Our staff has thoroughly researched information related to the dangers of mercury pollution and has compiled a brief list of commonly asked Questions & Answers. Here are some important facts about fluorescent lamps and their disposal...

General information | What if I'm a Contractor? | What if I'm a Business Owner?

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.

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.

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A. Mercury is highly toxic to humans and wildlife. It accumulates in the tissues of fish and other organisms inhabiting mercury-contaminated waters and builds up in the tissues of organisms higher up the food chain, including humans. In humans, mercury is toxic to the nervous system, affecting the brain, spinal cord, kidneys and liver. Mercury exposure is particularly significant for young children and pregnant women because mercury inhibits the development of the brain and the nervous system. Lowered intelligence, impaired hearing, and poor coordination are some of the effects seen in children with elevated mercury exposure.

Mercury also adversely affects wildlife. Eagles, osprey, common loons, river otters, mink, and other fishing-eating animals may suffer premature death, weight loss, difficulties reproducing, and other problems as a result of eating mercury-contaminated fish.

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Q. Why Should Contractors Be Concerned?

A. Mercury can be found in items such as thermostats, thermometers, tilt-switches, sump pump switches, relays, and fluorescent bulbs. Contractors can come in contact with these items on a daily basis either during construction or during demolition. Most often, these mercury-containing devices are disposed of as solid waste, and mercury ends up in the environment either by incineration, or by leaching into the land and water.

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Q. What Should Contractors Do?

A. Since mercury is a hazardous waste, demolition or renovation contractors are hazardous waste small-quantity generators and are subject to the new state Laws. See state and local laws.

Spent/replaced mercury-containing products must be managed as either hazardous waste or universal waste. If managed as a hazardous waste, the contractor must obtain an EPA ID number, manage hazardous waste properly prior to disposal, manifest all hazardous waste/mercury-containing devices and transport them through a certified hazardous waste hauler. The Thermostat Recycling Center (TRC) collects thermostats for free, but there is a small fee to dispose of fluorescent lamps, tilt switches, etc. Please see the attached list of fluorescent lamp and ballast recycling facilities.

If managed as a universal waste, the contractor can recycle mercury-containing devices free of charge with a recycler. Universal wastes are exempt from the Hazardous Waste Rules, but must be stored properly to prevent release, labeled correctly, self-transported, or shipped with a bill of lading.

As a contractor, you should attempt to use mercury-free alternatives whenever feasible, in order to reduce mercury at its source. Avoiding the use of mercury-containing devices eliminates the problem before it develops. A list of mercury-free alternatives can be found as an attachment to this fact sheet. In addition, you should remove and recycle mercury products during demolition. Many HVAC and plumbing/heating suppliers now recycle old mercury thermostats and tilt switches. For a list of participating businesses, please contact local state agency for More Information.

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Q. Does my business need to recycle fluorescent lamps?

A. Fluorescent lamps are classified as a universal hazardous waste and all businesses should recycle them. If you are a small business generating less than 220 lbs. of hazardous waste (including fluorescent lamps and other mercury-containing wastes) and less than 2.2 lbs. of acutely hazardous waste within any month of a calendar year, then your business may qualify as a Conditionally Exempt Small Quantity Universal Waste Generator (CESQUWG). (As an example, one box of 36 fluorescent lamps (four-foot long tubes) weighs about 24 lbs.)

CESQUWGs are not subject to the same rules for training, accumulation, and packaging of their hazardous waste that the larger hazardous waste generators are. However, they do need to follow the recycling and disposal requirements of the universal hazardous waste rules in the State of California. CESQUWGs can recycle their lamps at their local government sponsored Hazardous Waste Recycling and Disposal Programs. Or, they can choose to collect and ship the lamps to a lamp recycling business (see attached list of California recyclers).

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Q. What Should I Do with Used Fluorescent Lamps?

A. Before you start to recycle your fluorescent lamps, make sure you and your staff is aware of the regulations and best management practices for handling and storing the wastes. If you are unsure about what is required of you, contacts and Additional resources may be found at the web sites listed at the end of this article.

Breakages - If lamps are accidentally broken, clean them up promptly. Wear protective plastic or latex gloves to avoid touching the glass with your bare hands. Use pieces of cardboard to push the glass into a pile and carefully pick up the shards, placing them inside a heavy plastic bag that is placed inside of box or in a rigid container that can be sealed. Place a label on the container indicating that broken lamps are inside. Do not mix broken lamp debris in with the unbroken spent lamps you are recycling; otherwise the recycler for handling the wastes may charge you extra.

Recycling - Used lamps should not be accumulated for more than one year from the date you start collecting them until the time you recycle them.

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Q. Where can I recycle used fluorescent lamps?

A. Recycling Firms - Arrangements can also be made with a lamp recycling business to accept the lamps and ship them to a recycling business on your own. Common transportation carriers (e.g., UPS and FedEx) can pick up the lamps and transport them to a recycler. Also, some recyclers can schedule pick-ups from your business as a part of one of their regular routes. Check with a recycler to find out what their particular options and requirements are. To find a list of local recyclers click here.

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Q. How else can you help reduce mercury pollution?

A. Buy low-mercury fluorescent lamps - Major lighting manufacturers now produce lamps with up to 80% less mercury than standard fluorescent lamps, such as Philips, Alto, GE, Ecolux, and Sylvania Ecologic. However, none of these lamps are completely mercury-free, so they need to be recycled.

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