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Flourescent Lamp Recycling

On July 6, 1999, EPA added hazardous waste lamps to the federal list of "universal wastes". Hazardous waste lamps are any lamps that are characteristically hazardous. That is, they fail the Toxicity Characteristic Leaching Procedure (TCLP). This includes fluorescent, high-intensity discharge, neon, mercury vapor, high-pressure sodium, and metal halide lamps if they are characteristically hazardous. Fluorescent lamps are hazardous because they contain mercury.

The new rule became effective on Jan. 6, 2000. The Universal Waste Rule of 1995 was designed to reduce the amount of RCRA hazardous waste disposed of in municipal waste landfills, encourage recycling and proper management of some common hazardous wastes, and reduce the regulatory burden on businesses currently managing these materials as hazardous waste. "Universal wastes" are hazardous wastes; however, they have less stringent requirements for storing, transporting, and collection. Universal wastes are regulated under 40 CFR 273 and 25 PA Code 266b. Options for managing lamps include managing them as hazardous waste, managing them under the universal waste rule, or using a type of lamp that is not hazardous.

The change in federal regulations has been adopted into the Pennsylvania Hazardous Waste Management regulations by reference under 25 Pa Code 260a.1. The major differences between the federal regulations and the PA regulations is that the federal regulations allow a very small quantity generator (someone generating less than 220 pounds of hazardous waste per month) to dispose of their waste in a municipal waste landfill while Pennsylvania does not allow it (see 25 PA Code 261a.5 (b)).
The effect of this regulation is that, in Pennsylvania, all fluorescent lamps, if hazardous, must be managed as either a universal waste or manifested as hazardous waste. Lamps from households are not subject to these requirements because household waste is excluded from regulation as hazardous waste at 40 CFR 261.4(b)(1) which is incorporated by reference in the PA regulations.

There are newer lamps on the market that have lower levels of mercury and thus are not hazardous waste. If the lamps pass the TCLP they are not hazardous waste and may be disposed of in a municipal waste landfill.