Any designer or engineer who specifies energy-efficient lighting for
buildings can assist owners with lamp recycling decisions. During
the course of your business, you have significant interaction with building
owners, contractors, and electrical distributors. Therefore, it
is important for you to have an understanding of the regulations that
apply to these groups. It is also important to have an understanding
of the end-of-life management of the energy-efficient products you specify.
FEDERAL AND STATE RULES
Most states in the U.S. have adopted a less burdensome set of regulations
for dealing with hazardous waste lamps and several other hazardous waste
items. These regulations are known as the Universal Waste Rule
(UWR). If lamps are sent for recycling under the UWR, there are
less stringent requirements for storage, record keeping and transportation
as compared to managing them under the full Subtitle C hazardous waste
Distributors and contractors may have some level of involvement in the
disposal of spent mercury-containing lamps. For example, the wholesale
distributor who purchases and supplies lamps for your projects may offer
lamp recycling box programs to the contractor or building
owner. A box program is when an empty box with shipping
labels is supplied, the user takes as long as needed to fill it and
when full, the prepaid box is shipped to the recycler of choice.
The contractor may not only install lamps, but may also be involved
in the ongoing maintenance and disposal of those lamps at end-of-life.
The building owner may employ a facility manager who oversees the final
disposition of used lamps. All of these parties can help.
Specifiers should include end-of-life considerations when lighting is
chosen for buildings. In addition to life-cycle costs of lamps,
energy savings and fixtures, mercury lighting disposal/recycling costs
should be considered in the overall economics of using energy-efficiency
lighting. Remember, owners and contractors are responsible for regulatory
compliance. Specifiers can assist by providing them with information
about the fact that lamps are hazardous waste, that owners and contractors
have legal responsibilities, and that there is a network of local resources
As a specifier, you are frequently involved in the selection of efficient
lamps for retrofits. Any lighting retrofit will generate a large
number of waste lamps. These lamps may contain some combination
of mercury, cadmium, antimony and lead. Environmental considerations
call for everyone involved in a lighting retrofit project to pay close
attention to proper disposal of this waste.
The services of a competent, properly licensed, recycling service for
both lamps and ballasts is highly recommended for any retrofit project.
It should be noted that the most significant environmental enforcement
actions concerning incorrect handling of waste lamps and ballasts have
involved lighting retrofits.
In the U.S., if the lamps classify as hazardous waste, it is the responsibility
of the owner to manage the waste correctly; and contractors involved
may share that legal responsibility. While specifiers have no
specific legal responsibility for end-of-life management of the lamps
they recommend (except for lamps in their own facilities), specifiers
can be influential in assisting customers with recycling options by
providing the information included here as well as the resources and
links for their local area.
The Canadian provinces have similar concerns about environmentally responsible
lamp disposal. Lamp recyclers are also available in Canada.
website has information on lamp disposal and recyclers in Canada.
Mexico has passed a version of the U.S. UWR, which includes mercury-containing
lamps. Implementation is the responsibility of the 31 states.
Details are not yet available.
The major exposure to mercury in lamps arises from lamp breakage.
As the old lamps are removed from their sockets, they should be carefully
packed to avoid breakage. Federal rules suggest using the cartons
supplied with the new lamps for this purpose; alternatively, the lamp
recycling service may be able to provide larger containers that will
minimize the labor and handling involved. States have different
requirements regarding the number of broken lamps that can be included
in a shipment of universal waste lamps. Careful handling of waste
lamps will, therefore, minimize disposal costs.
For more information specific to your state, consult the State-by-State
Stringency Comparison Table. We also encourage you to set up recycling
programs for the spent mercury-containing lamps in your own facilities.
For more specific information see the How to section in
the Message for Building
Owners and Managers.
SETTING UP RECYCLING SERVICES
Recycling services are provided by Association of Lighting and Mercury
Recyclers (ALMR) member companies anywhere in the United States and
its territories, Mexico and Canada. Services are available to large
lamp users, small businesses, contractors, municipal government agencies
and they are also available to households and the public through household
waste collection programs. Either directly or through a network
of transportation contractors, material can be picked up in any U.S.
community. There are also a number of lighting, maintenance and
other building contractors who will collect spent lamps and get them
recycled for their customers.
Lamp collection programs can be designed for all generators:
users can participate by using a box program, where
a container is provided and when full it can be sent to any recycler
via ground mail shipment. This is a prepaid program and
labels and shipping papers are provided.
larger users, recyclers can arrange milk-run pick-ups and common
carriers will transport lamps to accumulation facilities throughout
the country, where they are consolidated for shipment to destination
very large generators, materials can be picked up in trailer loads
are numerous collection locations around the country that ship
large quantities of lamps to recycling Destination Facilities
(state authorized recyclers) every day.
typically provide customers with collection/shipping services
and containers for lamps. They will also arrange all aspects of
getting lamps recycled for anyone who is interested.
Individuals and small users can also take lamps to any locally
operated household waste facility in their community. For
a list of community programs see www.earth911.org.
Recycling. The Responsible
Thing To Do.”©
For more information