Fluorescent lighting offers tremendous energy savings, but responsibly dealing with failed lamps and ballasts is extremely important.
Photo: Philips The benefits of fluorescent lighting are well known. Fluorescent lights convert electricity into illumination three to five times as efficiently as incandescent lights. Lamp life is far longer. And improvements in fluorescent lighting technology—electronic ballasts and high-quality, tri-chromatic ballasts—make fluorescent lighting a fully acceptable substitute for incandescent lighting in nearly all applications.
While offering tremendous environmental advantages through energy savings, the disposal of used fluorescent lighting equipment raises serious environmental concerns. Fluorescent lamps contain the toxic heavy metal mercury. Magnetic ballasts made prior to the late 1970s contain highly toxic polychlorinated biphenyls (PCBs).
Doing the right thing from an environmental standpoint generally means incorporating fluorescent lighting into our buildings. But it also means properly dealing with disposal of any older fluorescent and HID lighting equipment that is being removed and minimizing any new toxics introduced.
Fluorescent Lamps and Mercury
Fluorescent lamps work by passing an arc of electricity through mercury vapor in the lamp. The charged mercury atoms give off ultraviolet (UV) light, which is absorbed by a phosphor powder coating on the inside of the cylindrical glass lamp. Thus energized, these phosphors emit the white light that we see. To generate the mercury vapor, a small amount of elemental (liquid) mercury is added to each lamp during manufacture. This mercury is instantly vaporized when the lamp is turned on, and it recondenses when the lamp is turned off. You can see this small droplet of mercury if you slowly tip a fluorescent tube back and forth. Most types of HID (high-intensity discharge) lamps—mercury vapor, metal halide, and high-pressure sodium—also contain mercury.
We are concerned about mercury because it is a potent neurotoxin with the potential to build up in the food chain. During the 1950s, thousands of children in Japan were born with neurological disorders as a result of their mothers consuming fish from Minamata Bay that were contaminated with mercury from industrial waste. Inorganic mercury is readily absorbed by certain anaerobic bacteria in aquatic ecosystems and converted into organic forms, such as methyl mercury, that can be absorbed by aquatic plants and animals. As animals higher on the food chain eat plants and animals containing mercury compounds, the mercury levels increase through a process called
bioaccumulation. Mercury is one of the few trace metals that bioaccumulates in food chains. A walleye pike can have a mercury concentration 250,000 times that of the water it lives in.
In a fluorescent lamp, mercury atoms are energized by an electric arc, generating UV light. The phosphor absorbs this UV and emits visible light.
Roughly one-third of the mercury in our air and water comes from natural sources, such as volcanoes and forest fires; the rest comes from anthropogenic (human) sources. Coal-fired power plants and incineration of municipal solid waste are the leading sources of airborne mercury in the U.S. (see sidebar below). Approximately one gram of airborne mercury falls on a 20-acre lake each year from airborne sources. Currently, 38 states have fishery advisories for high mercury levels on one or more bodies of water—meaning that the fish might be unsafe to eat.
Mercury can also get into aquatic systems by leaching from landfills into groundwater, and from there into streams and rivers. In 1989, 643,000 kg of mercury was discarded in municipal solid waste in the U.S., according to a 1992 EPA report, and 84% of this was landfilled. Household batteries were by far the largest contributor of mercury in solid waste in 1989, with other sources, including paints and pigments (4.0%), thermostats and thermometers (3.9%), mercury-containing lamps (3.8%), and dental waste (0.5%). Due to reductions in mercury use in batteries, the share of mercury from fluorescent and HID lamps was projected to jump to 13.3% of the mercury in municipal solid waste by 1995, with fluorescent lamps accounting for 97% of that and HID lamps 3%. The EPA Office of Solid Waste estimates that roughly 600 million fluorescent lamps are discarded each year.
The amount of mercury in fluorescent lamps is quite variable, depending on the type of lamp and when it was made. T-12 lamps (which are 12/8ths of an inch—38 mm—in diameter) contain a lot more mercury than T-8 lamps (8/8ths of an inch—25 mm—in diameter), and the mercury use per lamp has dropped considerably over the past 15 years. Most 48-inch (1.2 m) T-12 fluorescent lamps in use today have 20 to 60 milligrams of mercury in them, though some have as much as 80 mg, and new ones average 22.8 mg. The thinner (and more energy-efficient) T-8 lamps being made today contain an average of 14 mg, and one company, Philips Lighting, has reduced mercury levels far below that (see sidebar). Compact fluorescent lamps (CFLs) are highly variable in their mercury content, with an industry average of 4 mg.
Over time, some of the mercury in a fluorescent lamp migrates into the phosphor powder, the glass, and the aluminum electrodes in the lamp end-caps. To safely remove mercury from discarded fluorescent and HID lamps and prevent release into the environment, careful recycling and reprocessing is required. There are several dozen companies in the U.S. that specialize in mercury recovery from fluorescent and HID lamps.
Philips ALTO™ low-mercury fluorescent lamps have replaced more than 3,000 old bulbs at the John G. Shedd Aquarium in Chicago. Over 61 grams of mercury have thus been removed from Shedd’s ceilings, where it represents a serious hazard to the aquatic environment.
