Mercury Lamp Waste Management

A common inquiry we receive concerns proper management of spent mercury-containing lightbulbs or “lamps” and how lamp crushers can be used in the waste management process.

Mercury is a hazardous material. All fluorescent lamps and compact fluorescent lamps (CFLs) contain elemental liquid mercury, as do high-intensity discharge (HID) lamps such as mercury vapor, metal halide, and high-pressure sodium lamps. When a lamp is broken, the mercury vaporizes into an invisible, odorless, and tasteless vapor. Inhaling mercury vapor is extremely dangerous to human health. If released to the environment, the mercury can be transformed to methylmercury, which is more toxic than elemental mercury and which bioaccumulates within food chains.

Normal handling of intact lamps presents a very low risk of mercury exposure. Repeated exposure to broken lamps or a one-time exposure to a large number of broken lamps increases the risk. The key is to protect lamps from accidental breakage and properly manage spent lamps.


Since January of 2000, the USEPA has allowed spent mercury lamps to be managed as universal waste. A lamp generator can be a Small Quantity Handler of Universal Waste (SQHUW) or a Large Quantity Handler of Universal Waste (LQHUW) depending on the number of spent lamps accumulated at one time. See for the federal universal waste handler requirements in 40 CFR 273 Subparts B and C. Recycling of mercury lamps is strongly encouraged. If a facility does not choose to manage their mercury lamps as universal waste, they must then be disposed of as a full RCRA hazardous waste.

In addition, some states require broken lamps to be handled according to full RCRA hazardous waste regulations. Be sure to check with your state’s environmental agency for up-to-date waste handling requirements. The National Electrical Manufacturers Association (NEMA) makes available an interactive map with links to state environmental agencies and fact sheets. You can access the map at A USEPA table of links to state universal waste regulations is also available at

Sections 273.16 and 273.36 of the Universal Waste Rule discuss the general employee training requirements for small and large quantity handlers of universal waste. Specifically for mercury lamp management, the Association of Lighting and Mercury Recyclers (ALMR), with support from USEPA, developed an easy-to-use “Training Module (1-hour version) for Generators and Handlers of Fluorescent and Mercury-Containing Lamps (and Ballasts).” The document is available for download at

Lamp Crushers

Crushing is the intentional, controlled breaking of mercury-containing lamps into an appropriate storage container. Crushing itself is not recycling, but it can be part of a facility’s lamp recycling program. Crushing lamps can have several benefits: reduced risk of accidental lamp breakage during packaging and shipping of whole spent lamps; reduced handling time by eliminating the need to package and ship whole lamps; reduced storage space requirements.

A drum-top crusher is a mechanical device that is mounted on the top of a 55-gallon drum. The lamps are fed into the crusher and the crushed components are stored in the drum until ready for pickup for recycling or disposal. A 55-gallon drum typically can hold 1,000 or more crushed 4-foot lamps or the equivalent amount of other lamp types.

The lamp components are not separated during crushing, so the drum will contain mercury, phosphor powder, glass, and metals. The mercury will tend to evaporate, so an activated carbon filter is used to capture mercury vapor before it can be released to the ambient atmosphere. Dust filters and HEPA filters are also used to prevent particulate release.

Proper filter disposal depends on the specific type of crusher you use. The technical specifications for each type of crusher being considered or used should be carefully studied and understood to ensure filters are installed, checked, changed, and disposed of properly.

Monitoring and PPE

Areas in which a lamp crusher is used should be monitored for mercury vapor and mercury-containing particulates. The monitoring can be accomplished using various methods such as wipe sampling and air sampling.

At a minimum, Level D PPE should be used by employees operating the crusher or otherwise working in the immediate area. Higher levels of PPE may be required depending on the specifications of the specific crusher and area monitoring results.


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The 4 Types of Universal Waste

We’ve talked about universal wastes on our blog before but never in much detail. Today, I’m going to break down the four categories to help explain what is included, what is regulated, and where information regarding them can be found in 40 CFR. Before reading on, remember that any state specific regulations may vary and should always be varified with local government. That said, please continue reading for more information about batteries, pesticides, mercury containing equipment, and lamps.

