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Bulb Eater® Manual
How do I know if my waste is hazardous?
All generators of waste, except households, are responsible for determining if their waste is hazardous under
current state and federal regulations. Hazardous wastes can either be included on specific lists or exhibit
hazardous characteristics. This determination can be done by knowledge of the waste or by testing the waste.
What’s hazardous?
Persons who generate wastes are responsible for determining whether their wastes are hazardous. One
common method for determining whether a waste is hazardous is the Toxicity Characteristic Leaching
Procedure (TCLP) test. The TCLP test is a laboratory test that simulates the potential leaching of hazardous
wastes under conditions typically found in municipal solid waste landfills. If the concentration of mercury in
water that is passed through a sample of crushed fluorescent lamp fragments exceeds 0.2 mg/liter, the
crushed lamp fragments are classified as a hazardous waste. (See test method 1311 in “Test Methods for
Evaluating Solid Waste, Physical/ Chemical Methods,” EPA Publication SW846 for more information about the
TCLP procedures.)
In most cases, standard fluorescent lamps and lamp fragments fail the TCLP test and are considered
hazardous wastes. Facilities should treat the spent lamps and lamp fragments as hazardous wastes unless
they test the spent lamps and fragments and determine that the wastes are non-hazardous. Facilities should
manage the spent lamps as hazardous waste according to applicable federal, state, and local requirements.
New low-mercury lamps have been introduced into the market. While these lamps may pass the TCLP test
and be considered non-hazardous, some states - like Minnesota and Vermont - still prohibit persons from
disposing of even these non-hazardous lamps in a solid waste landfill. You may want to talk with a State EPA
representative to find out how you may handle spent lamps in your state.
Please note that regardless of whether the State in which you are located allows you to dispose of lamps in
your dumpster with other non-hazardous trash, the lamps do contain mercury and mercury vapors are released
into our environment when you throw lamps in the trash. Typically, the lamps break in the dumpsters, during
transportation or in the landfill and release mercury into the air or groundwater. These hazardous releases are
a risk to surrounding communities.
Facilities that throw their spent lamps in the trash thinking they are saving money may be mistaken. Throwing
spent lamps in the trash may result in the person being held responsible for the cleanup of a remote and costly
Superfund site. Because of the potential liability under Superfund, Air Cycle Corporation believes facilities that
decide to recycle their spent lamps are making a smart decision that benefits not only the environment but also
the bottom line.
What are universal wastes?
Universal wastes are specific hazardous waste streams that facilities can choose to manage in an alternative
manner in place of the more complex hazardous waste requirements. These wastes are typically generated by
many facilities and are often not properly managed under hazardous waste regulations.
Universal Wastes include:
Lamps
– Including fluorescent, high intensity discharge (HID), sodium vapor, mercury vapor, neon, and
incandescent lamps Batteries
– Including spent dry cell and lead-acid batteries Pesticides – Including certain
suspended, canceled, or unused pesticides Devices containing elemental mercury
– Including thermostats,
switches, thermometers, manometers, barometers, and various medical devices.