Photo: Edward G. Lines, Jr., John G. Shedd Aquarium In most states, discarding large numbers of fluorescent lamps in municipal solid waste is now prohibited, but the regulations vary widely from state to state and are confusing. Under federal law, fluorescent lamps are considered hazardous waste if they fail the toxic char- acteristic leaching procedure (TCLP) test. Under this test, the waste can contain no more than 0.2 mg of mercury per liter of waste. Although some companies continue to argue that there is uncertainty about whether fluorescent lamps pass or fail the TCLP test, the most definitive study to date—
Management of Used Fluorescent Lamps: Preliminary Risk Assessment – Final Report (Revised May 14, 1993), produced for the EPA—states that “fluorescent lamps definitely exhibit the hazardous toxicity characteristic as defined by the TCLP.” (The report did not address Philips’ new ALTO lamps.)
There is currently a hot debate going on in Washington about how to treat discarded fluorescent lamps under federal regulations. Two of the largest lamp manufacturers—General Electric and Osram Sylvania—are pushing the EPA to grant lamps a special exemption to the regulations governing hazardous waste disposal. Under this designation, they would be considered “conditionally exempt” and could be landfilled at will. Michael Bender, Executive Director of the recently formed Coalition of Lamp Recyclers, worries that this move could put the 30-plus fluorescent lamp recycling companies that have been formed in the past several years out of business.
The other major lamp manufacturer—Philips—has invested a great deal of money redesigning their lamps to reduce the mercury content, and they support stricter regulation of discarded lamps with high mercury levels. “Our competitors are asking for a conditional exemption, and we think that’s a mistake,” Philips’ Steve Goldmaker told
EBN.
The other option EPA is considering for lamp waste management is to
allow lamps to fall under the Universal Waste Rule, a designation—rather than conditional exemption —that would simplify red tape for recycling. Michael Bender promotes the Universal Waste Rule designation for discarded lamps. “We have not seen a decision because nearly all state agencies are strongly opposed to the conditional exemption,” he told
EBN. The fact that EPA has so far failed to rule out the conditional exemption for fluorescent lamps shows how much sway its supporters hold in Washington.
PCB ballasts collected in 55-gal. drums for recycling.
Source: FulCircle, Inc. Even under the Universal Waste Rule most small generators of hazardous waste—less than 100 kg of total hazardous waste per month (300 to 450 4-foot F40 lamps)—could remain exempt from disposal regulations for high-mercury-content fluorescent lamps. Small generators account for an estimated 15% of the fluorescent lamps entering the waste stream. Minnesota and Wisconsin are the only states that currently outlaw disposal of all fluorescent lamps in the municipal solid waste. A list of regulations state-by-state is available in the EPA brochure
Safe recycling of fluorescent lamps involves separation of the three primary components of the lamp: glass, aluminum end-caps, and phosphor powder (which is where most of the mercury resides in a used lamp). Technologies exist to crush and separate these materials very effectively, reclaiming nearly all of the mercury. The recovered mercury is triple-distilled and sold on the commodity market. Other recovered materials can also be marketed. Philips, for example, uses a lot of recycled phosphor in its new lamps, according to Goldmaker.
Mercury Technologies International has been recycling fluorescent lamps since 1992 and recycles 100% of the lamp waste, according to Emily Betterly of the company’s Hayward, California facility. “Nothing goes to the landfill,” she says. After extraction of mercury, recovered glass from the company’s California operation is shipped to a manufacturer of fiberglass insulation. Recovered aluminum is shipped to a smelter. And recovered phosphor powder is processed into a product for the mining industry. After purification, mercury is sold on the open market.
Because the value of recovered products from lamp recycling is relatively low—mercury is worth less than $2.40 per pound ($5.30/kg)—we have to pay to properly dispose of used lamps, and this cost is significant. The cost for fluorescent lamp recycling typically ranges from 24¢ to 60¢ per F40 lamp, with an average of 40¢ per lamp. This is a significant cost, considering that new lamps cost as little as $2 each. HID lamp recycling typically costs $1.25 to $4.50 per lamp, with an average of $2.50. These estimated costs do not include packaging or shipping.
In some ways, more troubling than the mercury in fluorescent and HID lamps are the polychlorinated bi-phenyls (PCBs) in old ballasts. Until 1979, virtually all fluorescent and HID ballasts were made with capacitors that contained PCBs. These ballasts each contain approximately 0.6 to 1.0 ounces (17-28 g) of 90%-pure PCB, in a clear or yellowish, oily liquid form. Some may also contain PCBs in the tarry asphaltic “potting” material that is used as insulation in the ballast. The EPA estimates that there are 200 million to 800 million PCB-containing ballasts currently in use today— containing up to 40 million pounds (15,000 tonnes) of PCB.
