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Lighting: How Does Your Disposal Program Stack Up?

Key Points
  • Older lighting products, such as fluorescent lamps and HID bulbs, often contain hazardous materials.
  • State and federal regulations place strict requirements on safe disposal of these lighting products.
  • A number of resources are available to help you find lamp recyclers in your area.

Considering an LED upgrade? What a bright idea! You'll reap the benefits in energy savings, improved light quality and lower maintenance costs. Unfortunately, there's a dark side. The popularity of LEDs has led to a growing pile of discarded fluorescent lamps and high-intensity discharge (HID) bulbs that often contain hazardous materials, such as mercury or lead. If your existing lighting system uses such technologies, how do you dispose of them? Here we provide some advice on what to do with used bulbs and lamps.

Old lampsFollow the rules

Discarded lamps and bulbs containing mercury are regulated by the U.S. Environmental Protection Agency (EPA) under the Universal Waste Rule (UWR). This rule is designed to reduce the regulatory burden and cost for storage, record keeping and transport; it also encourages recycling. Lighting technologies covered under the UWR include:

  • Fluorescent
  • Neon
  • Mercury vapor
  • High-pressure sodium
  • Metal halide

A hazardous waste generator (a business, building owner or third party) who accumulates less than 11,000 pounds of total waste onsite at any one time is considered a small quantity handler of universal waste and the following requirements apply:

  • No EPA ID is required
  • Up to one year of storage time is allowed
  • Employees only need minimal mercury-handling training
  • Minimal marking and labeling of waste lamps is required
  • No special tracking or reporting for waste shipped to recyclers

Check with your local waste management agency for recycling options and disposal guidelines in your community. State hazardous waste requirements can be more stringent than federal regulations.

Watch your step

As you replace lights, or begin the upgrade process, how do you cope with all of those old bulbs or lamps? The EPA provides a 10-step process for managing mercury-containing lighting products:

  1. Assess your facility. How many lamps are in your facility and where are they located? How are you handling and storing used lamps?
  2. Become knowledgeable about state and federal requirements. Consult your state’s regulations for specific requirements for managing hazardous waste lamps.
  3. Select a recycler. Choose a recycler that will serve your needs and provide assurance your waste lamps are properly managed to minimize your liabilities.
  4. Establish a process for managing used lamps. Designate a dry, secure area in your facility to store used lamps.
  5. Safely handle and store used lamps. Lamps should be stored in a way that avoids breakage. Containers must be closed, structurally sound and compatible with the contents of the lamps.
  6. Properly manage broken lamps. Develop procedures for handling broken lamps and educate staff.
  7. Create procedures for getting lamps to the recycler. Your options range from dedicated pick-up to self transport to a local collection facility.
  8. Educate employees. Inform staff about the dangers of hazardous waste and train them according to state and federal waste regulations.
  9. Record and track data. Require that the recycler provides documentation of proper disposal.
  10. Include recycling costs in your budget. Costs vary depending on the type of lamp, quantity and whether transport is included.

Locating recyclers 

How do you find lamp recyclers? The National Electrical Manufacturers Association maintains a list of Commercial Lighting Lamp Recyclers. The Association of Lighting and Mercury Recyclers provides a searchable map of member recycling organizations. Contact your state waste management or environmental agency for more information about recycling locations in your area.

Image source: iStock 


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