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Proper Management of Bulbs and Batteries for Facilities and Businesses

Spent compact fluorescent light bulbs (CFLs), fluorescent light bulbs, and batteries must be managed in accordance with the District of Columbia regulations.  The information below is not comprehensive; it is presented in plain English and does not include all possible variations. Please see the regulations for full text. 

As a property manager, you may also be generating other waste streams including but not limited to used oil, waste petroleum products, waste paint thinners, waste solvents, and waste pesticides.

To see information for residents, please click here and here.

General Requirements for CFLs, Fluorescent Light Bulbs, and Batteries

1.  You must manage (and dispose of) this type of waste in compliance with the regulations.  You may NOT throw this type of waste in your property’s regular trash.

2.  Your method of management will determine the waste's classification (universal waste vs. hazardous waste).

3.  Each address where universal waste and/or hazardous waste are generated must obtain an EPA ID number from the DDOE Hazardous Waste Branch prior to generating the waste. To apply for an EPA ID number, click here.

Managing CFLs and Fluorescent Light Bulbs as Universal Waste

All intact CFLs and fluorescent light bulbs (or lamps) may be managed as universal waste.

High Intensity Discharge (HID) lamps are also universal waste.  Examples of HID lamps include metal halide, ceramic metal halide, mercury vapor, sodium vapor, neon, and xenon.

Light Emitting Diodes (LEDs) and incandescent lamps are not universal waste and may be placed in the municipal trash.

1.  As soon as the lamps are removed from the fixture, they must be placed in a container.  The container must remain closed except when adding or removing lamps.

2.  The container must be labeled with one of the following text options:

a. Universal Waste – Lamps
b. Waste Lamps
c. Used Lamps

3.  The container can be a cardboard box.  The box that new lamps were purchased in is often suitable, so long as it is not damaged and can still be closed.  Paperboard containers are also available from vendors.

4.  Your facility must be able to demonstrate that the lamps have been onsite for less than one year.  Several options are allowed. The easiest is to mark the date that the first lamp was placed in the container on the container.

Disposal of Universal Waste Lamps

You may ship universal waste lamps in approved containers to an approved disposal or recycling facility or you may arrange to have them picked up from your facility by an authorized transporter and delivered to an approved disposal or recycling facility.

Managing CFLs and Fluorescent Light Bulbs by Drum-Top Crushing:

If you choose to use a drum-top crusher and crush your fluorescent light bulbs, you must assume the contents are hazardous waste until such time as it is proven that the contents are NOT hazardous waste. If you wish to declare the waste non-hazardous, you must test the contents of the drum, and the contents must pass TCLP. Click here for more information on making a waste determination.  Click here for information on the proper management of hazardous waste.

Hazardous waste must be removed by an authorized hauler transporter using a universal hazardous waste manifest and must be transported to an approved disposal or recycling facility.

Managing Batteries:

Common examples of regulated batteries include batteries in most electronic devices, such as computers (towers, laptops, and tablets), cell phones, walkie-talkies, and power tools.  Battery types include lead-acid batteries (from cars, emergency light systems, uninterruptable power supplies, etc.), nickel-cadmium (Ni-Cad), nickel metal hydride (NiMH), lithium, and other rechargeables.

Alkaline batteries are not regulated and can be recycled by some vendors or may be placed in the municipal trash.

Managing batteries as universal waste:

1.  Batteries must be intact and not leaking.  Broken or leaking batteries must be managed as hazardous waste. 

2.  Batteries must be labeled with one of the following text options:

a. Universal Waste – Batteries
b. Waste Batteries
c. Used Batteries

3.  Small batteries may be placed in a container, and either the container or each battery may be labeled.

4. Your facility must be able to demonstrate that the batteries have been onsite for less than one year. The easiest is to mark the date that the battery became a waste on the battery or container.  Other options are allowed; please see the regulatory text here.

Disposal

You may ship universal waste batteries to an approved disposal or recycling facility using approved containers or arrange to have them picked up from your facility by an authorized transporter and delivered to an approved disposal or recycling facility.

or

You may turn in some batteries to a scrap metal dealer or battery distributor. You must keep proof that the battery(ies) was/were returned for a deposit or was/were sold to a scrap metal dealer. 

 

Related Content:

Hazardous Waste Laws and Regulation
Cleaning up Broken Compact Florescent Light Bulbs (CFLs)
Solvents in the Workplace - How to Determine if They are Hazardous Waste
Managing Your Hazardous Waste: A Guide for Small Businesses
US DOT Guidance on Shipping Batteries
Resources for Businesses
Proper Disposal of Pharmaceuticals for Residents Only
Proper Disposal of "Sharps" for Residents Only
Lead-Based Paint Accreditation, Certification and Permitting
Tenant Rights Under the District's Lead Law
Lead Related Regulatory and Legislative Affairs
Taking Care of the Environment Makes Good Business Sense

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