Minnesota Department of Transportation

511 Travel Info

Regulated Materials

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Used Fluorescent Lamps, High-Intensity Discharge Lamps and Other Mercury-Containing Items

This guidance document is prepared by MnDOT personnel and is intended only for use on MnDOT projects, including partnership projects, and MnDOT Maintenance Operations.

MnDOT has prepared this guidance document to provide its internal procedures and requirements for work performed on MnDOT rights of way, including MnDOT-owned facilities.

This document should not be construed as a full description of all regulations pertaining to the subject matter. Contact the Regulated Materials Unit in the MnDOT Office of Environmental Stewardship for additional information or legal requirements.

Management of Fluorescent, HID Lamps and Other Mercury-Containing Items

The Minnesota Pollution Control Agency regulates materials containing mercury. MnDOT is responsible for proper storage, record keeping and transportation of mercury-containing waste.

Equipment containing mercury includes but is not limited to the following: electrical switches (including silent switches), thermostats, gauges, batteries (may be within smoke detectors and emergency lighting), exit signs, security systems, alarm systems, thermometers, barometers manometers, relays, thermocouples and the following types of lighting: fluorescent, mercury vapor, metal halide, high-pressure sodium, low-pressure sodium, neon and HID (high-intensity discharge) lamps.

Light-emitting diode (LED) lamps have a circuit board and are regulated as electronic waste. Waste electronic guidance.

General Requirements

  • Do not tape fluorescent lamps together.
  • Do not break or crush fluorescent lamps.
  • Consult Guidance Document “Mercury Spills” for mercury spill response procedures.
  • No hazardous waste license or license fees are required.


  • Do not accumulate more than 1,000 mercury containing lamps on site. If so, contact RMU staff for additional requirements and fees.
  • Store used fluorescent lamps and HID lamps in the original box or a box of similar size. To prevent breakage, box spacers may be needed.
  • Store other mercury-containing items in a sturdy cardboard box or plastic pail.
  • Keep box/container in a designated storage location out of outside elements.
  • Label box/container “Used Fluorescent Lamps”, “Used High-Intensity Discharge Lamps”, “Thermometers for Recycling” “Switches for Recycling” or other clear description on the container.
  • Date container when full, container must be shipped off-site within one year of date.
  • If mercury-containing products break, store the broken pieces in a sealed container (5-gallon plastic pail with cover). Label the container with a clear description of the waste such as “Broken Thermometers” or “Broken Fluorescent Lamps”.

Transport and record keeping

  • No reporting requirements to the MPCA are required outside the Metro area. However, records must be kept on quantities generated and shipping papers that document where the waste is recycled.
  • Can transport in MnDOT vehicles.
  • Follow waste handling guidance.