Fluorescent Lamps and PCB Ballasts

**Rev 10.19.01**

**Document Summary: This document covers technical information regarding
the toxicity of fluorescent lamps and PCBs Ballasts and the accompanying
environmental compliance responsibilities. It has broad applications \--
from the removal of one light bulb to planning a large scale re-lamping
project or structure demolition. It should be used as a companion
document to State mandates and a list of qualified recycling firms.**

Introduction

In the context of this guidance, \"fluorescent lamp\" applies
generically to mercury-containing lamps, including metal halide,
high-pressure sodium, and mercury vapor lamps. Lamps contain about 40
milligrams of elemental mercury, depending on the brand and manufacture
date. Mercury-containing lamps also may contain lead and small amounts
of antimony, cadmium, and manganese. Some of these compounds are
reported to have moderate to severe toxicity.

Essential for proper operation of fluorescent lamps are integral units
known as ballasts or capacitors. Fluorescent lamp ballasts are either
\"dry\" capacitors or \"wet\" capacitors. Wet capacitors, produced
before 1979, contain a fluid or liquid insulation medium such as
polychlorinated biphenyl (PCB), which is toxic, thus complicating the
management of fluorescent lamps. It is estimated that millions of
ballasts in existence contain PCBs. The production of PCB-containing
ballasts was discontinued after 1979. Dry capacitors do not contain a
fluid insulation medium.

According to the National Electrical Manufacturers Association,
fluorescent light bulbs account for about 0.2 % (or about 34 tons) of
the total mercury releases. Millions of mercury-containing lamps are
purchased each year. Manufacturers are working to reduce the mercury
content of fluorescent light bulbs to the lowest feasible level.
However, light bulbs containing mercury have a high-energy efficiency,
and 100 % mercury free light bulbs are not technically feasible at this
time. The mercury levels affect the light bulb\'s life C generally the
higher the mercury per lamp, the longer the life. Even the new \>energy
saver= lamps designed to replace the conventional lamps contain small
amounts of mercury. In addition to being toxic, PCBs and mercury
accumulate in human and animal tissue and the environment. If released
into the environment, mercury can become transformed into more toxic
forms and concentrate in food chains, where humans become exposed
through the ingestion of mercury-contaminated food. There is also the
potential for PCBs to form highly toxic dioxin compounds under certain
combustion conditions. Therefore, there are some environmental issues to
consider in disposal of lamps and ballasts.

Disposal of Fluorescent Lamps and Ballasts

When discarded, fluorescent lamps become subject to the requirements of
the Resource Conservation and Recovery Act (RCRA). [^1] RCRA regulates
the management of hazardous waste from its generation through disposal.
Fluorescent lamps destined for disposal are considered solid waste and,
as with any solid waste, the generator must determine if the lamps are
hazardous waste. Although fluorescent lamps are not listed hazardous
wastes, they may exhibit the characteristic of toxicity, due primarily
to their mercury content, The Toxicity Characteristic Leaching Procedure
(TCLP) is used to determine if solid wastes exhibit the characteristic
of toxicity. When the TCLP results indicate a level of mercury greater
than 0.2 parts per million (ppm), the fluorescent lamps exhibit the
toxicity characteristic and are, therefore, a hazardous waste. A
generator must use either his or her knowledge of the waste or the
actual TCLP test to determine if the waste is hazardous. TCLP results
often vary for fluorescent lamps, depending on several factors,
including how the sample was collected and the TCLP methodology. EPA has
tested fluorescent light bulbs based on the new TCLP. In this testing,
about 50% of the fluorescent light bulbs, were determined to be a
hazardous waste.

Virtually every component of a fluorescent lamp can be recycled,
including end caps, glass tube, wire, mercury, and phosphor powder. The
recycled glass can be used as feedstock in the manufacture of glass
products, or as cement filler. The metallic portion often is sold as
scrap. Retorting recovers mercury, which, after further purification, is
often reused in thermometers, barometers, and electronic devices.
Fluorescent lamp recycling plants are diverse in their activities.
Recycling capacity ranges from a few hundred to several thousand lamps
daily. In a typical operation, lamps are crushed or pulverized,
producing primarily glass, metal, and mercury-bound phosphor powder.
Firms that do recycle the fluorescent light bulbs may separate out
mercury and the phosphor powder, the glass, metal, and other materials.
About 99% of the mercury is recovered.

