Portfolio Manager waste
Portfolio Manager tracks 29 waste and material types, including "Lamps/Light Bulbs" and "Batteries", each as recycled or disposed. Amounts are entered by weight.
A facility lamp recycling program needs closed, labeled containers at each site, storage under one year, and records you can roll up. We collect fluorescent, CFL and HID lamps, ballasts and batteries by scheduled pickup or a mail-back box.
Each building that holds spent lamps runs its own one-year clock under 40 CFR 273.15. This illustrative card shows how a portfolio view can keep every clock in sight.
Example layout, not real data. Each site's day count runs from the date on its oldest container against the one-year storage limit in 40 CFR 273.15.
How to read the example: "Ship soon" flags a site past nine months, a threshold you set for yourself. "On the clock" means the oldest container is younger than that. "Record filed" means the last pickup closed with a certificate of recycling and a new container has started.
A site holding less than 5,000 kg of universal waste is a small quantity handler. A busy campus or a long-neglected storage room can cross that line, and the duties change with it. The clock and the count both start at the site.
"A used lamp becomes a waste on the date it is discarded". A lamp pulled from a fixture and set aside for recycling starts its one-year clock that day.
Each site must be able to show how long its lamps have been stored. A date on the container, an inventory system, or a marked storage area can do it.
The federal limit is 5,000 kg held "at any time", counted across lamps, batteries, pesticides, mercury equipment and aerosol cans together. Spent batteries count toward the same total as lamps.
The federal text does not say "per site", but state guidance applies it location by location. New Jersey counts waste "accumulated at the collection site". Florida counts what handlers hold "at their locations at any time".
A site expecting to reach 5,000 kg must notify EPA and get an EPA ID number first. Large quantity handler status then lasts through the end of the calendar year.
Large quantity handlers keep a record of each shipment for three years. A log, invoice, manifest or bill of lading can serve as that record.
Even small handlers must inform employees of "proper handling and emergency procedures". That includes whoever changes lamps on site.
ALMR's message to owners says "regulatory compliance remains the responsibility of the owner of the lamps". Hiring a vendor does not move that duty.
Sources: 40 CFR Part 273, via Cornell LII; New Jersey and Florida state guidance; ALMR. Federal rules shown. States can be stricter. Not legal advice.
Sustainability reporting asks for waste by weight and by asset. A record for every job, filed by site, gives each building the numbers those frameworks ask for.
Portfolio Manager tracks 29 waste and material types, including "Lamps/Light Bulbs" and "Batteries", each as recycled or disposed. Amounts are entered by weight.
One MR prerequisite covers "a minimum of two of the following three waste streams: batteries, mercury-containing lamps, and electronic waste". It is titled Storage and Collection of Recyclables.
MRp1 includes "Establish safe storage areas for batteries and mercury-containing lamps". The same policy prerequisite also lists "Safe disposal of batteries and lamps".
GRESB 2026 collects hazardous and non-hazardous waste by weight, at the asset level. Per-site weights from each job's record support that reporting.
EPA's 10-step lamp program guide includes "Track Documentation: maintain Certificates of Recycling". A certificate of recycling for every job builds that file site by site.
J.J. Keller describes it as the "recycler's certification of, typically, the total weight" received on a date. It is recommended practice, not a federal mandate.
Sources: ENERGY STAR Portfolio Manager waste and materials guidance. LEED v4 prerequisites as summarized by LEEDuser, a secondary source. GRESB 2026 reference material. EPA lamp recycling program guide. J.J. Keller.
The same routine works for two buildings or forty. What changes from site to site is volume, and volume decides pickup or mail-back.
Note each address, its rough lamp count, who changes lamps there, and whether ballasts or batteries come out too.
Closed containers that prevent breakage, labeled "Used Lamp(s)" or "Waste Lamp(s)", dated when the first lamp goes in.
Staff, vendors and tenant contractors follow one rule: whole lamps go to the labeled container.