Universal Waste – Batteries 

BatteriesThis includes discarded primary (non-rechargeable) and secondary (rechargeable) batteries that contain elements such as cadmium, lead, or mercury, which would render them RCRA-hazardous.

Examples are nickelcadmium (Ni-Cad), sealed lead-acid, or mercury-oxide batteries. Lead-acid batteries (such as automotive batteries) that are generated, transported, or collected to be reclaimed, or regenerated, but not reclaimed where stored, under provisions of 40 CFR 266, Subpart G, “Spent Lead-Acid Batteries Being Reclaimed,” do not need to be managed as universal waste. However, waste lead-acid batteries not managed, or eligible for management, under 40 CFR 266, Subpart G, are subject to the Universal Waste Rule requirements. Lead-acid batteries that are stored at facilities that reclaim them are subject to RCRA regulation as specified in 40 CFR 266.80(b).

Many commonly generated waste batteries, such as dry cell zinc-carbon and alkaline (“long life”) batteries, typically do not contain appreciable amounts of the hazardous elements of concern, and hence would not be required to be managed as universal waste. However, they may be managed along with universal waste batteries, and this is encouraged in the interest of diverting them from less desirable disposal destinies such as incineration or disposal in solid waste landfills.

Universal Waste – Pesticides

PesticidesSeveral classes of discarded pesticides that would otherwise be regulated as characteristic or listed hazardous waste may be eligible for management under the Universal Waste Rule:

(a) Stocks of unused suspended or canceled pesticides that are subject to a voluntary or mandatory recall under the section 19(b) of the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA), or a voluntary recall by a registrant of a pesticide that is not in compliance with FIFRA;

(b) Stocks of other unused pesticide products that are collected and managed as part of a waste pesticide collection program.

Pesticides not subject to the prescribed recalls may have to be managed as hazardous waste when discarded. Farmers managing and disposing such pesticides in accordance with the hazardous waste exclusion in 40 CFR 262.70, and complying with prescribed disposal instructions, are not subject to the Universal Waste Rule. Recalled or unused pesticides are not considered waste until a decision to discard them has been made. However, they remain subject to the requirements of FIFRA.

Universal Waste – Mercury Containing Equipment

mercury thermometerThis category was added to the Federal Rule at 40 CFR 273 on August 5, 2005.  It includes devices, items, or articles which contain elemental mercury that is integral to their functions and which would otherwise be regulated as a hazardous waste when discarded by virtue of exhibiting the toxicity characteristic (TC) for mercury (hazardous waste code D009).

Some examples of such items include mercury-containing thermostats (formerly a separate universal waste category in the original rule), thermometers, barometers, mercury switches, and certain types of meters, regulators, and gauges, in which elemental mercury is contained in ampules or otherwise enclosed and can be managed intact. This category does not include cathode ray tubes or other types of electronic equipment in which elemental mercury is not integral to function, nor does it include mercury waste that is generated as a byproduct through the process of manufacturing or treatment.

Universal Waste – Lamps

lampsThis category was added to the Federal Rule at 40 CFR 273 on July 6, 1999. The universal waste lamp category is slightly broader than its predecessor in that it includes lamps that are hazardous for any characteristic, not just for mercury. However, fluorescent light bulbs remain the most common item in this category of universal waste. This category does not include associated light fixture components such as ballasts.

Hazardous waste lamps become subject to this rule if they are hazardous waste under 40 CFR 261, and when they are permanently removed from a fixture or determined to be discarded.

A note about crushing: In adopting the Federal category of universal waste lamps, the Indiana rule has added a prohibition against intentionally breaking or crushing waste lamps that are managed under the reduced requirements of the Universal Waste Rule.

This is a consequence of the interpretation that crushing of hazardous waste bulbs is treatment, which is explicitly prohibited under the Universal Waste Rule (40 CFR 273.11(b) and 273.31(b)). The only circumstance where hazardous waste lamps may be crushed is when they are managed as fully regulated hazardous waste (rather than as universal waste) which is treated (i.e., crushed) in tanks or containers by the generator of the waste under the implied generator treatment allowance in 40 CFR 262.34, and in conformance with all applicable hazardous waste management standards. Check with local government to find regulations like this applicable in your state.