feature lamp disposal rules change �flash! hot products �futurespast who turned on the lights? �trade in flux lighting certification �making contact manufacturers mentionedin this issue �vol. 4 no. 2

In this issue12235

Beginning in January 2000, regulationsgoverning the way largenumbers of mercury-containing lamps are

disposed eased. In July 1999,the U.S. Environmental

Protection Agency (EPA)decided to change the

lamps’ classification in thehope that simplified disposalregulations would encouragerecycling.

The EPA has been consideringthe change for several years, and its

decision follows as many as 40 statesthat have developed their own regulationsfor lamp disposal (see “State regulations”below).

In its ruling, the EPA classified lampscontaining mercury and other hazardous

waste as universal waste, which is a subset ofhazardous waste. The ruling streamlines federal

regulations for lamp disposal or recycling, with the goal of reduc-ing the number of lamps containing hazardous waste in munici-pal landfills and incinerators while increasing the number oflamps being recycled. Under the universal waste rule, anyone

who disposes of or handles universalwaste lamps in bulk (a “handler”) canrecycle or send them to a hazardouswaste landfill without filing the ex-tensive paperwork required for haz-ardous waste. The ruling includesfluorescent, high-intensity discharge,neon, mercury vapor, high-pressuresodium, and metal halide lamps.

The universal waste category appliesto several common, widely dispersedhazardous wastes, including pesticides,batteries, thermostats, and now lamps.The EPA developed the category partlyto encourage the growth of recyclingprograms so that even those disposing ofsmall quantities might find more oppor-tunity to recycle hazardous items than todispose of them in municipal landfills.

Since 1994, the EPA has been con-sidering whether toissue a conditionalexclusion for lamps,which would haveexcluded them fromhazardous wasteregulations if theywere disposed of byrecycling or in a linedlandfill, or to apply

the universal waste rule. “Universalwaste has been an option for lamps allalong,” said Marilyn Goode, specialistwith the EPA Office of Solid Waste.

Spent lamps have been considered hazardous waste since 1990,and the universal waste rule was first issued in 1995. “It took awhile to listen to all the options and decide that universal wastewas the best way to go.”

Lamp disposalrules change

by Kathleen Daly

Questions about TCLPBy John D. Bullough

Mercury is the primary reason spent fluorescent lamps areconsidered hazardous waste, although some lamps also containlead. Mercury can cause kidney,nerve, and brain damage in adults,children, and developing fetuses ifthey are exposed to large amounts orare exposed over a long period oftime (see “Mercury in lamps”). In itsdecision, the EPA referred to studiesthat show mercury from municipallandfills has in some cases leachedinto drinking water sources inamounts above the 2 parts perbillion allowed by the EPA. Thosestudies included Superfund andother landfills that may includeindustrial waste and other hazardousmaterial not commonly found inmunicipal waste landfills. In addi-tion, lamps that go to municipalincinerators release up to 90% of themercury they contain into the air,unless the incinerators have emissioncontrols.

While hazardous waste regulationsrequired that lamps disposed of inlarge quantities be recycled or sent tohazardous waste landfills, “we dohave reason to believe that a lot ofthese lamps have wound up in mu-nicipal landfills,” Goode said. “Thepoint of putting them under univer-sal waste is to streamline the require-ments to bring about bettermanagement of these wastes.” Inother words, the EPA hopes thatreducing paperwork and other regulations for lamps will leadto better compliance.

Stateregulations forlamp disposalState waste disposal regulations take

precedence over federal regulations ifthe state’s are more stringent. In thosecases, waste generators must follow stateregulations. For example, two states requirethat all fluorescent lamps be recycled.

Anyone disposing of spent lamps shouldcontact their state hazardous waste authori-ties to determine what regulations apply.Contact information for these state agen-cies is available at the EPA’s Web site(www.epa.gov/regional/federal/envrolst.htm). Envirobiz InternationalEnvironmental InformationNetwork’s Web site alsocontains state listings(www.envirobiz.com/searchmenu.htm, click on govern-ment regulatory agencies).

Earth’s 911, a non-profiteducational public-privatepartnership, provides recy-cling resources by zip codeat its Web site (www.1800cleanup.org.)Earth’s 911 can also be reached by calling1-800-CLEANUP.

Mercury inlamps

Fluorescent lamps require small amounts ofmercury to operate – from less than 10

milligrams in new low-dose lamps to 23 milli-grams in typical fluorescent lamps. As an arc ofelectricity passes through the lamp, the mer-cury vaporizes and emits ultraviolet radiation.The radiation activates the phosphor powdercoating inside the lamp, allowing the radiationto become visible as light. Once the lampswitches off, the mercury condenses to a liquidstate. As lamps age, different componentsabsorb some of the mercury.

Mercury, a naturally occurring element,can cause serious health problems includingdamage to the kidney, brain, and developingfetuses. The Agency for Toxic Substances andDisease Registry, part of the U.S. Departmentof Health and Human Services, recentlyestablished a new, higher minimal risk level(MRL) for methyl mercury, the organic formof the element most frequently consumed bypeople when they eat fish. The new MRL of0.3 micrograms per kilogram of body weightper day is 3 times the 0.1 microgram perkilogram per day MRL established in 1994.The agency defines an MRL as “an estimate of

continued on page 3

www.epa.gov

www.envirobiz.com

www.1800cleanup.org

➤Lamp Disposal Websites

already aware of whether the lamps arehazardous waste through results of previ-ous testing or manufacturer information.If the TCLP from a lamp sample results ina high enough concentration of solublemercury, the lamp is considered hazardouswaste and is subject to specific and oftenexpensive disposal procedures.

