Q. Are LED bulbs a RCRA hazardous waste and can they be shipped and recycled as a Universal Waste along with fluorescent bulbs?
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A. Regarding your first question, “are LED bulbs a RCRA hazardous waste?” the federal universal waste rule defines “lamp,” also referred to as a “universal waste lamp,” “as the bulb or tube portion of an electric lighting device. A lamp is specifically designed to produce radiant energy, most often in the ultraviolet, visible, and infra-red regions of the electromagnetic spectrum. Examples of common universal waste electric lamps include, but are not limited to, fluorescent, high intensity discharge, neon, mercury vapor, high pressure sodium, and metal halide lamps” (40 CFR 273.9). As you can see, LED lamps are not explicitly included or excluded from the definition. Any lamp (LED or otherwise) that does not exhibit one or more of the hazardous waste characteristics of 40 CFR 261 (ignitability, corrosivity, reactivity, or toxicity) is not considered hazardous waste (40 CFR 273.5(b)). Lamps that are not hazardous wastes may be disposed of in municipal waste management facilities.
It is the responsibility of the generator of the lamp to determine whether it is a hazardous waste. One way to make the determination is through the Toxicity Characteristic Leaching Procedure (TCLP). The TCLP attempts to replicate the conditions in a municipal landfill to detect the mercury concentration of water that would leach from the landfill. If the mercury concentration exceeds 0.2 milligrams per liter (mg/L), the lamp fails the toxicity test and must be managed as a hazardous waste (or as a universal waste). If the TCLP analysis puts the mercury below the 0.2 mg/L maximum concentration limit, the lamp does not have to be managed as a hazardous waste or a universal waste. EPA has noted, however, that mercury-containing lamps often fail the TCLP and that the test results can vary considerably, depending on the lamp manufacturer, the age of the lamp, and the laboratory procedures used. Note that California also lists the Waste Extraction Test (WET) in 22 CCR 66273.24 to determine the characteristic of toxicity.
Your second question is whether LED bulbs can “be shipped and recycled as a universal waste, along with fluorescent bulbs?” The universal waste regulations do not specify whether universal waste bulbs must be sorted by type, i.e. whether the neon bulbs must be packaged and shipped separately from the metal halide lamps, etc. The universal waste regulations for lamps address packaging, labeling, and, If the universal waste being shipped off-site meets the definition of hazardous materials under U.S. Department of Transportation (DOT) standards, packaging, labelling, marking, and placarding the shipment and preparing the shipping papers in accordance with the applicable DOT standards.