Environmental Program Fact Sheet

Management of Mercury-Containing Lamps

Purpose

Mercury is a heavy metal which can be released to the environment from both human activities and natural sources. Man-made sources of mercury include fluorescent lights, thermometers, batteries, medical equipment and electrical switches. Since mercury is extremely toxic to living organisms, is persistent and mobile in the environment, and readily bioaccumulates in the food chain, proper management of mercury-containing wastes is essential to protect public health and the environment.

This fact sheet was developed to help ensure safe and environmentally sound management of mercury-containing lamps by providing generators general information on the regulation and proper management of this waste. Any person who generates waste mercury-containing lamps is subject to applicable hazardous waste management regulations. (Households as defined in 40 CFR 261.4(b)(1) which generate waste mercury-containing lamps are exempt from regulation. However, DEP strongly encourages households to bring their waste lamps to a municipal household hazardous waste colleciton day/facility.) This fact sheet is intended only for generators of waste mercury-containing lamps who send their lamps off-site for treatment, storage, recycling, or disposal. Generators who intend to crush lamps on-site must first apply to the Department of Environmental Protection (DEP) for a hazardous waste treatment permit.

This fact sheet does not replace or supercede applicable hazardous waste management regulations. The reader is advised not to rely solely on the information contained in this document but to read all applicable regulations set forth in sections 22a-449(c)-100 through 110 and 22a-449(c)-11 of the Regulations of Connecticut State Agencies (RCSA), and the Code of Federal Regulations (CFR) Title 40, Parts 260 through 271.

What are mercury-containing lamps?

Mercury-containing lamps are electric lamps in which mercury is purposely introduced by the manufacturer for the operation of the lamp. Examples of common mercury-containing lamps are:

Fluorescent lamps
High intensity discharge (HID) lamps; including,

a. Mercury vapor

b. Metal halide

c. High pressure sodium

Other specialty lamps

How are waste mercury-containing lamps regulated in Connecticut?

In Connecticut, waste mercury-containing lamps are, in most cases, a hazardous waste and subject to the provisions of the Resources Conservation and Recovery Act (RCRA) Subtitle C and Chapter 446 of the Connecticut General Statutes.

How does a generator determine if his mercury-containing lamps are a RCRA hazardous waste?

Section 22a-449(c)-102(a)(1) RCSA, incorporating 40 CFR 262.11, requires generators to determine if their lamps are RCRA hazardous. A hazardous waste determination can be done by having the lamps tested or by using knowledge of the hazard characteristic of the waste (a.k.a. knowledge of process). Please refer to the Department's fact sheet on Hazardous Waste Determinations for further information.

What testing is required and who can do it?

The test required to determine if mercury-containing lamps are hazardous is called the Toxicity Characteristic Leaching Procedure (TCLP). The TCLP is a specific test performed in accordance with EPA publication SW-846 and the protocol found in EPA's report "Management of Used Fluorescent Lamps: Preliminary Risk Assessment", October, 1992 (Rev. May 14, 1993), prepared by SAIC (Science Applications International Corporation). Generators having their lamps tested must supply the laboratory with an intact lamp representative of the type(s) to be discarded, and the laboratory must be capable of conducting the test in accordance with SW-846 and the SAIC testing protocol for DEP to consider the results valid. Generators should check with their laboratory to ensure they are capable of conducting the TCLP test in accordance with SW-846 and the SAIC protocol. A list of laboratories licensed by the Connecticut Department of Health Services to perform the test can be obtained by calling that Department at (860) 509-7389.

How can a generator use knowledge of process to make a hazardous waste determination?

EPA's report "Management of Used Fluorescent Lamps: Preliminary Risk Assessment" concluded that fluorescent lamps are a RCRA hazardous waste when discarded. Based in part on this information, DEP believes that most mercury-containing lamps are a RCRA hazardous waste. Generators may avoid the expense of testing by assuming their lamps are RCRA hazardous and managing them accordingly.

