Mercury-Containing Light Bulb (Lamp) Frequent Questions

Fluorescent light bulbs contain some elemental mercury, like the mercury that is found in an older fever thermometer. The mercury can be in vapor, liquid or solid forms. Mercury is a necessary component to the operation of most energy-efficient lighting. Light bulbs that contain mercury use 75% less energy than regular light bulbs and last up to 10 times longer. Fluorescent light bulbs (including compact fluorescent light bulbs) and high intensity discharge (HID) light bulbs are the two most common types of light bulbs that contain mercury. Fluorescent light bulbs are commonly used for the lighting of schools, office buildings, and businesses.

What are high intensity discharge (HID) light bulbs?

High intensity discharge (HID) light bulbs contain varying amounts of mercury. The amount of mercury can vary depending on the type of HID light bulb. The three most commonly used types of HID light bulbs are mercury vapor, metal halide, and high pressure sodium. HID light bulbs are typically used when high levels of light are required over large areas and when energy efficiency and/or long life are desired. These areas include gymnasiums, large public areas, warehouses, outdoor activity areas, roadways, parking lots, and pathways. HID light bulbs, especially metal halide, are increasingly used in small retail and residential areas.

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What are low-mercury light bulbs?

Linear fluorescent light bulbs that contain 3.5 to 4 milligrams of mercury are referred to by manufacturers as"low-mercury light bulbs." The amount of mercury in these light bulbs is considerably less than the amount of mercury in standard linear fluorescent light bulbs, which typically contain from 8 to 14 milligrams of mercury. Manufacturers have made significant mercury reductions in fluorescent light bulbs since the 1990's and are continuing to make further reductions. Some low-mercury light bulbs can be identified by metal "end caps" (the metal pieces at the end of the linear tube) that are painted green. These are sometimes referred to as "green-tip" bulbs. Low-mercury light bulbs may also identified by green etchings on the lamps. Other linear fluorescent light bulbs may have low mercury content, but this is not indicated on the bulb or packaging. The best way to determine the mercury content of a fluorescent bulb is to contact the bulb manufacturer.

EPA encourages the recycling of mercury-containing light bulbs, regardless of the mercury content. Find out what household hazardous waste collection and recycling programs are available in your area by visiting epa.gov/bulbrecycling or Earth911.org. In addition, some states may require the recycling or management of all mercury-containing light bulbs as a hazardous waste, regardless of the mercury content (i.e., California, Massachusetts and Vermont). For information specific to your state, please contact your state environmental regulatory agency.

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What are compact fluorescent light bulbs (CFLs)?

compact fluorescent light bulbs ( CFLs) are an energy efficient and cost effective lighting alternative to regular incandescent light bulbs. A compact fluorescent light bulb fits in a regular light bulb socket or can be plugged into a small lighting fixture. CFLs are typically used in homes and are increasingly used by businesses. They use 75% less energy than incandescent light bulbs and last up to 10 times longer. Every CFL can keep more than 400 pounds of greenhouse gas emissions out of the atmosphere. Learn more about compact fluorescent light bulbs on Energy Star's Web site. 6 different fluorescent bulbs

CFLs contain an average of 5 milligrams of mercury. However, the amount of mercury can vary depending on the company that makes the light bulb and type of compact fluorescent light bulb.

In most states, households are not required to manage their CFLs as a hazardous waste after they burn out. However, EPA encourages the recycling of all CFLs when they are ready to be discarded. Household hazardous waste collections usually accept these light bulbs. Find out what CFL collection and recycling programs are available in your area by visiting epa.gov/bulbrecycling or Earth911. In addition, some states or localities may require households to recycle their CFLs. For information specific to your state, contact your state or local environmental regulatory agency.

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General

How does a CFL or other fluorescent light bulb work?

A CFL or other fluorescent light bulb is made up of a phosphor-coated glass tube that contains some mercury vapor. When the electric current is switched on, the mercury vapor is energized, causing it to send out ultraviolet (UV) energy. The phosphor coating absorbs the UV energy, which causes the phosphor to fluoresce and send out visible light. Without the mercury vapor to produce UV energy, there would be no light.

