Facility Managers Have Reasons to Consider Recycling Spent Fluorescent Lamps

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Twenty-first century facility managers and 19th-century hat-makers may have something in common. In the 1800s, hat manufacturers used mercury to make felt hats. The workers, inhaling the fumes, often suffered from mercury poisoning. Remember the Mad Hatter from Alice in Wonderland?

Mercury is now seen as a significant environmental threat. And facility managers have a role in reducing that threat. The reason is simple, says Steve McGuire, environmental marketing manager with Philips Lighting: "All fluorescent and HID lamp products contain mercury."

If the lamps are simply thrown away and end up breaking, the mercury becomes airborne and can harm the environment, says Jennifer Dolin, manager of sustainability and environmental affairs with Osram Sylvania.

Airborne mercury often contaminates waterways, where it ends up in fish that live in them, says Ray Graczyk, president of NLR, a waste-recycling firm. When mercury-contaminated fish is eaten in large enough quantities, it can affect humans' nervous system, particularly those of young and unborn children.

The amount of mercury in a single lamp is small. According to the Interstate Mercury Education and Reduction Clearinghouse (IMERC), about 60 percent of lamps sold in the United States in 2004 contained no more than 10 milligrams of mercury. However, add up the estimated number of lamps sold that year, and the total amount of mercury tops 20,000 pounds, IMERC reports. IMERC is a division of the Northeast Waste Management Officials' Association.

What's more, about 600 million lamps each year head into the garbage from the commercial sector, says Graczyk. Even if each of the lamps contains just five milligrams of mercury, the total comes to about 13,300 pounds.

Would it be better, environmentally speaking, to use incandescent bulbs? The answer is no. The emissions from coal-fired power plants contain significant amounts of mercury. Because fluorescent lamps are more efficient and last longer than incandescent bulbs, the net amount of mercury released into the environment is lower with fluorescent lamps, according to the National Electrical Manufacturers Association (NEMA).

Moreover, the mercury in the lamps can easily be controlled through proper recycling, says Mark Tibbetts, NEMA's director of recycling initiatives. In fact, the recycled mercury often is re-used in new lighting products, says Joseph Howley, manager of environmental marketing with General Electric.

However, the rate of lamp recycling for commercial buildings currently stands at about 25 percent, says Paul Abernathy, executive director of the Association of Lighting and Mercury Recyclers. That means lamp recycling represents a significant opportunity for facility managers.

Legal Ramifications

Facility managers should be aware of federal and state regulations covering used lamps. The U.S. Environmental Protection Agency puts standard fluorescent lamps in a category of hazardous waste known as universal waste. Universal waste regulations impose requirements for disposal, storage, transportation, labeling and other matters related to used lamps. Low-mercury lamps that pass the EPA toxicity test known as the TCLP are exempt from universal waste rules.

All states have either adopted the federal universal waste rule or have implemented even more stringent regulations for used lamps, Tibbetts says.

Some small businesses are exempt from universal waste rules, but rules vary across the country, says Mark Kohorst, senior manager of environment, health and safety with NEMA. Some states prohibit any mercury from entering the waste stream, which means that even small businesses must dispose of lamps in accordance with universal waste rules.

Moreover, a facility's obligations under the rules can depend on other wastes it generates, Abernathy says. Other hazardous waste from a facility, together with the lamps, may be enough to move the facility out of the category of "conditionally exempt small quantity generator," and the facility manager would be responsible for properly recycling the lamps and other waste.

The penalties for ignoring waste disposal rules can quickly add up, Abernathy says. Besides fines, penalties include supplemental environmental projects that the company must complete, such as participating in a neighborhood clean-up or restoring a waterway.

Fluorescent Recycling Centers Now Established and Growing

Finding a recycling firm is fairly straightforward. The lamp recycling industry in the United States is established, growing and has the capacity to recycle all the lamps in use, Dolin says.

Each facility's recycling needs and schedule will vary based largely on the volume of lamps, as well as the other waste that it generates. Some facility managers can store lamps in their buildings for up to one year without involving regulators, says Abernathy. Each year, however, they have to provide evidence that lamps were recycled by obtaining a certificate from a recycler. Any generator of hazardous waste, including lamps, retains liability for the waste forever. "The only way it goes away is if you have evidence that it's gone and the hazard doesn't exist any more," Abernathy says.

