ALP: As a business owner, what is the proper way to dispose of fluorescent light bulbs that are no longer in use in my buildings?

May 2005

Fluorescent light bulbs are often considered to be a “hazardous waste” under state and federal requirements due to the presence of mercury, a toxic and volatile metal, in the lamp.   Previously, when fluorescent lamps were destined for recycling, they were not considered a waste by Ohio EPA and, therefore, were not subject to regulation under Ohio’s hazardous waste rules.   Ohio EPA now considers such waste lamps to be “spent materials,” which are regulated as a hazardous waste even when recycled, unless they are managed as universal wastes.

This new regulation applies to many businesses that generate waste fluorescent lamps.    Such businesses have the option of handling their lamps as hazardous waste or as universal waste.   Managing hazardous waste lamps under the universal waste rules eases certain requirements imposed on generators of spent lamps and may be advantageous for many businesses.

Generators of fluorescent lamps who want to take advantage of the universal waste rule must comply with several requirements, including proper packaging of used lamps to minimize breakage and labeling used lamps or their containers to identify the contents and the date the lamp became a waste.    Universal waste handlers must ensure delivery of their lamps to a permitted destination facility.  Universal wastes may only be accumulated on-site for one year.  If more than 5,000 kg of universal waste will be accumulated on-site at any one time, Ohio EPA must be notified and a hazardous waste ID number obtained.

Recycling waste fluorescent lamps remains a prudent business practice, as it can minimize long term liability.  However, due to recent regulatory changes in Ohio, additional requirements must be met when disposing or recycling such lamps.  In addition, generators should carefully evaluate any vendors who will manage such lamps, and ensure appropriate contractual and insurance protections are in place.