To manage the disposal process of fluorescent light bulbs, they must be
stored for recycling, in their cardboard tubes and in boxes protected
from damage. When a fluorescent lamp is broken, the mercury can
evaporate at room temperature. (There are no known health hazards from
exposure to lamps that are intact.) All boxes must be labeled as
Auniversal waste-spent fluorescent lamps.@ A label is provided on the
last page of this guidance that may be printed out and completed with
the applicable name and date. The lamps must be dated and recycled or
disposed of within a year. This process must be documented. An easy
pneumonic for the basic requirements is the LAMP rule:

[LAMP rule]{.underline}

[LAMP rule]{.underline}L = Label and Date

A = Arrange for recycling with in a year

M = Must Document

P = Proper Storage

Spent light bulbs may be hazardous waste and should be handled
appropriately. Some states have mandatory recycling and have banned
mercury-containing lamps from their landfills. In most states, mandatory
recycling allows lamps to be managed and disposed of as Universal Waste.

Because of PCBs' (polychlorinated biphenyls) toxicity, persistence and
potential ecological damage via water pollution, manufacture of PCB was
discontinued in the U.S. in the late 1970s. PCBs are toxic chemicals
according to U.S. EPA. While there is only a small amount, about one
ounce, of PCBs in each light ballast capacitor, there are a large number
of ballasts in the U.S. About half of the one billion ballasts,
estimated as currently installed, were manufactured before 1979 and
usually contain PCBs.

Identifying Ballasts Containing PCBs

Older fluorescent light ballasts have small capacitors that contain high
concentrations of PCBs (polychlorinated biphenyls). Disposal of pre-1979
light ballasts requires some knowledge of ballasts. Nearly all ballasts
manufactured before 1979 contain PCBs. Ballasts manufactured after July
1, 1978 that do not contain PCBs are required to be clearly marked \"No
PCBs\". Look for the \"No PCBs\" label and check the date stamp to see
if the ballast was made after 1979. Unmarked ballasts or ballasts
without a date code should assumed to contain PCBs.

Although very few ballasts leak, those that are leaking can usually be
identified. Try to determine if a ballast is leaking before removing it
from the fixture. Most PCB leaks are visible. If clear or yellow oil is
visible on the surface of a ballast, that ballast is probably leaking.
Chemically resistant gloves must be worn when handling the ballast.
Don\'t throw used ballasts around as leaks could result. Place the
ballast in a heavy plastic bag. Technically, if PCB ballasts are
leaking, they must be disposed of as regulated hazardous waste (TSCA).

The primary purpose of the PCB regulations is to remove PCBs from the
environment permanently. The primary law regulating PCBs is the Toxic
Substance Control Act (TSCA). [^2] TSCA regulates the manufacture, sale,
use, and disposal of certain chemical substances, and requires testing,
tracking, pre- screening, and record keeping of chemical products. TSCA
also regulates the disposal of PCBs. In specific situations, ballasts
are exempt from TSCA requirements. For instance, TSCA does not regulate
the disposal of a non-leaking, Small Capacitors. A fluorescent lamp
ballast is classified as a Small Capacitor if it contains less than
three pounds of dielectric fluid and/or has a total volume of less than
100 cubic inches. A lighting ballast is also considered a Small
Capacitor if it has a volume between 100 and 200 cubic inches and has a
total weight of less than nine pounds.

Small Capacitors are subject to TSCA under two conditions. If the Small
Capacitor is leaking PCBs, it is regulated as a PCB Article, as defined
in the federal PCB regulations. [^3] PCB Articles with concentrations at
500 parts per million (ppm) or greater must be disposed of in an
incinerator, [^4] or a chemical waste landfill. [^5] PCB Articles
disposed of at a chemical waste landfill must be drained of all free
flowing PCBs and the drained PCBs greater than 500 ppm must be disposed
of by incineration.[^6]

In the second condition, Small Capacitors (intact or leaking) owned by
any person who manufactures or at any time manufactured PCB-containing
capacitors or PCB-containing equipment, [^7] must ensure delivery of the
PCB-containing capacitor to a TSCA-permitted incinerator for disposal.
PCB-containing ballasts also may be subject to regulation under the
Comprehensive Environmental Response, Compensation and Liability Act
(CERCLA).[^8] CERCLA has many features including establishing reportable
levels for certain substances and a notification requirement for release
of these substances. PCBs are a hazardous substance under CERCLA.
Releases exceeding one pound during a 24-hour period must be reported to
the National Response Center (NRC). [^9] For information on reporting
requirements, contact your RECO. [^10]

Disposal of Non-hazardous, Non-leaking, PCB-Containing Ballasts

Thirteen states ban PCB ballasts from permitted landfills, and another
17 states have special policies or requirements regarding disposal of
PCB ballasts.

