Frequent Questions

Can broken mercury-containing lamps be managed as universal waste pursuant to Part 273?


EPA has not limited the definition of "lamp" in §273.9 to intact lamps only.  Broken lamps may be managed as a universal waste but are typically more expensive to recycle or dispose as compared to intact lamps.  State regulations can be more stringent and may not allow management of broken lamps as universal waste.  

Under the Universal Waste rules of 40 CFR Part 272, universal waste lamps must be stored and packaged in a way that minimizes breakage. The containers or packages must remain closed and lack evidence of leakage, spillage or damage that could cause leakage under reasonably foreseeable conditions (§§273.13(d)(1) and 273.33(d)(1)). Examples of acceptable packaging include evenly spacing the lamps in double or triple-ply cardboard containers with closed lids (64 FR 35479; July 6, 1999). 

If, however, any unintentional breakage does occur, then universal waste handlers must immediately clean up and contain any lamps that are broken or show evidence of breakage, leakage, or damage that could cause the release of mercury or other hazardous constituents into the environment (§§273.13(d)(2) and 273.33(d)(2)). An example of such containment includes placing unintentionally broken lamps in closed wax fiberboard drums (64 FR 35479; July 6, 1999). 

For more information about the regulations, go to:


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