UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
OFFICE OF
AIR AND RADIATION
March 29, 1993
Dear Green Lights Participant:
The Green Lights program printed "EPA Answers Your Questions About
Fluorescent Lamp Disposal" in the December "Green Lights Update". Attached for your
information is a reprint of the article. It is important that Green Lights participants are
aware of Federal requirements for the disposal of mercury-containing lamps and handle
them accordingly. Remember that these requirements apply to all users of mercury
containing lamps, not only Green Lights participants.
If you have any questions or comments, please contact the numbers listed on the
attached document, or contact the Green Lights Program at:
Green Lights Program
U.S. Environmental Protection Agency
401 M Street, S.W.
Mail Code 6202J
Washington, D.C. 20460
Thank You!
Sincerely,
^/Jackie Krieger, Chief
Implementation Section
Green Lights Branch
Printed on Recycled Paper
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&EPA
United States
Environmental Protection
Agency
Air and Radiation
6202J
EPA 430-F-93-002
January 1993
Fluorescent Lamp ^
Disposal \tos
Green
EPA Answers Your
Questions About
Fluorescent Lamp
Disposal
EPA has been receiving an
increasing number of questions
as to whether used fluorescent
lamps are a hazardous or non-
hazardous waste, as well as
requests for guidance on the
best waste-handling methods.
EPA is happy to take this
opportunity to answer these
questions and to provide clearer
guidance on the status of
current federal regulations on
fluorescent lamp disposal.
uestion: Why is proper
disposal of fluorescent
lamps important?
Fluorescent lamps contain small
quantities of mercury that may
be harmful to the environment
and to human health. To prevent
these materials from polluting
the environment, used lamps
must be handled in an
environmentally safe manner.
uestion: Are fluorescent
lamps considered a
hazardous waste?
According to current federal law,
fluorescent lamps may be a
hazardous waste. Under the
Resource Conservation and
Recovery Act (RCRA), used
fluorescent lamps, like most
other wastes, are subject to
evaluation against the RCRA
hazardous waste characteristics,
including the toxiciry
characteristic. The generator of
the waste is responsible for
making this determination.
Wastes found to exhibit
toxicity characteristics are
defined as hazardous wastes and
must be managed according to
hazardous waste storage,
treatment, and disposal
regulations, unless otherwise
excluded. The mercury content
of fluorescent lamps can cause
them to be classified as
hazardous under this regulation,
requiring their management as a
hazardous waste.
uestion: What is EPA's
thinking on lamp
disposal?
EPA's Office of Solid Waste is
responsible for implementing
RCRA. It is currently assessing
the hazards of mercury-
containing wastes via land
disposal. A full range of options
is being considered, including
changing the regulatory levels
for mercury and developing
specific rules for fluorescent
lamps. Although the end result
of this evaluation could be
deregulation, EPA encourages all
Green Lights participants, as well
as other fluorescent lamp users,
to handle fluorescent lamps in
compliance with current
hazardous waste regulations.
uestion: Should IstM
[ & \Join the Green Lights
L 1 Program? Will Uzbtins
upgrades expose me to haz-
ardous waste regulation?
All lamp disposers, regardless of
whether or not they participate
in Green Lights, are subject to
hazardous waste regulations.
However, a comprehensive
energy-efficient lighting program
(such as Green Lights) can
reduce the cost of complying
with these regulations. First, a
good energy-efficient lighting
upgrade typically includes some
type of control strategy (e.g.,
occupancy sensors, energy
management systems), which
will reduce lamp burning hours.
This means that the lamps will
not have to be replaced as
frequently, reducing total
disposal costs. Second, a good
energy-efficient lighting program
typically includes a lighting
management plan whereby an
independent contractor replaces
all of the lamps on a pre-deter-
mined schedule. These service
1/93 7009
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contracts can include removal
and disposal of the spent lamps
(if desirable to both parties),
thereby reducing the burden of
complying with the regulations.
I uestion: What is the
Green lights Program
doing to help partic-
ipants address this issue?
The disposal of used fluorescent
lamps has been an important
consideration in Green Lights
since the program's inception in
1991. Green Lights has educated
participants on'the proper
disposal of both fluorescent
lamps and PCB-containing
ballasts by issuing fact sheets
and by devoting a chapter of the
Green Lights Lighting Upgrade
Manual to the topic.
I uestion: What are the
I A \ftnancial implications
of disposal?
The costs of complying with
these regulations are not trivial,
but they are not extraordinary.
In California, where earlier state
regulation has lead to significant
experience with regulated lamp
disposal, a 4-foot fluorescent
lamp typically costs 50 cents to
remove, transport, and dispose,
in compliance with regulations.
This cost can be put into
perspective in two ways. First,
the cost of operating a lamp
(including ballast losses) for its
20,000-hour life is $64 at the
national average electric rate of 7
cents per kilowatt-hour. The 50-
cent disposal cost of the lamp is
quite modest in comparison.
Second, replacing an old
fixture with a new one usually
costs about $100-$150, including
installation. Disposing of an old
fixture's lamps will cost approx-
imately $2, depending on market
conditions and disposal services
purchased. If the new fixture uses
half the electricity of the old fix-
ture (as is typical with Green
Lights upgrades), then the electric
bill savings will pay for the cost
of disposing of the old lamps
after 310 hours of operation—
about 1 month for most busi-
nesses. Essentially, lamp disposal
will extend the payback of a pro-
ject by approximately 1 month.
uestion: What role do
states play in fluor-
escent lamp disposal?
States may classify mercury-
containing lamps as hazardous
waste and may regulate their
disposal independent of EPA's
regulations. Check with your
Regional EPA office or the solid
and hazardous waste department
of your state environmental
protection agency for require-
ments concerning disposal of
mercury-containing lamps in
your area.
I uestion: Witt there be
more mercury in the
environment if I convert
to energy-efficient lighting?
No, there will be less. Power
plants burning fossil fuels to
generate electricity for lighting
systems also generate air
pollutants such as carbon
dioxide, sulfur dioxide, and
nitrogen oxides, as well as toxic
trace metals, including mercury.
More mercury is emitted from
power plants supplying electri-
city to lamps than is found in the
lamps themselves. Upgrading to
energy-efficient lighting therefore
keeps more mercury out of the
environment than would leaving
inefficient lighting in place.
Mercury emissions are reduced
by 60 percent through reduced
power plant emissions when
inefficient lighting is replaced
with efficient lighting.
uestion: Can lamps be
made with less
mercury?
Yes. American manufacturers are
working to adopt new processes,
which can significantly reduce
the amount of mercury needed to
operate a lamp.
uestion: Who should I
contact if I have
rther questions
about the disposal of
fluorescent lamps?
If you have questions about
handling fluorescent lamps as a
hazardous waste, please call the
RCRA Hotline at 1-800-424-9346
(703 920-9810 in the Washington,
DC area). Questions about the
Green Lights Program should be
directed to the Green Lights
Hotline at 202 775-6650.
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