Ballasts are assumed to also contain hazardous chemical substances such as polychlorinated biphenyls (PCBs) or di(2-ethythexyl) phathatlate (DEHP) unless they are marked or tested to show that they do not contain these substances. Ballasts that are properly marked as non-containing will be considered non-hazardous waste and may be recycled or managed as an industrial solid waste. If these non-leaking ballasts are not properly marked, they should be assumed to contain PCBs or DEHP and managed according to federal, state and/or local authorities regarding all applicable disposal regulations. Any leaking ballasts must be managed under state and federal hazardous waste rules.

The following should help in providing a procedure for controlling fluorescents and other lamp sources and ballasts. The process is only as good as the transporter, the recycler, and your ability to get people to follow a reasonable policy and keep careful records to avoid human risk and liability, and minimize environmental damage.

Management of Fluorescent and Other High-Intensity Lamp Sources

Mercury and/or lead escapes into the atmosphere when lamps are broken, causing environmental problems when the mercury vapor or lead descends to the ground and settles into surface waters with rain. A potential health hazard exists to people who become exposed to the mercury vapor or lead when lamps are broken. The following guidelines are important in managing the hazard:

1. Do not crush or break the lamps. Store lamps in a manner that will prevent them from breaking. If possible, package unbroken used lamps in boxes lined with newspaper and tape securely. Do not tape lamps together for storage or shipment for recycling. Some recycling facilities do not accept lamps that are taped together.
   
   
2. Mark each container or storage area Used Lamps for Recycling or Hazardous Waste - Used Lamps. If lamps are accidentally broken, store in a non-metal closed container marked Broken Fluorescent Lamps. Broken lamps may be sent to a recycling facility or managed according to federal/state hazardous waste requirements.
   
   
3. Store lamps in an on-site waste storage area where they will not break. If you cannot store them on-site, you may transport the lamps following the appropriate federal/state transportation requirements.

Managing Used Ballasts Containing PCBs or DEHP

Used, non-leaking ballasts containing PCBs or DEHP may be recycled or disposed under the proper requirements listed in federal/state hazardous waste guidelines. Waste ballasts can be stored and sent for off-site shipment in approved Department of Transportation (DOT) containers that will hold waste at all times. Mark storage and shipping containers appropriately (PCB or DEHP Ballasts for Recycling or Hazardous Waste PCB or DEHP Ballasts).

Inspect the storage area regularly to ensure ballasts/containers are not leaking. Dispose or recycle ballasts according to federal/state hazardous waste guidelines. Notification to the National Response Center

(800-424-8802) may be necessary when disposing certain quantities of PCB or DEHP-containing ballasts in a 24-hour period.

Lamp/Ballast Transportation Requirements

Contact federal/state agencies regarding the transportation of lamps and non-leaking ballasts for disposal or recycling. Most states have a listing of local businesses or programs with county agencies that have material drop-off sites or can arrange for a pick-up of the waste from your facility.

Lamp/Ballast Recordkeeping Requirements

To track transported lamps and ballasts for disposal or recycling, federal agencies require the use of a waste-tracking invoice or manifest. The hazardous waste landfill, incinerator, or recycler that you use will provide you with this form. The manifest will identify the type and quantity of the waste, the generator, the transporter, and its ultimate destination. Also check your state requirements regarding the type of manifests that will be needed and how long your records should be kept. A good recommendation is to keep the following documents for a minimum of three (3) years:

1) The number of lamps removed from service during each calendar year; and

2) Waste-tracking invoices or manifests of ballasts and lamps.

Clean-Up of Broken Fluorescent Lamps

1. Fluorescent lamps rarely break in fixtures, but if there is a broken lamp, remove it cautiously. Be sure the electric outlet is off (at the power breaker) before attempting to remove the lamp or broken pieces. Use work gloves to protect your hands.
   
   
2. If the fluorescent light fixture has a plastic diffuser lens or is an enclosed fixture, open it carefully to avoid having pieces of the broken lamp fall on you. Carefully place all of the pieces of the lamp in a double plastic bag (two plastic garbage bags, one inside the other). Sweep or brush any smaller pieces into a dustpan to put them in the bag.
   
   
3. If a lamp has fallen out of an open fixture and broken on the floor, desk etc., be sure to avoid stepping on any of the pieces. Pick up all larger pieces and place them in the double plastic bag. Sweep up any smaller pieces in the dustpan and place in the bag as well.
   
   
4. Using a solution of trisodium phosphate (TSP) and water, wash all hard surfaces that can appropriately be washed, e.g. the lamp fixture itself, the floor where pieces have fallen, desk or filing cabinet where pieces have fallen, etc.
   
   
5. Wipe these areas with clear rinse water to avoid leaving traces of TSP residue. Allow to air dry.
   
   
6. If the lamp was broken on a carpeted area, be sure to pick up and sweep all broken pieces. Use a paper towel dampened with water to carefully blot up any residue and fine pieces of broken glass. Dispose of the paper towel.
   
   
7. Twist the neck of the double plastic bag shut, fold it over and secure with a tie. Fold it over again and secure it again. Label the bag, indicating the number of broken lamps and the date. Place bag in a non-metal storage container for disposal or recycling.

Clean-up of a Leaking Ballast

1. Wear protective clothing (goggles, gloves, apron made from neoprene, butyl, or nitrile, boots (if needed), and a chemical cartridge respirator with an organic vapor cartridge).
   
   
2. Clean all nonabsorbent surfaces:
   a) Remove spilled oil with a rag, paper towel or by scraping with a putty knife.
   b) Wipe twice with a rag containing mineral spirits, kerosene, turpentine, or rubbing alcohol.
   c) Wipe once with a full-strength solution of a trisodium phosphate-based cleaner such as Soilex™ or Spic' n Span™.
   
   
3. Wrap all oil-contaminated materials (the leaking ballast, rags, gloves, absorbent materials like drapes or carpet) in newspaper. Place in double plastic bags.
   
   
4. Store in DOT-approved containers.
   
   
5. Properly label waste (either as PCB or DEHP-contaminated hazardous waste) and ship via hazardous waste transporter to a hazardous waste facility according to federal/state guidelines. Notify the National Response Center (800-424-8802) if one pound or more of PCB waste material (equivalent to the amount in 12-16 ballasts) or 100 pounds or more of DEHP waste material (equivalent to the amount in 1,600 ballasts) is being disposed of in a 24-hour period.