Re:Household incandescent light bulbs = hazardous waste?

[David Hixson <david_hixson@wssrap-host.wssrap.com>]

Correspondence from at least two bulb manufacturers (General Electric and
Philips Lighting) state that incandescent lamps have the potential to be
classifed as a hazardous waste due to the lead used in the solder on the base of
the lamps. Both manufacturers reference the Toxic Characteristic Leachate
Procedure (TCLP) which is the EPA's definitive test for determining
characteristic hazardous waste.
Although we have no TCLP data on lamp bases, we have analyzed elemental lead per
TCLP which resulted in extractable concentrations greatly exceeding the
regulatory threshold of 5 mg/l.   

Be aware that the exclusion outlined in 40 CFR 261.4(b)(1) only applies to
household waste derived from households not commerical or industrial sources.


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