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Properly Managing Fluorescent Bulbs

Does your business or institution use lamps? If so, it’s important that you are aware of Ohio EPA’s requirements related to disposal of lamps. Businesses, schools, retail stores, restaurants, offices and other non-household operations that generate waste lamps are subject to Ohio EPA’s rules. If you are throwing your lamps in the dumpster, you may be illegally disposing of hazardous waste.

The term lamps encompasses all types of common light bulbs and lamps, including:

  • fluorescent;
  • incandescent, high-intensity discharge (HID);
  • high-pressure sodium;
  • metal halide;
  • mercury-vapor;
  • neon; and
  • LED.

Lamps can contain mercury and other heavy metals such as lead, cadmium and barium. If the lamps contain these metals over certain limits in the hazardous waste rules, the lamps, when they are disposed of or recycled, are classified as a hazardous waste. Hazardous waste lamps that are improperly disposed of lead to environmental contamination and pose a threat to public health.

How do you know if waste lamps are hazardous waste?

Before you throw your lamps in the trash, you must evaluate them to determine if they are hazardous. To do this, you can:

  • rely on the analytical data provided by the lamp manufacturer; provided that the lamps were tested for all relevant hazardous waste characteristics and the analytical data is current;
  • have the lamps tested by a lab to determine if the levels of metals are below the regulatory limits found in OAC rule 3745-51-24; or
  • assume that the lamps are hazardous.

How do you manage hazardous waste lamps?

There are two methods for managing your hazardous waste lamps. Ohio EPA recommends that you manage your waste lamps under the Universal Waste Rules (UWR) found in Ohio Administrative Code (OAC) Chapter 3745-273.

The UWR streamlines collection requirements for lamps. Many businesses find managing used lamps under the UWR eliminates many regulatory requirements and is easily implemented as part of their recycling programs. By following the UWR, your business can reduce the financial and regulatory requirements of managing hazardous waste and can help protect the environment. If you do not manage your hazardous waste lamps under the UWR, then you must manage them under Ohio EPA’s hazardous waste rules found in OAC Chapter 3745-52.

What are my requirements for managing hazardous lamps under the UWR?

Managing waste lamps as universal waste requires that you store, label and dispose of them in a specific manner. Most businesses are small quantity handlers of universal waste, accumulating less than 11,000 pounds (5,000 kg or approximately 17,000 four-foot lamps) of universal waste at any time. The UWR requires a small quantity handler to:

  • store the used lamps in a container that minimizes breakage and is designed to contain a potential release (many businesses use the same packaging in which new lamps are shipped from the manufacturer);
  • label the container Universal Waste Lamps, Waste Lamps or Used Lamps;
  • keep the container closed unless adding or removing lamps;
  • inform all employees who handle or have responsibility for managing waste lamps of the proper handling and emergency procedures for spills and cleanup;
  • not store used lamps for more than one year, and
  • send or take your used lamps to another UW handler or permitted destination facility.

Who can I send or take my UW lamps to?

You can only send or take your waste lamps to another UW handler or to a permitted destination facility (if in Ohio). Ohio EPA maintains a list of recyclers on our Fluorescent Lamp website. If you transport your own waste lamps to either another universal waste handler or to a universal waste destination facility you must comply with the universal waste transporter requirements.

May I use a lamp crusher to crush the lamps I generate?

If you manage waste lamps under the UWR you are not allowed to crush them. If you want to crush your own lamps you must either manage them under the hazardous waste rules following the generator requirements in OAC Chapter 3745-52, or evaluate the spent lamps to demonstrate that they are non-hazardous.

Read more about proper management of lamps in Ohio EPA’s Managing Fluorescent Lamps fact sheet. Small businesses can also contact the Office of Compliance Assistance and Pollution Prevention (OCAPP) at (614) 644-3469 or (800) 329-7518 for free help. OCAPP is a non-regulatory office of Ohio EPA with a goal of helping small businesses understand and comply with the environmental requirements.