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How much mercury is in a CFL or other fluorescent light bulb?

The amount of mercury in a CFL or other fluorescent light bulb typically ranges between 3.5 milligrams to 15 milligrams. The amount of mercury varies depending on the type of fluorescent light bulb, the company that makes the light bulb, and when the fluorescent light bulb was made. Although companies have greatly reduced the amount of mercury used in light bulbs over the past 20 years, they are not yet able to completely eliminate the need for mercury. The amount of mercury in a single fluorescent light bulb is small. However, collectively, large numbers of fluorescent light bulbs contribute to the amount of mercury that is released into the environment. EPA encourages the recycling of all mercury-containing light bulbs.

What are the health effects of mercury exposure?

Compact fluorescent light bulbs (CFLs) and other fluorescent light bulbs contain small amounts of mercury. For example, an average CFL contains 5 milligrams or about 1/100th of the amount of mercury found in a mercury fever thermometer. By comparison, older thermometers contain about 500 milligrams of mercury. It would take 100 CFLs to equal that amount.

No mercury is released when the bulbs are intact or in use; exposure is possible only when a bulb has been broken. Learn about how to clean up broken bulbs by visiting EPA's Mercury Web site.

You can view information about the health effects associated with mercury exposure on EPA's Mercury Web site. If you are concerned about your exposure to mercury, you should consult your physician.

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What are the advantages of using a CFL or other fluorescent light bulb?

CFLs or other fluorescent light bulbs are an extremely energy-efficient lighting option. These light bulbs are significantly more energy efficient than incandescent light bulbs because they require less energy to provide the same amount of light. The use of fluorescent light bulbs, rather than incandescent light bulbs, reduces the release of mercury and greenhouse gases from coal-burning power plants. If every home in America replaced just one incandescent light bulb with an ENERGY STAR qualified CFL, it would save enough energy to light more than 3 million homes and prevent greenhouse gas emissions equivalent to those of more than 800,000 cars annually. Also, fluorescent light bulbs are more cost effective because they last up to 10 times longer than incandescent light bulbs. EPA strongly encourages the recycling of all mercury-containing light bulbs after they burn out.

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Are there any mercury-free, energy-efficient alternatives to mercury-containing light bulbs?

Lighting products that use light-emitting diodes (LEDs) are energy-efficient and mercury-free. LEDs are currently used in applications ranging from traffic signals and exit signs, to Christmas tree ornaments and the Times Square New Year's Eve Ball. LED’s are directional lights. They do not radiate light 360 degrees as CFLs and other fluorescent lamps do. Most households use LEDs for task lighting rather than general room lighting. LEDs are more suited to task-specific lighting such as desk lamps, reading lights and nightlights.

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Recycling and Management

Are there regulations that require households to collect and recycle mercury-containing light bulbs?

Under federal regulations, commercial and industrial entities are required to manage mercury-containing light bulbs as a hazardous waste after they burn out. However, households are exempt from these regulations. Some states (i.e., California and Massachusetts) and counties may have more stringent requirements than the federal regulations. In these states, you must either take the fluorescent light bulb to a household hazardous waste collection facility or to a recycling facility. You should be aware of the requirements in your state. For state specific requirements, please contact your state environmental regulatory agency. Whether your state or county has stronger requirements or not, EPA encourages you to recycle all mercury-containing light bulbs.

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What should I do with a CFL or other fluorescent light bulb after it has burned out?

Some states may require households to recycle their mercury-containing light bulbs after they burn out. In addition, EPA strongly encourages the recycling of all CFLs and other fluorescent light bulbs. CFLs or other fluorescent light bulbs that are discarded in the trash will break and some mercury will be released into the environment. Recycling these light bulbs will reduce the chance that mercury ends up in the environment. Household hazardous waste collections usually accept these light bulbs. For information about state-specific requirements, please contact your state or local environmental regulatory agency. Find out what household hazardous waste collection and recycling programs are available in your area by visiting Where You Live or Earth911.org.

