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Lighting Waste Disposal

Both lighting upgrades and routine maintenance entail the removal of lamps and ballasts from the system. These lamps and ballasts must be disposed of according to state and Federal regulations; if they conflict, then the stricter regulations must be obeyed. Mercury-containing fluorescent and high-intensity discharge (HID) lamps and PCB-containing ballasts are two types of potentially hazardous waste.

All fluorescent and HID lamps have mercury content. The U.S. Environmental Protection Agency (EPA) regulates mercury disposal under the Resource Conservation and Recovery Act (RCRA). Because the cost of testing the lamps may be prohibitive, it is generally wise to consider all lamps being disposed of as hazardous waste. As hazardous waste, lamps must either be recycled or disposed of in hazardous waste landfills as opposed to municipal solid waste landfills. They cannot be incinerated.

Small generators are exempt from RCRA regulations. Small generators are companies that generate less than 100 kilograms of hazardous waste per month; in terms of lamps only, this is about 300-350 4 ft. T12 lamps or 400-450 4 ft. T8 lamps per month.

The cost of recycling a 4 ft. fluorescent lamp can be about $0.50-0.75/lamp vs. about $0.25-$0.50 for landfill disposal (as of 1995, source: EPA Green Lights); usually, recycling does not make the initial cost of a lighting upgrade unprofitable. When fluorescent lamps are recycled, the waste is crushed, then separated into phosphor powder, recovered mercury, metal and glass that are eventually put to reuse.

In recent years, the major lamp manufacturers have introduced a number of low-mercury fluorescent and HID lamps (example: Philips' Alto fluorescent lamp) that are designed to pass EPA tests, allowing them to be disposed of in municipal solid waste landfills. Check with the state hazardous waste agency or agencies having jurisdiction to see if the lamps can be disposed of as solid waste.

In addition, both the U.S. EPA and the states have been relaxing their regulations regarding the disposal of fluorescent and HID lamps. Again, check with the applicable state hazardous waste agency or agencies to determine the specific requirements for handling, storage, transportation and disposal of mercury-containing lamps.

Ballasts manufactured and distributed in the United States prior to 1979 contain polychlorinated biphenyls (PCBs), which is a hazardous material. Since many magnetic ballasts can enjoy a service life of 25 years or longer, many of these ballasts are still in existence. If a ballast label is marked "NO PCBs," then it is not a PCB ballast; if there is no such marking, then the ballast is assumed to contain PCB fluid.

PCB ballasts are treated differently if they are leaking or non-leaking. If the ballast is leaking PCB fluid, special care must be taken because any material that the fluid touches is immediately considered PCB-contaminated waste and must be disposed of accordingly.

If the PCB ballast is leaking, it must be disposed of in an EPA-approved incinerator.

Non-leaking PCB ballasts are not covered by Federal regulations, although if a pound or more of PCBs is disposed of in a 24-hour period (about 12-16 magnetic F40 ballasts) the generator of the waste must notify the National Response Center at (800) 424-8802. State and local regulations vary. Some require that the ballasts be handled, stored, shipped and disposed of as hazardous waste, while others simply deny disposing of them in a municipal solid waste landfill. As is the case with mercury-containing lamps, it is the generator's responsibility to identify and obey the strictest applicable regulations among any government entity having jurisdiction. There are three ways to dispose of non-leaking PCB ballasts:

Landfill Disposal
Some states permit the generator to dispose of non-leaking PCB ballasts in various landfills. The cost can be about $0.50 per ballast for the disposal cost alone (1995, source: EPA Green Lights), not including handling, transportation and documentation fees. However, the generator may be held liable for later Superfund cleanup costs even if PCB ballast disposal is allowed at those landfills.

The ballasts can be destroyed in a high-temperature incinerator. This can cost about $5.00 per ballast just for the incineration procedure alone (1995, source: EPA Green Lights).

The ballasts can be recycled, meaning contaminated materials are separated and destroyed in an incinerator while useful materials such as copper and steel can be recycled. This option can cost about $3.50 per ballast for the recycling procedure alone (1995, source: EPA Green Lights).

Again, contact state and local authorities to determine applicable regulations to the disposal of PCB ballasts. This article was produced as a general guide and may contain dated information. Regardless of what option is chosen, it is usually wise to keep permanent records of all PCB disposal activities.