There are three main federal laws which apply to lamp recycling:

The Resource Conservation and Recovery Act (RCRA) requires that generators test a representative sample of mercury-containing lamps to determine if they should be treated as hazardous waste. Mercury concentration is tested using the Toxicity Characteristic Leaching procedure (TCLP), which attempts to replicate the leaching of water from a municipal waste landfill. Lamps must be managed as hazardous waste if the mercury concentration exceeds 0.2 mg per liter. In addition, lamps must be managed as hazardous waste if they are not tested and proven non-hazardous.

The Comprehensive Environmental Compliance and Liability Act of 1980, or CERCLA, which is also known as the Superfund law, states that all generators of mercury-containing lamp waste could be held liable for any future Superfund cleanups at a land disposal site. In addition, the law requires immediate notification and cleanup action for any disposal of one pound or more of mercury in a 24 hour period.

3. UWR
The USEPA adopted the UWR in May 1995 (40 CFR Part 273). At that time the EPA allowed individual states to adopt their own UWRs or other local policies addressing lamp disposal. Most states have already adopted some policy to prohibit lamp disposal in municipal landfills and are granting handling exemptions to generators who recycle their lamps. On July 6, 1999 the Federal EPA added fluorescent lamps to the Universal Waste Rule (UWR); this went into effect on January 2000. This rule is designed to reduce the amount of hazardous waste items in the municipal solid waste (MSW) stream, encourage recycling and proper disposal of certain common hazardous wastes, and reduce the regulatory burden on businesses that generate these wastes.


• Universal Waste Rule Fact Sheet (effective 01.06.00)
• Universal Waste Rule (Federal Register 40 CFR 260, 261, 264 - 07.06.99)

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