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Regulatory Requirements for Management of Fluorescent and High Intensity Discharge Lamps

Fluorecycle, Inc. has worked with the Illinois Environmental Protection Agency (IEPA) while developing our Lakemoor, Illinois facility. Our efforts with the IEPA on the first lamp recycling facility in the State have helped shape the IEPA’s lamp management policies.
The primary regulations governing spent fluorescent and high intensity discharge (HID) lamps are contained in Title 35 Illinois Administrative Code Part 733 (35 IAC 73). These regulations, often called the Universal Waste Regulations, are somewhat vague and subject to interpretation. We have raised a number of questions and discussed many issues with the IEPA. Following are questions and answers that may be of particular interest to you.

Q. Who must comply with the regulations governing fluorescent lamps? Isn’t there an exemption for small quantity generators?

A. The regulations will affect all commercial and governmental lamp users, only households are exempt. The majority of building owners and tenants will be generators and small quantity handlers. Building management firms and construction companies will typically be small or large quantity handlers and transporters. The requirements of the Universal Waste Regulations are summarized in a document titled “Fact Sheet - Regulatory Requirements for Management of Fluorescent and High Intensity Discharge Lamps” prepared by Fluorecycle, Inc.

The exemption you have noted is a Resource Conservation and Recovery Act (RCRA) provision for Conditionally Exempt Small Quantity Generators (CESQG). The IEPA does not consider this exemption to be applicable to fluorescent and high intensity discharge lamps since they are classified as universal wastes. According to the IEPA, fluorescent and HID lamps can not be disposed of in municipal landfills or through incineration in Illinois, regardless of quantity, unless they pass the TCLP test.

Q. Who is the generator? Is it the building owner? the tenant? the management company that removes the lamps?

A. The building owner or tenant (if the tenant maintains the lighting) is the generator. The building owner or tenant remains the generator if he/she hires a contractor to remove lamps as part of maintenance or demolition. The contractor is a universal waste handler in this scenario.

Q. Who has liability for the lamp management and “disposal.”

A. Lamp generators, handlers, transporters, and destination facilities are responsible for specific requirements described in the Universal Waste Regulations. Ultimately, the generator retains liability for ensuring his/her lamps have been managed in accordance with the regulations. It is therefore extremely important that the generator ensures the destination facility being used is properly permitted, can legally issue a certificate of destruction, and recycles the lamps in an environmentally responsible manner in accordance with applicable regulations.

Q. Do spent lamps need to be manifested?

A. No. Part of the reason for designating these mercury-containing lamps as universal wastes is to reduce the regulatory requirements for the lamp users. Being able to ship spent lamps without a manifest is an example of the reduced requirements.

Q. Can I crush lamps to save storage space? Is crushing a good idea?

A. The generator, universal waste handlers or transporters are allowed to crush lamps on the
generator's site only
for volume reduction. Requirements for crushing equipment, personnel training, allowable emissions from the crushing units, and record keeping and reporting are specified in 35 IAC 733. Crushed lamps must still be destroyed and recycled at a destination facility.

Crushing at a generator’s site may or may not make economic sense. The generator or handler must assess whether the cost of the crushing, (apparatus, labor, & processing) and meeting regulatory requirements are justification based on the storage space saved.

We would like to work with you to set up your lamp management program and to become your lamp recycling facility.

Please call us at 815-363-4411 to discuss how we can help you with your lamp management efforts.

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