Cleaning & Maintenance Management Online
September 2013 Facility Focus
overhead lighting

Properly Disposing Of Used Lighting

Knowing how to handle the disposal of lighting implements is not only prudent, it’s the law.

September 11, 2013

Property and building managers either contract for or perform maintenance for indoor and outdoor lighting as one of their required duties.

With recent energy efficiency requirements moving everyone to use next-generation lighting — compact and linear fluorescent lamps (LFL/CFL) indoors, as well as high-intensity discharge lamps (HIDs) in outdoor lighting — all locations should have a plan for tracking the end-of-life management of spent lamps.

Every lamp using fluorescent technology requires the inclusion of some level of mercury to function.

Most lamps also have some lead in them from solder used in their construction.

With either mercury or lead, this content requires proper management for any lighting to keep these materials out of the environment.

If it is understood that any broken fluorescent lamp requires special handling in cleanup and disposal, then all lamps — no matter what claims are made about their toxicity characteristics — should be handled in a way ensuring no mercury is released to the environment.

Appropriate management requires collection and transfer to a licensed recycler to complete proper end-of-life recovery, disposal and/or reuse of materials.

In other words, all lamps should be handled as universal waste, not household waste.

In order to comply with your obligations as a building or property manager, state or federal regulations under the Resource Conservation and Recovery Act (RCRA) need to be followed. 

Disposal Needs

The RCRA Universal Waste Rule (UWR) and Subtitle C hazardous waste regulations regulate businesses managing and disposing of fluorescent lamps and other mercury-containing lighting (HIDs, etc.) and devices (i.e. thermostats).

Property managers should store used lamps to minimize any breakage.

Any releases to the environment from broken lamps must be contained immediately and handled properly.

All employees should be trained on proper lamp management — including all emergency procedures in case of breakages or spills.

If you’re thinking of disposing of your lamps as non-hazardous materials as some lighting companies promise, every batch of lamps shipped must be tested to comply with RCRA requirements.

If not tested, you must 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, so check local regulations to avoid problems.

Small Quantity Handlers

According to the U.S. Environmental Protection Agency website regarding 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.

Conditionally Exempt Small Quantity Generator

A generator or location that produces no more than 100 kg (220 pounds) of hazardous waste, or no more than 1 kg (2.2 pounds) of acutely hazardous waste, per calendar month is a Conditionally Exempt Small Quantity Generator (CESQG).

This is inclusive of 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 action.

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 states of Vermont and Minnesota 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 the EPA encourage the proper and complete recycling of used mercury-containing lamps — no landfilling of any materials.

Recycling Levels

The amount of lamps estimated to be returned for proper management hovers around 20-30 percent of all lamps.

While businesses do better than households in this regard, four out of five lamps removed from service in businesses and managed properties are not properly managed.

As lamps cycle from old technologies to more efficient and longer-lived technologies, the amount of resources put into them will increase as well.

These resources will need proper management and should be viewed as finite and in need of proper management.

The days of out of sight — out of mind are no longer.

Managers and professionals need to ensure that all lamps receive proper treatment by having them managed properly through a lighting waste handler to ensure their proper management.


Eric Uram has served as a board member on the Association of Lighting and Mercury Recyclers representing the company MRT Systems AB International as their North American sales and service representative. He serves on the Sierra Club’s National Toxics Committee and is the executive director for SafeMinds, a non-profit dedicated to ending the crisis of preventable neurological impacts and disorders in children.

Storage Standards

  • Used lamps may be stored in drums, boxes or the cartons they originally came in.
  • The packaging must remain closed unless lamps are being added or removed.
  • Used lamps must be clearly labeled as: “Universal Waste Lamps” or “Waste Lamps” or “Used Lamps.”
  • All broken lamps must be stored in a sealed container separate from intact lamps.

Shifting Technology

Fluorescent Powder

While LFL and CFL technology continues to advance; newer, more efficient lighting technologies are under development.

Improvements in current LFL/CFL technology includes improving the fluorescent powders used in lighting.

These increase efficiency and operational characteristics making them more acceptable in all applications.

These powders contain several Rare Earth Elements (REEs).

These REEs have increased in value both strategically — as a need for military applications and in use by our federal government — as well as a resource for other lighting and display applications built by U.S. industry.

Making recycling a common practice helps ensure strategic supplies of these REEs will remain available for new products.

Hg Content

Lamp dosing technologies and methods have greatly improved.

This allows for greater precision in the amounts of mercury introduced into lamps allowing manufacturers to ensure more uniform production and overall characteristics.

Lamp recyclers continue to keep a closed-loop on the mercury needed for lamps produced domestically as well as finding uses for the glass and aluminum from spent lamps.

The emerging market for REEs improves the market for recycling, but this has not yet transferred into profit for recyclers.

As a result, the ability to recycle lamps requires some cost assistance.

At least for the time being, or until a solution is put into place requiring no-fee recycling as we are seeing in some states — including Maine and Washington — building managers should look for recycling options.

Light Emitting Diodes (LEDs)

LEDs hold great promise once a few issues are resolved.

Content issues still indicated some levels of toxic elements in production of LEDs currently found in the marketplace.

Problems associated with the use of lead solder as well as small amounts of some toxic metals internal to the LED are being addressed by the lighting industry.

But, the amounts and types of materials they contain have become more valuable resulting in greater value to consumers and regulators alike for managing them through recycling instead of as waste.