The EPA in July 1994 indicated that spent fluorescent lamps must be treated as hazardous waste if they failed the TCLP test. Spent lamps must be taken either to recycling facilities or disposed of at a hazardous waste site. Waste characterization utilizing TCLP is the responsibility of end users, and disposal regulations may differ from state to state. For the past 15 years, there has been industry-wide agreement on the importance of mercury reduction and some significant progress has been made. As impressive as the reduction has been, lamps with 22.8 milligrams of mercury still do not pass the TCLP test.
Barriers exist for further improvements toward mercury reduction.
Philips Lighting has pioneered key achievements in further progress of mercury reduction. The first step in reducing the criteria level of mercury is to have greater control over the precise amount injected into the lamp. To implement a more precise mercury dose, Philips invented and patented an off-line mercury capsule injection system to deliver a metered amount of mercury into each lamp. Next, the capsules are mounted in the lamp and are only activated when the lamp proves to be hermetically sealed. This method is an integrated part of the process to standardize the quantities of mercury in each lamp.