Testing is an expensive process and sonot all lamps are tested. TCLP costs about$140 per lamp, which means testing allspent lamps for mercury is not economi-cally feasible. Yet one lamp passing TCLPis no assurance that other lamps in thesame class and brand will pass. The Na-tional Electrical Manufacturers Association(NEMA) worked with the EPA in 1991and 1992 to develop a series of laboratorytests to study problematic testing proce-dures, methodologies, and sampling.

The lighting industry has criticized thetest used to determine whether spent

fluorescent and high-intensity discharge(HID) lamps are hazardous waste becauseof its variability.

The U.S. Environmental ProtectionAgency (EPA) in 1990 established thetoxicity characteristic leaching procedure(TCLP) to measure the presence of toxicmaterials such as benzene, chloroform,lead, or mercury within waste products,including lamps, destined for landfills. Yetthe EPA also presents information aboutpotential variability of test results in itsLighting Upgrade Manual.

TCLP tests for mercury in a solubleform. Because fluorescent and HID lampscontain some soluble mercury at the endof life, they are potentially toxic waste andmust be tested unless the generator is

continued on page 3

continued on page 4

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2

flash!

futurespast: Who turned on the lights?by Marilyn R.P. Morgan

�

Covering advances in

lighting technologies,

techniques, and trade

Editor: Kathleen Daly February 2000Sponsor: U.S. Environmental Vol. 4, No. 2 Protection AgencyProduction Manager: Susan MaharResearch: Julie Harell

Sandra Vasconez

Lighting Futures (ISSN 1081-8227) ispublished by the Lighting Research Cen-ter, Rensselaer Polytechnic Institute. Formore information about Lighting Futuresand other Lighting Research Center publi-cations, contact Publications,Lighting Research Center, RensselaerPolytechnic Institute, Troy, New York12180-3590, phone: 518-276-8717,fax: 518-276-4835, email: lrc@rpi.edu,web: www.lrc.rpi.eduContents © 2000 Rensselaer PolytechnicInstitute. All rights reserved. Neither theentire publication nor any of the informa-tion contained herein may be duplicatedor excerpted in any way in any other publi-cations, databases, or other media withoutexpress written permission of the pub-lisher. Making copies of all or part of thispublication for any purpose other than forundistributed personal use is a violation ofUnited States copyright law. Mention ofspecific products, technologies, applica-tions, and organizations does not implytheir endorsement by the Lighting Re-search Center or the U.S. EnvironmentalProtection Agency. The Lighting ResearchCenter does not test or validate any claimsmade in Lighting Futures. All productnames mentioned herein are the trade-marks of their respective manufacturers.

Send editorial correspondence toKathleen Daly, Lighting Research Center,Rensselaer Polytechnic Institute, Troy,New York 12180-3352 fax: 518.687.7120,email: dalyk@rpi.edu

GE exhibited fluorescent lamps at the 1939 New York World’s Fair.

The fluorescent lamps that light our stores,schools, and offices were, only 64 years

ago, exotic creations from the lab makingtheir debut at an Illuminating EngineeringSociety of North America (IESNA) conven-tion. The beginning of these ubiquitous lampswas less auspicious, dating to ancient timesand fueled by people’s fascination with naturalphosphorescence.

In 980 A.D., the emperor of China heardof a picture on which an ox mysteriouslyappeared each evening. When he examinedthe picture, he discovered that the artist hadpainted the ox with a luminous paint contain-ing oyster shell. Six hundred years later ashoemaker in Bologna, Italy, discovered that arock called heavy spar was luminous afterexposure to strong light. After another centurythe story continues, again with oyster shells,when an Englishman heated the ground shellswith sulfur to make luminescent calciumsulfide. The German poet Goethe also experi-mented with naturally luminous substances.

In the 19th century, researchers discoveredthat they could vary both the intensity andduration of a material’s phosphorescence byadding small amounts of copper and bismuth.In 1859, Becquerel described his experimentswith tubes of luminescent materials and rari-fied air. Edison, inventor of the first practicalincandescent lamp, also invented a fluorescentlamp in 1896 that used X-rays to excite fluo-rescent radiation in calcium tungstate on theinside walls of a vacuum chamber (a glassbulb). Unlike his incandescent lamps, thislamp was not practical. He discontinued workon the project after his assistant suffered severeburns from the X-rays

The search went on for the right combina-tion of ultraviolet source and fluorescent

material, with mercury becoming first choiceas the source. French and German experi-ments in the early 1930s showed promise, andin 1934 work began in the U.S. as well. At-tendees at the IESNA convention in Cincin-nati in September 1935 saw the first publicexhibition in the U.S. of a practical low-voltage fluorescent lamp.

The new lamps provided decorative light-ing for the 100th anniversary celebration of theU.S. Patent Office in 1936 and at the twoworld’s fairs in 1938 and 1939. In April 1938,fluorescent lamps were offered commerciallyin three sizes and seven colors. They producedcolored light at 200 times the efficiency of theolder filament lamps with filters, according toadvertising of the day, and for a time itseemed that providing colored lighting for

special purposes would be thefluorescents’ main use.

