Other States

What’s Hazardous?

Persons who generate wastes are responsible for determining whether their wastes are hazardous. One common method for determining whether a waste is hazardous is the Toxicity Characteristic Leaching Procedure (TCLP) test. The TCLP test is a laboratory test that simulates the potential leaching of hazardous wastes under conditions typically found in municipal solid waste landfills. If the concentration of mercury in water that is passed through a sample of crushed fluorescent lamp fragments exceeds 0.2 mg/liter, the crushed lamp fragments are classified as a hazardous waste. (See test method 1311 in “Test Methods for Evaluating Solid Waste, Physical/ Chemical Methods,” EPA Publication SW846 for more information about the TCLP procedures.)

In most cases, standard fluorescent lamps and lamp fragments fail the TCLP test and are considered hazardous wastes. Facilities should treat the spent lamps and lamp fragments as hazardous wastes unless they test the spent lamps and fragments and determine that the wastes are non-hazardous. Facilities should manage the spent lamps as hazardous waste according to applicable federal, state, and local requirements.

New low-mercury lamps have been introduced into the market. While these lamps may pass the TCLP test and be considered safe to landfill, some states – like Minnesota and Vermont – still prohibit persons from disposing of even these non-hazardous lamps in a solid waste landfill. You may want to talk with a State EPA representative to find out how you may handle spent lamps in your state.

Please note that regardless of whether the State in which you are located allows you to dispose of lamps in your dumpster with other non-hazardous trash, the lamps do contain mercury and mercury vapors are released into our environment when you throw lamps in the trash. Typically, the lamps break in the dumpsters, during transportation or in the landfill and release mercury into the air or groundwater. These hazardous releases are a risk to surrounding communities.

Facilities that throw their spent lamps in the trash thinking they are saving money may be mistaken. Throwing spent lamps in the trash may result in the person being held responsible for the cleanup of a remote and costly Superfund site. Because of the potential liability under Superfund, we believe facilities that decide to recycle their spent lamps are making a smart decision that benefits not only the environment but also the bottom line.

EPA Regulatory Information

Chicago Lamp Recycling provides the information in this section in order to familiarize customers with the regulations governing lamp disposal, and to identify for customers the government agency that may regulate their operations. Customers may use this information as a starting point to determine how their facilities are regulated. Customers are cautioned against relying solely on the information contained below and should contact their state environmental protection agency for more information to determine how lamps are regulated in the states in which they operate.

Mercury produces a hazardous waste. Every form of it is toxic and yet mercury is an essential element in millions of fluorescent lamps throughout the United States and millions more throughout the world. State and federal regulatory agencies are working to reduce mercury releases to the environment. Since January 1, 2000, the United States Environmental Protection Agency (USEPA) has allowed for spent lamps to be managed as Universal Wastes. The Universal Waste Rules (UWR) are designed in part to simplify the management of mercury-containing wastes including spent fluorescent lamps. The Rules are also intended to encourage recycling, thereby reducing mercury emissions to the environment.

As an alternative to managing lamps as universal wastes, a facility may elect to manage its spent lamps as hazardous wastes. Hazardous waste rules – like the universal waste rules – are promulgated under the federal Resource Conservation Recovery Act (RCRA) and state laws equivalent to RCRA. RCRA regulates hazardous wastes “from the cradle to the grave.” RCRA Subtitle C requires a waste generator to properly identify, treat, store, transport and dispose of hazardous wastes. The USEPA oversees the RCRA program but has delegated to the States the responsibility for the day-to-day management of the program. (See State EPA office website links below for more information concerning RCRA and the State agencies which administer RCRA.)

Universal vs. Hazardous

State and federal laws require persons to properly manage their lamps. Persons can choose to manage their lamps under either the universal or hazardous waste regulations. While certain persons benefit from the ability to treat spent lamps as universal wastes, others find that it makes more sense to continue to manage spent lamps as hazardous wastes.

In the past, persons who chose to manage spent lamps as hazardous wastes complained that storing the intact lamps on-site took up too much space, that storing the intact lamps on-site created concerns about meeting RCRA-imposed storage deadlines, and that shipping costs for hazardous wastes were higher than for universal wastes. Managing lamps under universal waste rules allows a much longer time for storage on site and eliminates the paperwork and manifesting required under hazardous waste rules. Shipping costs are lower since transporters need not have specialized hazardous waste licensing.

For more guidance about lamp crushing and waste regulation, please contact your state Environmental Protection Agency or click on your state link to access their website. (Some states also have guidance papers available for how to properly dispose of your waste.)

Alabama- www.adem.state.al.us
Alaska- www.state.ak.us
Arizona- www.adeq.state.az.us
Arkansas- www.adeq.state.ar.us
California- www.calepa.ca.gov
Colorado- www.cdphe.state.co.us
Connecticut- www.dep.state.ct.us
Delaware- www.dnrec.state.de.us
Florida- www.dep.state.fl.us
Georgia- www.dnr.state.ga.us/dnr/environ
Hawaii- www.hawaii.gov/dlnr/
Idaho- www.state.id.us/deq
Illinois- www.epa.state.il.us
Indiana- www.state.in.us/idem/
Iowa- www.iwrc.org
Kansas- www.kdhe.state.ks.us
Kentucky- www.dnr.ky.gov
Louisiana- www.deq.state.la.us
Maine- www.state.me.us/dep
Maryland- www.mde.state.md.us
Massachusetts- www.magnet.state.ma.us.dep
Michigan- www.michigan.gov/deq
Minnesota- www.dnr.state.mn.us
Mississippi- www.deq.state.ms.us
Missouri- www.dnr.mo.gov
Montana- www.deq.state.mt.us
Nebraska- www.dnr.ne.gov
New Hampshire- www.des.state.nh.us
New Jersey- www.state.nj.us/dep
New Mexico- www.state.nm.us
New York- www.dec.state.ny.us
North Carolina- www.enr.state.nc.us
Ohio- www.epa.ohio.gov/
Oklahoma- www.deq.state.ok.us
Oregon- www.deq.state.or.us
Pennsylvania- www.dep.state.pa.us
Rhode Island- www.state.ri.us/dem
South Carolina- www.scdhec.net/eqc
South Dakota- www.state.sd.us/denr
Tennessee- www.state.tn.us/environment/swm
Texas- http://www.tceq.state.tx.us
Utah- www.eq.state.ut.us
Vermont- www.anr.state.vt.us
Virginia- www.deq.state.va.us

Guidance Info

Washington- www.dnr.wa.gov
West Virginia- www.wvdnr.gov
Wisconsin- www.dnr.state.wi.us
Wyoming- www.deq.state.wy.us