Disposing of Lamps
June 2007
UNIVERSAL WASTE RULE - Disposal of spent tanning lamps
Under Federal rules, some mercury and lead containing lamps will fail the TCLP
(toxicity characteristic leaching procedure) test and will therefore be classified as
hazardous waste. Certain Wolff System sunlamps, and certain commercial lighting
lamp types from various manufacturers are designed to pass the TCLP test and are
therefore classified as non-hazardous (solid waste) under Federal rules, and under
most state rules.
Federal EPA includes TCLP-failing lamps in the Universal Waste Rule that became
effective on January 6, 2000. The impact of this rule is that it may be slightly less
expensive to dispose of lamps as Universal Waste than as Hazardous Waste, because
certain storage, transportation and record-keeping requirements may be reduced or
eliminated. Under Federal rules, certain classes of users are exempt from the
requirements of the Universal Waste Rules.
While many states have adopted the Federal Universal Waste Rule, each state is free
to interpret the Universal Waste Rule as they see fit, provided it is no less stringent
than the Federal rule. ("Universal" means a widely distributed waste, and not that there
is one uniform rule throughout the U.S.)
For example:
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Most states allow exemptions for households
Many states allow small quantity generator (user) exemptions
Some states define small quantity generator differently
Some states allow lamps to be crushed prior to disposal
Some states allow lamps to be treated in some way by the generator prior to landfilling
Some states classify wastes using methods other than TCLP and/or require all lamps
to be recycled whether or not they test hazardous
It is therefore important that generators (users like tanning salons) should contact their State
or local environmental regulatory agency and obtain the current requirements for lamp
disposal for themselves.
UNIVERSAL WASTE RULE
Federal rules for handling and disposal of Hazardous Waste lamps:
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Q. 1. Are lamps that pass the TCLP test considered hazardous waste?
A. No. The Federal Universal Waste Rule considers such lamps solid waste.
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Q. 2. How does EPA regulate the handling and disposal of Hazardous Waste lamps?
A. Hazardous Waste lamps will be regulated under the Federal Universal Waste Rule.
The Rule was originally developed to regulate the disposal of other widely generated
wastes that contain toxic materials, such as batteries and pesticides.
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Q. 3. Where does the Federal Rule for Hazardous Waste lamps apply?
A. The Rule will apply only in certain states that do not run their own comprehensive
hazardous waste programs. For details, including regulating agencies in each state,
see Q.8. below. The Rule became effective as of January 6, 2000.
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Q. 4. What are the rules for the disposal of lamps in other states?
A. Many states did not wait for EPA and incorporated lamps into their own versions of
the Universal Waste Rule; a few states have more stringent regulations, such as
Connecticut, Florida, Minnesota, Maine, Rhode Island, New York, California, Vermont,
and Massachusetts (effective May 2008).
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Q. 5. What impact does the Federal Universal Waste Rule have on lamp disposal?
A. This can only be answered in general terms because some states have adopted
their own versions of the Rule, but the Federal guidelines are as follows:
o The Rule applies only to lamps that fail the Federal TCLP test that is used to
determine if a waste is hazardous.
o The Rule does not apply to households.
o The Rule does not apply to those users (small waste generators) who generate
less than 220 lbs. of hazardous waste per month. Assuming no other hazardous
waste is generated, this allows approximately 225 six-foot TCLP-failing
sunlamps per month to be disposed as a non-hazardous waste.
o Users who generate more than 220 lbs. of hazardous waste per month are
subject to the Rule. Any lamps that are handled as universal waste are
excluded from the totals for other hazardous waste.
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Q. 6. Does the Rule ban certain methods of disposal?
A. Not if you are a user (generator) that is exempt, i.e. a household or small waste
generator as defined above. Exempt users may continue to dispose of any lamps as
non-hazardous waste unless your State or local regulations disallow your exemption,
or restrict certain types of disposal. However, it is not recommended that any mercury
or lead-containing lamps be placed in any waste stream. Recycling is the most
responsible method of lamp disposal.
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Q. 7. What are the requirements for large waste generators?
A. Generally, if lamps are handled as universal wastes, there are less burdensome
regulations for the record keeping, storage and transportation than if the lamps are
handled as ordinary hazardous waste. Again, the exact requirements vary from state
to state.
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Q. 8. Where can I find out about the regulations that apply to me in my state?
A. An excellent source is the web site for NEMA's (National Electrical Manufacturers
Association) web site at: www.nema.org/lamprecycle. Check out the State Lamp
Recycling Regulations and Contact page. This lists the environmental regulatory
agency in your state, and their specific regulations. Various names for the responsible
agencies are used from state to state. You may also check Government listings in the
phone book under environmental protection, environmental quality, environmental
health. Another resource is the Association of Lighting and Mercury Recyclers at
www.almr.org.
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Q. 9. Does the lamp manufacturer or distributor have the responsibility of helping me
manage spent lamps?
A. Under Federal law, the user (generator) has primary responsibility for correctly
managing hazardous wastes.
Summary of Lamp Disposal Options
Caution: May be subject to overriding State or local regulations
Lamp
Status
Conditionally
exempt small
generators*
Small non-exempt+
or large generators++
Not generally
restricted
Not generally
restricted
Recycle, or handle as
Universal or
Hazardous waste
Passes Not generally
TCLP restricted
Not generally
restricted
Not generally restricted
Fails
TCLP
Households
* Disposes of less than 220 lbs. of hazardous waste per month
+ Disposes of more than 220 lbs. of hazardous waste per month
++ Disposes of more than 2200 lbs. of hazardous waste per month
Conclusion:
Learn the local or State regulations where you operate.
Know that local or State regulations can be changed at anytime.
The Federal Rule does not apply to small generators (about 225 lamps/mo.)
Consider using lamps that have passed the TCLP test such as select Wolff System
sunlamps.