By 1947, a 40-watt white lamp gaveabout six times the lighting value of asimilar 1938 fluorescent lamp. Improve-ments including two-lamp ballasts,instant starting, and the availability ofcircline lamps brought increasing publicacceptance of fluorescents. Recent im-provements in technology to reducehum and flicker, the availability of easy-to-install screwbase compact fluorescentlamps, and new luminaire designs thatlook less industrial and more home-likehave accelerated this trend asfluorescents continue to make their wayinto U.S. homes.

Lutron Electronicsimproves remote-controlleddimmingLutron, manufacturer of the Spacer dimmer,has introduced the Spacer System handheldremote-controlled dimmer for areas such asexecutive offices, cafes, boutiques, small con-ference rooms, and home theaters. The systemcan change light levels or use different combi-nations of lights from a handheld remote orfrom the wall-mounted master control. Userscan preset up to four lighting scenes and recallthem later. The system uses standard wiringand is appropriate for incandescent and halo-gen lighting.

Lutron

Philips updates itsMasterColor metal halides

Philips Lighting has replaced the traditionalquartz arc tube technology in its MasterColormetal halide lamps with ceramic arc tubes.Philips has also removed lead from the glassand replaced lead in the solder with silver,resulting in lamps that pass the U.S. Environ-mental Protection Agency’s toxic characteristicleaching procedure (TCLP) for hazardouswaste. The line consists of screw-based ED-17s (replacements for standard and 3K metalhalide lamps), reflector PARs, and single- anddouble-ended linear lamps for accent andfloodlighting applications.

Philips Lighting Company

Vandal-resistant,ADA-compliant luminairesavailable from Morlite

Morlite Systems now has a line of fixtures—the LPL Sconce Series—that are suitable forpublic environments such as schools, parkinggarages, commercial workrooms, and sportsfacilities. The Sconce Series fixtures are wallluminaires that can be combined with anavailable battery pack to provide vandal-resistant emergency lighting. Illumination isprovided by a choice of two 26-watt quad-tube compact fluorescent lamps or two 40-watt single-ended biax fluorescent lamps. AUV-stabilized, interlocking shock-resistantpolycarbonate lens with linear prisms is avail-able in optically clear or translucent opal withadditional lens and housing protection. Theluminaires are UL and CUL listed and ADAcompliant.

Morlite

Uni-Form metal halideoffers high lumens in smallpackageVenture Lighting’s new ED17 200-wattUni-Form metal halide lamp is designed fornew and retrofit applications where energy-efficient, high-lumen lamps are required. This200-watt medium-base lamp can fit in asmaller fixture than a standard 250-watt lamp.

Venture says the lamp produces 21,000 lu-mens, has a performance life of 12,000 hours,a color temperature of 4000K, and a CRI of65. The ED17 is also available with a mogulbase of 15,000 hours. Venture has designedmetal halide ballasts for the ED17, includinglow-current crest factor ignitor constant-wattage autotransformer ballasts in Quad-Tap, Tri-Tap, and 480-volt versions and a277-volt controlled-current reactor ballastwith ignitor starting.

Venture Lighting International

Sportlite announcesenergy-saving alternativeto HID

An alternative to HID fixtures, Sportlite’sLX800 Series high-bay fixtures with 42-wattcompact fluorescent lamps have multiplelamps to reduce glare. The LX800 Series hasAMP snap-lock electrical connectors andspring-clip secured ballasts for ease of installa-tion and maintenance. Four-level steppeddimming is available. The LX800 Seriescomes in four styles

Sportlite �

For four years, Lighting Futures hasbrought you and thousands of other

readers timely information about the futureof technologies and systems for lighting ourhomes, offices, and roadways. Throughfeature articles, columns, and departments,Futures has provided a glimpse of what wecan expect from the lighting we use – interms of energy, environmental impact,human factors, even beauty and aesthetics.Working with the sponsor of Lighting Fu-tures, the U.S. Environmental ProtectionAgency, Lighting Futures is evolving in thenear future. After the next issue, Futures willcontinue to provide timely and insightfulnews and information about new and forth-coming developments in lighting, but willdo so through a medium that itself is evolv-ing – the World Wide Web. Yes, this maychange the way you read Futures, and whileit would be easy to say that this is being doneonly to save paper (although this is a nicebenefit!), this transition also offers opportu-nities for Futures to provide new kinds ofinformation about lighting technologies andapplications. What kinds of information,you ask? Stay tuned – next issue, the lastFutures as you know it, will give you moredetails about what to expect. We hope thatyou will join us for the ride. �

John D. Bullough,Future Lighting Futures Editor

The Future ofFutures

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Questions about TCLPcontinued from page 1

NEMA has published five new standardsfor TCLP sample preparation after years ofresearch and testing. The NEMA Web site,www.nema.org, contains informationabout the standards.

Why solublemercury?

The EPA developed TCLP as a way todetermine if a waste is hazardous, and ittests for a variety of hazardous materialsbesides mercury, said Greg Helms, environ-mental protection specialist with the Officeof Solid Waste. EPA staff determined thatthe way to do this was to simulate the high-est risk – and likeliest disposal – for thosematerials, he said. They chose a municipalsolid waste landfill.

“We thought a municipal solid waste(MSW) landfill was plausible and probablythe highest risk scenario,” Helms said.“That was because MSW landfills cangenerate acidic conditions which can mobi-lize metals like mercury, lead, and cad-mium. We postulated that as plausibleworst case management.”

