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Frequent Questions about Regulations that Affect the Management and Disposal of Mercury-Containing Light Bulbs (Lamps)

Types of Universal Waste
Broken Lamps

Lamps are fragile and can easily break. The regulations distinguish between accidental breakage that occurs during normal transport and intentional breakage or crushing. While there is no specific amount of breakage that is considered accidental, less than 5% is generally acceptable. Anyone who chooses to recycle lamps under the Universal Waste Rule should take standard precautions to minimize breakage, such as using the boxes from new lamps to store old ones. More specific guidance on this is available from recyclers.

Read how to clean up a broken CFL or other fluorescent lamp.

Regulatory Overview
More Information on Which Lamps are Subject to Waste Management Requirements
More Information on Who is Subject to Waste Management Requirements

Regulatory Overview

How are mercury-containing bulbs (called “lamps” in the regulations) regulated?

Mercury-containing lamps are managed under both federal and state regulations. Note that regulations may vary from state to state, and some states have regulations that are more stringent than those of the federal government. As a result, you should check with your state and local governments to learn how their regulations apply to you.

Federal Laws

Determining whether your mercury-containing lamp is hazardous waste. Under federal regulations, the vast majority of mercury-containing lamps are considered a hazardous waste. If you do not test your mercury-containing lamps and prove them non-hazardous, you must assume they are hazardous waste and handle them accordingly.

TESTING to determine if your lamp is a hazardous waste. Under federal regulations, a lamp is considered a hazardous waste if it exhibits the characteristic of hazardous waste toxicity. Waste generators must determine whether or not a lamp exhibits this characteristic by using the Toxicity Characteristic Leaching Procedure (TCLP) to test the lamp. This test measures the leachability of certain metals, including mercury and organic constituents. Under this procedure, the waste leachate must contain less than 0.2 milligrams per liter (mg/L) of mercury in order to pass the test.

  • Lamps that pass the TCLP are not hazardous and therefore, are not subject to federal regulations.
  • If the mercury concentration exceeds 0.2 mg/L, the lamp fails the toxicity test and should be managed as hazardous waste.

Note that regulations may vary from state-to-state. For more information specific to your state, contact your state environmental regulatory agency.

USING GENERATOR KNOWLEDGE to determine if your lamp is hazardous waste: A generator may also use general knowledge to determine whether or not a lamp is hazardous. General knowledge may or may not be provided by a lamp manufacturer. Generators may be able to find out more about the regulatory status of mercury-containing lamps by contacting the manufacturer. However, generators should note that some states require generators to test their lamps to determine if the lamps are non-hazardous. Under both federal and state laws, the ultimate responsibility for determining whether a lamp is hazardous lies with the waste generator, not the lamp manufacturer. Again, if you do not test your mercury-containing lamps and prove them non-hazardous, assume they are hazardous waste and handle them accordingly.

Universal Waste Rule. Disposal by businesses of lamps that fail the TCLP and are therefore considered hazardous may be managed under

Promulgated in 1995 (60 FR 25492 (PDF); now at Title 40, Part 273 of the Code of Federal Regulations), the UWR established reduced regulations for generators of certain widely used hazardous wastes such as batteries, pesticides, and thermostats. Lamps were added to the Universal Waste Rule in 1999 (64 FR 36466 (PDF)).

Whether waste generators can manage their mercury-containing lamps under the Universal Waste Rule depends on the amount of hazardous waste generated each calendar month. Businesses disposing of less waste can follow the more streamlined processes; businesses with more waste may have to comply with more complex requirements.

The Universal Waste Rule provides flexibility in the management of lamps, streamlined requirements for waste handlers, and promotes recycling. Easing the regulatory burden associated with the management of this waste reduces administrative, shipping, and disposal costs, making it easier to recycle this material. Handlers managing waste under the Universal Waste Rule have streamlined requirements for:

No permitting is needed and no special tracking or reporting is required when businesses send lamps to recyclers. Lamp recyclers can assist waste generators and other handlers in setting up recycling/management programs. Learn more about how to establish a recycling program.

View a comparison of regulatory requirements under Subtitle C versus under the Universal Waste Rule.

In addition, Congress specifically excluded household waste from the hazardous waste regulations (i.e., household exemption).

The federal hazardous waste regulations also set a minimum threshold for waste quantities, and hazardous wastes from small-volume generators are not regulated as stringently (i.e., Conditionally Exempt Small Quantity Generator (CESQG)).

