- Due to mercury concerns, recycling fluorescent bulbs is highly recommended by the Tennessee Dept. of Environment and Conservation and is required for most facilities throughout the state
- Crushing fluorescent bulbs is allowed in Tennessee
- Crushed bulbs are considered universal waste in Tennessee
- Prepaid bulb recycling by mail is allowed in Tennessee
Detailed Tennessee Fluorescent Bulb Recycling Regulations
The stringency chart below provides examples of state regulations compared to the EPA regulations.
We strongly recommend that you discuss stringency with your primary state regulatory contact. This information should not be interpreted as definitive legal guidance. This document was produced in June 2004, and we do not guarantee its accuracy after that date, as state policies may change at any time.
("same" means the state policy is the same as the federal policy)
Confused about terminology (CESQG, UW, TCLP, etc.)? Refer to this glossary for help.
|Where can waste from CESQG go?||Can the waste be declared non- hazardous, based on TCLP?||Other stringency or exemptions?|
|Federal EPA||Generators producing less than 100 kg (220 pounds) of hazardous waste (HW) or 1 kg acute HW in each month, including all HW generated. CESQGs are exempt from federal rules, but not exempt from liability (40 CFR 261.5)||Waste may go to any Municipal Solid Waste Landfill (MSWLF)||Wastes that test less than 0.2mg/l soluble mercury are not considered hazardous under federal rules.||Crushing can only be done by generator (40 CFR 262.34); crushed waste that is not UW- must be managed as RCRA HW. Crushing not allowed within federal UWR, but may be within State UW regulations. No one may crush third-party lamps without treatment authorization . No mobile treatment units.|
|Tennessee||Exemption only for <15 lamps per month||Waste must go to RCRA Sub-C facility||same||Crushing allowed by generator with pre approval, for volume reduction only, with monitoring and training.|
State Regulatory Contacts
|Primary Contact||Title||Agency Address||Phone|
|Robert Nakamoto||Environmental Protection Specialist||
Department of Environment and Conservation, Division of Solid Waste Management
5th Floor, L&C Tower 401 Church St.
Nashville, TN 37243
|Secondary Contact||Title||Phone||Area of Responsibility|
|Louis Bordenave||Manager of Planning, Reporting and Waste Reduction||(615) 532-0095|
|TDEC Main Number||(615) 532-0104 or (888) 891-8332|
|Web Links and Informational Resources|
|April 2012 Lamp Crushing Advisory Letter (PDF)||http://www.aircycle.com/local/pdf/TN-lamp-crushing-advisory-letter-2012.pdf|
|UW Management Guidance Paper (PDF)||http://www.aircycle.com/local/pdf/tennessee.pdf|
|Tennessee Department of Environment and Conservation Home Page||http://www.state.tn.us/environment/|
|Universal Waste Rule||http://www.state.tn.us/sos/rules/1200/1200-01/1200-01-11/1200-01-11-.12.pdf|