Handling Mercury Containing Lamps

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Compact fluorescent lamps (CFLs) and other energy efficient lighting, such as linear fluorescent and high intensity discharge (HID) lamps, contain a very small amount of mercury, an element essential to achieving energy savings. While these lamps help consumers and businesses cut their lighting energy usage and reduce energy costs, it is important that any product containing mercury be properly managed when it becomes waste to protect public health and the environment. Lighting manufacturers, through their trade association, National Electrical Manufacturers Association (NEMA) have developed a Web site, lamprecycle.org, to provide information to commercial and residential users about recycling lamps. In an exclusive interview with TFM, Mark Tibbetts, who directs NEMA’s recycling initiatives, answered questions about developments in lamp recycling and the role of lamprecycle.org. TFM: Why has NEMA launched this education campaign on lamp recycling? What are NEMA’s goals for this campaign? Tibbetts: There are a couple of key reasons. While NEMA has been promoting fluorescent lamp recycling for a decade, there is heightened awareness in light of recent federal energy legislation about the energy conservation benefits of fluorescent lighting and the savings in electric bills. Secondly, several states have banned disposal of fluorescent lamps into the normal waste stream, forcing consumers and businesses to keep waste lamps out of the trash. NEMA feels it is important to provide a unified message about both the economic and environmental benefits of fluorescent lighting, while at the same time showing how easy it is to manage environmental issues at the end of a lamp’s life. NEMA’s lamprecycle.org website does this in one location. Fluorescent lamps are generally four to five times more efficient than incandescent bulbs; however, energy efficient lighting products such as fluorescent lamps, CFLs, and high intensity discharge (HID) lamps contain small amounts of mercury. The mercury is contained within the lamp and is not exposed to the environment unless the lamp is broken. The release of mercury is most likely to occur when the lamp is thrown in a garbage truck or a dumpster. While lamps are not a major source of mercury pollution, the improper disposal of large numbers of lamps does add to mercury in the environment. Burning hazardous wastes or incinerating disposed materials, to the extent that an incinerator does not control all mercury emissions, can also release mercury into the environment. The best way to prevent the release of mercury from lighting is to recycle lamps and not dispose of them in the solid waste stream. Recycling lamps captures the small amount of mercury, allowing it to be reused. TFM: From your experience, what do you see as the most common and/or “biggest” challenges to facility managers correctly executing a lamp recycling program? Tibbetts: First, the incorrect perception that lamp recycling will be a significant additional cost is the biggest issue. And second, this is fundamentally about changing behavior, and as we all know, change is hard. But it is important to note that the downside of not recycling is significant. Depending on the state and/or volume of lamps disposed, the costs associated with an enforcement action by state or federal regulators can dwarf those of implementing a lamp recycling program. TFM: Can you provide a ballpark figure on how much a facility manager can expect to pay for recycling of fluorescent lamps? Tibbetts: There are a couple ways of quantifying the costs associated with recycling lamps. First, looking at it from a life cycle perspective, the cost to recycle lamps represents less than 1% of the total life cycle cost, since most of the cost is associated with energy usage. Another figure that is worth citing comes from Trammell Crow Company: “A fluorescent lamp recycling program will impact an average property operating expense budget by less than one-tenth of one percent.” TFM: Massachusetts and Maine are two states that have passed relatively stringent regulations. What are the states to watch in terms of those that might be passing updated regulations on mercury containing lamps in the near future? Tibbetts: At least eight states have regulations more stringent than current federal regulations. Additional legislation is most likely in the Northeast, Great Lakes, and Pacific Northwest. TFM: If a facility’s lamp volume and/or local and state regulations exempt that facility from having to recycle mercury containing lamps, what other reasons should facility managers consider for pursuing a recycling program? Tibbetts: Simply put, it’s the right thing to do. For instance, 48 states have issued fish consumption advisories for mercury. While mercury containing lamps are not a significant source of mercury, they are an easily controlled source. Mercury is a persistent bio-accumulative toxin that can affect animal and human health, and we all share a responsibility in keeping it from the environment. TFM: The federal Universal Waste Rule (UWR) differs in a number of ways from state regulations, and regulations vary from state to state. That said, are there any constants in terms of rules contained across the board? Tibbetts: Used (also known as “spent”) mercury containing lighting products are regulated by the U.S. Environmental Protection Agency (EPA) under the Resource Conservation and Recovery Act (RCRA) in the part known as Subtitle C. Subtitle C is where hazardous waste regulations are addressed. In 1999, the EPA added mercury containing lamps to the list of products that may be managed under the “Universal Waste Rule.”  This is the baseline regulation, and facility managers should familiarize themselves with the rule. However, states may adopt more stringent regulations, and many have done so. Facility managers should research the specific regulations in the states where they manage properties. TFM: As opposed to sending intact lamps to a recycler, some facilities employ lamp crushing machines on-site and have those materials picked up by a service provider. What is NEMA’s position on that approach? Tibbetts: NEMA takes no specific position on different approaches to managing spent mercury containing lamps; however, it is important for facility managers to check the regulations in the states where they manage properties, as not all states permit crushing or have additional regulatory requirements. In addition to directing the National Electrical Manufacturers Association’s (NEMA) recycling initiatives, Tibbetts serves as the executive director for the Thermostat Recycling Corporation (TRC). He was previously the director of site operations and grant programs for PowerUp non-profit. Tibbetts holds his bachelor’s and master’s degrees from the University of Maine. He currently resides in Alexandria, VA.

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