Environmental protection

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An analysis of the lighting industry shows a significant shift from the use of incandescent bulbs to fluorescent bulbs. Incandescent bulbs use more fossil fuel energy, cost more and are less effective than fluorescent bulbs, which produce more lumens. Usage of fluorescent bulbs, however, is not entirely without risk because they contain mercury, a chemical compound that can have debilitating effects on humans upon prolonged exposure. The risk of leaving mercury deposits in landfills is high; therefore, recycling seems the most conscientious and environmentally safe recourse. Our analysis will show that a national fluorescent bulb recycling law not only helps the environment but promotes new business growth and job opportunities as well.

Because of mercury’s unique properties, the most effective way to dispose of wastes that contain the hazardous substance is by recycling. This requires the separation of the mercury waste from other compounds by a process called “screening.” When recycling fluorescent bulbs, the glass and metal end caps are removed from the waste and the resulting residue is then processed by a series of heating cycles to produce elemental mercury with a purity of 99.99 percent.

The traditional 4 foot bulb contains approximately 15 mg of mercury. In contrast, the compact fluorescent lamps (CFLs) contain approximately 2 to 3 mg of mercury per bulb. The reduction of mercury content was a result of the green movement of the 1990s to reduce the amount of mercury in fluorescent lamps. Continued illegal disposal of mercury wastes continues, resulting in unnecessary exposure to people and the planet. However, a grass roots movement to protect the environment has created momentum to generate a national law prohibiting the disposal of fluorescent bulbs in landfills.

In recent times, manufacturers in the fluorescent lighting industry have made an effort to reduce mercury content in the light bulbs produced. Consequently, fluorescent bulbs manufactured from the late 1990s through the present contain less than 50 percent of the mercury found in fluorescent bulbs manufactured during the mid-1980s.1 Despite the reduced amount of mercury in these lamps, the question arises as to whether fluorescent bulbs are still hazardous. Under current federal and multiple state laws, mercury-containing lamps may be considered to be a hazardous waste. If the mercury content of a waste lamp exceeds the regulatory Toxic Characteristic Leaching Procedure (TCLP) limit of 0.2 milligrams per liter, the lamp(s) fail the toxicity test and must be managed as hazardous waste.

In addition to mercury, they contain other materials -- such as lead and polychlorinated biphenyls (PCBs) -- which could be potentially harmful to human health and the environment. As stated in the Federal Register (Volume 64, Number 128, Page 36467) published on July 6, 1999, “mercury has proven mobile in municipal solid waste landfill environments, migrating in leachate to contaminate ambient groundwater at concentrations exceeding the federal maximum contaminant levels (MCLs) used for drinking water.”

Two Disposal Options for Generators
Recycling is the sensible option to ensure that mercury-containing fluorescent lamps are disposed of properly and toxic materials are not released into the environment. In addition, recycling can create excellent business opportunities.

The U.S. Environmental Protection Agency (EPA) offers generators the option of classifying spent lamps as either hazardous wastes or universal wastes Universal wastes have the content and potential to be recycled, despite having hazardous properties. IN contrast, hazardous wastes cannot be recycled. By promoting pollution prevention (P2) through the reduction of waste generation at the source, the Universal Waste Rule (UWR) (40 Code of Federal Regulations 273) streamlines the requirements for management of waste fluorescent lighting.

On July 6, 1999 in the Federal Register (Volume 64, Number. 128, Page 36466), the U.S. Environmental Protection Agency (EPA) added mercury-containing lamps (e.g. fluorescent bulbs) as a new federal universal waste. The guidelines of the UWR encourage the collection and recycling of certain hazardous wastes, including fluorescent bulbs, batteries, pesticides and mercury-containing equipment (e.g. thermostats). The UWR is advantageous because it facilitates a reduction of administrative requirements for recordkeeping, crisis awareness, and education makes the data collection process easier. This leads to generators having no manifesting requirements, unless the lamps are transported out of state or in states that do not recognize lamps as a universal waste. Finally, there is an increase in on-site storage time available for spent bulbs by adhering to this regulation.

A conditionally exempt small quantity generator, which produces 100 kilograms (kg) a month or less of hazardous wastes(equal to approximately 3,000 four foot fluorescent lamps), is allowed to dispose of mercury-containing materials via recycling or a qualified disposal facility. This allows an entity up to one year to accumulate its waste lamps prior to disposal. Many environmentalists hope that eventually a law will be enacted making it mandatory for all generators to recycle mercury-containing wastes.

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