The following are answers to commonly asked questions regarding the management of waste fluorescent lamps that exceed the regulatory limit for mercury via the Toxicity Characteristic Leaching Procedure (TCLP).

In Delaware, waste fluorescent lamps generated by businesses can be managed in one of three ways:

As a solid waste if it is demonstrated the spent fluorescent lamps do not exceed the TCLP regulatory limit (0.2 mg/L) for mercury.

As a hazardous waste if no analytical data is available to demonstrate the spent fluorescent lamps are not hazardous or if analytical testing reveals the spent fluorescent lamps are hazardous

Or under the Universal Waste Rule (UWR) contained in Delaware’s Regulations Governing Hazardous Waste, Part 273.

The only exception is for household hazardous waste as defined in the regulations (See §261.4(b)), which includes any waste routinely derived from households.

Disclaimer: The information below is intended to serve as a guide to responsible waste management and does not supersede Delaware’s Regulations Governing Hazardous Waste (7 DE Admin. Code 1302). Regulations specific to Universal Waste Lamps can be found in Part 273 of the regulations.

How do I Manage Lamps if They are Non-Hazardous Waste?

Since all fluorescent lamps contain some level of mercury, the best management practice is proper recycling. Non-hazardous waste fluorescent lamps may not be disposed in a Delaware solid waste landfill, with the exception of the municipal solid waste landfills operated by the Delaware Solid Waste Authority (DSWA).

Prior to disposal in a DSWA landfill, permission must be obtained. For further information, contact the DSWA at 302-739-5361.

How do I Manage Lamps if They are Hazardous Waste?

Hazardous waste lamps, or those with no generator or manufacturer analytical data to prove otherwise, must be managed as a hazardous waste and you must comply with the applicable Regulations Governing Hazardous Waste for waste generation, transportation and disposal as required of your generator category classification.

An alternative would be managing the lamps under the Universal Waste Rule.

What is the Benefit of Managing Lamps Under the Universal Waste Rule?

The Universal Waste Rule is designed to simplify the management of mercury-containing devices.

A small quantity universal waste handler may accumulate up to 5,000 kg (11,000 pounds) of universal waste for a period of one year.

Unlike hazardous waste, universal wastes are not required to be transported by a Delaware permitted hazardous waste transporter. Further, use of a hazardous waste manifest is not required.

The requirements for generators of universal waste, along with the requirements for managing such wastes are found in Part 273 of Delaware’s Regulations Governing Hazardous Waste.

Can I Use a Lamp-Crushing Device?

If you desire to manage your waste fluorescent lamps under the Universal Waste Rule, the crushing of fluorescent lamps is prohibited.

Generators wishing to crush lamps are treating a hazardous waste and must, at a minimum, comply with the requirements for treatment and disposal in Delaware’s Regulations Governing Hazardous Waste.

A permit from DNREC’s Division of Air Quality may also be required. Contact the Compliance and Permitting Section for further information.

Can I Recycle Hazardous Waste Fluorescent Lamps?

Fluorescent lamps are still considered hazardous waste (unless there is data showing otherwise), even if they are sent to a recycling facility. Therefore, waste fluorescent lamps must be managed as a universal waste or hazardous waste in full compliance with Delaware’s Regulations Governing Hazardous Waste.

Can Hazardous Waste Fluorescent Lamps be Accumulated in a Satellite Accumulation Area?

Small quantity and large quantity generators of hazardous waste may manage these wastes as hazardous waste in accordance with the Satellite Accumulation Area regulations. (§262.15(a))

Remember, all containers are to be closed unless waste is being added or removed and marked with the words “Hazardous Waste” and a description of the hazard of its contents. The containers must be compatible with the waste within and maintained in good condition. (§262.15(a)(1-5))

The Compliance and Permitting Section (CAPS) allows generators of hazardous waste fluorescent lamps to maintain one satellite area, provided this area is located near, and under the direct control of, the personnel responsible for maintaining and replacing fluorescent lamps at the site.

Once the lamps are accumulated, each box or container holding the lamps must be dated and moved to the site’s hazardous waste accumulation area. Once in the accumulation area, the waste fluorescent lamps may be accumulated up to the number of days afforded a site’s generator category classification, e.g., 90 days for large quantity generators of hazardous waste or 180 days for small quantity generators of hazardous waste.

Waste lamps that are accumulated as hazardous waste must be counted with monthly generated hazardous waste quantities and comply with all applicable requirements for generators of hazardous waste. Waste lamps that are accumulated as hazardous was waste cannot be managed under the provisions of the universal waste rule.

Can a Very Small Generator Dispose of Hazardous Waste Fluorescent Lamps in A Delaware Landfill?

No, Delaware’s Regulations Governing Hazardous Waste prohibit disposal of any hazardous waste from businesses into a solid waste landfill, such as those operated by the Delaware Solid Waste Authority (DSWA). Delaware generators of hazardous waste may not use these landfills as a disposal option.

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