Hazards

Bright, cool-burning fluorescent lamps are commonly used in both industry and offices.  Chances are, you have them now.   However, fluorescent tubes contain mercury and lead, which are hazardous materials.  When you remove old fluorescent lamps, there are specific rules about how to handle and dispose of them, because they are double trouble:They pose a serious environmental hazard the mercury can leach out of landfills and poison both the soil and drinking water.They are also a health hazard workers can be exposed to dangerous mercury fumes and lead powder whenever fluorescent lights are broken.  Mercury exposure poses many serious health risks, including permanent nerve and kidney damage.

 

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Federal Regulations

In the federal hazardous waste lamp rule, a lamp, also referred to as a universal waste lamp, is defined as the bulb or tube portion of an electric lighting device.  Examples of common universal waste electric lamps include fluorescent, high intensity discharge (HID), neon, mercury vapor, high pressure sodium, and metal halide lamps.Under the federal rules, a used lamp becomes a waste on the day that it is discarded.  An unused lamp becomes a waste when the handler decides to discard it.  Some states' definitions of universal waste lamp differ from the federal definition.  Some also have different criteria for when a lamp becomes a waste.  Be sure to check state universal waste rules before disposing of waste lamps.EPA added hazardous waste lamps to the federal list of universal wastes regulated under the Resource Conservation and Recovery Act (RCRA), effective in January 2000 (see 40 CFR 273.13 and 273.33 of the existing universal waste rule that addresses requirements for hazardous waste lamps).  The intent is to encourage the recycling of hazardous waste lamps so that fewer spent lamps, and the mercury inside them, end up in landfills.Conditionally exempt small quantity generators who dispose of less than 100 kilograms (220 pounds) of hazardous waste of any kind in a month are not subject to RCRA hazardous waste management standards.  They may dispose of spent lamps in municipal solid waste landfills.  If you store more than 100 kilograms but less than 5,000 kilograms (11,000 pounds) of universal wastes in a month, you are considered a small quantity handler of universal waste and subject to special handling and labeling requirements.  Large quantity handlers of universal wastes who store more than 5,000 kilograms of universal waste are subject to notification requirements in addition to the special handling and labeling requirementsYou are allowed to accumulate properly stored fluorescent lamps on-site for up to one year.  By the end of this year, you must arrange for transportation to a proper recovery, treatment, or disposal facility.

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Illinois Regulations

In Illinois, the newly amended Universal Waste Rule encourages recycling or proper disposal of waste lamps.

The Illinois Pollution Control Board amended the Illinois Universal Waste Rule (on April 2, 1998) to cover mercury-containing lamps. Wastes in this special category of hazardous waste are called “universal” because they are broadly generated. Pesticides, thermostats and batteries also can be classified as universal wastes.The Illinois Universal Waste Rule encourages hazardous waste lamps to be properly collected, recycled or disposed of. Managing mercury-containing lamps under the streamlined requirements of the Illinois Universal Waste Rule:

  • Eliminates permits for universal waste handlers and transporters;
  • Eliminates manifests (except when lamps are transported through or are treated or disposed in states not recognizing waste lamps as universal waste);
  • Eliminates their contribution to your total volume of hazardous waste;
  • Increases the time you may store waste lamps;
  • Reduces record keeping, training and emergency preparedness requirements.

Proper Labeling

Individual waste lamps or containers must clearly state one of the following:

  1. "Universal Waste Mercury-Containing Lamps"
  2. "Waste Mercury-Containing Lamps"
  3. "Used Mercury-Containing Lamps"Storage Requirements

Mercury-containing bulbs can be stored on site for up to one year (or longer if they can demonstrate more time is needed to collect quantities necessary for proper recovery, treatment or disposal). Handlers must record on each lamp or lamp container the date lamps became waste.

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Crushing Lamps

Universal waste handlers and transporters may crush mercury-containing lamps only to reduce their volume, and only at the site where waste lamps are generated, provided:

Crushing occurs in a closed system designed and operated to prevent mercury emissions from exceeding 0.1 milligrams per cubic meter, measured on a time-weighted average over an eight-hour period, as rated by the crusher’s manufacturer;

The Illinois EPA is notified of crushing activities quarterly, in a form acceptable to the Agency;

Crushing occurs in a well-ventilated and -monitored area, to ensure compliance with applicable OSHA exposure limits;

Employees crushing lamps are thoroughly familiar with emergency procedures and proper handling of mercury waste;

Crushed lamps are stored in closed, nonleaking containers;

Spilled or leaked materials are transferred immediately to closed containers.

Crushing may pose health and environmental risks if mercury vapors are released. Also, lamp recyclers may prefer whole lamps to crushed ones.

 

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UIS Management of Bulbs

All spent fluorescent bulbs are collected by the physical plant employees and placed in recycling containers clearly marked for "mercury containing bulbs". The bulbs are picked up twice a year by a licensed hauler. Currently, UIS is generating around 5,000 bulbs per year.


Cleanup of broken bulbs

A single bulb does not contain enough mercury to render it hazardous. A single, broken bulb can be swept and disposed of in one of the campus dumpsters. For more information on chemical spill cleanup procedures, contact raebig.bob@uis.edu or call 206-6531.

Household Lamps 

Mercury-containing lamps discarded by households are not subject to hazardous waste rules and can be accepted by municipal-waste landfills; however, the Illinois EPA recommends you take these lamps to household-hazardous-waste collection centers.

 

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