Waste fluorescent lamps contain toxic mercury and lead and are usually hazardous waste. Tanning facilities should recycle their hazardous waste fluorescent lamps rather than dispose of them in landfills.
Why are waste lamps regulated?
Waste lamps can be regulated as hazardous waste because they contain toxic mercury and lead. If these lamps are burned or thrown into landfills, the mercury and lead in them can be released into the environment, where contamination problems may occur. Two types of lamps are of concern:
- Fluorescent lamps
- High- and low-pressure mercury vapor lamps
These lamps contain mercury in concentrations that can exceed the toxicity characteristic leaching procedure's (TCLP) limit. (The TCLP test is a common laboratory test used to determine if solid waste contains harmful concentrations of certain pollutants.) Every tanning business generates waste lamps that could become a hazardous waste problem if not properly handled. The Wisconsin Department of Natural Resources (DNR) has developed guidance encouraging lamp recycling that protects the environment while reducing the regulatory burden for managing waste lamps. The DNR guidance:
- Allows waste lamp generators to safely store and recycle their lamps without strictly following hazardous waste regulations.
- Does not permit businesses to dispose of waste lamps in sanitary landfills if the waste lamps contain heavy metals that exceed hazardous waste limits.
Waste lamps that aren't recycled are subject to hazardous waste regulations that usually require storage, transport and other licenses or approvals from the state DNR.
What should I do with my waste lamps?
Place waste lamps in the cardboard sleeve or box in which replacement tubes arrived, then store the lamps where they can't be broken, such as in a safe closet or basement. Mark the area and containers where waste lamps are stored as a hazardous waste storage area so people don't accidentally throw trash on the tubes and break them. If tubes are broken, they should be stored in a heavy plastic bag placed inside a rigid container. Broken lamps may go to a recycler if the recycler will take them. Otherwise, broken lamps should be managed as hazardous waste.
Waste lamp generators may contract with a solid or hazardous waste transporter to move lamps to a recycler. Recyclers can be found in the Yellow Pages under Recycling Centers or on the DNR website. Generators also may safely transport their lamps to the recycler. Generators may accumulate waste lamps from several locations in a central facility to ease transport and recycling. As long as waste lamps are going to a recycler in Wisconsin, it's not necessary to fill out a hazardous waste manifest for transportation in Wisconsin, although it's encouraged. If these wastes are being shipped to or through other states, then the transportation rules of those states should be checked. Waste lamp generators also do not need to fill out annual reports for their waste lamps. This policy does not relieve generators of other hazardous wastes from any hazardous waste requirements.
When lamps are replaced, ballasts also are frequently replaced. Ballasts are heavy metal boxes associated with fluorescent fixtures that regulate the flow of electricity. Ballasts manufactured before 1979 may contain PCBs (polychlorinated biphenyls). PCBs in our environment are toxic chemicals that pose a health risk to people and wildlife. If a ballast is marked "No PCBs," assume it doesn't contain PCBs. If the ballast isn't marked, assume it contains PCBs. Please call the DNR for information on management and disposal of PCB ballasts: DNR Recycling at 608-267-7566.
To locate bulb recyclers in your area, check the DNR website. The DNR list is not meant to be complete or an endorsement; it is a list of services known to be available. The DNR website also has more information on lamp/bulb recycling.