Lights & lamps

Can you manage lamps as universal waste?

You can manage any type of lamp that designates as dangerous waste as universal waste.

Are used lamps dangerous waste?

When determining if used lamps are dangerous waste:

1. Assume that they are.
2. Sample and test to determine if they are, in fact, dangerous waste.
3. Use manufacturer’s information, safety data sheets, and other available information to determine toxicity.

How do you manage lights and lamps as universal waste?

Because glass bulbs can easily break, the Universal Waste Rule (WAC 173-303-573) for lights and lamps requires specific handling.

Store properly

To prevent breakage and release of toxics to the environment:

• Store lamps in structurally sound containers, such as cardboard boxes or fiber drums.
• Keep containers closed when not adding lamps.
• Immediately clean up any broken lamps, and store debris in a closed container.

Label correctly

Clearly label to show the type of waste and accumulation start date. Labels must include:

• The words universal waste lamps (see our universal waste labels for example), waste lamps, or used lamps.
• The accumulation start date (used and unused lamps become waste on the date you decide to discard them).

Track accumulation time

Universal waste has a one-year time limit for on-site accumulation. Use one of the following methods to track accumulation time:

• Mark or label each item or container with the accumulation start date.
• Use an on-site inventory system.
• Use shipping documents or receipts to show it was sent to a facility able to accept universal waste.

Recycle or dispose

All universal waste must go to a destination facility equipped and permitted to handle and recycle universal waste (such as a business that is already managing universal waste, government-sponsored collections, or hazardous waste management firms).

• Do not crush lamps if handling as universal waste.
• Do not treat or dispose of universal waste yourself. Treatment will make universal waste count as dangerous waste treatment
• You may self-transport to other handlers or a destination facility without official documentation of your waste. Remember, you are ultimately responsible for your waste.

Frequently asked questions