If your state or local environmental regulatory agency offers no other disposal options except your household garbage, place the fluorescent light bulb in a plastic bag and seal it before putting it in the trash. If your waste agency incinerates its garbage, you should search a wider geographic area for proper disposal options. Never send a fluorescent light bulb or any other mercury-containing product to an incinerator.

For more information specific to your state, contact your state environmental regulatory agency.

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What should I do if a CFL or other fluorescent light bulb breaks?

View information pertaining to spills, disposal and cleanup on EPA's Mercury Web site.

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Why is it important to recycle CFLs or other fluorescent light bulbs?

CFLs or other fluorescent light bulbs thrown into the trash are usually sent to a landfill or incinerated. These disposal methods will lead to releases of elemental mercury into the environment through breakage and leakage. There is also the potential for exposure to mercury from broken fluorescent light bulbs thrown in a dumpster, trash compactor, or trash can. Approximately 670 million fluorescent light bulbs are discarded each year in the United States. These discarded bulbs can release approximately 2 to 4 tons of mercury per year into the environment. Once in the environment, mercury can be converted to an organic form that accumulates in living organisms and contaminates the food chain. To prevent the release of mercury, the fluorescent light bulbs should be taken to a recycler before they break. Recyclers can recover the mercury and other components for reuse.

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What happens to CFLs or other fluorescent light bulbs when they are recycled?

Virtually all components of a CFL or other fluorescent light bulb can be recycled. The metal end caps, glass tubing, mercury and phosphor powder can all be separated and reused. Recyclers often sell the metallic portions as scrap metal. The recycled glass can be remanufactured into other glass products. The mercury can be recycled into new fluorescent light bulbs and other mercury-containing devices.

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Universal Waste Handlers

Definitions

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 information pertaining to "universal waste" on the Universal Waste Web site:

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What is a mercury-containing lamp?

A mercury-containing lamp is the bulb or tube portion of the lighting device that contains a small amount of elemental mercury. Mercury is a necessary component to the operation of most energy-efficient lighting products. Lamps that contain mercury use 75% less energy than incandescent bulbs and last approximately ten times longer.

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What are compact fluorescent light bulbs?

Compact fluorescent light bulbs (CFLs) are an energy efficient and cost effective lighting alternative to traditional incandescent lamps. A compact fluorescent light bulb fits in a regular lamp socket or can be plugged into a small lighting fixture. CFLs are typically used in homes and are increasingly used by businesses. They utilize 75% less energy than incandescent lamps and last up to 10 times longer. The use of CFLs presents an opportunity to prevent mercury from entering the air, where it most affects our health. The highest source of mercury in the air comes from burning fossil fuels such as coal, the most common fuel used in the U.S. to produce electricity. A power plant will emit 10 milligrams (mg) of mercury to produce the electricity to run an incandescent lamp compared to only 2.4 mg of mercury to run a CFL for the same time. Every CFL can keep more than 400 pounds of greenhouse gas emissions out of the atmosphere. In addition to the environmental benefits of using CFLs, when you replace standard incandescent lamps with high-efficiency compact fluorescent light bulbs, you can reduce your overall home or business energy use and your lighting costs by up to 75%. Learn more about compact fluorescent light bulbs on Energy Star's Web site. 6 different fluorescent bulbs

CFLs contain an average of 5 mg of mercury. However, the amount of mercury can vary depending on the manufacturer and type of compact fluorescent light bulb. As with standard fluorescent lamps, businesses that use CFLs must dispose of them (at the end-of-life) in accordance with federal regulations. Regardless of the amount of mercury, EPA encourages the recycling of all CFLs.

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What are low-mercury lamps?

Some manufacturers of fluorescent tubes produce "low-mercury lamps" that they claim pass the Toxicity Characteristic Leaching Procedure (TCLP) test for mercury. Under federal regulations, the TCLP determines if a lamp is a hazardous waste. 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. 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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What is lamp crushing?

Crushing is the intentional breaking of fluorescent and other mercury lamps for the purpose of volume reduction. Crushing reduces the physical volume of lamps but does not recover any mercury. Crushing is not recycling, but it can be a step in the process when the crushed material is further treated by a recycling process that includes retorting. Generally, hazardous waste lamps should not be landfilled as municipal solid waste. Authorized states have varying regulations regarding the handling, recycling and disposal of mercury-containing lamps. Handlers that choose to intentionally crush lamps must do so in accordance with authorized state programs. For more information specific to your state, contact your state environmental regulatory agency.