The health and environmental risks of PCBs are well known and widely accepted. PCBs cause a wide range of health problems, ranging from liver injury and skin disorders to reproductive problems—PCBs can mimic natural hormones and disrupt the endocrine system. Like mercury, PCBs tend to bioaccumulate in natural ecosystems, so that top predators have PCB levels many thousands of times higher than the background levels. In fact, the PCB level found in a dead beluga whale in the St. Lawrence River—500 parts per million—was ten times the level required to designate a material as hazardous waste in Canada! A dramatic drop in reproductive rates of belugas has been found in the river. Even in the Arctic, far from industrial sources of PCBs, researchers have found extremely high PCB levels in remote Inuit populations where the people hunt and fish for their food—the PCBs came from lower latitudes where they built up through the food chain.
Federal regulations clearly spell out the proper disposal of PCBs—and the potential liability of not doing so. On a federal level, PCBs are regulated by the Toxic Substances Control Act and the Superfund Law (the Comprehensive Environmental Response, Compensation and Liability Act, or CERCLA). The Toxic Substances Control Act is limited, primarily prohibiting disposal of PCB- containing ballasts only if they are leaking PCBs. The Superfund Law specifically defines PCB as a hazardous substance and prohibits the disposal of more than one pound. Under the law, the “release” or “threat of release” of more than a pound of PCBs (16-25 ballasts’ worth) in a landfill triggers a Super-fund action—thus, any landfill where a significant number of ballasts are dumped could become a Superfund site. A memo from the Region VII EPA office in 1991 concluded that the disposal of eight or more PCB-containing ballasts in a landfill is subject to the reporting requirements under the Superfund Law—and that “failure to report places the individual or firm in violation of CERCLA 103.”
The EPA has proposed rule changes that would tighten federal standards for PCB disposal, but at the same time streamline red tape. Under the proposed rule, a fluorescent ballast would be considered hazardous waste if the potting material contained PCBs (currently if capacitors are not leaking PCBs, they can be disposed of in municipal landfills in most states). The rule change would also reduce non-regulated disposal of non-leaking ballasts by a waste generator to one pound of PCB (about 25 ballasts) per
year.
PCB ballasts are further regulated by the Department of Transportation and the Occupa- tional Safety and Health Administration (OSHA). Plus, states have various other regulations regarding disposal of PCB ballasts, with some states banning landfill disposal of PCB ballasts altogether.
Federal law requires that ballasts manufactured after July 1, 1978 that do not contain PCBs must be labeled “No PCBs.” You should assume that any ballast that is not specifically marked as being free of PCBs contains the toxin.
To complicate things, many old PCB ballasts leak. Note that leaking clear or yellowish oil (pure PCB) is a lot more dangerous than leaking tar, even though the latter seems a lot messier. Not all of this asphaltic potting material contains PCBs, and if it does, it is probably only at a concentration of 50 ppm or so (vs. 900,000 ppm for the PCB in the capacitor). Leaky ballasts should be handled differently and extremely carefully, due to risk of contamination from the PCB (see recommendations in sidebar below).
Fortunately, PCBs can be effectively destroyed in high-temperature hazardous waste incinerators. The safest approach is either to transport ballasts to a specialized PCB incinerator, of which there are just a few in the U.S., or to deliver ballasts to a facility that removes the four-ounce (124 g) capacitors for incineration and recycles the other uncontaminated metals—which account for roughly 80% of the weight. Capacitor incineration/ballast recycling typically costs $4-$6 per ballast, and whole-ballast incineration typically costs $6-$10 per ballast.
When ballast manufacturers learned about the health and environmental hazards associated with PCBs, some switched to Di (2-ethylhexyl) phthalate (DEHP), which is also hazardous. Widely used as a plasticizer in PVC, DEHP is listed in the
Seventh Annual Report on Carcinogens as being “reasonably anticipated” to be carcinogenic. In pure form, DEHP is listed as a hazardous waste under RCRA. However, according to EPA, once it has been used in a lighting ballast, it is no longer considered hazardous. DEHP is also regulated under the Superfund Law, with a 100-pound (37 kg) threshold for reporting. In other words, if disposing of 100 pounds of DEHP (about 1600 DEHP ballasts) in a 24-hour period, notification of the National Resource Center (800/424-8802) is required. DEHP was used in certain ballasts starting in 1979, then eliminated from ballasts for 4-foot fluorescent lamps in 1985 and from ballasts for 8-foot lamps and HID fixtures in 1991. DEHP is far less of a concern than PCBs. To avoid future concerns about substances in fluorescent ballasts, specify only electronic—not magnetic—ballasts.
Final Thoughts
Environmentally responsible building is more than simply choosing the right materials and producing energy-efficient buildings. It requires considering the entire lifecycle of a building and what goes into it. In some cases, even with best intentions, we have put products into our buildings that can result in significant health and environmental damage. So it is with fluorescent lighting.
Even though there is a significant cost involved, proper disposal of fluorescent lamps and older ballasts should be an extremely high priority for any contractor concerned about the environment. The costs of proper disposal should be included in the cost of any relamping and demolition work—and clients should be made aware of why those costs are included. Recommendations on equipment selection and disposal are included in the checklist above.
(1997, October 1). Disposal of Fluorescent Lamps and Ballasts. Retrieved from https://www.buildinggreen.com/feature/disposal-fluorescent-lamps-and-ballasts
