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The End is Nigh: Addressing LED Lamps and Luminaires at End-of-Life

February 14, 2024

There are many stages to sustainability, including environmentally safe mining of chemicals; chemical processing; manufacturing components; assembling components; packaging products; shipping products for distribution; selling products; shipping products to homes and businesses; and using products. The lighting industry is making strides in some of these areas, but we have historically done a poor job on the final step of sustainability: a product’s end-of-life.

For over 100 years, the industry has had no national plan to recycle incandescent lamps. As a result, tens of millions of incandescent lamps containing lead have been thrown into landfills allowing lead to potentially seep into watersheds. Elevated blood lead levels (BLLs) of children living near landfills were related to increased soil lead levels. Toxic effects of lead included adverse outcomes such as encephalopathy or death for children.¹ Different approaches to decrease lead levels include environmental surveillance, BLL screening, and soil abatement, which are costly. But recycling was never built in as part of the solution.

Next came high-intensity discharge lamps followed by fluorescent lamps. For decades, these were also sent to the landfills. As lamps broke under pressure, mercury escaped and potentially made its way into the soil. (Additionally, fluorescent lamps manufactured up to the 1940s used toxic beryllium compounds, which contributed to the death of factory workers.) However, while the industry struggled to reduce mercury levels in fluorescent lamps, U.S. states began mandating that the lamps be recycled. Using large industrial recycling machines, the mercury was reclaimed in a vacuum, the glass separated for reuse in things like fiberglass, and phosphors and endcaps collected for reuse. Upon a visit to such a factory in Connecticut, I was told that in excess of 95% of the lamp was reclaimed for future use. This was a brilliant solution and is ongoing as we replace fluorescent and HID lamps with LEDs.

The U.S. Department of Energy (DOE) has been encouraging the use of LEDs since the time they offered a prize for an LED lamp that would closely resemble the characteristics of a 60-W incandescent lamp. Having set new efficiency standards for many screw-in lamps, most incandescent and halogen lamps couldn’t make the cut, but LEDs could. Similarly, new DOE efficiency standards have effectively ruled out the manufacturing or import of T12, T8 and T5 fluorescent lamps. Several states (seven at my last count) have gone a step further by banning the sale, offer or distribution of most fluorescent and compact fluorescent lamps.

This is all happening without a plan in place for LED end-of-life recycling. Upon making a call to my local authorities asking what to do with a burned-out LED lamp, I was told they don’t contain mercury, and to just throw them in the trash.

So, why am I concerned? Because LEDs and LED circuit boards contain, among other things, arsenic, gallium, indium, cerium, europium, gadolinium and yttrium. While I can’t even pronounce some of these names, I do know that arsenic is not something I want in my drinking water. In drinking water supplies, arsenic poses a problem because it is toxic at low levels and is a known carcinogen. Even if the arsenic is bound to other elements (like gallium) there seems to be no confirmed research on what the breakdown will be over decades in a landfill.

TCLP leachate concentrations of arsenic greater than 5 milligrams per liter require disposal in a hazardous waste landfill. When the leachate arsenic concentration is below 5 milligrams per liter, the waste is classified as non-hazardous and suitable for disposal in a municipal solid waste landfill. So, a couple of lamps would not be prohibited. But arsenic contamination of ground water may persist for many years after the closure of a landfill because of the high organic carbon content of contamination, according to the U.S. Geological Survey.

Once again, the lighting industry has forged ahead for the sake of energy savings and/or convenience without a sustainably favorable end-of-life solution. The U.S. Environmental Protection Agency estimates there are over 100 million exit signs in America. The first generation of LED exit signs (I began selling them in the 1980s) have already begun to fail. Even if the signs are not burned out, it is doubtful their lumen output meets UL standards for safety. Similarly, some municipalities are considering replacing thousands of LED streetlights because they can cost justify new LED lights with greater energy efficiency. Throwing all these older exit signs and/or luminaires into the landfill is not a sustainable solution.

While it is now too late to set the clock back so we can continue using fluorescent until we have a viable solution for LEDs, we need to step up quickly and find answers. Electrical vehicle manufacturers recognize the need to recycle their batteries in the future. Their primary motivation may be the valuable materials in those batteries, but they are spending money now to get it figured out. 

Europe has been ahead of the U.S. on most of these lighting-related problems. As an example, they reduced mercury levels in lamps ahead of the U.S. The European Semiconductor Industry Association (EESIA) rigorously manages arsenic in the semiconductor manufacturing environment, and there is no consumer exposure. The end-of-life phase of electronic products is covered by the EU WEEE (Waste Electrical and Electronic Equipment) Directive and, therefore, potential exposure is minimized by treating the products as hazardous waste.

Effective January 2023, in Ontario, Canada, lamp/bulb manufacturers have new “extended producer responsibility” requirements for end-of-life management of “lighting” under Ontario Regulation 522/20: Electrical and Electronic Equipment. This includes both residential and commercial lamps sold in Ontario. But not luminaires.

The National Association of Innovative Lighting Distributers’ Sustainability Committee’s white paper supports the practice of recyclable and/or reusable components. An example would be using recyclable lamps versus integral LEDs, which will be hard to extract from luminaires. Using replaceable parts in luminaires would allow for greater, easier recycling. Using recyclable materials in luminaires (aluminum, cork, wood, plastic) will help, but those parts need to be easily separated out.

While some big box stores are accepting LED lamps for recycling, I have been unable to find out where they are going and how much of the lamp is being recycled. Regardless, this is a solution for homeowners, and what we need are solutions for commercial upgrades.

It may take legislation at local, state or federal levels to demand recycling, and the industry needs to be prepared to get a high level of the lamps and luminaires recycled out. There are many organizations promoting sustainability. End-of-Life should be a consideration.

Another helpful solution would be for manufacturers to create an industry website that explains why, how and where to recycle LED lamps and luminaires.


THE AUTHOR |

Jeffrey Schwartz, IES Member Emeritus, is owner of JDS1 Consulting and president of the IES Portland, OR, Section.


References

1. M.A. Kim and K.A. Williams, “Lead Levels in Landfill Areas and Childhood Exposure: An Integrative Review,” Public Health Nursing, vol. 34, no. 1, 2017.