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