The EPA’s main concern at the time wasgroundwater contamination, he said. “Ifyou put waste X in a landfill, how muchbad constituent would leach out and reachdrinking water wells and how much (water)would be unusable? Drinking water stan-dards were used as a reference value,”Helms said. “We tried as best we could tosimulate (the) aggressiveness and conditionsof an MSW landfill.”

How TCLP worksThe EPA Publication SW846, Test Methodsfor Evaluating Solid Waste, Physical/Chemi-cal Methods, Method 1311, “Toxicity Char-acteristic Leaching Procedure,” gives theprecise details of TCLP. For solid materialssuch as lamps, a sample of the materialweighing at least 100 grams is broken intopieces small enough to meet one of thefollowing criteria:

• the narrowest dimension of every piecemust be smaller than 1 centimeter

• the surface area of the material must beat least 3.1 square centimeters per gramof material

One way to assure meeting the first crite-rion is by passing the material through a

9.5-millimeter standard sieve. Once thematerial is prepared, it is placed in a vesselwhere an extraction fluid consisting of anacetic acid solution is added. After thematerial is mixed in this solution continu-ously for 18 hours, the liquid is extracted.The test for mercury requires that the con-centration of soluble mercury in this liquidbe less than 0.2 milligrams per liter for thematerial to be regarded as non-hazardous.Lamps may also contain mercury that is notsoluble and so does not show up on the test.

TCLP questionsPeter Bleasby, director of industry relationsand standards for OSRAM SYLVANIA,points out that “TCLP only determineshow much mercury is soluble. TCLPdoesn’t quantify the amount of mercury inproducts.”

Joe Howley, GE Lighting environmentalmarketing manager, agreed that TCLPresults depend on several variables, such aswhich lamp parts are tested or a lab’s testingprocedures. He advocates standardizing theTCLP for lamps.

TCLP tests for a variety of toxins, andtherefore is somewhat less precise than itmight otherwise be. “I think TCLP ingeneral does a decent job as a screen,”Helms said. “It was never intended to be aquantitative predictor of leaching under allcircumstances. If people want a more pre-cise test, then they have to be willing to dealwith a regulatory system or a test systemthat is going to be more complex.”

Mercury poses particular problems inthat it is very volatile and is liquid at roomtemperature, Helms said. However, henoted that soluble mercury is more likely tomigrate than metallic mercury. “I guess thebottom line on TCLP is if we are doing thetest for general use, it’s not going to beperfect,” he said. “It’s a screening test. It’snot going to be extremely precise. In gen-eral I think TCLP has worked pretty well inidentifying substances that are hazards.”

The EPA Green Lights Program’s 1995Lighting Upgrade Manual (EPA 430-B-95-003) identifies several factors that can con-tribute to inconsistent test results, including:

• Lamp age. Mercury concentrationsin fluorescent lamps remain relativelystable throughout the life of a lamp.However, the relative amount of soluble

Mercury inlampscontinued from page 1the daily human exposure to a hazardoussubstance that is likely to be without ap-preciable risk of adverse non-cancer healtheffects over a specified duration of expo-sure.”

The U.S. Food and Drug Administrationlimits the amount of methyl mercury in fishto 1 part per million, and recommends thatconsumers limit their consumption of largepredatory fish with levels at or near 1 partper million to 7 ounces per week. For drink-ing water, the U.S. Environmental Protec-tion Agency (EPA) has established amercury limit of 2 parts per billion.

Mercury from lamps can get into theenvironment through breakage, which canrelease both mercury and mercury-con-taminated phosphors. Incineration releasesboth soluble and non-soluble mercury intothe atmosphere and accounts for 90% ofthe mercury released into the atmospherefrom fluorescent and HID lamps. In its1997 Mercury Study Report to Congress, theEPA estimates that mercury emissionsfrom landfills in 1994-95 from all sourceswas less than 0.1 tons; the mercury emis-sions from fluorescent lamp recycling wasalso less than 0.1 tons for the same year.

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Mercury:a careful balancing act...

mercury tends to increase as the end oflife approaches. Because of this, the samelamp that could pass the TCLP testwhen new might fail the test whenspent. If samples submitted for theTCLP are new lamps, they might notaccurately predict soluble mercuryconcentrations of spent lamps destinedfor landfills.

• Laboratory procedures. TheTCLP, as outlined by the EPA, leavesroom for significant variations inlaboratory procedures. The size of thepieces tested, for example, can varyconsiderably. As pointed out by ScienceApplications International Corporationand reported by Paul Walitsky, managerof environmental affairs for PhilipsLighting, in ECON Magazine, January1996 (“Shedding Light on FluorescentWaste”), following the TCLP mightresult in a loss of mercury before themercury concentration is measured.Sample consistency is also important.Two samples from the same lamp maygive different results with the TCLP. A4-foot T8 fluorescent lamp weighs about200 grams; a T12 fluorescent lamp ofthe same length weighs about 300grams. NEMA recommends that theentire lamp be tested, not merely a 100-gram sample of lamp material.

One important qualification about theTCLP is that it is designed to estimatepotential leaching of toxic substances fromlandfills into adjacent ecosystems. However,many fluorescent lamps are disposed of viaincineration. Incineration releases 90% oflamp mercury, whether soluble or insoluble,directly into the air unless incinerators havethe proper filtering equipment. New regula-tions for emission control will take effectthis year.

When the EPA developed TCLP in theearly 1990s, air pathways were not consid-ered, Helms said, but that is changing. TheEPA recently released a new study of riskfrom waste by releases to the air, and isreviewing its mercury waste treatment stan-dards for an update, he said.

