Fluorescent and High-Intensity Discharge (HID) lighting provides the environmental benefit of energy efficiency, since they can use up to 75 percent less electricity than incandescent lighting. However, the phosphor powder found inside fluorescent lamps (both the tubes and the new "energy-saver" lamps designed to replace conventional incandescent light bulbs) contains mercury, which can be toxic.
Fluorescent lamps generated by a resident of a residential life facility are exempt from RCRA requirements due to the household waste exclusion (40 CFR 261). This exclusion applies to household waste derived from single and multiple residences, and other residential units. In order for the waste to be exempt from the RCRA regulations, the waste must be generated by individuals on the premises of a household, and it must be comprised primarily of material found in waste generated by consumers in their homes. It is important to note that state or local regulations may be more stringent than federal regulations; state and local agencies should be contacted for details on their policies and regulations concerning household hazardous waste.
Fluorescent lamps not satisfying the household waste exclusion are subject to the federal universal waste management requirements in 40 CFR 273, which include:
- Following procedures for storing waste lamps (whether they are intact or broken) in such a way that they are properly contained. The container(s) must be structurally sound, adequate to prevent breakage or, in the case of broken waste lamps, leakage; and compatible with the contents of the container.
- Labeling, as appropriate, the wastes: "Universal Waste-Lamp(s)," "Waste Lamps(s)," or "Used Lamp(s)."
- Tracking the length of time universal waste accumulates to ensure that the waste does not accumulate for more than one year (unless the facility can demonstrate that accumulating universal wastes for more than one year is necessary to facilitate proper recovery, treatment or disposal).
- Providing universal waste training to employees that covers responsibilities for universal waste handling and emergency procedures.
- Containing all universal waste releases and determining whether any released material is hazardous waste.
In addition, large quantity handlers of universal waste--those who accumulate 5,000 kg or more of universal waste at any given time--are required to notify the EPA of its universal waste management and retain records of all universal wastes shipped from and received by the facility. (Other wastes considered to be universal wastes include spent batteries, pesticides and mercury thermostats.) If spent batteries and mercury-containing devices (e.g., thermostats), fluorescent lamps and waste pesticides are not managed as universal wastes, then these wastes must be managed according to applicable RCRA hazardous waste requirements. Some states also have their own, sometimes more stringent, regulations.
For the complete text of the federal regulations (40 CFR 261 and 273), click here:
40 CFR 261
40 CFR 273