Facility managers can find recyclers at www.almr.org, the Web site of the Association of Lighting and Mercury Recyclers, or www.lamprecycle.org, which offers lists of recycling firms.

To start, the recycler will need some basic information, such as the size of the building, the approximate number of lamps to be recycled and the estimated recycling schedule, Abernathy says.

Some recyclers offer "box programs," which are well-suited for smaller companies, Howley says. The recycler sends the facility a box designed to store spent lamps safely, as well as packing materials and instructions. Once a box is full, or at least once a year, the facility manager checks that lamps are properly packed, seals the box and sends it to the recycler.

Some facilities with larger numbers of lamps may want to consider a bulk recycling program, says Barry Jordan, national sales manager for electronics recycling with Veolia ES Technical Solutions. The facility manager accumulates one or two pallets of lamps to be recycled (following applicable guidelines for storage) and then calls for a pick-up by the recycling firm.

At the recycling facility, most of the materials in the lamps, including the glass and metal, are recycled, says Linda Barr, chief of the chemicals management branch in the resource conservation and recovery office of the EPA. The lamps are crushed and the mercury captured and reheated, Tibbetts says. Currently, the mercury is re-used, often in new lighting systems, although the market for this may eventually decline, he says.

One recycling option available in some areas is the use of a device to crush lamps at the facility itself. Rather than transport the lamps to a recycling facility, crushers are designed to crush any lamps that need to be recycled in such a way that none of the mercury leaks. However, the use of crushers is controversial, and some states and municipalities prohibit it, Tibbetts says. Also, by using a crusher, the facility manager must then ensure the mercury is handled properly. "It opens a can of worms that many locations don't want to open," Tibbetts says.

Vetting Recyclers

Facility managers can take several steps to evaluate potential recycling firms. All recycling companies should have an audit book that is verified by the state regulator, indicating where and how the company operates, and how it processes lamps, Jordan says. This book should be available for review by those interested in working with the firm.

Analyzing this information is key, because the hazardous waste regulations are written so that if a recycler goes out of business without fulfilling its obligations, the entity that generated the waste retains responsibility for it. That's why facility managers need a good handle on the recycler's waste disposition process and its financial resources; a few fly-by-night firms have taken their customers' money, but failed to actually recycle their waste. Facility managers also need to check the firm's references, as well as its compliance with state recycling regulations, Jordan says.

It's also important to recognize that some firms are brokers, and don't actually recycle any waste themselves. Instead, their role is to bring together firms that generate waste with those that handle recycling. Most are legitimate businesses. However, if a facility manager uses a broker, it is still important to get information on the company that will be doing the recycling.

To be sure, properly disposing of lighting devices and ensuring that the mercury contained within them is appropriately recycled carries a slight cost. While many recyclers can sell some of the materials they recycle, this doesn't generate enough revenue to cover their expenses, Jordan says.

Several factors come into play in determining final cost. These include the number of lamps to be recycled and the distance to the recycling facility. Generally, the expense is manageable, and typically comes to about 1 percent of the total cost of owning and operating a light, Dolin says. In contrast, the energy needed to operate the lamp accounts for about 86 percent of the overall cost. Another estimate of the cost of recycling is about 8 cents per foot of lighting, plus shipping, says McGuire.

Looking to the Future

While many in the industry have dedicated much money and their top scientists' time to finding alternatives to mercury in fluorescent lights, they haven't been able to eliminate it completely and still provide a lamp that performs effectively.

However, they have made great strides in reducing the amounts of mercury used. As recently as 1990, mercury-containing lamps held an average of 43 milligrams of mercury, NEMA reports. By 2004, more than half the lamps sold contained less than 10 milligrams of mercury, according to NEMA.

Some day, alternative lighting technologies, including LED (light emitting diodes) or OLED (organic light-emitting diode) could help society switch to mercury-free lights, Howley says.

For now, facility managers should follow the regulations that cover the disposal of lamps that contain mercury. Mercury is one pollutant that can be controlled by recycling. Ensuring that it is recycled is "the right thing to do," Tibbetts says.

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