As a result, waste lamps may, or may not, be regulated as hazardous waste under the federal hazardous waste regulations, depending upon the status of the generator of the waste and the specific lamps involved.

State Laws

Each state has its own program for management of mercury-containing lamps. Most states have adopted and currently implement the federal Universal Waste Rule (UWR).

Note that several states have regulations that are more stringent than the federal UWR. For example, all mercury-containing wastes are banned from landfills in Vermont regardless of whether they were disposed of by CESQGs or households. New Hampshire does not have reduced requirements for CESQGs in its hazardous waste regulations. Several other states (CA, MN, NY, ME, CT, and RI) either ban the disposal of mercury-containing lamps or have limited the amount of lamps entering disposal facilities. Other states are contemplating similar bans. Check with your state to determine your regulatory requirements. For more information specific to your state, contact your state environmental regulatory agency.

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What are the proper recycling/disposal procedures for businesses under the Universal Waste Rule?

While disposal requirements for mercury-containing lamps vary from state to state, the federal Universal Waste Rule (see 40 CFR 273) lays out the following basic standards for handling spent lamps:

Additional Information:

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More Information on Which Lamps are Subject to Waste Management Requirements

How does EPA define the term “lamps” in its waste regulations? 40 CFR 273.9

Lamp, also referred to as “universal waste lamp,” is defined as the bulb or tube portion of an electric lighting device. A lamp is specifically designed to produce radiant energy, most often in the ultraviolet, visible, and infra-red regions of the electromagnetic spectrum. Examples of common universal waste electric lamps include, but are not limited to, fluorescent, high intensity discharge, neon, mercury vapor, high pressure sodium, and metal halide lamps. View more information about universal wastes.

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Do I need to recycle low-mercury (“green end cap”) fluorescent lamps?

Under federal regulations, the Toxicity Characteristic Leaching Procedure (TCLP) determines if a lamp is a hazardous waste. Lamps that pass the TCLP test for mercury are not hazardous and therefore, are not subject to federal regulation. This test measures the leachability of certain metals, including mercury and organic constituents. Under this procedure, the waste leachate must contain less than 0.2 milligrams per liter (mg/L) of mercury in order to pass the test. Learn more about the TCLP. Some manufacturers of fluorescent tubes produce “low-mercury lamps” that they claim pass the TCLP test for mercury.

The amount of mercury in a low-mercury bulb can range from 3.5 to 4 milligrams compared to a standard fluorescent bulb which ranges from 8 to 14 milligrams of mercury. These lamps may be identified by green end caps (often referred to as green-tipped lamps), or green etchings on the lamps.

EPA encourages the recycling of all mercury-containing lamps, regardless of the mercury content. Note that if you do not test your low-mercury lamps and prove them non-hazardous, assume they are hazardous waste and handle them accordingly.

Some states require that all mercury-containing lamps be recycled or managed as a hazardous waste, regardless of the mercury content. For information specific to your state, contact your state environmental regulatory agency.

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When does a mercury-containing lamp become a waste?

A used mercury-containing lamp becomes a waste on the date the generator/handler permanently removes it from its fixture. An unused mercury-containing lamp becomes a waste on the date the handler decides to discard it.

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Do the lamps in tanning beds contain mercury? If so, how are they regulated?

The lamps in tanning beds contain as much or more mercury than standard fluorescent lamps that are managed under the Universal Waste Rule (UWR) or full Subtitle C hazardous waste regulations. For state-specific regulations, generators (i.e., tanning salons) should contact their state or local environmental regulatory agency to obtain current requirements for lamp disposal. Salon owners may also want to check with local or state health departments that often permit and regulate this industry.

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More Information on Who is Subject to Waste Management Requirements

Who is affected by the universal waste regulations?

Commercial and industrial businesses and other entities such as hospitals, schools and universities, and state and local governments that commonly use or manage lamps may be subject to the management requirements for universal waste lamps. These regulated entities may handle hazardous waste lamps as a universal waste and must comply with certain management standards depending upon how they are classified in the universal waste system:

Additional Information:

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What are the waste management requirements for small quantity and large quantity handlers of universal waste lamps? 40 CFR 273.13(d) and 40 CFR 273.33(d)

Small Quantity Handlers

(d) Lamps. A small quantity handler of universal waste must manage lamps in a way that prevents releases of any universal waste or component of a universal waste to the environment, as follows:

(1) A small quantity handler of universal waste must contain any lamp in containers or packages that are structurally sound, adequate to prevent breakage, and compatible with the contents of the lamps. Such containers and packages must remain closed and must lack evidence of leakage, spillage or damage that could cause leakage under reasonably foreseeable conditions.

