EHS Management, Hazardous and Solid Waste

Universal Waste: How Long Do You Have to Remove Fluorescent Bulbs After Facility Closure?

Experts at® recently responded to the question of how long an organization has to remove fluorescent bulbs from its facility since the facility closed operations. Read on to learn the answer.

fluorescent lamps, bulbs

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To have the maximum amount of time to remove your fluorescent bulbs at your facility, you would want to manage your fluorescent bulbs in accordance with the universal waste rules at 40 CFR 273. A fluorescent bulb, provided it’s hazardous and therefore eligible to be managed as a universal waste lamp, becomes a waste:

  • If used, on the day it is discarded, or
  • If not used, on the date it the handler (e.g. the generator) decides to discard it.

In other words, a hazardous waste lamp does not become a universal waste lamp subject to the universal waste regulations until it is waste – which occurs when it is discarded.

Generators of universal waste lamps can keep such wastes onsite (i.e. at your facility) for 1 year. This is in contrast to the periods of time that generators of hazardous waste can keep hazardous waste onsite. Small or large quantity handlers of universal wastes can keep universal wastes onsite for 1 year, whereas small quantity generators of hazardous waste (SQGs) and large quantity generators of hazardous waste (LQGs) can keep hazardous wastes onsite for, respectively, 180 and 90 days. In your scenario, the 1-year period for universal waste is measured from the time the waste is generated (the date it becomes a waste). These wastes can be accumulated (stored) longer at your facility if you can demonstrate to the EPA or your state environmental regulatory agency that more time is necessary to properly recycle the universal waste.

It is up to you to establish the date that the lamps became a universal waste. That could be the earliest date that the bulbs were removed from their lamp fixtures, or, if left in their fixtures, possibly the date that the facility was closed.

Note: This question was answered by experts at

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