TCLP, however, has not predicted therelease of mercury from lamps into theenvironment as a whole. It can be usefulonly as a predictor of the potential for alamp to leach mercury into the ground. �

continued on page 5

Lightingcertification

By Devki RajGuru

What is a lighting professional? TheNational Council on Qualifications

for the Lighting Professions – or NCQLP –is trying to answer that question. TheNCQLP is not alone. Other organizations,such as the Illuminating Engineering Soci-ety of North America (IESNA) and theInternational Association of Lighting De-signers (IALD), have also been working foryears to raise the bar for lighting practice.NCQLP developed as an independent orga-nization to establish and then maintain a setof requirements that would become a neces-sity to practice as a professional in therealm of lighting.

As stated in promotional literature, “TheNCQLP is a non-profit independent certify-ing body founded in 1991 by practitionersin the lighting industry.” Composed ofvolunteers from within the industry, theNCQLP’s goal is to ensure effective andefficient lighting practice. So far, 798 peoplehave earned lighting certification.

Three years ago, the NCQLP unveiledthe Lighting Certification (LC) program. Athree-step program, it involves work expe-rience, a comprehensive exam, and a sys-tem of continuing education. Candidatesfor the LC program are not required tohave an educational degree in the field oflighting, nor is the LC credential at presentrequired by any agency to practice in thefield of lighting. Currently, the portion ofthis program attracting the most attentionis the exam.

Applied Measurement Professionals(AMP), an independent organization, ad-ministers and scores the exam, which itconducts annually at various sites around theU.S. and Canada. “The exam has been verycarefully and precisely created to test aperson’s knowledge on three cognitive levels:recall, application, and analysis and evalua-tion,” said Christopher Cuttle, LC, a formermember of the NCQLP Test Committee.

The four-hour exam is divided into twosections: 100 multiple-choice questions andfour simulation problems. Multiple- choicequestions test knowledge, while the simula-tions test skills gained through experience.The test covers six specific areas of lightingpractice, each weighted according to itsimportance. “The exam is meant to be com-prehensive, covering a broad curriculum,”said Russell Leslie LC, associate director ofthe Lighting Research Center (LRC) atRensselaer Polytechnic Institute.

Many of the initial takers were longtimeprofessionals, Cuttle said. “The aim of LC isto raise standards of practice, and as thishappens, it can be expected that the examwill increase in difficulty as well,” Cuttlesaid. The pass rate for the most recent exam,given in 1999, is 80%.

Anyone considering taking the examshould read the pamphlet from NCQLPthat clearly sets out eligibility, exam formatand content, as well as the applicationform. Contact the NCQLP directly at(301) 654-2121, or email toinfo@ncqlp.org for a copy.

Why Test?If the LC is not required, why should anyonespend the time to study and money to takethe exam? Industry members agree that theexam is comprehensive and a good start toensuring that a practitioner knows the basics,but it does not guarantee ability or excellencein the field.

Mark Godfrey of Pacific Lightworks inPortland, Oregon, took the 1998 exam. “Ibelieve that this is a positive way to ensure tomy clients that I am qualified,” he said. His

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The EPA estimates that 1% of the 158 tons of mercury released intothe environment by human activity in the United States in 1994–95came from spent mercury-containing lamps, compared with 87% fromcombustion sources such as incinerators and coal-burning power plants.

Paul Abernathy, executive director of the Association of Lighting andMercury Recyclers, said the hazardous waste regulations for lamps werelargely ignored.

“Historically there has been widespread non-compliance with the rulesthat have affected lamp management. About 88% of lamps have beenthrown into the garbage,” Abernathy said. Much of that non-compliancemay be the result of ignorance, he said, noting that many businesses andbuilding owners do not know they have been violating hazardous wasteregulations by sending their lamps to the municipal landfill.

“We also think because there’sbeen wholesale non-compliancefor years and because EPA hasn’tformally resolved the issue untilthis year, there’s been little pres-sure (on) local governments to addfluorescent lamps (to their wasterecycling programs),” he said.With EPA’s support for recyclingthrough the universal waste ruling,that may change. For example,municipal solid waste facilitiesbegan offering recycling for batter-ies after they were declared a uni-versal waste.

Many lamps, however, areexempt from disposal regulations.Residents, exempt in most statesfrom lamp disposal regulations,dispose of 15% of mercury-containing lamps, while 40 statesalso exempt some small businessesfrom regulations, similar to thefederal regulations’ conditionallyexempt small quantity generators,said Ric Erdheim, senior managerfor government affairs for theNational Electrical ManufacturersAssociation.

Joe Howley, GE Lighting envi-ronmental marketing manager,said the universal waste ruling mayincrease recycling. “Before, theywould have to use these full haz-ardous waste regulations to recycle(lamps), and this was sort of a

disincentive to recycle because these people weren’t normally familiarwith the regulations, didn’t want to deal with them, or weren’t familiarwith how to deal with them,” Howley said. “This may make it simpler. Italso would make it simpler for EPA to go in and encourage people torecycle. Instead of saying, ‘Now you have to follow several pages of regu-lations,’ (EPA) could say, ‘Now you should recycle,’ and get them torecycle in a very simple manner without a lot of paperwork.”

In the years during which the EPA delayed its decision, the agencyallowed states to add spent fluorescent lamps to their own universal wasteprograms, resulting in a patchwork of regulations for lamp disposal acrossthe country. As a result, more stringent state regulations will supercedethe new federal regulations (see “State regulations” page 1).

