A recycling program is one way facility managers can contribute to the reduction of the mercury released into the environment. And a critical mass in the number of U.S. states requiring removal of most mercury containing lamps from the commercial waste stream may soon be reached.
On July 12, 2005, New York State will join the ranks of seven other states that require all commercial facilities to recycle mercury containing lamps, whether or not the lamps are designated as hazardous waste. The other states that require commercial facilities to recycle these lamps are Minnesota, Vermont, Maine, Connecticut, Rhode Island, California, and Florida. In New York, households and very small generators of lamp waste are exempt from the new rule.
Prior to the start of the New York mandate this summer, only lamps which fail the toxicity characteristic leaching procedure (TCLP) are required to be recycled. TCLP is a test used by the U.S. Environmental Protection Agency (EPA) to determine if an item is hazardous waste. The procedure is designed to simulate how much of a toxic chemical (in this case, mercury) would leach from the product if it were put into a landfill.
The movement in New York requires every mercury containing lamp to be recycled, regardless of whether or not it passes TCLP. This steps up the action to reduce the emission of mercury into the environment.
Fluorescent and high intensity discharge lamps need mercury to operate. Their energy efficiency comes from the ability of the mercury to generate ultraviolet energy.
In 2003, lamp manufacturers used some 13 tons of mercury, of which about seven tons ended up in lamps. The other six tons were left in equipment and other channels involved in the various stages of manufacture.
This is not an insignificant amount. But is it enough to raise concern?
When lamps break, a small amount of the mercury is in the vapor state and can add to the atmospheric burden. With some 600 to 650 million mercury containing lamps sold in the U.S. each year, even these small amounts of mercury vapor can add up significantly.
The threat of mercury toxicity has been widely reported. Occurrences related to mercury happen almost every day. Therefore, the need for recycling as a means of keeping mercury from entering the ecosystem becomes urgent.
A recycling program for the facility can significantly reduce the threat of mercury. However, the mitigation of environmental consequences can begin earlier in the life cycle of the bulb.
For many years, the EPA has offered a hierarchy of options for those involved with waste management, and this list is applicable to the mercury situation.
Source Reduction. This is often considered the first line of defense against mercury related pollution events. It is much easier to put less of something into a product initially than it is to clean up more later.
Lamps manufactured with low mercury content enable facility managers to satisfy the source reduction approach. When shopping for lamps, facility managers can ask suppliers about the mercury content level in the product.
Additionally, facility managers can access reference materials on source reduction from INFORM, Inc., an independent, nonprofit organization focused on solutions to environmental and health related problems, and the U.S. Green Building Council (USGBC) LEED-EB Ratings System. (See Web resources at the end of this article.)
Reuse. In the case of mercury containing lamps, this second exercise in the pollution prevention hierarchy is directed toward manufacturers. Those organizations can reuse the mercury generated by the lamp recyclers after triple distillation is performed. Triple distillation is a treatment used to purify the mercury back to a level that can be reintroduced into lamps.
The glass from a used lamp, however, cannot be used to manufacture new lamps. During the recycling process, the old glass acquires tiny bits of metal, which would cause problems in the manufacturing process.
Recycling. Applied to lamps, recycling is an excellent way to prevent mercury from entering the ecosystem. In 1991, there were only five or six lamp recycling facilities operating in the U.S. Currently, there are more than 40 such operations.
The Association of Lighting & Mercury Recyclers (ALMR), formed in 1999, represents approximately 80% of the lamp recyclers in the U.S. For a list of the members, visit the ALMR Web site or www.Lamprecycle.org, a site developed by the lamp section of the National Electrical Manufacturers Association.
Those interested in USGBC LEED-EB certification should note that while a recycling program for fluorescent lamps alone will not earn credits toward certification, such a program does meet part of the “Occupant Recycling” requirements.
Whether the facility manager is mandated by law to recycle, or if the action is voluntary, the question of implementation remains: how do facility managers institute lamp recycling programs? A conversation between the facility manager and the lamp distributor is a good starting point.
In several areas around the country, lamp distributors are offering reverse distribution. This means the delivery truck that brings new lamps also takes back the old ones, for a recycling fee. Since the truck would otherwise return to its site empty, this is a very efficient way to recycle the lamps.
