Recycling Spent Bulbs

Q. Thanks for your September 2006 column, “Spent Bulbs as Hazardous Waste.” Because of the column, I had our maintenance manager evaluate how we handle our spent fluorescent bulbs. Needless to say, this issue fell through our regulatory cracks and were tossed into the trash despite that we were already a small quantity hazardous waste generator. Now that we know we have mercury containing fluorescent bulbs, and we want to recycle them, what next? M.N.

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A. In addition to fluorescent lamps, mercury is found is mercury vapor and other high voltage discharge type lamps.
Depending upon where you live, the good old-fashion Yellow Pages is a place to start. In my city, I found a bulb or lamp recycler under “recycling centers.” Of course, you can go onto the web, type in “spent bulb recycling” or “lamp recycling” and you will get numerous hits. Spent bulbs can go directly to a recycler or to a universal waste handler/collection facility which then ships to a recycler.

Next is to decide how to ship the bulbs. Some of our clients store the spent bulbs into the same container from the lighting supplier and then use that package to ship out. Others purchase shipping containers from bulb recyclers. The cost of these containers include, prepaid, shipping back to recycler and recycling costs. Either way, the bulbs are able to be shipped by common carrier since they are not hazardous waste based upon EPA regulations.

In addition, USEPA and the states have several requirements for the storage and labeling of spent bulbs destined for recycling; these are: 

• Designate an area for the accumulation and storage of the spent bulbs; label this area "UNIVERSAL WASTE—LAMPS" or "USED LAMPS FOR RECYCLE"
• Label each container "USED LAMPS FOR RECYCLE" or "USED MERCURY-CONTAINING LAMPS"
• Label each container with the date you start to accumulate spent bulbs in that container
• Store spent bulbs for no more than one year.

Some states have specific language regarding the labeling of storage area and containers, so check with you state’s waste management agency. We have typically found all the information we need through state EPA web sites.

Several months ago, one of our clients, an electroplater and large quantity generator of hazardous waste, was routinely inspected by the state EPA. One of the questions she asked was how they handled their spent fluorescent lamps. She was taken to the labeled storage area with the labeled boxes and told that they were recycled. Satisfied, she asked no more questions regarding this issue.

As you can tell, recycling spent bulbs is fairly easy and keeps toxic mercury out of the human environment.