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SOLID AND HAZARDOUS WASTE
HAZARDOUS WASTE LAMP FACT SHEET



SOLID AND HAZARDOUS WASTE
HAZARDOUS WASTE LAMP FACT SHEET

On June 17, 2002, New Jersey adopted an amendment to the Universal Waste Rule (UWR) including hazardous waste lamps as a universal waste. Lamps (also called universal waste lamps) are defined in the rule as: “the bulb or tube portion of an electric lighting device. A lamp is specifically designed to produce radiant energy, most often in the ultraviolet, visible, and infra-red regions of the electromagnetic spectrum. Examples of common universal waste lamps include, but are not limited to, fluorescent, high intensity discharge, neon, mercury vapor, high pressure sodium, and metal halide lamps.” The adopted amendments to the Universal Waste Rule were effective on December 17, 2002.

Under the UWR, a generator of universal waste lamps is regulated as a small or large quantity handler. A small quantity handler of universal waste accumulates less than 5,000 kilograms (11,000 pounds) of universal waste at any given time. This includes all types of universal waste being generated at the site. A large quantity handler of universal waste accumulates greater than 5,000 kilograms of universal waste at any given time. The management requirements for small quantity handlers are found at N.J.A.C. 7:26A-7.4 and the management requirements for large quantity handlers are found at N.J.A.C. 7:26A-7.5. A generator of universal waste lamps may send their lamps to another universal waste handler or to a lamp processor.

The processing of universal waste is not allowed under the New Jersey Universal Waste Rule without an approval from the Department. The use of any lamp-crushing device would be considered processing. Therefore a generator of hazardous waste lamps would not be able to crush the lamps and still manage the crushed lamps as a Universal Waste.

However, a lamp-crushing device may be used to crush hazardous waste lamps provided the crushing is done in accordance with the requirements for the treatment of a hazardous waste in an accumulation container, as set forth by N.J.A.C. 7:26G-6.1 [i.e., 40 CFR 262.34(a)] and 7:26G-9.1 (i.e., 40 CFR Part 265, Subparts I, AA, BB, and CC). If a certain type of treatment in accumulation containers poses a significant risk to human health or the environment, the Division of Solid and Hazardous Waste may require a hazardous waste permit to be obtained for this process. Additionally, it is important to note that the air filter on the crusher must be working properly in order to meet this requirement. The emission of mercury vapors from the crushing unit could constitute a “significant risk to human health or the environment”.

The requirements for treatment in an accumulation container do not allow for treatment to be performed in a satellite accumulation area per 40 CFR 262.34(c). Therefore, the container in which the crushed lamps are accumulated must be managed in accordance with the requirements applicable to fully regulated generators of hazardous waste found at 40 CFR 262.34(a).

In addition to complying with New Jersey’s Hazardous Waste Regulations, any generator using a crushing device may need to obtain an air permit for the device. For information regarding air permits, contact the Bureau of New Source Review at (609) 292-9258. There may also be federal reporting requirements under the land disposal restrictions in addition to New Jersey’s requirements. For information on land disposal restrictions contact the EPA RCRA/Superfund/EPCRA Hotline at (800) 424-9346.

If a generator of hazardous waste lamps chooses to crush the lamps in accordance with the above requirements for the treatment of a hazardous waste in an accumulation container, the crushed lamps would no longer qualify as a universal waste. The crushed lamps would have to be managed as a hazardous waste in accordance with the New Jersey Hazardous Waste Regulations, as set forth at N.J.A.C. 7:26G.

Some manufacturers of mercury containing lamps (MCL) currently offer to consumer’s lamps that contain lower concentrations of mercury as an alternative to the standard MCL. Though some of these new lamps may be considered more “environmentally friendly” and even pass the TCLP test, they still contain what the Department considers a significant amount of mercury. The impact mercury-containing wastes have on the environment and the costs incurred by the New Jersey Municipal Solid Waste Facilities to manage mercury-containing wastes are considerable, so the Department encourages generators of all MCL to manage it as a recyclable material.

Last Revised 08/30/07

 

 

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Department of Environmental Protection
P. O. Box 402
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Last Updated: September 14, 2007