Hazardous Waste Management

10 Steps to Get Rolling on a Recycling Program for Universal Waste Lamps

Step 1: Assess Your Facility

To do this, ask the following questions: How many fluorescent lamps are in the facility? Where are they located? How often do you change your fluorescent lamps? How many fluorescent lamps are you disposing of each month and year? How are you handling and storing the used lamps? Do all employees know what to do with a used fluorescent lamp?

Step 2: Know the Rules

Take a look at your state’s regulations for state-specific requirements for managing hazardous waste lamps, noting the specific requirements that pertain to the Universal Waste Rule. Lamp recyclers should be aware of state and federal requirements and are generally able to help in this area.


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Step 3: Select a Recycler

When choosing the right recycler for you, the key is to be picky. Here are some things to consider when choosing a recycler:

Price – Pricing represents the recycler’s ability to service you and your customers and meet your needs, while at the same time being price competitive. While everyone works on a budget, the old adage–you get what you pay for–can apply here too. A good rule of thumb is to get more than one quote and compare.

Service – Think about responsiveness, timeliness, program flexibility and customization, the personnel you will be working with, whether there will be intermediates, the capabilities of the firm and the equipment they will be using

Risk Management – Recyclers are obligated to reduce or eliminate pollution risks for their clients. In order to remove the mercury from the waste, recyclers must comply with numerous federal and state regulations. Important factors for evaluating recyclers include:

  • Do they meet insurance requirements for general and pollution liability?
  • What is the financial health of the company?
  • What indemnities or other assurances do they offer clients?
  • What is their environmental record and compliance history?
  • What about government permits and approvals for facility operation or transportation?
  • What are their operations and safety procedures and records?
  • What about their vapor control technology and monitoring records?
  • What about hygiene and medical surveillance information?
  • What is the status of a facility closure plan?
  • Do they keep facility audit reports?
  • What is the availability of key regulatory contacts?

Don’t get overwhelmed with this list. You are entrusting your hazardous waste to a third party and you need assurances. Ask potential recycling contractors about any of these items. Also, get some references and/or check with the state agency that regulates recycling facilities for compliance histories.


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Alternatives to Recyclers–If you can’t find a recycler that meets your needs, contact your lamp distributor to see if they offer a recycling service for their customers—this is becoming quite common for distributers. 

Step 4: Establish a Process for Managing Used Fluorescent Lamps

Designate an area within your facility to store used lamps. It should be an area that is dry and where the lamps will not be broken. Ideally, this area would have an air handling system that is independent from the rest of the building.

Step 5: Safely Handle and Store Used Fluorescent Lamps

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 bans. Close and securely seal boxes/containers with tape. Three-inch PVC (polyvinyl chloride – 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 1 year.

In tomorrow’s Advisor, we’ll cover the last 5 steps for developing a recycling program, plus an introduction to a tried and true solution for state EPA regulation compliance.