Lamp recycling doesn’t have to be a headache. While convoluted laws and regulations cloud the issue and make compliance seem impossible – or not worth the effort – it boils down to this: You’re required to recycle and mercury is bad for people and the environment. Here’s how to do the job.
Lighting that contains mercury includes high intensity discharge (HID) lamps, neon/argon lamps, and fluorescent and compact fluorescent lamps (CFLs). While the amount of mercury contained in these lamps is tiny (usually around 5 milligrams), their prevalence poses a potential environmental threat. In 1999 the EPA instituted the Universal Waste Rule (UWR), a law that applies to lighting and other potentially hazardous materials. According to the EPA, millions of mercury-containing lamps are sold in the U.S. each year, and most are discarded improperly.
Due to their greater energy efficiency and the mercury released by power plants, the mercury-containing lamps are responsible for less mercury in the environment than less efficient incandescent lamps without mercury. Still, that fact has not stopped manufacturers from reducing the mercury in their lamps.
“The lighting industry has aggressively reduced the amount of mercury in these lamps over the last few decades – by up to 92%,” says Jennifer Dolin, manager of sustainability and environmental affairs at OSRAM SYLVANIA in Danvers, MA. Nevertheless, lamps need to be recycled to prevent environmental damage.
Although LEDs do not contain mercury or lead, Dolin says they should also be recycled to recover materials like aluminum. Lamp recyclers process LEDs similarly to other lamp types, even though LEDs contain a chip and can be considered electronic waste.
The implementation of the UWR has been complicated, to say the least. Paul Abernathy, executive director at the Napa, CA-based Association of Lighting and Mercury Recyclers (ALMR), says, “One of the lingering problems with the EPA’s rule is that it allowed states to do whatever they wanted to do, to raise the bar or create policies that were different or more stringent than the federal policies.”
Figuring out your lighting recycling requirements can be daunting. The variables include location, the number and types of lamps, company size, and any other hazardous materials your company generates. While navigating the different federal and local policies is a complex task, it is important because, Abernathy says, the owner of the lamps is liable forever – yes, forever – for where they end up.
Unfortunately, the law and stewardship of the environment don’t seem to be compelling arguments for some businesses to recycle. Abernathy says only a third of U.S. companies are recycling. Experts agree that the varying policies and requirements are daunting and probably deter some facility managers and building owners, who are already too busy and operating on a tight budget.
“There’s confusion as to what facility managers should do with spent lamps and ballasts,” says Dolin. “Recycling is the most responsible method of disposal, but each state, and many local municipalities, have different regulations.” Multistate corporations struggle with implementing a uniform recycling policy because state requirements vary greatly.
Many organizations dive in, though, and work through the red tape to create a lamp recycling program. It takes time and focus – mostly in finding and vetting a reputable service provider.
On the bright side, an entire industry of lighting recycling vendors and related businesses has sprung to life. Building owners and managers have never had so much information and expertise at their disposal.
Setting Up a Recycling Program
Follow these best practices for implementing a lamp-recycling program.
1) Do your homework. Assess your facility’s needs and research federal and state recycling requirements for mercury-containing lamps.
2) Budget for recycling costs. Make sure you are allocating funds to cover recycling. You should also budget for related training for employees, including education on what to do in case of lamp breakage (see “Dealing with Broken Bulbs” on page 38). The EPA requires that employees be trained on managing universal waste (UWR standards 40 CFR 273 and 40 CFR 273.36).
3) Find a service provider. “Make some calls and shop around,” says Mark Kohorst, senior manager at Rosslyn, VA-based National Electrical Manufacturers Association (NEMA). “See what they can do for you, and make sure you check out their credibility. You want to work with someone legitimate who is actually processing and recovering the mercury. You don’t want to end up with someone who is not doing what they are advertising.”
Fred Ribelli, national sales manager at Veolia in Port Washington, WI, adds, “Facility managers should not select vendors based solely on price. They need to do their due diligence. Generally, if the pricing for recycling or disposal is fairly cheap, there could be issues.”
4) Choose the type of service that works for you. “The logistics are pretty easy,” says Abernathy. “You know how many light bulbs are in your building, and you know how often you change them out.” Different vendors offer different services, including onsite pick-up or shipping, etc. “The lamp recycling industry can tailor programs to meet any facility manager’s needs,” adds Dolin. “They offer prepaid recycling kits for small volumes of lamps. One price includes round-trip transportation of recycling containers, lamp and/or ballast recycling, and a certificate of recycling. They might coordinate direct pick-up for large volumes of lamps.”
To promote recycling of mercury-containing lamps by commercial and industrial users, EPA developed an outreach program supported by funds awarded to state and nonprofit organizations. The organizations included the following resources on lamp recycling.
- Association of Lighting and Mercury Recyclers (ALMR). At its website ALMR offers information on laws and regulations, program news, and a map that identifies lamp recyclers.
- Northeast Waste Management Officials’ Association (NEWMOA). Information for commercial property managers includes interviews with management companies that promote recycling, surveys of innovative programs in the commercial sector, and information on identifying mercury lamps.
More information from EPA on lamp recycling for businesses is available at www.epa.gov/osw/hazard/wastetypes/universal/lamps.
5) Get proof. Keep records on recycling your lamps and ballasts. To verify that your waste is going to the proper place (and that you’re dealing with an actual recycler and not a broker), a certificate is required from the destination facility – the place where the actual recycling happens. You don’t want to find yourself on the wrong end of an enforcement action. “A certificate of recycling from the destination facility is the proof you need to protect yourself,” says Abernathy.
Start Now, Start Right
Until a uniform national policy for lamp recycling exists, facility managers will have to do their best to execute recycling in their buildings. If the task is too daunting, don’t hesitate to bring in outside help. Recycling consultants can wade through the details, and service providers can be found at NEMA’s www.lamprecycle.org. Your lamp distributor may provide recycling services.
Think ahead to recycling when specifying and purchasing lighting. Dolin recommends considering lamp life: “Longer life lamps lower the number of lamps purchased over the life of the building and reduce the number and costs of lamps recycled.” Ribelli encourages FMs to look at manufacturers knowledgeable about end-of-life waste management.
“Progressive manufacturers are taking into account the future of the circular economy,” says Ribelli. “This is the concept that all items will eventually have an end of life and there is a best way to reuse the components for future, new-product manufacturing. You build the recycling into the manufacturing process.”
Jenna M. Aker is a contributing editor for BUILDINGS magazine.