Fact Sheets

How to Manage

Used Fluorescent and
High-Intensity-Discharge Lamps
as Universal Wastes

View Brochure: Facts on Compact Fluorescent Lamps & Proper Disposal

This fact sheet is for general information only. It is not intended to replace, interpret or modify the regulations for managing hazardous fluorescent and high-intensity-discharge (HID) lamp wastes in Illinois.

Why is proper disposal of used fluorescent lamps important?

Improper disposal of used fluorescent and high density discharge lamps damages the environment. Fluorescent lamps illuminate countless businesses, stores, schools and homes. HID lamps (mercury-vapor, metal-halide and high-pressure sodium) are used for street lights, floodlights and industrial lighting. Unfortunately, most of these lamps have been improperly collected as municipal waste and dumped in ordinary sanitary landfills. When broken, these lamps release mercury and other metals that damage the environment.

Used fluorescent and HID lamps may be classified as hazardous waste due to their mercury content and are thus regulated under the Resource Conservation and Recovery Act (RCRA). These regulations provide for management of hazardous wastes. In Illinois, the newly amended Universal Waste Rule encourages recycling or proper disposal of waste lamps. The Illinois Pollution Control Board amended the Illinois Universal Waste Rule (on April 2, 1998) to cover lamps that meet the definition of hazardous waste. Wastes in this special category of hazardous waste are called "universal" because they are broadly generated. Pesticides, thermostats and batteries also can be classified as universal wastes.

The Illinois Universal Waste Rule encourages hazardous waste lamps to be properly collected, and subsequently recycled or disposed of.

What are my options for managing hazardous lamps?

In Illinois, you may follow the Universal Waste Rule described in this fact sheet (and in state regulations) or you may follow RCRA requirements for hazardous-waste handling, storage, treatment and disposal. You must choose one of these options.

How can I be sure my waste lamps are hazardous?

In order to manage these lamps properly, you may:

How does the Illinois Universal Waste Rule help me?

Managing waste lamps under the streamlined requirements of the Illinois Universal Waste Rule:

What conditions make me a universal waste handler?

If you generate universal waste or receive it for consolidation, you are a universal waste handler. If you treat, dispose, recycle or transport such wastes, you are not a universal waste handler.

Handlers who transport waste lamps are subject to all regulations affecting transporters. (Transport means moving wastes off-site.)

How do I tell if I'm a small- or a large-quantity handler?

Accumulating less than 11,000 pounds of universal waste at a time makes you a small-quantity handler; more than 11,000 pounds makes you a large-quantity handler. (It takes about 17,000 48-inch lamps to equal 11,000 pounds.)

What obligations apply to handlers and transporters?

Handlers and transporters are prohibited from disposing, treating, recycling or diluting waste lamps. Instead they must:

How should waste lamps be labeled?

Individual waste lamps or containers must clearly state one of the following:

How long can handlers accumulate universal wastes?

For up to one year (or longer if they can demonstrate more time is needed to collect quantities necessary for proper recovery, treatment or disposal). Handlers must record on each lamp or lamp container the date lamps became waste.

How should we train workers who handle waste lamps?

In-house training differs between small- and large-quantity handlers:

What shipping papers and records are required?

Large-quantity handlers must record each shipment of universal waste in a log, invoice, manifest, bill of lading or other shipping document, and include:

Records must be kept for at least three years from date of shipment. Small-quantity handlers are not required to keep records.

May I crush my lamps?

Universal waste handlers and transporters may crush waste lamps only to reduce their volume, and only at the site where waste lamps are generated, provided:

Crushing may pose health and environmental risks if mercury vapors are released. Also, lamp recyclers may prefer whole lamps to crushed ones.

How long may transporters store universal waste?

Transporters may store universal waste at a universal-waste transfer facility for no more than 10 days without becoming a universal waste handler subject to additional requirements. Transporters may take universal waste to only a universal waste handler, a universal-waste transfer facility or a universal-waste destination facility.

Do handlers and transporters need permits?

Universal waste handlers or transporters need not obtain hazardous waste management permits, but must manage these wastes in compliance with state regulations.

How should home-owners manage waste lamps?

Mercury-containing lamps discarded by households are not subject to hazardous waste rules and can be accepted by municipal-waste landfills; however, the Illinois EPA recommends you take these lamps to household-hazardous-waste collection centers. (Call your county recycling coordinator to find the center nearest you.)

What if I have questions not covered by this fact sheet?

For further information regarding the management of universal wastes and other hazardous wastes in Illinois, there are several additional resources available: 

Federal Fact Sheet: Some Used Lamps are Universal Wastes

Federal Final Rule on Hazardous Waste Lamps

Illinois Universal Waste Management Regulations

If you still have questions, please call the Illinois EPA's Bureau of Land Permit Section, at 217-524-3300.

Where can I locate a fluorescent lamp recycler near me?

For information purposes only; inclusion does not constitute endorsement; omission does not constitute disapproval. Compliance status should be verified with the environmental agency of the state where the facility is located.