Hazardous Waste Management

Universal Waste Lamps: Working Out a Recycling Program

Step 6: Create Procedures for Managing Broken Lamps

The easiest way to do this is to protect lamps from breakage. Remove lamps carefully and store used lamps in a location and manner that will prevent breakage.

Step 7: Decide How You’re Going to Get the Lamps to the Recycler

There are several options to consider when getting the lamps to the recycler.

Pick-up Service
Figure out the type and frequency of pick-up needed before you select your recycler.  Pick-up options will be determined by the size of the facility and the number of waste lamps generated. Here are your options:

Dedicated Pick-up – If you generate enough waste lamps to fill a truck it may be cost effective to contract for a dedicated pick-up (either once a month or upon request).

Mail-In or Box Program –Usually the best option if you only generate a small amount of waste lamps. In this type of program, a recycler can provide a container to fill with used waste lamps. When the container is full, it can be sent to the recycler via a prepaid ground mail shipment program.


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Milk-Run –This is when the recycler schedules a number of pick-ups from you. Milk-run collections are usually run on a set schedule, the frequency of the collection will need to be determined with the recycler at the time of contract negotiations. The number and frequency of waste lamps generated by an individual company will determine the collection frequency. This is the most common type of pick-up.

Self-Transport – If you generate a small amount of waste lamps or have the capacity to transport the waste lamps or are located in close proximity to the recycler, you may choose to self-transport the waste lamps to the recycler. Although the Universal Waste Rule eases restrictions on the transportation requirements for universal waste lamps, you still have to comply with DOT’s requirements under the Universal Waste Rule.

Some businesses that generate very small amounts of waste lamps may be able to take the lamps to a locally operated household hazardous waste collection facility in their community. Businesses should check with their local hazardous waste collection facility first to see if this is permissible.

Step 8: Train Employees

Teach your employees about the dangers of mercury in fluorescent lamps and your decision to recycle all fluorescent lamps. Employees should be trained in accordance with the Universal Waste Rule requirements for small quantity handlers of universal waste and large quantity handlers of universal waste (40 CFR 273.36).


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Step 9: Record and Track Data

Your recycler should offer a “Certificate of Recycling” that is documentation that the waste lamps have been properly recycled.  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. Keep this paperwork on file so that if any questions are raised about the disposal of waste lamps it can be verified that they were recycled in accordance with the Universal Waste Rule.

Step 10: Include Recycling Costs in Your Annual Budget

Recycling costs vary, depending on the type of lamp, quantities, and whether transportation is included. It is best to call for at least three quotes. The following price ranges are typical:

Tubes – 4¢ to 12¢ per linear foot
High Intensity Discharges – $1.50 – $2.00
Compact Fluorescent Lamps – 50¢ – $1.00

In addition, there may be a charge for pick-up, transport or mailing. The recycler can give you pricing.

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