It should be noted that lamp crushing can release mercury into the air and pose a health threat to crusher operators and building occupants if the crusher is not operating properly. Lamp crushing can pose a threat if operators do not have the appropriate protective equipment.

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What is drum-top crushing?

Drum-top crushing is done using a mechanical device that fits on top of a 55-gallon collection drum. Whole lamps are broken in the system but components are not separated, and the drum will contain hazardous mercury, phosphor powder, glass and mixed metals. Crushing lamps into drums releases mercury into the filter, which also becomes hazardous. Learn about the results of EPA's 2006 study on the performance of mercury lamp drum-top crusher (DTC) devices.

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General

How does a fluorescent lamp work?

A typical fluorescent lamp is composed of a phosphor-coated glass tube with electrodes located at either end. The tube contains enough mercury to serve as a conductor in a partial vacuum. When a voltage is applied, the electrodes energize the mercury vapor, causing it to emit ultraviolet (UV) energy. The phosphor coating absorbs the UV energy, which causes the phosphor to fluoresce and emit visible light without much heat. Without the mercury vapor to produce UV energy, there would be no light.

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What types of lamps contain mercury?

Fluorescent lamps (including compact fluorescent light bulbs) and high intensity discharge (HID) lamps are the two most common types of mercury-containing lamps. Fluorescent lamps are commonly used for the lighting of schools, office buildings, and businesses. HID lamps include mercury vapor lamps, metal halide, high-pressure sodium lamps and other specialty lamps that are used for streetlights, floodlights, parking lots industrial lighting and some automobile headlights. The Northeast Waste Management Officials Association provides information on how to identify mercury-containing bulbs.

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How much mercury is in a fluorescent lamp?

The amount of mercury in a fluorescent lamp ranges between 3.5 to 15 milligrams, depending on the type of fluorescent lamp, the manufacturer, and when the fluorescent lamp was manufactured. Although lighting manufacturers have greatly reduced the amount of mercury used in lighting over the past 20 years, they are not yet able to completely eliminate the need for mercury. 670 million mercury-containing lamps are sold in the United States each year. Approximately 76% of these lamps are improperly discarded at the end-of-life. Although the amount of mercury in a single fluorescent lamp is small, collectively, large numbers of fluorescent lamps contribute to the amount of mercury that is released into the environment. EPA encourages the recycling of all mercury-containing lamps.

What are the health effects of mercury exposure?

No mercury is released when the bulbs are intact or in use; exposure is possible only when a bulb has been broken. Learn about how to clean up a broken bulb by visiting EPA's Mercury Web site.

You can view information about the health effects associated with mercury exposure on EPA's Mercury Web site. If you are concerned about your exposure to mercury, you should consult your physician.

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What are the advantages of using a fluorescent lamp?

Fluorescent lamps are an energy-efficient lighting option. These lamps are significantly more energy efficient than incandescent lamps because they require less energy to provide the same amount of light. Electrical generation from coal-burning power plants releases mercury and greenhouse gas emissions into the environment. The use of fluorescent lamps, rather than incandescent lamps, reduces the release of mercury and greenhouse gases from these power plants. Also, fluorescent lamps are more cost effective because they last up to 10 times longer than incandescent lamps. EPA strongly encourages the recycling of all mercury-containing lamps at the end-of-life.

Are there any mercury-free, energy-efficient alternatives to mercury-containing lamps?

Lighting products that use light-emitting diodes (LEDs) are energy-efficient and mercury-free. LEDs are currently used in applications ranging from traffic signals and exit signs, to Christmas tree ornaments and the Times Square New Year's Eve Ball. LED’s are directional lights. They do not radiate light 360 degrees as CFLs and other fluorescent lamps do. Therefore, LEDs are more suited to task-specific lighting such as desk lamps, spotlights, security lights, and signage lighting.

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Regulations

How are mercury-containing lamps regulated under federal and state laws?