The Superfund Law (CERCLA) prohibits the disposal of more than one pound
of PCBs (12-16 or more ballasts) in a 24-hour period in a permitted
sanitary landfill.

Options under TSCA.[^11]

Solid waste landfill\--Often, landfill operators will require that
PCB-containing ballasts be drained before land filling and the drained
PCB material then must be sent to a PCB incinerator for disposal. This
method, if chosen, could heighten liability should the landfill become
subject to cleanup in the future. This method also may require special
reporting procedures to the appropriate regulatory authority. It is
recommended that non-leaking, intact ballasts not be disposed of in
large quantities at a solid waste landfill because of the potential for
cross-media transfer of pollutants and the possibility of nullifying the
environmental benefits of lamp replacement. The intent of the Small
Capacitor disposal rule was to allow random disposal in landfills by
householders and other infrequent disposers. For larger quantities of
Small PCB Capacitors used by commercial and industrial sectors, the EPA
encourages voluntary collection and disposal of Small PCB Capacitors in
chemical waste landfills, ballast decap recycling processing, or
high-temperature incinerators.

PCB Incinerator\--As previously stated, whole ballast incineration in a
TSCA-permitted incinerator is mandated for leaking PCB-containing
ballasts. In addition, non-leaking PCB ballasts may be disposed of by
incineration. However, the main drawback with incineration of intact
ballasts is that recyclable material is destroyed, sometimes at high
cost.

Recycling\--Encourage recycling, where possible. PCB-containing ballast
recycling is actually a three-step process, which separates the PCB
capacitor from the uncontaminated materials. PCB materials are sent for
destruction in a PCB incinerator, and the uncontaminated metals (copper,
steel, and aluminum) are recycled.

**Summary**

Lamps must be managed as Universal Wastes to be recycled.

It is recommended that lamps not be crushed. The practice of breaking
lamps may save space and facilitate transportation but also can cause
exposure to toxic levels of mercury. Also, mercury recovery levels are
lower in broken or crushed units.

Lamps must be segregated from ballasts. Ballasts containing PCBs (and
other toxic compounds) must be segregated from other ballasts.

Ballasts leaking PCB must be disposed of as regulated hazardous
substances in a TSCA-permitted incinerator, or chemical landfill. If a
landfill is chosen, PCBs must be removed prior to disposal of the
capacitor. Intact PCB containing ballasts also may be disposed of by
incineration or at a chemical landfill. The contractor should be
required to do this. It is essential that personnel cleaning up any
debris have appropriate training and wear protective clothing.

Tubes and ballasts must be stored in a secure area. Lamps and ballasts
should be carefully arranged and stored, protecting against accidental
breakage or damage. Lamp components and the storage area should be
appropriately labeled.

Before shipping, lamps and ballasts must be placed in protective
packaging. The original container or box may be sufficient for lamps. A
reputable transporter or carrier must be contracted to transport lamp
components to the receiving facility. Records of all invoices or
receipts from the transporter and receiving facility must be maintained.

For assistance with any of these procedures or locating a fluorescent
light fixture recycler, contact your RECO.

LJMAfluorescentlamps2001.doc

Rev 10.19.01

Carbonunitcontact 757.441.6298

Universal Waste

Universal Waste

**Spent Fluorescent Lamps**

**Date\_\_\_\_\_\_\_\_\_\_**

**Must be disposed of within one year**

Must be disposed of within one year

**POC\_\_\_\_\_\_\_\_\_\_\_\_\_\_**

.

.

[^1]: 42 U.S.C. 6901 *et seq*.

[^2]: 15 U.S.C. 2601 *et seq.*

[^3]: 40 CFR 761.3

[^4]: 40 CFR 761.70

[^5]: 40 CFR 761.75

[^6]: 40 CFR 761.70

[^7]: 40 CFR 761.60(b)(2)(iv)

[^8]: 42 U.S.C. 9601 *et seq. (also known as the Superfund Law*)

[^9]: 42 U.S.C. 9603 (a)

[^10]: At EASC, that individual is [Lynnette
    Ansell](mailto:Lynnette.J.Ansell@NOAA.gov) (757) 441 6298. A listing
    of RECOS in other regions is available at
    <http://www.ecs.noaa.gov/contacts/index.html>.

[^11]: Note: Where applicable, amore stringent state law governs.