Busy sites get scheduled pickup on a recurring route. Small ones use a mail-back box. Both feed the same record.
A recycling record for every job, filed by site and by stream, ready for your annual reporting.
In many portfolios, lamps get changed by in-house maintenance, an outside vendor and tenant contractors. Each one can leave spent tubes in a closet, a dumpster or a truck bed, and each one starts a clock.
Write one rule into vendor and tenant contracts: spent lamps go whole to the site's labeled container. Then tell staff the handling and emergency procedures, as 273.16 asks.
Read the compliance guideA building that fills a few dozen tubes a year rarely needs a scheduled pickup. A mail-back box can sit in the storage room until it is full, then ship from the front desk.
The one-year clock still runs. USPS lamp program bulletins say to write the accumulation start date on the box and to ship intact lamps only.
How mail-back boxes workShort answers for running lamps across a portfolio. Rules are federal unless a state is named.
It is a recycling box you fill on site and ship back, with no truck visit. It suits buildings with small, steady volumes. USPS lamp bulletins call for intact lamps only, a start date on the box, and recycling within one year. PCB ballasts stay out of lamp kits.
Federally, businesses typically manage them as universal waste under 40 CFR Part 273. A used lamp becomes waste on the date it is discarded (273.5). From then it needs a closed, labeled container and can be stored no longer than one year. Several states also ban landfilling lamps.
In some states, yes. Six states, California and Minnesota among them, ban landfilling even household lamps. Federally, very small quantity generators may choose to manage lamps under Part 273 (40 CFR 273.8). If those lamps are mixed with regulated universal waste, all of it is regulated.
Start with a site list and rough counts. Set one storage spot per building with closed, labeled, dated containers. Decide who changes lamps and put the rule in vendor contracts. Then choose pickup or mail-back by volume. Our compliance guide covers each federal duty in detail.
Volume decides it. Missouri's state lamp guidance calls the prepaid service used for small shipments significantly more expensive than pallet-load service. Sites that fill pallets usually fit scheduled pickup, and sites with a few boxes a year suit mail-back. See how pricing works for the units used.
Use the record from each job. A certificate of recycling typically states the total weight received on a date. Enter those weights by site in ENERGY STAR Portfolio Manager under "Lamps/Light Bulbs" or "Batteries", as recycled. Summed across sites, they show progress from one year to the next.
Yes. The federal threshold in 40 CFR 273.9 counts all universal waste held at any time. That means lamps, batteries, pesticides, mercury-containing equipment and aerosol cans combined. A site storing batteries next to its lamps adds both together. Our battery recycling page covers packing by chemistry.
The owner, site by site. ALMR's message to owners says "regulatory compliance remains the responsibility of the owner of the lamps". Large quantity handlers must keep shipment records for three years under 40 CFR 273.39. Filing every site the same way keeps any later review simple.
Often enough that no container at any site passes one year in storage, the federal limit in 40 CFR 273.15. Busy sites may need several pickups a year, and quiet ones a single visit. Setting a recurring schedule by site volume keeps every clock inside that window.
Yes. We collect fluorescent, CFL and HID lamps, ballasts and batteries, so one scheduled pickup can clear all three streams from a site. Keep each stream in its own container. We keep pre-1979 and unlabeled ballasts apart from the rest of the load, because they may contain PCBs.
Usually not. Business lamps are typically universal waste, and California, Minnesota, Washington, Maine, Massachusetts and Vermont ban landfilling lamps even from households. Write the rule into tenant and vendor contracts: spent lamps go whole to the site's labeled container. The owner remains responsible, according to ALMR.
Clean it up right away and seal the pieces in their own container. 40 CFR 273.13(d)(2) says to "immediately clean up and place in a container any lamp that is broken". Releases must be contained under 273.17. EPA's own cleanup page is written for homes, so follow your site procedure.
Send a site list with rough counts per building. We reply with a written quote for pickup, mail-back, or a mix of both.