Are fluorescent lamps a hazardous waste?
Most spent fluorescent, compact fluorescent, high-intensity discharge, and sodium vapor lamps will be characterized as toxicity characteristic hazardous wastes because of leachable mercury (D009) or lead (D008, from the solder in the end connectors) content, or as reactive (D003) because of the sodium vapor content. The exceptions to this assumption fall into three cases: • Generator provides documentation from manufacturers MSDS or product disposal information indicating that the disposed lamps do not exhibit a characteristic of hazardous waste and do not pose a short-or long-term risk to health or the environment when disposed in a Subtitle D landfill. Alternatively, generator may present certified laboratory results indicating that the lamps in question do not fail the Toxicity Characteristic Leaching Procedure (TCLP) for a characteristic of a hazardous waste. • Spent lamps which meet the criteria for household hazardous waste (HHW) at Regulation No. 23 261.4(b) are not considered t
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