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How to Establish a Recycling Program for Mercury-Containing Light Bulbs
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.
Step 3: Select a Recycler – Lamprecycle.org 
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.
- Pricing – Pricing represents the recycler’s ability to service you and your customers and meet your needs, while at the same time being price competitive. While pricing is key, as with many things, you usually get what you pay for. It is suggested that you question pricing and get more than one quote for your needs.
- Service – Important items include responsiveness, timeliness, program flexibility and customization, the personnel you will be working with, whether there will be intermediates, the capabilities of the firm and the equipment they will be using.
- Risk Management – Recyclers are obligated to reduce or eliminate pollution risks for their clients. In order to remove the mercury from the waste, recyclers must comply with numerous federal and state regulations. Important factors for evaluating recyclers include:
-
li>whether they meet insurance requirements for general and pollution liability;
- the financial health of the company;
- what indemnities or other assurances they offer clients;
- their environmental record and compliance history;
- the existence of government permits and approvals for facility operation or transportation;
- operations and safety procedures and records;
- vapor control technology and monitoring records;
- hygiene and medical surveillance information;
- the status of a facility closure plan;
- facility audit reports; and
- the availability of key regulatory contacts.
- Contact your lamp distributor to see if they offer a recycling service for their customers. Many distributors now offer this convenient “one-stop shopping” service to their customers. If not, contact a licensed hazardous waste transporter or contract with a company. Make sure the contractor is in compliance with federal and state requirements.
- You can also contract waste lamp management to a cleaning company or electrical contractor, but you must be sure that they are in compliance with federal and state regulations. You will be liable if the subcontractor improperly disposes of your waste lamps.
Recycler Selection Criteria
It is incumbent upon you to select a recycling contractor that will best serve your needs while at the same time give you the assurance that your waste lamps are properly managed to minimize your liabilities. To assist, we have provided some general criteria for selecting your recycler:
These items may seem extensive and your evaluation may seem daunting, but you are entrusting your hazardous waste to a third party and you need assurances. You are encouraged to ask potential recycling contractors about any of these items. It is perfectly acceptable to ask for references or to check with the state agency that regulates recycling facilities for compliance histories.
Alternatives to Recyclers
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.
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.
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.
Step 7: Procedures for Getting Lamps to the Recycler – To recycle lamps there are several options to consider.
- Pick-up Service – The type and frequency of pick-up required is important to determine prior to selecting a recycler. Pick-up options will be determined by the size of the facility and the number of waste lamps generated. The options include:
- Dedicated Pick-up – When a facility generates enough waste lamps to fill a truck it may be cost effective to contract for a dedicated pick-up (either once a month or upon request).
- Mail-In or Box Program – If you generate a small amount of waste lamps, you may choose this option. In this type of program, a recycler can provide a container to fill with used waste lamps. When the container is full, it can be sent to the recycler via a prepaid ground mail shipment program. If you are interested in this option, you should work with your lamp recycler to ensure that proper packaging, labeling and shipping requirements are met.
- Milk-Run – This is the most common type of pick-up. A milk-run is a route in which the recycler schedules a number of pick-ups from you. Milk-run collections are usually run on a set schedule, the frequency of the collection will need to be determined with the recycler at the time of contract negotiations. The number and frequency of waste lamps generated by an individual company will determine the collection frequency.
- Self-Transport – If you generate a small amount of waste lamps or have the capacity to transport the waste lamps or are located in close proximity to the recycler, you may choose to self-transport the waste lamps to the recycler. 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 waste lamps must still comply with Department of Transportation requirements under the Universal Waste Rule. Transportation requirements for universal waste can be found in 40 CFR 273.50.
- Some businesses that generate very small amounts of waste lamps may be able to take the lamps to a locally operated household hazardous waste collection facility in their community. Businesses should check with their local hazardous waste collection facility first to see if this is permissible.
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:
- A small quantity handler of universal waste must inform all employees who handle or have responsibility for managing universal waste. The information must describe proper handling and emergency procedures appropriate to the type(s) of universal waste handled at the facility.
- A large quantity handler of universal waste must ensure that all employees are thoroughly familiar with proper waste handling and emergency procedures, relative to their responsibilities during normal facility operations and emergencies.
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.
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:
- Tubes – 4¢ to 12¢ per linear foot
- High Intensity Discharges – $1.50 - $2.00
- Compact Fluorescent Lamps – 50¢ - $1.00
In addition, there may be a charge for pick-up, transport or mailing. Contact a recycler for pricing.