Fluorescent lamps

Scope

A lamp is defined in 40 CFR 273.9 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 (HID), neon, mercury vapor, high pressure sodium, and metal halide lamps.

Lamps that are not waste because they have not been discarded or that are not hazardous waste are not universal wastes.

Regulatory citations

• 40 CFR Part 262 — Standards applicable to generators of hazardous waste
• 40 CFR Part 273 — Standards for universal waste management

Key definitions

• Lamp, also referred to as “universal waste lamp”: 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.

Summary of requirements

Storage. Lamps should be stored in a way that avoids breakage. Containers must be closed, structurally sound, compatible with the contents of the lamps and must lack evidence of leakage, spillage or damage that could cause leakage or releases of mercury or other hazardous constituents. Fluorescent lamps can be stored in the original boxes or in boxes from replacement bulbs. Specially manufactured containers can be purchased for storing used lamps until they are ready for recycling. Your lamp recycler may also provide you with a container that makes storage, shipping or pick-up easier. Do not tape lamps together or use rubber bands. Close and securely seal boxes/containers with tape. Three-inch PVC (polyvinylchloride – plastic insulating tape) tape is recommended. Store boxes/containers in a dry place. Make sure that you work with your recycler to fully understand proper procedures for filling and securing boxes or containers of lamps. Label boxes/containers with one of the following: “Universal Waste-Lamp(s),” or “Waste Lamp(s),” or “Used Lamp(s).” Lamps must be recycled within one year. It’s important to protect lamps from breakage. Remove lamps carefully and store used lamps in a location and manner that will prevent breakage. Certificate of Recycling. A “Certificate of Recycling” is the recycler’s certification of, typically, the total weight of material received on a particular date and confirmation that it was processed in accordance with state and federal regulations. You should maintain this paperwork on file so that if any questions are raised about the disposal of your waste lamps, it can be verified that they were recycled according to the Universal Waste Rule.

“Green” lamps. Most major manufacturers are now producing a line of fluorescent lamps which they claim are non-hazardous low-mercury or “green end cap” lamps. When these bulbs are taken out of service, manufacturer’s data may be used to help determine if they are a hazardous waste. If they are not hazardous waste, EPA still encourages recycling because there is still some mercury in the lamps.

Also note that some states have rules that are more stringent than the federal rules discussed above. For example, a Mercury-Added Consumer Products Law addresses the disposal of mercury-containing lamps in New York State. The law primarily affects generators of low-mercury or “green end cap” lamps. Under this law, low-mercury or “green end cap” lamps that pass the TCLP are not mercury free and must be recycled or managed by an authorized facility.