Ask HRC: Safe Disposal of Mercury-Containing Light Bulbs

A Healthcare Risk Control (HRC) member recently inquired about policy requirements for the safe disposal of mercury-containing light bulbs. In our response, we note that most hospitals likely qualify as small-quantity handlers of universal waste under U.S. Environmental Protection Agency (EPA) regulations. A small-quantity handler is defined as a universal waste handler who does not accumulate 5,000 kilograms or more of universal waste (batteries, pesticides, mercury-containing equipment, or lamps, calculated collectively) at any time (see the definition at 40 CFR 273.13(d)). EPA specifies that the following procedures for these handlers of lamps containing mercury (more information is available from EPA at http://www.epa.gov/bulbrecycling/faqs.htm#handlers):

A small quantity handler of universal waste must manage lamps in a way that prevents...