Are all mercury-containing lamps a hazardous waste?
Under federal regulations, the vast majority of mercury-containing lamps are considered a hazardous waste. Note that if you do not test your mercury-containing lamps and prove them non-hazardous, assume they are hazardous waste and handle them accordingly. A lamp is considered a hazardous waste if it exhibits the characteristic of hazardous waste toxicity. The test used to determine whether or not a lamp is a hazardous waste is the Toxicity Characteristic Leaching Procedure, TCLP. Under this procedure, the waste leachate must contain less than 0.2 milligrams per liter (mg/L) of mercury in order to the pass the test (see 40 Code of Federal Regulations (CFR) Part 261.24 . Lamps that pass the TCLP are not hazardous and therefore, they are not subject to federal regulations. If the mercury concentration exceeds 0.2 mg/L, the lamp fails the TCLP and is managed as hazardous waste. It should be noted that some states consider all mercury-containing lamps to be hazardous. One example is the st
