Hazardous Waste Lamps
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Types of Hazardous Waste Lamps & Light Bulbs
Waste light bulbs and lamps may be hazardous waste because of the materials that they contain. Fluorescent lamps are often hazardous wastes due to their mercury content and LED light bulbs may be hazardous waste due to the lead solder used in their circuit boards.
The following types of waste light bulbs and lamps may be hazardous waste:
- Fluorescent (CFLs, tubes, etc.)*
- LED (bulbs, bars, etc.)
- High-intensity discharge (HID)*
- Mercury vapor*
- High pressure sodium*
- Metal halide*
*Low-mercury lamps that pass the Toxicity Characteristic Leaching Procedure (TCLP) are not as regulated hazardous wastes, but still contain mercury and are subject to the Mercury-Added Consumer Products Law, see the Managing Mercury-Added Consumer Products page for more information.
All of the light bulbs and lamps described above can be managed as universal waste lamps.
Standard mercury-containing lamps that fail TCLP must be managed as a hazardous waste in accordance with New York State Hazardous Waste Regulations or the Universal Waste Rule. See Disposal Options below.
If you're not sure if your lamps are hazardous waste, you may use information from the manufacturer (SDS sheets, Hg marking on the lamp, etc.) or have a laboratory run a TCLP analysis on them to determine their waste status. If you can't find data about your lamps or you don't want to have them analyzed, you can manage the lamps as universal waste or as regular hazardous waste.
How to Manage & Dispose of Your Lamps
Managing Lamps at Home
Households are exempt from the ordinary hazardous waste regulations, so there are no legal requirements for the management of hazardous waste lamps by households. Lamps discarded by households are also exempt from New York State's Mercury-Added Consumer Products Law.
However, there are some best management practices that homeowners can use to protect themselves and those around them from mercury exposures:
- Carefully handle mercury lamps when removing, installing or storing these bulbs to avoid breakage.
- Keep new bulbs in their original packaging until needed. Place used bulbs in rigid containers, like cardboard boxes and store away from areas where the box may be knocked over or crushed.
- Bring bulbs for recycling when you determine that you don't need them anymore; avoid holding on to bulbs longer than necessary to properly dispose of them.
The U.S. Environmental Protection Agency has a webpage with instructions for the general public about cleaning up broken CFLs (link leaves DEC website).
Disposing of Lamps
DEC strongly encourages households to recycle their lamps. Home improvement, retail and hardware stores often collect fluorescent lamps from the public at no charge. It's a good idea to contact these entities about their lamp acceptance policies before you bring them your lamps, to ensure that they take the type of lamps that you have.
Households can also contact their town or county solid waste management authority to determine if there are any household hazardous waste collection facilities or events in their community where hazardous waste lamps are collected or to contact local lamp recyclers to see if they accept lamps from households. For more information about household hazardous waste events call (518) 402-8678.
If there are no viable recycling options available, a household may legally dispose of lamps as normal household trash, if it's allowed by the municipality, the trash collector, and the disposal facility.
Businesses & Institutions
Generators of hazardous waste lamps may choose between handling their lamps under the traditional hazardous waste regulations (aka RCRA regulations) or as universal wastes. Low mercury lamps can also be handled under the universal waste rule to ensure compliance with New York State's Mercury Added Consumer Products Law. Once lamps are declared to be universal wastes, they must continue to be handled as universal wastes. Switching back and forth between the traditional RCRA approach and the Universal Waste Rule to avoid any requirements of your chosen approach is prohibited. For example, both management scenarios include storage time limits, but switching between the different regulations cannot be done to extend storage time.
A helpful guidance manual for small quantity hazardous waste generators, "Hazardous Waste Management Guide for Small Businesses in New York" (966 KB PDF) is available for download.
Traditional Hazardous Waste Regulations
The ordinary hazardous waste regulations require generators of potential hazardous wastes to determine if their wastes are hazardous waste and to manage their hazardous waste in accordance with their hazardous waste generator status (i.e., conditionally exempt small quantity generator, small quantity generator, or large quantity generator). The New York State hazardous waste regulations are found in 6 NYCRR Parts 370 through 374 and 376 (link leaves DEC website).
Universal Waste Rule
This rule is designed to simplify the management of specific hazardous wastes that are commonly generated in relatively small quantities by many entities while encouraging recycling and proper disposal. Although handlers of universal wastes must meet less stringent standards for storing, transporting and collecting wastes, the wastes must be sent for final recycling, treatment or disposal that complies with the full hazardous waste requirements. More information about this rule and be found on DEC's Universal Waste Rule page.
Comparison of Lamp Handling Options
|Lamps Managed as Hazardous Waste
|Lamps Managed as Universal Waste
|Count towards amount of hazardous waste generated
|Do not count toward amount of hazardous waste generated
|Accumulation Time Limits
90 days for LQGs
|Label containers as "Hazardous Waste"
|Label container or each lamp as "Universal Waste Lamp(s)", or "Waste - Lamp(s)" or "Used Lamp(s)"
|Waste Transporter Requirements
|Cannot crush lamps
|Requires a training program; requirements are under 6 NYCRR 373-3.2(g).
|Ensure all employees are thoroughly familiar with proper waste handling and emergency procedures related to lamp handling, relevant to their responsibilities during normal facility operations and emergencies.
|Hazardous Waste Annual Report
|Lamps must be included in annual report, if generator is required to file one.
|Lamps do not need to be included in annual report.
|Hazardous Waste Regulatory Fees & Special Assessments
|Lamps count towards hazardous waste regulatory fees and special assessments.
|Lamps do not count towards hazardous waste regulatory fees and special assessments.
