How Do I Know if I Need to Recycle Fluorescent Lamps?

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Some important facts concerning your fluorescent lamps and their disposal…

Q: Do I need to recycle my fluorescent lamps?

A: YES! All fluorescent lamps contain mercury. Mercury is a hazardous substance that when released to the environment can contribute to neurological impairment in child development. In addition, the U.S. Environmental Protection Agency considers mercury a persistent bio-accumulative toxic substance. Proper recycling of fluorescent lamps prevents mercury from being released to the environment.

Q: What about compact fluorescent lamps (CFL’s) – do I need to recycle them also?

A: YES! Compact fluorescent lamps also contain mercury. While CFL’s are energy saving and their use is encouraged, they provide a unique threat to the environment when disposed of improperly.

Q: Is there a law that requires fluorescent lamp recycling?

A: YES! There are many laws, regulations, and legal liability issues that require lamps to be recycled.

Consider the following:

  • All generators of spent fluorescent lamps are responsible for their proper disposal (Resource Conservation and Recovery Act, RCRA). The act specifies that unless you are a household, you are liable for proper disposal of your hazardous waste. Using a specific type of lamp, i.e. a low mercury lamp, does not satisfy the requirement. Only proper documentation, TCLP analytical tests, done by approved EPA methods by an approved EPA laboratory, will satisfy the legal requirement of proof that your waste is not hazardous.
  • If you do not have proper documentation then you will need to show where you have been sending your waste lamps. Note that if you do not have documentation showing your lamps as non-hazardous, then the law requires you to assume that they are hazardous waste. Once this assumption is made, then you will be required to prove that you have disposed of the hazardous waste using legal means. Sending lamps to a responsible lamp recycling organization will satisfy the requirement, provided the responsible recycling organization is registered with its State and or EPA as a bona fide lamp recycling entity.
  • Most states along with EPA have adopted Universal Waste Regulations for the disposal of lamps. These regulations allow lamps to be sent using common carriers without the need of a Hazardous Waste Manifest. This keeps the cost of transportation low and thus encourages the recycling of the lamps. Some aspects of the RCRA and Universal Waste regulations allow for “Conditionally Exempt Small-Quantity Generators” to become exempt for certain aspects of the regulations. None of these exemptions allow for improper lamp disposal.
  • Certain landfills, municipal waste incinerators and disposal facilities will not accept mercury-containing articles regardless of the TCLP value of the item or any Federal or State exemptions. Each disposal facility has its own permitting requirements with governing authorities and as such must comply with all permit requirements. Always check with your disposal facility before sending those items to them.
  • Of course, considering the above regulations, the safest and most responsible method of disposal is to utilize a legitimate mercury recycler.