Management standards

Universal waste lamps must be properly managed at a facility before being sent for recycling. Here’s what you need to do:

• Handle lamps carefully so as not to break them.
• Take the lamps as soon as they are spent to the designated storage area. Don’t store them in multiple locations or leave them, somewhere to be put away at a later time.
• Place the lamps in the designated containers or packages for storage, and keep the container or package closed unless adding or removing lamps.
• Label or mark the packages or containers holding the lamps with any of these words as soon as the first spent lamp is placed in the package or container:
• “Universal Waste–Lamp(s),” or
• “Waste Lamp(s),” or
• “Used Lamp(s).”
• Keep the storage area clean and free of obstacles and debris that could cause you or someone else to trip and break the lamps.
• Don’t store materials and equipment in the storage area that could cause breakage by, for example, falling onto a box of lamps.
• Periodically check the containers or inventory log to make sure the lamps aren’t past the 1-year storage time limit.

Time limit

Universal waste lamps have a storage time limit of 1 year at a facility. The 1-year time period is measured from the time the waste is generated, in other words, from the date a lamp becomes a waste. This requirement can be met by:

• Placing the lamp in a container that is marked or labeled with the earliest date that any universal waste in the container became a waste; or
• Marking or labeling each individual lamp with the date it became a waste; or
• Maintaining an inventory system that identifies the date each lamp became a waste or the earliest date that a lamp in a group of lamps became a waste.

Response to releases

If you break a bulb and a release of universal waste occurs, you should:

• Immediately contain all releases and residues of the lamp in a secure container.
• Report the breakage to your supervisor so that they can determine whether any material resulting from the release is hazardous waste and, if so, how to manage it.