The old regulationsUnder the federal Resource Conservation and Recovery Act (RCRA), spentlamps are determined to be hazardouswaste based on the toxicity characteris-tic leaching procedure (TCLP). The testestimates how much hazardous materialsuch as mercury would potentially leachfrom the product if the material wereplaced in a landfill (see “Questionsabout TCLP” page 1). Those lampsthat come through the TCLP with amercury concentration of 0.2 milli-grams per liter or greater are consideredhazardous waste.

Until lamps became universal wastein January, RCRA labeled anyonedisposing of lamps that fail TCLP a“hazardous waste generator,” withthree classifications. Conditionallyexempt small quantity generatorsdispose of less than 100 kilograms ofhazardous waste in a month and areexempt from RCRA requirements. Asmall quantity generator disposes ofmore than 100 kilograms of hazardouswaste (approximately 300 to 350 4 -foot T12 lamps) in a month and must follow substantial record-keeping,transportation, and storage regulation. Even more rigorous regulationsapply for large quantity generators who dispose of more than 1000 kilo-grams of hazardous waste a month.

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Lamp disposal rules changecontinued from page 1

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The mercury cycle

A naturally occurring element, mercury is a part of our world. Present in air, earth,

and water, mercury has many forms. It travelsthrough air, water, and soil and shifts formsdepending on its location and circumstances.For humans, large amounts of mercury poseserious health risks including neurologicaldisorders and birth defects. Yet the amount ofmercury in the world never actually changes.What changes is the amount of exposure hu-mans have to mercury and the form of theelement at the time of exposure.

Released by natural forces – a volcano, forexample – or by human activity such as, fossilfuel combustion, mercury enters the air. It cantravel substantial distances, falling miles fromits point of origin.

In water or in earth, inorganic mercury canbecome organic mercury through contact withbacteria and other substances. Methyl mercury,one of the more common and more toxicforms of organic mercury, is the form of mer-cury often present in water and fish.

Humans encounter mercury every day.According to the Agency for Substances andDisease Registry of the U.S. Food and DrugAdministration, the air we breathe typicallycontains about 2.4 parts of mercury per trillionparts of air. Humans can ingest mercurythrough contaminated water and fish, breathe

continued on page 5

Before the universal waste ruling, large and small hazardous wastegenerators were required to dispose of their lamps in a hazardous wastelandfill or recycle them; register with the EPA; fill out the hazardous wastemanifest, a complex, multi-part form with multiple copies; and use ahazardous waste transporter to bring their waste to appropriate recyclingor disposal facilities. Any generator of a hazardous substance can be heldliable for releases of that substance into the environment under the Com-prehensive Environmental Response, Compensation, and Liability Act.

The new regulationsFederal universal waste regulations apply to two categories of “handlers.” Asmall quantity handler accumulates up to 5000 kilograms of total universalwaste at one time, while a large quantityhandler accumulates more than 5000kilograms. Conditionally exempt smallquantity generators of hazardous wasteare exempt from federal universal wasteregulations.

Under federal universal waste regu-lations, large quantity universal wastehandlers are required to notify theEPA that they are handling universalwaste, obtain an EPA identificationnumber, and keep records for threeyears of incoming and outgoing ship-ments of universal waste. These rules,however, are less demanding thanthose for hazardous waste. In addi-tion, while some transportation ruleswill be in place, federal rules no longerrequire handlers to use hazardouswaste transporters to bring their lampsto a recycler or hazardous waste land-fill. Federal storage regulations are alsoeased, allowing longer storage periodsfor universal waste than are allowed for hazardous waste. Small quantitygenerators generally do not have to inform the EPA regional office abouttheir universal waste or keep records of universal waste shipments, butstate requirements may be more stringent.

Some states require that all fluorescent lamps be recycled, while othershave more limited exemptions than allowed under federal regulations. Toavoid violating state regulations, people disposing of fluorescent or HIDlamps should contact their state hazardous waste authority to find outspecific requirements (see “State regulations” page 1).

The recycling optionOne way to reduce the amount of mercury circulating in the environment isthrough recycling.

Philips Lighting supports recycling. Paul Walitsky, manager of environ-mental affairs for Philips Lighting, acknowledges that recycling may seemcostly, but the issue goes beyond cost.

“You are not paying for recovering mercury as a commodity when yourecycle. What you are paying for is keeping mercury out of the ecosystem,”Walitsky said. “How much is that worth? I cannot judge.”

Howley of GE Lighting takes the middle road on recycling, supportingthe concept while noting its drawbacks.

“I think recycling is a beneficial way to deal with the disposal of the lamps.There are situations where it doesn’t make sense. There are still a lot of techni-cal and economic hurdles associated with it,” he said. “It costs (the recyclers) alot more to collect and separate the materials of the lamp than (they) can geton the open market for the recovered materials.”

Abernathy of the Association of Lighting and Mercury Recyclers and theEPA disagree with concerns that the cost of recycling will prevent people

from retrofitting their lighting systems with lamps that are moreenergy-efficient. According to the EPA’s 1998 Lighting UpgradeManual, fluorescent recycling costs range from $0.06 a foot to$0.15 a foot, with an average of $0.10 a foot. A 4-foot, 40-wattT12 lamp costs approximately $0.40 to recycle, according to themanual, while putting lamps in a hazardous waste landfill costsabout $0.25 to $0.50 per 4-foot lamp. The EPA estimates that theenergy savings from an energy-efficient retrofit will offset anyincreased costs for recycling.

