Frequent Questions

Can a generator manage green tip fluorescent bulbs as universal waste or are these types of bulbs considered non-hazardous waste?

EPA does not have a separate policy regarding the disposal or recycling of "green tip" lamps. Although these bulbs are not listed hazardous wastes, they are still hazardous waste if they exhibit a characteristic. Under the RCRA regulations, generators must determine whether a waste exhibits a characteristic either by testing the waste or applying knowledge of the hazardous waste characteristic to the waste in lights of materials or the processes used (§262.11). It is the generator’s responsibility to make a hazardous waste determination for all green tip fluorescent bulbs prior to disposing of the bulbs. The green tip fluorescent bulbs typically contain mercury in lower quantities than other fluorescent bulbs. 

Fluorescent bulbs that are determined to be hazardous wastes may take advantage of the alternative, less stringent universal waste regulations found in Part 273. EPA developed the streamlined universal waste regulations to encourage recycling and resource conservation while ensuring adequate protection of human health and the environment (64 FR 36465, 36472; July 6, 1999). Managing non-hazardous fluorescent bulbs as universal wastes is not mandatory; however, EPA encourages recycling of fluorescent lamps whether hazardous or not. 

The hazardous waste lamp rule (64 FR 36466; July 6, 1999) is available at the following URL: 

http://www.epa.gov/epawaste/hazard/wastetypes/universal/laws.htm

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