HWTR Dangerous Materials

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Mercury-containing Lights and Lamps as Universal Waste

Photo: Tall containers holding spent fluorescent tubes as universal waste.

Most fluorescent and high-intensity discharge lamps can be classified as dangerous waste, typically because of the mercury content. Businesses may not be aware they could be illegally disposing of a dangerous waste and subject to penalties.

However, they can choose to manage these lamps as Universal Waste (UW). This allows for easier management of this waste, but UW rules must be followed.  Types of lamps that can be managed as UW include:

  • Fluorescent, compact fluorescent
  • Neon
  • High Intensity Discharge (HID) (e.g., mercury vapor, metal halide, high-pressure sodium)
  • Any other lamps that are dangerous waste

A dangerous waste generator has the choice of managing lamps as UW or under the more stringent dangerous waste requirements. In most cases UW management is much easier and the preferable alternative to dangerous waste management. Businesses that generate and manage dangerous waste and UW are considered both a dangerous waste generator and a UW handler. Regardless if you are a generator or a handler, you are liable for ensuring your waste is properly managed once it leaves your site.

A generator has three choices when determining if their spent lamps are dangerous waste:

  1. Assume that their lamps are a dangerous waste.
  2. Use manufacturer’s information, MSDS and other available information to determine toxicity.
  3. Sample and test to determine if it is dangerous waste.

Storing and Labeling Universal Waste Lights and Lamps

Because glass bulbs are easily broken, UW rules for lights and lamps require specific handling procedures. Store lamps in structurally sound containers, such as cardboard boxes or fiber drums. Keep containers closed when not adding lamps.

Clearly label or mark individual lamps or containers with:

  • The words "Universal Waste - Lamps," "Waste Lamps," or "Used Lamps."
  • The accumulation start date. (Used and unused lamps become waste on the date the handler decides to discard them.)
  • Identification of the contents.

You can only accumulate lamps for one year from the date they are generated. To document this, the collection container or individual UW lamp is typically marked with the first date of accumulation. An extension to the one year accumulation limit is allowed if the facility needs more time to collect enough items to facilitate proper recovery, treatment, or disposal.

Immediately clean up any broken lamps and store debris in a closed container.

Recycling and Disposing of Universal Waste Lamps

Lamp crushing is prohibited. While lamps cannot be crushed under UW regulations, lamp crushing is allowed as a dangerous waste treatment-by-generator activity. Ecology's Using Fluorescent Lamp Crushing Equipment explains.

Some local governments may have landfill bans on disposal of mercury-containing lamps or other mercury-containing items. Check with your local health department, solid waste agency, or landfill for specific requirements, as well as recycling or disposal options.

Large Quantity Handlers of Universal Waste (LQHUW) are either the original generators of the UW or businesses that receive and consolidate UW from other handlers before shipping to another handler or to a destination facility. Manage Universal Waste has more on LQHUW facilities.

UW may be sent to either another handler (acting as a collection point) or to a destination facility. Another handler could include any business that is already managing UW, government-sponsored collections, or hazardous waste management firms. Businesses that recycle or dispose of UW are called destination facilities. Ultimately, all UW must go to a destination facility. They are subject to dangerous waste regulations for recyclers and hazardous waste disposal facilities. A facility that only accumulates UW would not be a destination facility.

Why Do We Care About Lamps?

Nationally, about 680 million lamps are disposed of annually, most to solid waste disposal facilities, including landfills and solid waste incinerators. Fluorescent lamps contain a small amount of mercury, which is released when the lamp is broken. During waste handling and disposal, many lamps break, releasing mercury vapor and potentially exposing waste handlers to inhalation of those vapors.

Even in newer fluorescent tubes, mercury content ranges from 3.5 milligrams to 8 milligrams or more. Some older fluorescent tubes (pre-1999) contain up to 50 milligrams of mercury. HID lamps may contain up to 250 milligrams, depending on the lamp wattage.

Some lamps contain lead in the glass and lead solder in the base. Lead is a toxic metal that may leach from solid waste landfills into the ground water. Manufacturers are eliminating the lead by using non-leaded glass and solders in new lamps.

Although fluorescent and HID lamps contain toxic mercury and should be recycled, people are encouraged to continue using them because they use much less electricity and last much longer than other types of lighting.

Related information

Universal Waste Rule for Lamps describes this waste in detail, including handling requirements.

Manage Universal Waste gives general information on the management of all types of UW.