LED lamps can last a long time–up to 22 years (at 3 hours per day), by some estimates.
But eventually they will need to be replaced and disposed of.
While LED lamps don’t contain mercury like fluorescent lamps do, they are manufactured with circuit boards containing toxic lead solder. LEDs may also contain metals that the EPA considered hazardous like cadmium, nickel, and silver.
Under its RCRA hazardous waste program, EPA allows businesses to manage many types of hazardous waste lamps as “universal waste.” Universal waste is a category for wastes commonly generated by a broad range of industries that would otherwise be subject to hazardous waste regulation because of their hazardous constituents—namely lamps, batteries, mercury-containing equipment, pesticides and (now) aerosol cans.
To determine if LED lamps should be managed as hazardous waste or universal waste, we need to look to closely at the RCRA regulations.
Lamps as Universal Waste
The universal waste regulations define lamp
as “the bulb or tube portion of an electric lighting device” that is “designed to produce radiant energy, most often in ultraviolet, visible, and infra-red regions of the electromagnetic spectrum.”
The definition, found in 40 CFR 273.9, lists specific types of lamps that can be managed as universal waste: fluorescent lamps, high intensity discharge lamps, neon lamps, mercury vapor lamps, high pressure sodium lamps, and metal halide lamps.
While not mentioned by name in the definition, LED lamps certainly fit this definition.
Some states even explicitly include LEDs as part of their state universal waste program (e.g., Minnesota).
Universal Waste vs. Hazardous Waste
All universal wastes must first be hazardous wastes. That said, EPA does not require you to evaluate a waste if there is a possibility that the waste is hazardous. The generator may assume the waste is hazardous and manage it under the universal waste regulations.
If you know the lamp is not
hazardous waste, the EPA allows you to voluntarily follow the universal waste regulations. Many states have guidance documents stating the same.
If you don’t know for sure it is not
a hazardous waste and there is any reasonable expectation that it might be, the generator may assume it is a hazardous waste or would have to have it tested for suspected metals using the Toxicity Characteristic Leaching Procedure (TCLP) to prove it’s not.
Any lamp that does not
exhibit one or more of the hazardous waste characteristics of ignitability, corrosivity, reactivity, or toxicity is not considered hazardous waste and, therefore, will not be a universal waste [See 40 CFR 273.5(b)(2)].
Lamps that are not hazardous wastes may be disposed of in municipal waste management facilities. The EPA still encourages generators to recycle non-hazardous lamps rather than dispose of them.
One in 10 RCRA violations is related to mismanagement of universal waste. To prevent the most common universal waste management mistakes at your facility, check out this post: 4 Common Universal Waste Mistakes (And How to Avoid Them)
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