If You Recycle Lamps…
» Protect the environment
» Protect people
» Stay regulatorycompliant
» Part of effective
“green” program
If You Don’t…
» Negative impacts on environment, staff,
and public
» Out of compliance –
regulatory
issues arise
» Poor message to staff
and
customers
How Do I Recycle Lamps?
Options for Every Facility
» Drum-top crushing of lamps
» Mail-back shipping of intact lamps
» Bulk pickup of intact lamps
Mail-Back Recycling
Prepaid shipping of intact lamps to
a recycling facility for processing
• Convenient!
• Great for small
quantities
• Also recycle batteries,
ballasts, and e-waste
VaporShield®
VaporShield® is a specially treated
box that contains mercury vapor and
replaces the box and bag system,
speeding the loading process.
• Certified UN-compliant and ISTA®
Transit Tested Certified
• Brown craft cardboard is 100%
recyclable
Mailing of Intact Lamps
• Ships directly to permitted
lamp recycling facilities
• Mercury and all lamp
materials recovered
• Recycling certificates with
weights
Bulk Pickup of Lamps
Pickup and transport of large quantities
of intact lamps for recycling
• Recycle unlimited
quantities of waste
• Flexible scheduling for
recycling on as-needed
basis
• Perfect for locations where
lamp crushing not available
Drum-Top Lamp Crushing
Crushing of spent lamps into a drum for
pickup and shipment for recycling
• Most efficient lamp recycling
method for large operations
• Storage, space, & handling
benefits
• Improved environmental
program
Your Facility
Fines
Hazards
Bad PR
Safe and efficient lamp recycling
programs for any size facility!
Bulk Pickup
Bulb Eater®
EasyPak™
Your Facility
Fines
Hazards
Bad PR
Your Facility
Bulb Eater®
Bulk Pickup
800.909.9709
EasyPak™
www.AirCycle.com
How is it Recycled?
Lamp waste is shipped to permitted facilities to
safely extract mercury and recycle ALL materials
How is it Recycled?
How is it Recycled?
What Happens If You Don’t?
Environmental Regulations
& Lamp Recycling
What Happens If You Don’t?
» Negative impacts on
environment, staff, and public
» Out of compliance –regulatory
issues arise
» Poor message to staff and
customers
» Fines
Environmental Regulations
& Lamp Recycling
Subtitle C: Hazardous Wastes
40 CFR Parts 261-269
» “Cradle to Grave”
» Determination of HW
» Treatment, Storage, & Disposal
» Recordkeeping
» Generator Status
Subtitle C: Universal Wastes
40 CFR Part 273
» Hazardous materials that can be recycled
» Decreased recordkeeping & handling requirements
Subtitle C: Universal Wastes
40 CFR Part 273
Lamps & ballasts
 Electronic wastes
 Batteries
 Used oil, etc…
 Pesticides
 Mercury-containing
equipment
Universal Wastes
» Very little recordkeeping
» Labeling is important
» Generator responsible for seeing that
materials are “properly recycled!”
» Otherwise…HAZARDOUS!
Lamp Disposal Options:
Universal Waste Recycling!
 Intact Lamps
 Crushed Lamps (in 9 states)
 Reduced regulatory requirements
 Generator status
 Handling, storage, and shipping
Crushed Lamps
Universal Waste in 9 States
Colorado
Florida
Illinois
Maryland
Montana
New Mexico
Tennessee
Texas
Virginia
Crushed Lamps: Universal
 EPA ID # not required
 No manifests required
 Labeled: “Universal Waste – Lamps
to be Recycled”
 Must be handled according to
manufacturer’s specifications
 Responsible for “proper recycling”
 Certain additional state requirements
Lamp Disposal Options:
Recycling As Hazardous
 Crushed Lamps (allowed in 35 states)
 Lots of Benefits
 RCRA hazardous waste
regulations apply
 Generator status
 Handling, storage, and shipping
Crushed Lamps
Hazardous Waste in 32 States
Alabama
Alaska
Arizona
Arkansas
Delaware
D.C.
Georgia
Hawaii
Idaho
Indiana
Iowa
Kansas
Kentucky
Louisiana
Massachusetts
Michigan
Mississippi
Nebraska
Nevada
New Jersey
New York
North Carolina
North Dakota
Ohio
Oklahoma
Oregon
South Carolina
South Dakota
Utah
Washington
Wisconsin
Wyoming
Crushed Lamps: Hazardous
 Generator status and requirements
 RCRA – Subtitle C /TSD-permitted facilities
 Shipping manifests often required
 EPA ID # often required
 Additional requirements for SQG and LQG
 Additional state requirements
 Recycling certificates
Lamp Recycling Options
Disposal / Waste Determination
• Hazardous Waste
• Non-Hazardous Waste
• Low-Mercury Lamps
• Possible benefits for generator status
Determination: The
Case of Lamps
• Low-mercury lamps pass TCLP
• TCLP Testing (0.2mg/l)
• Landfill bans (0.025mg/l)
•Hazardous? Hazardous waste disposal
Subtitle C-permitted facility…still must be
recycled!
Environmental Regulations &
Lamp Disposal Options
Crush and ship for recycling
Mail or ship to recycle intact
X Improper disposal
Lamp Disposal Options:
Improper Lamp Disposal
» Violations
» Fines…$$
» Worker exposure
to mercury
» Bad PR
Lamp Disposal Options:
Improper Lamp Disposal
» Common Misconceptions…
• Conditionally Exempt
• Dilution is the Solution
• Low Mercury Lamps
Lamp Disposal Options:
Improper Lamp Disposal
» Exposures to
workers and the
public
Lamp Disposal Options:
Improper Lamp Disposal
» Bad public relations…
U.S. EPA Files $111,199 Complaint
Against College for Hazardous
Waste Violations ….including improper
management of spent lamps.
U.S. EPA Fines Iowa
company $54,786 for
NYC fined for improper lamp
disposal. U.S. EPA has reached an
agreement with New York City requiring it to
pay $50,000 in penalties and launch a
comprehensive program to properly manage
oldUS
light
bulbs
and computer
monitors…...
EPA
issues
fines for
lamp disposal violations
…has agreed to pay a $49,725 penalty
hazardous waste violations
and to voluntarily ensure that its
including…improper labeling and approximately 75 stores throughout
New York, New Jersey and Puerto Rico
management of spent lamps.
remain in compliance with the
requirements for the handling of spent
light bulbs.
Recycling Fluorescent Lamps:
Why, How, and What Happens
If You Don’t!
Presented by
Tom Griffin