Fluorescent Lamp Recycling

Fluorescent lamps have historically contained anywhere from 10 to 50 mg of mercury powder. Enough, by definition, that lamps "test" as a hazardous material; and are subject to Hazardous Waste (HW) Regulations. Some of the new "low-mercury" lamps now have as little as 3mg, which might be below HW thresholds. A few milligrams doesn't sound like a lot, but consider that there are an estimated 1.8 billion lamps being used in the United States.

This adds up to a lot of mercury, and studies show that nearly 3/4 of those lamps are not being recycled*. This is not to say that the use of fluorescent lamps is a bad thing - not at all. Today's fluorescent lamps are 4 times more efficient than conventional lighting. In fact, power generation contributes mercury to the environment, especially in states where a large proportion of the energy grid comes from coal. Over the projected lifetime of a fluorescent lamp, the mercury avoided through energy savings will be much greater than the mercury used in the lamp.

Regardless of how much mercury is in the lamps, recycling is the way to go. In Virginia, fluorescent lamps are considered to be Universal Wastes, and are not subject to Hazardous Waste Regulations as long as they are recycled. Disposal of lamps as regular solid wastes, however, could be considered a RCRA violation, resulting in fines and potential liabilities for mercury exposure. For more on Virginia's regulations on fluorescent lamps, see http://www.deq.state.va.us/waste/fllights.html.

Drum-Crushing Pilot

The Virginia DEQ supported a pilot project by the US EPA Region III to study the practical use of Drum-Top Crushers for facilitating the recycling of florescent lamps. Fluorescent lamps are much more energy efficient than incandescent lights; however, they do contain anywhere from 3-50 mg of mercury, which can be leaked to the environment if not handled properly and hopefully recycled. DEQ encourages recycling of fluorescents and generally treats those lamps as "Universal Wastes", as long as they are being stored for the purpose of recycling. Virginia is unique from other states in that they have adopted a provision which allows and supports the use of fluorescent lamp crushers to promote more recycling. Please see www.deq.virginia.gov/waste/fllguide.html.

Recycling of fluorescents is made difficult by the need for storage space and the likelihood of possible breakage. Various manufacturers are touting the effectiveness and logistical advantages of crushing the lamps prior to sending them for recycling and mercury recovery. These drum-top crushing units can "eat" up to 500 or more tubes while filtering off the mercury vapors. The drums are then transported to recyclers and mercury retorters for recovery. However, DEQ and its counterparts at EPA are still concerned about the safety and reliability of the emission controls.

In 2003, US EPA Region III partnered with AERC, a mercury retorting company based in Pennsylvania. AERC, however, operates an office in Ashland, Virginia; which has a large-scale tube-crushing device. AERC provided warehouse space and assistance in testing the various drum-crushing units. The units were tested during two separate times of the year, both here and at another recycling facility in Arizona. Testing involved evaluation of through-put and testing of the filtering and safety devices. The findings of the EPA Region III pilot project are due out in late 2004, and DEQ plans to incorporate these findings into its guidance of fluorescent light bulb handling.

Commercial Office Buildings Project

Even with the increasing availability of facilities and companies that can provide these recycling services, the majority of fluorescent tubes are not recycled. Data shows that the national recycling rate is less than 1/3. In consideration of this data, the Virginia DEQ and its EPA Region III partners are attempting to develop a pilot project to work with the owners of large-scale, corporate office space. In certain regions, the market of high-rise office space is dominated by only a handful of corporate owners. DEQ is now in the process of contacting these major stakeholders and in finding opportunities for public recognition for the first owners that volunteer to set the example. In addition, DEQ is working to develop a Best Management Practices Manual for Office Building Managers, based on the model of guidance produced by the Pennsylvania DEP.

Trammell-Crow Commits to Recycle Lamps

Left to Right : Rod Kincaid of Esquire Environmental, and Andrew Spey, Jay Reynolds, Andrew Ashton, Skip French and Mark Polhemus of Trammel-Crow

Trammell-Crow is the top owner of commercial office space in the Northern Virginia, DC, Maryland metropolitan area, managing 270 properties and over 22 million square feet. Nationwide, Trammell-Crow manages nearly 400 million square feet. In the DC area alone, that means over 2 million lamps in use. Trammell-Crow will be collecting all of its spent bulbs at these facilities through a contract with Esquire Environmental Services, Inc., based in Fairfax, and AERC Recycling Solutions in Ashland. Trammell-Crow will use a combination of drum-top crushers, "recycle-by-mail", and lamp pick-up.

Trammell-Crow solidified this commitment on January 26, 2005 at the regional property managers meeting in DC. As result, each of the contracting property managers received a plaque - the "Esquire Environmental Champions Award for Contributions to a Cleaner Environment".

Vice-President for Facilities Operations Mark Polhemus is a champion of this effort, and he hopes that Trammell-Crow will follow his region's lead across the country. "Trammell-Crow's portfolio of buildings is changing constantly. Therefore, we understand how important it is to make sure that the environmental side of the house is in order - just to minimize risks and liabilities. It makes good business sense, plus it's the right thing to do for the environment." Paced by Trammell-Crow's action, several other property management companies that were previously "on-the-fence" are following suit and plan to contract for fluorescent lamp recycling in the near future.

As a result of this project, the Trammell-Crow facilities have been recruited as members of Businesses for the Bay, the regional Pollution Prevention effort in support of the Chesapeake Bay restoration effort.

In addition, Virginia DEQ and other states have recommended that Trammell-Crow be recognized by the US EPA Region III and the National Partnership for Environmental Priorities www.epa.gov/epaoswer/hazwaste/minimize/join.htm.