The commercial sector is often regulated under different requirements than household/residential generators, depending on the industry within which the business operates. The following are some commodities that the average business generates that need proper disposal or recycling. The US EPA has published a short Guide for Generators of Hazardous Materials, it contains basic information on choosing a responsible recycler to serve your organization’s needs. If your organization is interested in using safer alternative products or ingredients the US EPA also has a Design for the Environment website listing Safer Chemicals and Fragrances that are high-performance and cost-effective.

Fluorescent & Compact fluorescent light bulbs

This information is to help commercial generators of mercury-containing lamps understand the importance of proper disposal of fluorescent and Compact Fluorescent Light Bulbs (CFLs). Over the past decade, state and federal regulations concerning mercury-containing lamp disposal have become increasingly complex, affecting a wide range of US businesses. Concerns over mercury releases to the air and water are driving stricter disposal regulations.  These concerns are also pushing consumers to consider environmentally safer and more energy efficient alternatives such as LED lighting.

Health Impacts
Mercury exposure occurs when a mercury-containing light bulb breaks and mercury is then released into the air in vapor form and then inhaled. Symptoms of mercury exposure include tremors; emotional changes (e.g., mood swings, irritability, nervousness, excessive shyness); insomnia; neuromuscular changes (such as weakness, muscle atrophy, twitching); headaches; disturbances in sensations; changes in nerve responses; performance deficits on tests of cognitive function. At higher exposures there may be kidney effects, respiratory failure and death.

Environmental Impact of Disposal Methods

Recycling has the advantages of:

1) keeping mercury out of the solid waste system where a portion of it could be released to the environment and

2) reusing certain raw materials from mercury-containing lamps, including mercury.

Studies indicate that mercury releases into the air from well-managed lamp recycling equipment and facilities is extremely small, somewhere between 0.2 and 0.4%. However, the cost of recycling is typically less than 1% of the electric savings from the reduced energy use of these lamps compared to non-mercury containing lamp technology. Today, lamp-recycling services are available across the US. A list of permitted local recyclers is available at the State of Hawai‘i Department of Health’s Hazardous Waste Section website – click on the “Haulers & Recyclers List” about one third down the page. A list of recyclers nationwide is available at

Federal Regulations

Under federal regulations, commercial and industrial entities are required to manage mercury-containing light bulbs as a hazardous waste after they burn out. In the federal hazardous waste lamp rule, a lamp, also referred to as a universal waste lamp, is defined as the bulb or tube portion of an electric lighting device. Examples of common universal waste electric lamps include fluorescent, high intensity discharge (HID), neon, mercury vapor, high pressure sodium, and metal halide lamps. Under the federal rules, a used lamp becomes a waste on the day that it is discarded. An unused lamp becomes a waste when the handler decides to discard it. EPA added hazardous waste lamps to the federal list of universal wastes regulated under the Resource Conservation and Recovery Act (RCRA), effective in January 2000 (see 40 CFR 273.13 and 273.33 of the existing universal waste rule that addresses requirements for hazardous waste lamps). The intent is to encourage the recycling of hazardous waste lamps so that fewer spent lamps, and the mercury inside them, end up in landfills. Conditionally exempt small quantity generators who dispose of less than 100 kilograms (220 pounds) of hazardous waste of any kind in a month are not subject to RCRA hazardous waste management standards. They may dispose of spent lamps in municipal solid waste landfills. If you store more than 100 kilograms but less than 5,000 kilograms (11,000 pounds) of universal wastes in a month, you are considered a small quantity handler of universal waste and subject to special handling and labeling requirements. Large quantity handlers of universal wastes who store more than 5,000 kilograms of universal waste are subject to notification requirements in addition to the special handling and labeling requirements. You are allowed to accumulate properly stored fluorescent lamps on-site for up to one year. By the end of this year, you must arrange for transportation to a proper recovery, treatment, or disposal facility. While most states apply these exemptions, a small but growing number of states ban the disposal of almost all mercury-containing lamps in solid waste.

Commercial Disposal Plan

A business waste reduction plan not only has a beneficial environmental effect, it can also be an integral waste management practice that can actually save money. Many large businesses are developing internal “Green Teams” that provides employees, staff, and managers the opportunity to discuss creative solutions that are workable for everyone, including customers. Once a Green Team is coordinated, the team can then assess and evaluate the waste stream. A waste stream evaluation identifies composition, quantity, and percentages of different materials. The more time spent analyzing the waste stream, the more information there is to create a detailed plan to address reduction, reuse and recycling of materials.

Education and training are key components to the success of a plan. The early and continued participation of employees, managers and even customers ensures the development of a solid working plan that can be easily implemented into the daily job duties of everyone involved. Seek out ideas and when possible, provide incentive that will motivate and keep interest.

Once the plan for waste reduction and diversion is completed, implement the initial steps. Once these early tasks have been in practice for a few weeks, a time for open discussion can occur to assess and evaluate what is working well and what needs some adjustment. It is best to take a few easy steps first. Implement tasks that are simple and train everyone in the practice of thinking critically about waste reduction and diversion. In a later phase, more complex tasks can be undertaken. Continually monitor, provide support and request feedback to properly plan and measure success.

State of Hawai‘i Department of Health, Office of Hazard Evaluation & Emergency Response

The mission of the Office of Hazard Evaluation and Emergency Response (HEER) is to protect human health, public welfare, and the environment and provide state leadership, support and partnership in preventing, planning for, responding to, and enforcing environmental laws relating to releases or threats of releases of hazardous substances, pollutants or contaminants. The HEER website contains various fact sheets on proper management techniques for hazardous substances, pollutants or contaminants. The have information on arsenic in Hawaiian Soils, arsenic in canec building materials, an assessment and cleanup of contaminated sites brochure and other information available. For information on Hazardous Substance Releases (a.k.a. “spills”) please visit their Spill Reporting and Emergency Response page for guidelines on reporting releases of hazardous substances and spill mitigation measures, as well as laws and regulations regarding the responsibilities of the owner or operator of a facility. Hazardous Substance Release Notification Guidelines and Notification Form.

Unwanted Pesticide Collection for Farmers, Landscapers & Businesses

Farmers & Businesses may properly dispose of unwanted or unused pesticides and herbicides via the State of Hawai‘i Department of Agriculture (HDOA) Pesticide Disposal Program. Quantities of materials accepted for disposal at no-charge are limited (up to 250 lbs.); for information on upcoming collections please contact the Department of Agriculture Hawai‘i Island Branch at 974-4142. Check the Department of Agriculture’s Pesticide Disposal Program website for more information on upcoming future events and deadlines for pre-registration. For more information on pesticide regulation and safety please contact the Department of Agriculture Hawai‘i Island Branch at 974-4142 or visit their website.


State of Hawai‘i