Are Compact Fluorescent Light Bulbs Hazardous Waste?

Posted on 4/24/2012 by James Griffin

Q. Are compact fluorescent light bulbs Hazardous Waste?
A. Maybe. Some, but not all, compact fluorescent light bulbs (CFLs) must be managed as hazardous waste. Even those CFLs that aren’t hazardous waste may still require special handling and care.
Compact fluorescent light bulbs are not listed as hazardous waste in 40 CFR Part 261, Subpart D, but do contain vaporous mercury (a toxic, persistent, and bio-accumulative pollutant). The amount of mercury in a CFL is minute, but traditional designs contain more than enough to exhibit the toxicity characteristic for mercury (D009) and qualify as hazardous waste. Some newer models contain less mercury and do not exhibit the D009 characteristic. For these low-mercury bulbs, check with local authorities for special disposal rules.
Starting this year, if a CFL contains any quantity of mercury, new FTC regulations require a “Contains Mercury” disclosure on the product labeling.
What This Means for Your Business
A facility that generates less than 100 kilograms of hazardous waste per month is conditionally exempt from RCRA. [40 CFR 261.5] If your business falls under this threshold, your lamps aren’t hazardous waste, but you should check with local municipal authorities to see if they have special requirements for CFLs. Non-exempt facilities must manage CFLs as hazardous waste under the normal RCRA rules or as “Universal Waste” following the alternative, less restrictive management standards from 40 CFR Part 273.
Universal waste handlers must:
Hazardous Waste CFL Lamps
  • Store universal waste lamps in closed, sturdy containers;
  • Label the containers “UNIVERSAL WASTE-LAMP(S),” “WASTE LAMP(S),” or “USED LAMP(S)”; and
  • Not accumulate universal waste lamps for more than one year
If lamps break, the handler must immediately clean them up and store the debris in a sealed container. The debris may have to be managed as hazardous (non-universal) mercury waste.
While only large quantity handlers (those who accumulate more than 5,000 kilograms of universal waste at any time) are required to keep records of their universal waste shipments, it’s not a bad idea for smaller handlers to follow suit.
What This Means for Your Household
All solid wastes generated by households are exempt from regulation as hazardous waste. Non-hazardous household wastes must be managed according to State and local rules for solid waste. These rules vary from place to place and may require or simply encourage you to recycle spent CFLs.
Contact your local municipality to see if they prohibit CFLs from municipal waste collection. If they do, they can tell you how to properly dispose of CFLs in your area. In many areas, retail stores serve as collection centers for CFLs and other household hazardous wastes. If those options are not available, then look for bulb manufacturers that sell pre-labeled shipping kits so you can send your spent bulbs back to the source for reclamation.
Cleaning Up Broken Lamps
When a lamp breaks, it releases mercury vapor to the air, which can later deposit on surfaces. For best practices and other guidance from the EPA on cleaning up broken lamps:

Tags: hazardous, RCRA, waste

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