The appeal offluorescent lampsWhile mercury is an environmental and health concern, fluorescentlamps are responsible for only a very small amount of the elementbeing released into the environment. At the same time, their energyefficiency means they are responsible for far less mercury enteringthe environment through coal-powered energy generation than thatwhich would be released with incandescent lamps at the samelighting level.

While most commercial and industrial settings already use fluo-rescent lamps, a retrofit to fluorescent lamps that are more energy-

efficient would increase efficiency and further reduce mercury emissions.Because incandescent lamps are found in homes, the opportunity for furtherenergy efficiency exists if more residential users begin to use energy efficientlight sources such as compact fluorescent lamps designed for residential

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fixtures or hardwire residential fluorescent lighting systems into their homes. Eachkilowatt-hour saved through energy efficiency prevents 0.04 milligrams of mer-cury emissions, the EPA estimates.

The lighting industry has taken significant steps to reduce the amount of mer-cury they use in lamps already. fluorescent lamps contained as much as 48 milli-grams of mercury through the early 1990s. The amount has decreased to 23milligrams, and new “low-dose” lamps have less than 10 milligrams. Compare

that to a paperclip, which weighs about 1gram. Further, many low-dose lamps pass theTCLP test and so are exempt from hazardouswaste and universal waste regulations. TheEPA, however, encourages recycling for allfluorescent lamps.

While reducing mercury in lamps is a signifi-cant accomplishment, the EPA universal wastedecision for lamps is designed to keep the mer-cury from waste lamps out of municipal landfillsand incinerators. The EPA predicted in the1997 report Mercury Emissions from the Disposalof fluorescent Lamps that the universal waste rulecould reduce mercury in the environment bymore than 600 kilograms this year. It is unlikelythat the debate about mercury in lamps andlamp disposal will end with this ruling; manu-facturers and environmentalists may never agreeon how much mercury is acceptable in lamps orin the country’s disposal system. One thing isclear: the element mercury will not disappearfrom the environment or from a variety ofenergy-efficient lamps.

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M anufacturers are lowering mercury contentin lamps and advertising that the low-dose

mercury lamps will pass the test that determineswhether a substance classifies as a hazardouswaste. Manufacturers have developed ways toreduce the soluble mercury in lamps withoutchanging the total mercury content. To pass thetoxicity characteristic leaching procedure (TCLP),a lamp must test with no more than 0.2 milligramsof soluble mercury per liter (see “Questions aboutTCLP” page 1).

“The traditional (4-foot) fluorescent lamps madethrough the 1980s and 1990s typically contained45 to 50 milligrams of mercury, so the fact that theindustry has gotten them down to less than 10 mil-ligrams (per lamp) is a pretty significant achieve-ment in terms of minimizing our use of thismetal,” said Joe Howley, GE Lighting environmen-tal marketing manager.

While reducing mercury is a benefit at disposaltime, manufacturers must balance that with lampperformance. Mercury dosages have to be calcu-lated precisely in the range of tenths of milli-grams, because a mercury dose that is too small

Lighting certificationcontinued from page 3

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Earth’s 911, 5110 N 44th Street, L120 Phoenix, AZ 85018, phone800.CLEAN.UP, www.1800cleanup.org � Envirobiz International Environ-mental Information Network, 7301 Ohms Lane, Suite 460, Minneapolis,MN 55439, phone 612.831.2473, www.envirobiz.com � GE Lighting, 1975Noble Road, Nela Park, Cleveland, OH 44112, phone 888.GE.BALLAST,www.gespectrum.com/inet � International Association of Lighting Design-ers (IALD), Merchandise Mart, Suite 11-114A, 200 World Trade Center,Chicago, IL 60654, phone 312.527.3677, www.iald.org � Lutron Electron-ics Co., 7200 Suter Road, Coopersburg, PA 18036-1299, phone800.523.9466, www.lutron.com � Morlite Systems Inc., 1805 PittsburghAvenue, Erie, PA 16502-1916, phone 800.865.5954 � NEMA (NationalElectrical Manufacturers Association), 1300 North 17th Street, Suite 1847,Rosslyn, VA 22209, phone 703.841.3200, www.nema.org � Philips Light-ing Company, 200 Franklin Square Drive, Somerset, NJ 08875-6800, phone732.563.3000, www.lighting.philips.com � U.S. Environmental ProtectionAgency, Ariel Rios Building, 1200 Pennsylvania Avenue N.W., Washington,DC 20460, phone 202.260.2090, www.epa.gov � Sportlite Inc., 5355 N.51st Avenue #26, Glendale, AZ 85301, phone 623.930.0074,www.sportlite.com � Venture Lighting, 32000 Aurora Road, Solon, OH,44139, phone 800.451.2606, www.venturelighting.com �

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will shorten lamp life or cause the lamp to fail, while too large a dose means the lamp mayfail TCLP.

“Obviously, we have issues with removing all of the mercury because it’s mercury thatcreates the ultraviolet energy that makes the lamp efficient,” Howley said. “If we drop themercury levels too low, we have concerns about lamp performance and lamp life. Once youdrop below 10 milligrams, you have to be very careful in how you design the lamp to as-sure that it performs the way the old lamps performed and achieves the same lifetimes.”

Low-dose lamps allow a variety of disposal options because the lamps pass TCLP. Theycan be discarded in municipal landfills or incinerated, which releases most of the lamps’mercury into the atmosphere. Low-dose mercury lamps can be recycled even if not classi-fied as hazardous waste by state and federal regulatory agencies.