(2) A small quantity handler of universal waste must immediately clean up and place in a container any lamp that is broken and must place in a container any lamp that shows evidence of breakage, leakage, or damage that could cause the release of mercury or other hazardous constituents to the environment. 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 to the environment under reasonably foreseeable conditions.

[60 FR 25542, May 11, 1995, as amended at 64 FR 36489, July 6, 1999]

Large Quantity Handlers

(d) Lamps. A large quantity handler of universal waste must manage lamps in a way that prevents releases of any universal waste or component of a universal waste to the environment, as follows:

(1) A large quantity handler of universal waste must contain any lamp in containers or packages that are structurally sound, adequate to prevent breakage, and compatible with the contents of the lamps. Such containers and packages must remain closed and must lack evidence of leakage, spillage or damage that could cause leakage under reasonably foreseeable conditions.

(2) A large quantity handler of universal waste must immediately clean up and place in a container any lamp that is broken and must place in a container any lamp that shows evidence of breakage, leakage, or damage that could cause the release of mercury or other hazardous constituents to the environment. 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 to the environment under reasonably foreseeable conditions.

[60 FR 25542, May 11, 1995, as amended at 64 FR 36489, July 6, 1999]

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What reduced requirements are applicable to generators of very few waste lamps?

Conditionally Exempt Small Quantity Generator (CESQG) Requirements

A generator that produces no more than 100 kg [220 lb] of hazardous waste, or no more than 1 kg [2.2 lb] of acutely hazardous waste, per calendar month is a Conditionally Exempt Small Quantity Generator (CESQG). This amount includes all hazardous waste, generated in a calendar month. Under federal regulations, this type of generator is exempt from the majority of hazardous waste regulations. However, CESQGs must ensure that their waste is sent to a permitted hazardous waste management facility, a permitted municipal or industrial solid waste facility, or a recycling facility. Contact your state environmental regulatory agency to see if your local municipal solid waste facility is permitted.

While federal regulations allow some mercury-containing lamps to be landfilled, certain states may prohibit this. Many states apply the CESQG requirement in a more stringent manner than the federal government and in other states the CESQG requirements are not applicable at all. For example, all mercury-containing wastes are banned from landfills in the state of Vermont regardless of whether they are disposed of by CESQGs or households. California enacted a similar ban in February 2006. New Hampshire does not have a CESQG exemption in its hazardous waste regulations. Therefore, you are strongly encouraged to know what is required in your state. For more information specific to your state, please contact your state or local environmental regulatory agency.

Whether your state regulates more stringently or not, all states and EPA encourage the recycling of used mercury-containing lamps.

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What are the labeling/marking requirements for universal waste lamps? 40 CFR 273.14

A small quantity handler of universal waste must label or mark the universal waste to identify the type of universal waste as specified below:

... (e) Each lamp or a container or package in which such lamps are contained must be labeled or marked clearly with one of the following phrases: “Universal Waste –– Lamp(s),” or “Waste Lamp(s),” or “Used Lamp(s).”

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Who can transport universal waste lamps?

Anyone can, if the lamps are whole. Intact mercury-containing lamps that are managed as a universal waste can be shipped by using a common carrier and Standard Bill of Lading in all states. An exception exists in the state of New York which requires that certified haulers must be used for shipments weighing more than 500 pounds. Generators may self-transport their own lamps. Lamp recyclers can provide boxes that are designed to reduce breakage during transport to a recycling facility. Although the Universal Waste Rule eases restrictions on the transportation requirements for universal waste lamps, self-transport of used lamps must still comply with the Department of Transportation requirements. Transportation requirements for universal waste can be found in 40 CFR 273.50.

If the lamps are intentionally crushed, such lamps cannot be shipped as universal waste in many states; therefore, the full hazardous waste transportation requirements may apply, including the hazardous waste manifest and use of a licensed hazardous waste transporter. For specific requirements regarding crushed lamps, you should check with your state environmental agency.

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