The traditional 4 foot bulb contains approximately 15 grams of mercury. In contrast, the compact fluorescent lamps (CFLs) contain approximately 2 to 3 grams 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.
If a facility chooses to store spent bulbs, strict UWR guidelines require that the mercury within is not released into the environment. The lamps must be stored in a sealed, shockproof container to prevent breakage. In addition, the containers must be clearly labeled as “Universal Waste-Lamps” or “Hazardous Waste” and stored in an appropriate location. The manufacturers of fluorescent tubes are also responsible for the proper labeling of mercury-containing lamps to alert customers to their hazards. In 2003, members of the National Electrical Manufacturers Association capitulated to the challenge of Vermont’s Mercury Reduction Act that required lamp manufacturers to label mercury-containing lamps sold in that state.2 With the labeling of the symbol “Hg” on each lamp, individuals should recognize these products contain mercury.
Racheting Up Recycling Efforts
The Association of Lighting and Mercury Recyclers (ALMR) is a not-for-profit organization dedicated to educating governments, municipalities and private businesses in the practice of recycling mercury devices. Its Lamp Outreach program has exposed the hazards of not recycling and, subsequently, prompted nine states to take legislative action to draft laws banning the landfill disposal of fluorescent bulbs. With the partnering of businesses and government, a collaborative plan to eliminate fluorescent bulbs in landfills is underway. ALMR’s position is that to further encourage recycling, the cost of recycling should be initially absorbed by the manufacturers, which then, in turn, pass the costs to the consumers. The consumer can then return the spent bulbs to their purchase point of origin. An international retailer, IKEA Corporation, has led the initiative of businesses promoting recycling.
“Sweden has been recycling for 20 years and has recently pushed for its stores in the United States to recycle,” Wendy Rogers, public relations representative from the IKEA store in Woodbridge, Va., said during an interview conducted by the authors of this article on Feb. 12.
According to Rogers, “There is a bin for the bulbs in every Ikea (29 in the United States). Once the bin at the Virginia store gets full, VIM (the recycler) comes and picks up the spent bulbs.” IKEA works locally with the Clean County Community Council in Virginia, and each U.S. IKEA location recycles similarly.
Domestically, General Electric has proposed that EPA develop a national recycling plan for mercury-containing compact fluorescent bulbs (CFLs). The company produces both incandescent and fluorescent bulbs. With an eye toward reducing the amount of greenhouse gases generated by the use of incandescent bulbs, GE is encouraging CFL usage.3 The increased usage of CFLs, however, means an increase of mercury into the U.S. waste streams. Wal-Mart, the retailing giant, has stated because of the trend toward greater CFL usage, “the increase in sales of CFLs could increase to 100 million units a year”
While a few businesses and local communities see the benefits of recycling, in order to eliminate mercury releases from improper disposal of fluorescent bulbs, a national recycling program still needs to be established. Rep. Gil Gutknecht (R-MN) introduced such a proposal, H.R.6261, on Sept. 29, 2006, in the U.S. House of Representatives. The proposed legislation would “require EPA and Department of Transportation to review tracking, storage, and packaging standards of mercury waste, and would review the recycling of all mercury devices, including light bulbs.”
Paul Abernathy, ALMR director, stated that state policies that are more stringent than the federal policy are vital. He made this response when asked in an interview conducted by the authors of this article on March 15, if state regulations, such as the New York Mercury-Added Consumer Products Law, encourage recycling.
“Only federal legislation that forces EPA to act will help, and no one knows when or if that will happen, so states are our last hope. The ALMR has targeted 12 states to attempt to get policies like California’s or New York’s to make it clear that dumping is no good and only recycling can assure proper management,” said Abernathy. “Another major factor is enforcement, and we aren't seeing much of that either. A little enforcement with some media attention will help a lot.”
Conclusion
To encourage universal recycling, creating an easy method for people is key. At this time only municipalities and local communities are implementing voluntary collection programs. Recycling at home or work generally involves expending additional time, space, effort and even money. Low disposal fees leave disposal an inexpensive method. Creating accessible recycling facilities is as necessary as educating the public on the importance of proper disposal. Making products with recycled material slows the depletion of non-renewable resources such as metal, oil and natural gas, and reduces the encroachment of new mining and drilling operations.
Generally, it takes less energy to make products with recycled materials than virgin materials. Using less energy as the result of recycling typically also means generating less pollution that impacts the surrounding air, water and soil. Fluorescent bulb recycling brings together the individual factors of science, business and government to benefit the environment and the quality of life for us all.
References
1 Reese Jr., Robert G. “Mercury” U.S. Geological Survey. 24 Jan. 2007. 1998 http://minerals.usgs.gov/minerals/pubs/commodity/mercury/430498.pdf
2 Truini, Joe “Lamp Makers Adding Labels.” Waste News 3 Feb. 2003: 3
3 Reeves, Dawn “GE Pushes for EPA Mercury Plan on Eve of Major Agency Bulb Campaign” Inside EPA. 23 Feb. 2007 http://marywood1.marywood.edu:2092/universe/printdoc
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