Ballasts & Lamp Disposal

Ballast Disposal

Disposal of ballasts remains regulated but not nearly as complex as disposing lamps (see below section for details). Older ballasts that were manufactured prior to 1979 include capacitors made with Polychlorinated Biphenyls (PCBs). PCBs are an environmental hazard identified by the Environmental Protection Agency (EPA) and hence are regulated under the Toxic Substances and Control Act (TSCA). Ballasts created after January 1, 1979, were mandated not to include PCBs.

For more information on how to dispose of ballasts, including companies that can help you, please visit lamprecycle.org.

Some electronic ballasts operating today may use lead solders – lead is a metal that falls under some regulation, including the Reduction of Hazardous Substances (RoHS), a European mandate that regulates lead, mercury, cadmium, hexavalent chromium, PBB, and PBDE in electronics used in Europe starting in July of 2006.

Today the most efficient lamps used are fluorescent and high-intensity discharge lamps containing minimal amounts of harmful mercury required for generating lighting.

The dangers associated with mercury have made such lighting solutions a regulated item by the United States Environmental Protection Agency (EPA) for their known health effects. The EPA a federal agency sets its own rules, but each state within the US may enact their own rules that add additional restrictions (i.e. California). These regulations affect labeling, handling as well as disposal.

Lamp Disposal

Disposal of lamps as solid waste (trash) is regulated through the Resource Conservation & Recovery Act (RCRA). In this legislation, lamps are bulbs are examined using the Toxic Characteristic Leaching Procedure (TCLP) to examine contains:

  • Hazardous Waste (40 CFR Parts 261, 262
  • Municipal & Other Non-hazardous Waste (40 CFR 258)

Given the regulation has been in place since 1990 under RCRA, lamp and bulb manufacturers such as GE and made great strides to limit the amount of mercury used within bulbs. For example, GE’s Ecolux lamps pass the TCLP testing procedure with less than 85% of mercury compared to older lamps. You may have seen this line in consumer goods, marketed with the “ECO” in the packaging and product details.

Managing the disposal of remaining lamps that do not pass the TCLP test is mandatory. The following states ban the disposal of any lamps that contain mercury:

  • California
  • Connecticut
  • Maine
  • Massachusetts (effective May 1, 2008)
  • Minnesota
  • New Hampshire
  • New York
  • Rhode Island
  • Vermont

If you disposing of a light or bulb in one of the states listed above, you must recycle the lamps according to the federal Universal Waste Rule (40 CFR Part 273) as well as any state regulations.

Within the Resource Conservation & Recovery Act (RCRA) you can dispose small quantities of non-TCLP-compliant lamp waste as a Conditionally Exempt Small Quantity Generator (CESQG) (40 CFR 261.5). This means that it must not create more than 220 pounds (100 kilograms) of total hazardous waste per month. This amount is not limited to just lamps/bulbs but all materials within the disposal exemption. The following set of lamps will weigh about 110 pounds or 50 kilograms in case you are in the middle of modernizing your lamps:

    • 180 4′ T12 Lamps
    • 270 4′ T8 Lamps
    • 455 4′ T5 Lamps

Moreover, besides the state regulations listed above, the below listed states limit Conditionally Exempt Small Quantity Generator (CESQG) according to these guidelines:

      • Colorado, Delaware, Illinois, North Carolina, Ohio and Pennsylvania do not accept hazardous waste from commerical facilities and organizations.
      • Arkansas, Virginia, and Wisconsin mandate licensed transportation certified to carry such materials.
      • In the states of Florida, Kansas, Maryland, Missouri, New York, and Tennessee there are varying limits of hazardous lamp disposal.
      • Louisiana has the strictest guidelines of all – it prohibits disposal under CESQG.
      • Municipal Waste Incinerators: Florida and Illinois prohibit disposal in municipal waste incinerators. Conversely, most waste in southern Florida is incinerated.

As you can see, each state has its own guidelines so be sure to check and confirm these regulations against what you are trying to dispose of. Regulations also change so please contact your local waste facility to confirm other rules.

Resource Conservation & Recovery Act (RCRA) Subtitle C regulations are quite prescriptive in that they include all hazardous wastes. On July 9, Universal Waste was an additional section added under the act which includes lamps, battery cells, pesticides, and equipment containing mercury.

The objective of Universal Waste guidance is to motivate organizations to recycle such wastes covered through streamlining how such items are gathered, managed, stored and transported.

Further information on this guidance can be found on the EPA website under the Universal Waste section.

References:
1. Environmental Protection Agency – www.epa.gov
2. National Electrical Manufacturers Association, www.nema/lamprecycle.org.