Generators may rely on TCLP results provided by the lamp manufacturer to document a claim that their lamps are not hazardous. Such documentation must be maintained on-site and made available for inspection by DEP staff.

How must non-RCRA hazardous mercury-containing lamps be managed?

In Connecticut, mercury-containing lamps that are non-RCRA hazardous are still considered a state hazardous waste and must be managed as a Connecticut Regulated Waste having the designation of CR05 - chemical waste solid. Contact the DEP's Waste Engineering and Enforcement Division at (860) 424-3023 for more information regarding the regulation of Connecticut Regulated Waste.

How must RCRA hazardous mercury-containing lamps be managed?

DEP requires generators of RCRA hazardous mercury-containing lamps to ensure that their lamps are transported to a facility permitted to accept such waste (e.g., a recycling facility or a treatment, storage or disposal facility (TSDF)). DEP strongly encourages generators to recycle both non-RCRA hazardous and RCRA hazardous mercury-containing lamps. Please refer to the list of Fluorescent Lamp Recycling Facilities permitted to accept waste lamps and lamp brokers for further disposal information.

Can a generator self-transport his own RCRA hazardous mercury-containing lamps?

Generators can self-transport RCRA hazardous waste in accordance with sections 22a-449(c)-11 and 103 RCSA. If a generator offers RCRA hazardous waste to someone else for transport off-site, that transporter must have a valid hazardous waste transporter permit from DEP. Contact the Waste Engineering and Enforcement Division at (860) 424-3570 for more detailed information on transporter requirements or for a list of permitted transporters.

What paperwork is required to ship RCRA hazardous mercury-containing lamps?

Federal and Connecticut hazardous waste regulations require RCRA hazardous mercury-containing lamps to be shipped on a properly completed hazardous waste manifest. (Generators that generate less than 100 kilograms of all hazardous waste in a calendar month are not required to use a hazardous waste manifest and may use a bill of lading.) Generators shipping lamps to another state should contact that state to assure compliance with any more stringent requirements which may be applicable.

How must RCRA hazardous mercury-containing lamps be packaged, accumulated and shipped?

Generators of RCRA hazardous mercury-containing lamps must manage them on-site in accordance with the requirements for packaging, labeling, marking, placarding, and accumulation time as found in section 22a-449(c)-102 RCSA, incorporating 40 CFR 262, and in 49 CFR Subchapter C - Hazardous Materials Regulations (DOT requirements). Lamps should be stored in a manner that will minimize breakage. Detailed guidance documents for conditionally exempt small quantity generators and small quantity generators can be obtained by contacting DEP's Waste Engineering and Enforcement Division at (860) 424-3023.

If a generator hires a contractor to replace, remove, or recycle mercury-containing lamps, who is responsible for compliance with the law?

Ultimately the generator hiring the contractor is responsible for compliance. However, if lamps are improperly managed by a contractor, both parties are potentially subject to enforcement action by DEP.

Are mercury-containing lamps a good environmental choice?

Yes. Mercury-containing lamps are energy efficient, resulting in lower electrical demand which saves money and reduces emissions from facilities generating electricity. However, proper management of mercury-containing lamps should be an integral part of any energy and waste management strategy.

How will mercury-containing lamps be regulated in the future?

DEP is proposing to amend its current regulations to adopt EPA's Universal Waste Rule. If this rule is adopted, DEP will list mercury-containing lamps as a universal waste within Connecticut. As a universal waste, mercury-containing lamps failing TCLP will still be considered a RCRA hazardous waste. However, many of the administrative requirements, such as manifesting and the use of permitted transporters, will not be required, and other requirements will also be reduced.

Where can I obtain additional information on proper management of mercury-containing lamps?

Additional information on the regulation and management of mercury-containing lamps can be obtained by contacting DEP's Waste Engineering and Enforcement Division at (860) 424-3023 or mail to:

Department of Environmental Protection
Bureau of Waste Management
Engineering and Enforcement Division
79 Elm Street
Hartford, CT 06106-5127

Last Updated: February 2001