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, it is necessary to check with state and local governments to learn how the regulations apply to you. See also How are mercury-containing lamps regulated under federal laws? and How are mercury-containing lamps regulated under state laws?

How are mercury-containing lamps regulated under 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. Note that if you do not test your mercury-containing lamps and prove them non-hazardous, 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. 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 (see 40 Code of Federal Regulations (CFR) Part 261.24 . 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.

Managing mercury-containing lamps: Lamps failing the TCLP may be managed under the Resource Conservation and Recovery Act (RCRA) full Subtitle C hazardous waste regulations or under the less stringent Universal Waste Rule (UWR). The UWR was promulgated in 1995 (60 FR 25492) and 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). EPA believes that the reduced regulations for these wastes make it easier to recycle them. Universal waste handlers have reduced requirements in the areas of notification, accumulation limit, storage time, manifest requirements and personnel training. Generators can learn more about the requirements for managing lamps on the Universal Waste Web site.

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.

How are mercury-containing lamps regulated under 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). Learn about state authorization for hazardous waste lamps on the State-by-State Stringency Comparison Table . 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 and businesses in Florida must dispose of less than ten lamps to qualify for the CESQG reduced requirements. 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. EPA encourages you to 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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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:

Small Quantity Handler of Universal Waste
Large Quantity Handler of Universal Waste
Transporter of Universal Waste
Destination Facility

For detailed information on how the regulations apply to these four categories, please review the Universal Waste Generation & Management Comparison Table.

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How are spent fluorescent lamps managed under the universal waste rule?

The Universal Waste Rule provides flexibility in the management of lamps, streamlined requirements for waste handlers, and promotes recycling. Waste handlers managing waste under the Universal Waste Rule have streamlined requirements for:

Obtaining an EPA ID Number;
Labeling containers;
Storing materials on site;
Responding to releases; and
Tracking and transporting waste.

Easing the regulatory burden associated with the management of this waste reduces administrative, shipping, and disposal costs, making it easier to recycle this material.

The Universal Waste Rule provides different requirements for generators depending on the amount of hazardous waste (mercury-containing lamps) generated each calendar month. For example, businesses disposing of less universal waste can follow the more streamlined processes. Businesses with more waste may have to comply with more complex requirements.

The Universal Waste Rule can be found at Title 40, Part 273 of the Code of Federal Regulations. The following is a list of questions that specifically addresses the requirements for management of hazardous waste lamps:

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

(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]

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

(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 and businesses in Florida must dispose of less than 10 lamps to qualify for the CESQG exemption. 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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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 can be 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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Management

Are all mercury-containing lamps a hazardous waste?

Under federal regulations, the vast majority of mercury-containing lamps are considered a hazardous waste. Note that if you do not test your mercury-containing lamps and prove them non-hazardous, assume they are hazardous waste and handle them accordingly. A lamp is considered a hazardous waste if it exhibits the characteristic of hazardous waste toxicity. The test used to determine whether or not a lamp is a hazardous waste is the Toxicity Characteristic Leaching Procedure, TCLP. Under this procedure, the waste leachate must contain less than 0.2 milligrams per liter (mg/L) of mercury in order to the pass the test (see 40 Code of Federal Regulations (CFR) Part 261.24 . Lamps that pass the TCLP are not hazardous and therefore, they are not subject to federal regulations. If the mercury concentration exceeds 0.2 mg/L, the lamp fails the TCLP and is managed as hazardous waste. It should be noted that some states consider all mercury-containing lamps to be hazardous. One example is the state of Vermont. For information specific to your state, contact your state environmental agency. EPA encourages the recycling of all mercury-containing lamps, regardless of the mercury content.

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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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What should I do if a fluorescent lamp breaks?

View information pertaining to spills, disposal and cleanup on EPA's Mercury Web site.

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What is the proper recycling/disposal method for businesses?

