Determine universal waste lamp handling requirements under 40 CFR Part 273 before demolition removes fixtures

Steps

1. Read 40 CFR Part 273 (Subpart B for small quantity handlers) to confirm that lamps (the bulb/tube portion of lighting fixtures, including mercury-containing types) are one of the five federally designated universal waste categories, alongside batteries, pesticides, mercury-containing equipment, and aerosol cans
2. Before demolition removes lighting fixtures, plan for lamp removal, handling, and storage in containers/packages that minimize breakage and remain closed with no evidence of leakage, spillage, or damage per 273.13
3. Determine handler status (small quantity vs. large quantity handler) based on the accumulated weight of universal waste lamps on-site at any time, since storage/labeling/time-limit obligations scale with handler category
4. Route accumulated universal waste lamps to a permitted universal waste destination facility for recycling or proper disposal rather than mixing them with general C&D debris
5. Check state-level universal waste rules in addition to the federal 40 CFR 273 baseline — many states (including Pennsylvania per state DEP guidance) implement their own fluorescent-lamp recycling program requirements that can be stricter than the federal floor