[xoxoxoBruce]

From here.

Fluorescent lights and HID lamps have traditionally had one important drawback: relatively high environmental costs associated with their use, specifically, the disposal costs. Because they contain mercury and trace amounts of lead and other metals regulated under the Resource Conservation and Recovery Act (RCRA), fluorescent light tubes and HID lamps may be considered hazardous waste. Even small quantities of these metals may be potentially harmful to human health and the environment, especially when mass quantities of used tubes are landfilled. Used fluorescent light tube disposal in municipal landfills is, in fact, considered the second largest source of mercury pollution entering the environment. These pollutants can often migrate into groundwater supplies or even become airborne (due to mercury’s relatively high volatility), at which time they pose an even greater environmental threat. To combat that threat, the U.S. EPA has established separate regulations that control the collection and management of certain widely generated hazardous wastes, including fluorescent light tubes and HID lamps, known as universal wastes. Under the universal waste rule, the specified widely generated hazardous wastes remain hazardous wastes, but are not subject to the full hazardous waste management rules. Rather, EPA determined that these identified wastes can be more effectively managed under simpler rules that subject universal waste handlers (including generators) to less stringent standards for collecting, storing, and transporting the wastes. EPA's primary objective in designating hazardous waste lamps as a universal waste is to minimize releases of mercury to the environment, ensure safe handling of the lamps, and to keep the lamps out of landfills. Other major goals of the universal waste regulations are to reduce the regulatory burden on facilities that generate those wastes and to encourage facilities to recycle their universal wastes.

Facilities that wish to crush fluorescent tubes on-site prior to recycling should consult their local regulatory agency first. Crushing may be considered treatment of a hazardous waste, thereby subjecting the facility to numerous additional requirements.

Alto lamps have recently come on the market which are produced with low levels of mercury. These lamps have passed the EPA’s Toxic Characteristic Leaching Procedure (TCLP) and are considered non-hazardous waste.