Disposal of mercury-containing lamps by businesses is regulated under the Universal Waste Rule (UWR) and full Subtitle C hazardous waste regulations. Most businesses cannot dispose of hazardous mercury-containing lamps in municipal solid waste landfills (some exemptions apply) but the UWR allows for streamlined handling that makes it easier to get lamps to appropriate recycling facilities. The federal UWR imposes minimal requirements (no permitting is needed and no special tracking or reporting is required) when businesses send lamps to recyclers. Note that regulations may vary from state-to-state. For more information specific to your state, contact your state environmental regulatory agency. Any lamp recycler can assist in setting up a program. Learn more about how to establish a recycling program.

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What might happen if accidental breakage occurs?

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.

Learn how to cleanup broken fluorescent bulbs by visiting EPA's Mercury Web site.

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Can anyone transport universal waste lamps?

Yes, 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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Recycling

What types of lamps need to be recycled?

Under federal regulations, if a mercury-contain lamp fails to pass the Toxicity Characteristic Leaching Procedure (TCLP) it is considered hazardous. Learn more about the TCLP. Under federal regulations, the vast majority of mercury-containing lamps are considered a hazardous waste. Note that if you do not test your mercury-containing lamps and prove them non-hazardous, assume they are hazardous waste and handle them accordingly. All mercury-containing lamps, whether hazardous or not, will release mercury into the environment when broken outside of a controlled recycling process. Therefore, EPA encourages the recycling of all mercury-containing lamps. These lamps include all fluorescent lamps and all high intensity discharge lamps (including mercury vapor, metal halide, and high pressure sodium).

State regulations are generally equivalent to or more stringent than federal regulations. Some states that have more stringent regulations are California, Massachusetts and Vermont. For more information specific to your state, contact your state environmental regulatory agency.

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Should I recycle low-mercury ("green end cap") fluorescent lamps?

The amount of mercury in a single “low-mercury lamp” ranges from 3.5 to 4 milligrams. Although the amount from one lamp is small, collectively, large numbers of fluorescent lamps contribute to the amount of mercury that is released into to the environment. Therefore, EPA strongly encourages the recycling of all mercury-containing lamps. Under federal regulations, the Toxicity Characteristic Leaching Procedure (TCLP) determines if a lamp is a hazardous waste. Lamps that pass the TCLP for mercury are not hazardous and therefore, are not subject to federal regulation. Learn more about the TCLP. 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. In addition, some states have regulations that are more stringent than federal regulations and may require the recycling of all fluorescent lamps even if they are not considered to be a hazardous waste. For more information specific to your state, contact your state environmental regulatory agency.

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Why is it important to recycle lamps?

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What happens to the lamps when they are recycled?

Virtually all components of a fluorescent lamp can be recycled. The metal end caps, glass tubing, mercury and phosphor powder can all be separated and reused. Recyclers often sell the metallic portions as scrap metal. The recycled glass can be remanufactured into other glass products. The mercury can be recycled into new fluorescent lamps and other mercury-containing devices.

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What are the basic recycling procedures for businesses?

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:

Used lamps that are accumulated for recycling should be stored in packaging that minimizes lamp breakage. 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. Any broken lamps must be stored separately in a sealed container. Used lamps must be clearly labeled as "Universal Waste Lamps" or "Waste Lamps" or "Used Lamps."
Used lamps should be stored and handled in a way that prevents breakage. Any releases to the environment from broken lamps must be contained immediately and handled properly. Please see "What should I do if a fluorescent lamp breaks?" for suggested procedures.
Businesses are responsible for educating their employees on the proper handling of used mercury-containing lamps and emergency procedures in case of breaks or spills.
Businesses may accumulate and store used lamps for up to one year before sending them to a recycler. The container in which the used lamps are stored should be marked with the earliest date that the lamps were placed into the container. Businesses should check with their state or municipality to see if any other regulations apply.
Shipments must only be sent to other handlers of universal waste or a final destination facility where recycling occurs. Those transporting waste lamps must comply with Department of Transportation regulations in 49 CFR 171-180. Transporters are responsible for containing any releases to the environment.
Neither a business nor transporters may dispose of, dilute (mix with other wastes), or treat mercury-containing lamps. Businesses should check with their state or municipality to see if other regulations apply.

Additional Information:

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Mercury-Containing Light Bulb (Lamp) Frequent Questions

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Universal Waste Handlers

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