From an environmental standpoint, it also makes sense. Transportation is reduced and extra handling is eliminated. The recycler then travels to the distributor to pick up the lamps instead of going to each customer individually.
Some distributors may not have the room to store extra product while awaiting the arrival of the recycler. As an alternative, distributors often make arrangements with recyclers to service their customers.
Another alternative is the pre-paid box program. For isolated or low volume facilities, this can be an attractive method. The distributor or recycler sells empty boxes on which the freight has been pre-paid back to the recycling facility. When the box is full, the user calls the local express pickup designated by the recycler, and the box is picked up and delivered to the recycler’s facility.
A fourth choice is to deal directly with the recycler. These companies have sales personnel available to talk with facility professionals who want to start a program.
While costs for recycling services vary–freight distance and volume play a large role in the pricing structure–prices generally run from 6¢ to 10¢ per foot (or 24¢ to 40¢ per four foot lamp).
There are regulations in place designed to make recycling hazardous waste items easier. Established in 1995 by the Federal Government, the Universal Waste Rule (UWR) applies to lamps deemed hazardous by virtue of the TCLP. The UWR, a subset to the Resource Conservation and Recovery Act, applies to a variety of waste (including, but not limited to, fluorescent lights, high intensity discharge, neon, mercury vapor, high pressure sodium, and metal halide lamps).
The rule was created to ease the regulatory burden on businesses that generate the specified waste and choose to recycle. Adopted by all of the states, UWR established and outlined requirements for shipping, labeling, length of storage allowed, training requirements, and record keeping (only for destination facility, but common sense says the shipper should keep the bill-of-lading). Individual states may impose their own regulations on the rule as well.
Often, the UWR is also used to handle lamps which are deemed non-hazardous. This is because TCLP does not measure how much mercury is actually contained in a product or how much may be released under non-landfill conditions. Therefore, just because the lamp is not deemed hazardous by TCLP does not mean it is free of mercury.
The Recycling Process
During the recycling process, the lamps are sent through a closed chamber in which a vacuum is generated. The lamps are crushed, and the material is moved through a series of screens. Air flow, vibration, and size of the particles determine where each of the materials ends up in the recycling equipment. At the top are the largest pieces (usually the lamp bases), below are the glass pieces, and at the lowest level is the phosphor, which is the white powder seen on the inside of the lamp tubes.
This part of the process is where a good deal of the mercury is gathered. The phosphor is removed from the chamber in trays, put into a retort, and heated. The mercury vaporizes, cools, and recondenses into a container. At 99.7% pure, it is commercial grade but not lamp grade. This is where the triple distillation process mentioned earlier occurs.
What happens to the glass and metal bases? The glass goes to various end uses such as fiberglass making and roadway material. The aluminum bases are sent to an aluminum smelter for recycling, and the zinc plated iron is sent to scrap metal handlers. There is mercury attached to each of these materials. How much mercury will depend on the individual process. At present, there is only one lamp recycler that heats up the entire lamp, thus recovering as much of the mercury as possible.
Currently, mercury lamp recyclers gather approximately 23.3% of the mercury containing lamps disposed of each year, most from commercial installations. This means the remainder is disposed of in solid waste. That, coupled with the mercury left on the metal and glass parts, means only a small percentage of the mercury in lamps is actually recovered.
This fact contributes to a rationale for coupling source reduction with recycling. By combining both approaches, it should be possible to recover a significant part of the mercury currently ending up in solid waste landfills.
The time to start a mercury lamp recycling program is now. Facility managers who implement a recycling program in conjunction with source reduction in their purchasing are making an effort. It is possible to begin reversing the environmental damage, and it all begins at the facility management office.
Walitsky is president of The Industrial Ecology Co. LLC in Parsippany, NJ. Previously, he worked at Philips Lighting, where he was responsible for environmental compliance for all Philips Lighting facilities in North America. He can be reached by e-mail at firstname.lastname@example.org.
U.S. Green Building Council (www.usgbc.org) See the LEED EB Ratings System/Materials and Resources section.
Association of Lighting & Mercury Recyclers (www.almr.org)