University of Arkansas at Little Rock
Policy Name: Mercury Containing Fluorescent Lamp and Light Bulb Management
Policy Number: LR 702.3
Effective Date: August 1, 2007
Revised Dates: November 3, 2023
Most Recent Review Date: November 3, 2023
The University of Arkansas at Little Rock (UALR) in accordance with the Environmental Protection Agency (EPA) and the Arkansas Department of Environmental Quality (ADEQ) regulations regarding the Resource Conservation and Recovery Act (RCRA) is committed to the proper management and handling of mercury containing light bulbs and lamps. The utilization of proper disposal and or recycling procedures mitigates the opportunity for hazardous mercury deposits to enter the environment through conventional waste disposal methods. These procedures will be outlined and detail explained to express policy adopted by UALR as a permanent operating procedure.
According to the EPA Test Method 1311, bulbs or lamps which pass the Toxicity Characteristic Leaching Procedure (TCLP) test are considered universal waste under EPA regulation 40 CFR Part 273 and the Arkansas Pollution Control and Ecology Commission (APC&EC) regulation number 23 section 273 and pose no leaching hazard to disposal in a Class 1 sanitary landfill. Bulb and lamp manufacturers conduct these tests and depict that designation on the packaging of the device or on the device itself. Such devices and manufacturers include Philips’ AltoTM and Sylvania’s ECOLOGICTM line. These products can be identified by “green tip” banding on the ends of the bulb or by the package designation AltoTM or ECOLOGICTM. These products have been submitted to TCLP testing and have returned a value that is not greater than 0.2mg/L of mercury per device. The EPA and ADEQ threshold limit value (TLV) is 0.2mg/L of mercury for TCLP testing. Furthermore, bulbs and lamps that have not been TCLP tested and do not exhibit a “green tip” or package designation as environmentally safe products are to be considered hazardous materials and are regulated according to EPA 40 CFR part 264 for storage of hazardous materials. UALR has an ADEQ permitted hazardous materials storage building on campus located on the north side of Fribourgh Hall. At a time to be identified by the Environmental Health and Safety Office (EHS), coordination for recycling or pick-up and disposal of the hazardous materials will be executed. If disposal is selected, the disposal company chosen will be certified, licensed and a permitted facility according to the Department of Transportation (DOT) Title 49 regulations for transportation of hazardous materials and the EPA regulation 40 CFR parts 264/265 Subparts A – E for the transportation, treatment, storage and disposal of hazardous materials. Hazardous material pick-up will be conducted according to the ADEQ guidelines regarding materials and quantities allowed to conditionally exempt small quantity generators (CESQG). UALR has such a designation and is identified as a CESQG by the ADEQ.
UALR retains inventory of light bulbs, lamps, ballasts and associated devices in the Facilities Management warehouse at Central Stores. Primarily Philips AltoTM bulbs are used for general lighting needs on campus. These bulbs are TCLP compliant with EPA and ADEQ requirements regarding disposal of bulbs as non-hazardous waste. Also, these devices comprise the majority of the UALR bulb and lamp inventory. Other necessary bulbs and lamps that do not meet TCLP requirements are also stored at the Facilities Management warehouse. The Philips AltoTM bulbs in UALR inventory include the following:
|130773||Universal SLS 20 Alto Marathon|
|135749||Universal SLS 25 Alto Marathon|
|146910||Universal SLS 14 Alto Marathon|
|208876||MHC 70 /C/UM/3K ALTO|
|268334||PL-T 32W/35/4P ALTO|
|268755||PL-T 42W/35/4P ALTO|
|368746||C150 S55/C ALTO|
|368795||C250 S50/ ALTO|
|368811||C400 S51/ ALTO|
|368837||C1000 S52/ ALTO|
|378638||FB34CW 6/EW ALTO|
|378943||FB32CW 6/EW ALTO|
|38313||PL-C 13W/41 FLR LAMP/4P|
This list is subject to revision as new and different bulbs are introduced to or eliminated from the system. All current procedures regarding new and old bulbs and lamps will be followed according to this management plan. All other bulbs and lamps in use by UALR that do not meet the criteria of being TCLP compliant will be treated as hazardous material waste and disposed of or recycled according to state and federal law.
Procedures for Mercury Containing Fluorescent Lamp and Light Bulb Management Policy
Methods and Procedures
The collection and storage procedures for the mercury containing light bulbs and lamps will be administered by the UALR Facilities Management Department. The procedures are as follows:
- Each department on campus is responsible for notifying Facilities Management at 501-569-3390 whenever they need replacement of a bulb or lamp.
- An electrician or qualified person will replace the bulb or lamp and return it, intact, to Facilities Management warehouse for storage in a designated area.
- When storing the bulb or lamp, the person returning the item will place it carefully in the box in which it was received or a suitable box to prevent breakage or damage.
- A log will be located in the Facilities Management warehouse at the bulb and lamp storage designated area and it will be the responsibility of the person returning the bulb to document completely the returned item.
- Once the box is full, it will be inspected, packing material added, labeled, and taped securely to await hazardous material waste pick-up or recycling transport.
- If any bulbs or lamps are broken, the pieces must be immediately cleaned up and placed in a plastic bag. Any residue must be swept up using a dust pan and brush to ensure the entire residue is removed. The person cleaning the broken pieces should wear gloves and eye protection to prevent injury. The person should then wash their hands thoroughly with soap and water.
- At a time deemed necessary by the Environmental Health and Safety Office (EHSO) in accordance with state and federal regulations, the bulbs and lamps will be scheduled for hazardous material waste pick-up or recycling depending on which option is deemed appropriate by Facilities Management.
- If any department chooses to replace their own bulbs and lamps, the person replacing the bulb will be responsible for temporarily storing the used bulb or lamp in a safe manner to prevent breakage or damage. The items must be stored in a secure location until Facilities Management can be notified to pick them up.
There is one alternative to this plan. Without an approved management program in place, the university will be required to pay a recycling fee at the point of purchase of the bulb or lamp that is in addition to the price of the bulb or lamp. These prices have been found to be extensively more expensive than the option of proper disposal and/or alternative recycling methods.
Upon approval of this plan, the plan will become effective immediately. All staff and faculty will be advised as to procedure and protocol regarding the UALR Fluorescent Lamp and Light Bulb Management Plan. The plan will be available to anyone who wishes to review it. A master copy will be kept on file at UALR Facilities Management.
This plan and the procedures outlined will be monitored continually by the EHSO for accuracy of intent, due diligence of reporting, and logistical and operational protocol compliance. The plan itself will be reviewed annually by the UALR Environmental Health and Safety Committee to ensure compliance with state and federal regulations.
Source: Environmental Health and Safety
Approved By: Environmental Health and Safety Committee, Aug. 1, 2007
Custodian: EHS Committee