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How to Establish a Recycling Program for Mercury-Containing Light Bulbs

Bulb picture
Types of Universal Waste

Step 1: Assess Your Facility
Step 2: Become Knowledgeable About State and Federal Requirements for Managing Fluorescent Lamps
Step 3: Select a Recycler
     –– Recycler Selection Criteria
     –– Alternatives to Recyclers
Step 4: Establish a Process for Managing Used Fluorescent Lamps
Step 5: Safely Handle and Store Used Fluorescent Lamps
Step 6: Properly Manage Broken Lamps
Step 7: Procedures for Getting Lamps to the Recycler
Step 8: Educate Employees
Step 9: Record and Track Data
Step 10: Include Recycling Costs in Your Annual Budget

Outlined below are steps that businesses can undertake to properly manage used univeral waste lamps.

Step 1: Assess Your Facility – Assessing your facility is a key step to implementing a recycling program. In assessing your facility, the following questions should be answered: 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: Become Knowledgeable about State and Federal Requirements for Managing Fluorescent Lamps – Consult 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 will be able to provide assistance in this area. A link to a list of recyclers is provided under Step 3.

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Step 3: Select a RecyclerLamprecycle.org Exit EPA sponsored by the National Electrical Manufacturers Association (NEMA) maintains a list of companies claiming to recycle or handle spent mercury-containing lamps. Also provided below are general criteria that should be considered when selecting a recycler.

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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.

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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 one year.

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Step 6: Properly Manage Broken Lamps – Create procedures for managing broken lamps. Protect lamps from breakage. Remove lamps carefully and store used lamps in a location and manner that will prevent breakage.

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Step 7: Procedures for Getting Lamps to the Recycler – To recycle lamps there are several options to consider.

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Step 8: Educate Employees – Inform 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 (40 CFR 273) requirements for small quantity handlers of universal waste (40 CFR 273.16) and large quantity handlers of universal waste (40 CFR 273.36). The requirements are as follows:

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Step 9: Record and Track Data – It is important to require that the recycler provide documentation that the waste lamps have been properly recycled. You should obtain a “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 waste lamps it can be verified that they were recycled in accordance with the Universal Waste Rule.

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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:

In addition, there may be a charge for pick-up, transport or mailing. Contact a recycler for pricing.

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