BONUS Professional Development: Lamp Recycling Logistics

By Daniel Krall
Web exclusive follow up to the story published in the February 2011 issue of Today’s Facility Manager

In the February Professional Development column of Today’s Facility Manager, I explained why recycling spent fluorescent lamps still matters, even in a tough economy like the one we face now. Recycling lamps can mitigate the financial, environmental, and public relations risks of throwing them out, as well as generate additional benefits like green marketing opportunities. This month, I review the lamp recycling options available to facility managers (fms), and provide a snapshot of what lamp recycling often looks like for a small facility of less than 150,000 square feet.

When lamps burn out or are replaced in a lighting system retrofit, fms typically have three options for recycling them: sending them back in mail in boxes or containers; arranging a pickup of intact lamps in bulk quantity; or crushing lamps for storage and eventual pickup. While a bulk lamp pickup or use of a lamp crushing system can be appropriate for some occasions (such as a major lighting retrofit where spent lamps are generated on a large scale over a short period of time), a mail in program is usually more suitable for the day to day lamp recycling needs of a facility under 150,000 square feet.

The manager of a typical small facility confronts several questions when considering lamp recycling: “What is mail in lamp recycling?” “How are my spent lamps regulated?” “If I don’t generate many lamps, am I still required to recycle them?” and “How do I set up a program for my facility?”

Mail in lamp recycling is the procedure of filling purpose made containers with spent fluorescent lamps for shipment via mail to a material recovery facility for processing. It is probably the most common method of recycling lamps and is also known as mail back or prepaid recycling. Although the term “prepaid” is often used interchangeably with “mail in” and “mail back,” it specifically refers to all inclusive recycling programs that bundle prepaid return shipping and waste recycling fees with the box. Prepaid programs may also include features like online certificates of recycling and services that report recycling totals.

Containers vary widely in design, but many use a combination of cardboard to hold the lamps and a plastic liner to contain mercury vapor in the event of breakage. Containers from major mail in recycling providers should meet U.S. Department of Transportation requirements for proper container markings and construction, as well as the Occupational Safety and Health Administration standard for mercury release during storage or shipment of no more than 0.1 milligram of vapor per cubic meter of air.

Mail in lamp recycling programs are widely available, being permitted in District of Columbia and all U.S. states except Maine. However, because of shipping difficulties due to location, many providers do not offer mail in recycling in Alaska or Hawaii.

Spent fluorescent lamps are regulated at both the federal and state level through hazardous and universal waste rules (UWRs). The federal UWRs require commercial generators to recycle spent fluorescent lamps while streamlining the regulations for doing so. Although most states have adopted the UWRs, several states enforce regulations that are more stringent than the federal rules.

In states that do apply the UWRs, facilities generating more than 100 kilograms but less than 5,000 kilograms of universal waste (including lamps, ballasts, batteries, or mercury containing electronic waste) per month are called Small Quantity Generators (SQGs). Facilities under 150,000 square feet typically fall into this category. SQGs are regulated under the federal rules, while generators of more than 5,000 kilograms of universal waste per month may be subject to more stringent disposal requirements.

Facilities that generate less than 100 kilograms of universal waste per month, known as Conditionally Exempt Small Quantity Generators (CESQGs), are subject to less stringent regulations under the UWRs. Because regulations vary extensively from state to state, check with your state environmental regulatory agency to learn how your spent fluorescent lamps are regulated.

While starting a lamp recycling program may not seem worth the effort for a small facility that generates fewer lamps, throwing them out exposes the organization to financial, environmental, and public relations risks. A recycling program can minimize these risks and create benefits like positive market exposure and a safer workplace.

The first step of starting a program is to identify the types and quantities of lamps to recycle. Since facilities of less than 150,000 square feet typically do not generate enough spent lamps to fill a container upon its arrival, one or two containers per lamp type is usually enough to get started. Partially filled containers should be sealed and stored in a secure location to avoid potential breakage and exposure to mercury vapor.

After a container is filled, it is shipped to a recycling center, often using an included prepaid mailing label. Some providers offer programs that automatically send a replacement container to the facility when a full container is shipped. Automatic container replacement saves fms time and money by virtually eliminating the paperwork required to maintain a supply of recycling containers and can help facilities avoid running out of containers and becoming non-compliant with lamp disposal regulations. Alternatively, fms should reorder the needed containers prior to shipping full containers in order to remain regulatory compliant.

The final step of a small facility lamp recycling program is to monitor recycling efforts. Some mail in recycling programs even include access to online tools like recycling reports, container tracking, and certificates of recycling that make it easy for fms to record and analyze facility recycling activity.

Recycling reports often use a graphical interface to display recycling totals in sortable categories like type, amount, and date of lamps recycled. Recycling reports can be used to track facility recycling progress for internal use or to publicize the organization’s environmental efforts to purchasers and customers.

Using a container tracking function, fms can check the status of a specific container or review the various types of lamp containers that are being used at the facility. Container tracking can ensure containers do not get lost and forgotten in a corner of the facility and help fms plan for container reordering.

Official certificates of recycling are issued by the material recovery facility once the recycling of the contents of a lamp container is confirmed and distributed to the facility through the mail in recycling provider. Some mail in programs offer web-based certificates of recycling storage and retrieval that give fms the flexibility to print, e-mail, or fax the certificate whenever proof of regulatory compliance is needed.

While the benefits of starting a lamp recycling program for a facility under 150,000 square feet may not seem immediately obvious, a small facility recycling program is a big step toward minimizing the mercury risk that fluorescent lighting poses to an efficient, safe workplace and a safe environment.

Krall is marketing project coordinator at Air Cycle Corporation, an environmental service and product provider specializing in fluorescent lamp, ballast, battery, and electronic waste recycling. For more information, e-mail or check back at in upcoming months for more lamp recycling articles and resources from Air Cycle.