The mercury cyclecontinued from page 4mercury, and even absorb it through the skin if theycome in contact with it. Federal agencies have estab-lished levels of mercury exposure that are deemedacceptable, though debate on those levels continues(see “Mercury in lamps” page 1).

In the Mercury Study Report to Congress issued in1997, the U.S. Environmental Protection Agencyestimated that approximately 5500 tons of mercuryare released into the atmosphere each year from allsources, including anthropogenic, natural, and oce-anic emissions. Of that, approximately 3% camefrom sources in the United States in 1995. Combus-tion sources accounted for 154.7 tons of the 158 tonsof anthropogenic emissions from the United States,while lamp breakage accounted for only 1.5 tons.That figure is low, yet the National Electrical Manu-facturers Association has argued that it is too high.The numbers are derived from a model that cannotaccurately represent the emissions from brokenlamps, said Ric Erdheim, NEMA senior manager forgovernment affairs. “Only recently has data beenavailable” that would allow an accurate model to bedeveloped, he said.

employer agrees. Pacific Lightworks paid the examination fee and helped Godfreystudy for the exam. All designers in the firm who are eligible now have the LC.

Marianne Maloney, of Fisher Marantz Stone in New York, started out as anarchitect, but discovered lighting design just out of school. She has a degree in arelated field that requires its own rigorous examination. “I feel that taking the exammatters as a benchmark,” she said. “It establishes a baseline of knowledge, similarto a rite of passage, that states I am not a beginner anymore.”

Burr Rutledge, a graduate of the LRC’s MS in Lighting program and a light-ing designer with H.M. Brandston and Partners Inc., is still considering takingthe exam. “There is no outward perceived advantage, other than, as a youngprofessional, it adds another layer of credibility,” he said. Time to study and costof examination fees are important deciding issues for young lighting profession-als, he said.

“It looks good on a resume, a show of commitment to the profession,” saidPatty Glasow, principle at Auerbach+Glasow in San Francisco. “But when hiringfor a small firm, a person’s personality can be just as important as their skills andexperience.” As a firm policy, Auerbach+Glasow supports the NCQLP exam bypaying the fee and purchasing study materials for employees. The LC credentialgives them confidence in a person’s level of basic knowledge, but does not replaceexperience, she said.

OSRAM SYLVANIA considers the test sufficiently important for its employeesthat 16 have so far earned the right to put LC on their business cards, includingseveral in top management, said Pamela Horner, LC, manager of general lightingeducation with the lamp manufacturer.

“I would say that the NCQLP Lighting Certified program shows our totalcommitment to all aspects of lighting, not just to maufacturing,” Horner said.

“Furthermore, the credential is important in order to dem-onstrate our knowledge and our leadership to our custom-ers, especially in three areas: in sales, in productmanagement, and in education.”

The program fits into the company’s existing commit-ment for employee training, she said, so that manypeople use their professional improvement benefits tostudy for and take the exam. The company also showedits support by featuring the 16 LC employees in theinternal newsletter.

“We’ve publicized it internally, so people are aware thatit exists, and we put LC on our business cards,” she said.

Diarmuid McSweeney, LC, director of industrial mar-keting for Holophane and a former NCQLP board mem-ber, continues to support the program.

“I believe that a minimum level lighting qualification isnecessary to raise the bar in our industry,” McSweeneysaid. “For companies such as Holophane, I believe it’simportant for our sales and marketing representatives toshow that they have the necessary expertise to be helpful totheir customers.”

Holophane encourages employees to attend courses toprepare for the LC exam and reimburses them their costswhen they pass it. As many as 25 employees have earnedLC, earning Holophane recognition at LightFair 1999 forhaving the most employees with LC, McSweeney said.

While the exam establishes a basic knowledge level, italso requires continuing education to maintain certifica-tion, he noted. “After three years you have to renew toshow that you are still current,” he said, through some of

the many possible methods of accruing lighting educationunits (LEUs), such as attending trade shows and courses, writingpapers, giving lectures, and reading approved lighting articles.

Another issue that has arisen is one involving who is eligible to takethe exam. Again, unlike engineering or architecture, an LC candidatedoes not necessarily need to be working in a lighting practice. Lightingis such a broad industry that manufacturers, sales representatives, andelectricians are included as “related fields” and can take the exam.

How does this affect international lighting professionals? In this dayof global economies and blurred boundary lines, many lighting prac-tices have gone worldwide, opening offices on far-off continents.Should lighting designers in other countries take an exam that is cur-rently written only for North America? The NCQLP lists reference

sources on which the exam is based, and these relate only to North Americanpractice. They make no reference to practices in other countries or to documentsissued by international bodies.

“The official position of the IALD is that lighting practice is in a state of transi-tion, and there are no finite answers to these questions. As an international organi-zation, we must represent the rights of our non-American members,” said MoragFullilove, executive director of the IALD. “The IALD has always believed in, andsupported, the importance of upgrading the quality of services.” More than 100IALD members have the LC credential, but until these issues can be resolved, theIALD will not require this credential for its members.

Regardless of how lighting practice gets there, lighting professionals are deter-mined to achieve a level of professionalism and credibility similar to that of theengineering and architecture professions. The general feeling throughout the in-dustry is positive. The LC creates a comprehensive base, and in the future, moreprecise and specialized requirements may emerge to work in conjunction with theLC for specific areas of lighting practice.