1See Lamp Crushing section below for more information.
Low-mercury lamps that are not hazardous waste do not need to be counted towards generator status and do not need to be reported on your annual hazardous waste report, if you are required to file an annual report. However, under the "Mercury-Added Consumer Products Law," (MACP Law) even low-mercury lamps are subject to certain management standards.
If these non-hazardous low-mercury lamps are commingled with universal waste lamps, all of the lamps are regulated as universal waste. Management of mercury-containing lamps as universal waste meets the requirements of the MACP Law. DEC strongly encourages the recycling of all lamps that contain mercury.
Lamps being managed under the Universal Waste Rule cannot be crushed. If you want to crush your lamps, you need to manage the lamps under the traditional hazardous waste regulations. This will require you to count the weight of the lamps when determining your hazardous waste generator category, and meet applicable generator, transporter and transfer facility standards. Crushing is considered to be a form of hazardous waste treatment, so hazardous waste lamps can only be crushed if the process is exempt from hazardous waste treatment regulations (6 NYCRR 373-1.1(d)(1)) (link leaves DEC website).
Common exemptions that might apply to crushing lamps are: on-site treatment by a conditionally exempt small quantity generator (6 NYCRR 373-1.1(d)(1)(v)); crushing being performed as the first step of a recycling process if the lamps will be directed to a mercury recycler (6 NYCRR 373-1.1(d)(1)(viii)); or treatment in the same tank or container in which the lamps are stored (6 NYCRR 373-1.1(d)(1)(ix)). Generators wishing to use one of the last two of the exemptions listed here should seek specific guidance from the RCRA Compliance and Technical Support Section (see the Additional Assistance section below for contact information). Crushed lamps are usually considered hazardous waste for mercury, and sometimes for lead, and must be handled and disposed of in accordance with normal hazardous waste requirements. Associated mercury filters from the crusher units may also be exempt as a characteristic sludge going for reclamation if the filters are being sent for mercury reclaim (6 NYCRR 371.1 Table 1) (links leave DEC website).
Facilities that use in-house lamp crushers should be aware of possible personnel exposures to mercury vapor when using those units.
Small quantities of incidentally broken lamps may be managed as universal waste. Large quantities of broken lamps or purposefully broken lamps must be managed as hazardous waste. If breakage does occur, follow this procedure:
- Open a window and leave the room for 15 minutes or more to allow mercury vapor to dissipate.
- Carefully scoop up all fragments and powder with stiff paper or cardboard and place them in a rigid container compliant with the universal waste rule, close the container, and seal the seams with duct tape. When cleaning up the bulb, use disposable rubber gloves, if available (i.e., do not use bare hands). Wipe the area clean with damp paper towels and place them in a plastic bag. Do not use a vacuum or broom to clean up the broken bulb on hard surfaces.
- Place all clean-up materials in the sealed plastic bag. Place the first bag in a second sealed plastic bag. Dispose of the clean-up debris (gloves, tape, etc.) as hazardous waste. Wash your hands after cleaning up the bulb.
- If a fluorescent bulb breaks on a rug or carpet: First, remove all materials you can without using a vacuum cleaner, following the steps above. Sticky tape (such as duct tape) can be used to pick up small pieces and powder. If vacuuming is needed after all visible materials are removed, vacuum the area where the bulb was broken, remove the vacuum bag (or empty and wipe the canister). Place all clean-up materials in the sealed plastic bag. Place the first bag in a second sealed plastic bag. Dispose of the clean-up debris (gloves, tape, vacuum bag, etc.) as hazardous waste. Wash your hands after cleaning up the bulb.
You can dispose of hazardous waste lamps generated by your business using one of the recycling options listed below.
Visit DEC's List of Fluorescent Lamp Recyclers page.
Listed recyclers and companies that manage mercury-containing lamps are in no way endorsed by DEC and are only provided as a courtesy for the public.
Search online for "Fluorescent lamp disposal," "Hazardous waste disposal," "Waste disposal," "Waste recycling," etc., along with the name of the city or county you're located in to find vendors servicing your area.
Some electrical distributors/retailers provide waste management services, offering a convenient, one-stop shopping arrangement for lamp purchasing and spent lamp management. Ask your lamp distributor if they provide this service.
Waste lamps managed by a distributor in this manner must be managed as a universal waste. Otherwise, utilizing this service may put you out of compliance. Always ask them to ensure your lamps will be managed under the Universal Waste Rule.
If you require assistance with a particular issue with hazardous lamps or light bulbs from a business or institution, you may contact DEC for technical assistance by phone at (518) 402-8652 or by email at [email protected].
If you require assistance with a particular issue with hazardous lamps or light bulbs from a household, you may contact DEC for technical assistance by phone at (518) 402-8678 or by email at [email protected].
For updated information about mercury and the management of mercury-added consumer products in New York State, visit the Management of Mercury-Added Consumer Products page.