Training Focus — Everybody’s got light bulbs — but what do you do when you’re done with them?

By: Lisa Neuberger

Publication: Environmental Regulatory Alert

Date Posted: 03/20/2019

EPA’s universal waste program is intended to encourage best management practices leading to recycling of common hazardous waste streams such as batteries and certain light bulbs (that EPA refers to as lamps). Because the universal waste regulations, found in 40 CFR Part 273, are less stringent than the hazardous waste regulations, states that run their own solid and hazardous waste programs do not have to adopt them. Your state may have more rigorous requirements in place.

What do you do with your light bulbs when you are done with them?

The universal waste system covers two types of handlers:

  1. Small quantity handlers of universal waste (SQHUWs)
  2. Large quantity handlers of universal waste (LQHUWs)

Small quantity handlers never accumulate more than 5,000 kilograms of universal waste at any one time.

When universal wastes are managed according to the regulations, they may be accumulated for up to one year and may not need a manifest for shipping. Also, universal wastes do not need to be counted when determining your hazardous waste generator category.

Wastes that federal EPA allows you to handle as universal wastes are:

  • Batteries,
  • Pesticides,
  • Mercury-containing equipment, and
  • Lamps.

Note that EPA has proposed to add aerosol cans to the universal waste list.

If you do not manage the wastes listed above as universal wastes, then you must make a waste determination on them and possibly manage them as hazardous wastes.

All universal wastes must be managed in a way that prevents releases to the environment. This means storing batteries so that they will not be damaged or start fires and storing lamps so that they are not broken, releasing mercury into the air.


Universal wastes must be stored in a sturdy, leakproof container that is labeled with the contents.

Batteries should be labeled “Universal Waste – Batteries,” “Used Batteries,” or “Waste Batteries.”

Each lamp or a container or package of lamps must be labeled or marked clearly with one of the following phrases: “Universal Waste-Lamp(s),” or “Waste Lamp(s),” or “Used Lamp(s).” The same goes for pesticides, mercury-containing equipment, and someday soon, aerosol cans.


SQHUWs do not need to track universal waste that is sent offsite, but LQHUWs need to keep a record of each shipment of universal waste. The record does not have to be a hazardous waste manifest; it could also be a log, invoice, bill of lading, movement document, or other shipping document.

About the author
Lisa Neuberger - EH&S Editor

Lisa joined J. J. Keller & Associates, Inc. in 2008. She serves as a resource for customers on environmental, health, and safety topics, and has a passion for the safe management of hazardous waste. She specializes in OSHA’s workplace injury and illness recordkeeping and reporting, flammable liquids, and sanitation standards and in EPA’s solid and hazardous waste regulations.

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