Image facility focus Courtesy of Tyler Olson/Hemera/Thinkstock Properly Disposing Of Used Lighting Knowing how to handle the disposal of lighting implements is not only prudent, it’s the law. P By: Eric Uram Property and building managers either con-tract for or perform maintenance for indoor and outdoor lighting as one of their required or federal regulations under the Resource Conservation and Recovery Act (RCRA) need to be followed. duties. With recent energy efficiency require-ments moving everyone to use next-gen-eration lighting — compact and linear fluo-rescent lamps (LFL/CFL) indoors, as well as high-intensity discharge lamps (HIDs) in outdoor lighting — all locations should have a plan for tracking the end-of-life manage-ment of spent lamps. Every lamp using fluorescent technology requires the inclusion of some level of mer-cury to function. Most lamps also have some lead in them from solder used in their construction. With either mercury or lead, this content requires proper management for any light-ing to keep these materials out of the envi-ronment. If it is understood that any broken fluo-rescent lamp requires special handling in cleanup and disposal, then all lamps — no matter what claims are made about their toxicity characteristics — should be han-dled in a way ensuring no mercury is re-leased to the environment. Appropriate management requires col-lection and transfer to a licensed recycler to complete proper end-of-life recovery, dis-posal and/or reuse of materials. In other words, all lamps should be handled as universal waste, not household waste. In order to comply with your obligations as a building or property manager, state Disposal Needs The RCRA Universal Waste Rule (UWR) and Subtitle C hazardous waste regulations regulate businesses managing and dispos-ing of fluorescent lamps and other mercury-containing lighting (HIDs, etc.) and devices (i.e. thermostats). Property managers should store used lamps to minimize any breakage. Any releases to the environment from broken lamps must be contained immedi-ately and handled properly. All employees should be trained on proper lamp management — including all emergen-cy procedures in case of breakages or spills. If you’re thinking of disposing of your lamps as non-hazardous materials as some lighting companies promise, every batch of lamps shipped must be tested to comply with RCRA requirements. If not tested, you must assume they are hazardous waste and handle them accord-ingly. Some states require that all mercury-con-taining lamps be recycled or managed as a hazardous waste, regardless of the mercury content, so check local regulations to avoid problems. must manage lamps in a way that prevents releases of any universal waste or compo-nent of a universal waste to the environment, as follows: ■ A small quantity handler of universal waste must contain any lamp in con-tainers or packages that are structur-ally sound, adequate to prevent breakage and compatible with the contents of the lamps. Such containers and packages must remain closed and must lack evi-dence of leakage, spillage or damage that could cause leakage under reason-ably foreseeable conditions. ■ A small quantity handler of universal waste must immediately clean up and place in a container any lamp that is broken and must place in a container any lamp that shows evidence of breakage, leakage or damage that could cause the release of mercury or other hazardous constituents to the environment. Containers must be closed, structurally sound, compatible with the contents of the lamps and must lack evidence of leakage, spillage or dam-age that could cause leakage or releases of mercury or other hazardous constitu-ents to the environment under reasonably foreseeable conditions. Conditionally Exempt Small Quantity Generator A generator or location that produces no more than 100 kg (220 pounds) of hazard-ous waste, or no more than 1 kg (2.2 pounds) of acutely hazardous waste, per calendar month is a Conditionally Exempt Small Small Quantity Handlers According to the U.S. Environmental Pro-tection Agency website regarding lamps, a small quantity handler of universal waste 38 CM/Cleaning & Maintenance Management ® • September 2013
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