cfl recovering, recycling and disposal - implementation guideline

7/31/2019 CFL recovering, recycling and disposal - Implementation Guideline

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CFL Recovery, Recycling & Disposal

Implementation Guideline


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Separation at Source:Separate CFLs rom normal waste stream

Private Transportation:

Homeowner delivery to collection point

Drop o Centres:Centrally-located CFL collection points

Transport:Bulk transport o CFLs

Storage and Treatment:

Temporary storage and treatment (i required)

Disposal:Disposal at an H:H-permitted landll acility

Recycling:Recovery o components and mercury or re-use

Fund and Administration Oversight:Proposed unction to oversee all aspects o CFL recovery

CFL Waste Management

Implementation Guidelines

Best practice or CFL waste management

Environment considered

Increasing environmental consciousness,

the prominence o climate changeconcerns and energy constraints globally

have prompted an intensied ocus on

energy eciency measures, resulting in a

signicant increase in the usage o CFLs.

Waste handling activities

An overview o best practice to ensure compliance with relevantlegislative requirements or the responsible handling o spent

Compact Fluorescent Lamps (CFLs).

The need or an environmentally acceptable, yet cost eective,

spent Compact Fluorescent Lamp (CFL) management programme

has become one o the environmental priorities in South Arica.

The main objective o this document is to provide practical guidelines

or the best available technologies and practices to all stakeholders

conducting any activities related to both the disposal or recycling o

spent CFLs.


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Roles and Responsibilities

How to use this document

The steps and activities or sae management o CFL waste, rom

separation at source to ultimate disposal at a hazardous landll

site or to a recycling acility, are outlined in the various sectionson the next page. Each section is colour-coded in accordance with

the specic identiying icon, or ease o reading. Within each o the

steps the various stakeholders involved and their responsibilities

are tabulated separately.

As an EXAMPLE, a representative rom a local municipality

interested in initiating retail drop-o centres in the municipal

area would:

STEP 1: Identiy rom the list o icons (reer cover page) the relevant

one or drop-o centres.

STEP 2: The blue-grey colouring o the identied icon

indicates the colour o the section o the document that deals with

drop-o centres.

STEP 3: Locate within the identied section tabulated guidelines

specic to a local municipality.

The short-term interventions include separation at source, drop-o centres, collection, storage and treatment,

then transportation to a hazardous landll or disposal, as an immediate solution. Long-term interventions,

which in time should replace short-term activities, will instead o disposal require the recycling o as

many o the constituent materials o the spent CFLs as possible and setting out the relevant responsibilities.

Each o these steps is set out on the next page, and the key roles and responsibilities o the parties

concerned with the managemento spent CFL waste, are discussed.

Distinct roles and responsibilities arise or all stakeholders conducting any management activities related toboth the disposal o spent CFLs to a hazardous landll (short-term intervention) or to a recycling acility (long-

term intervention).

1


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* Indication o the responsibilities and involvement oreseen or a unding and administration oversight entity Hg = mercury

CFL Waste Management

Minimum

Requirement

No CFLs to general

landll

No mercury released

in transport

No mercury

released in storage

No mercury

released in transportNo mercury released No mercury released

No mercury released

and no contaminated

components

Implementation

Guideline

Sae keeping to

prevent breakage

Suitable container

to prevent breakage

Sae intermediate

storage

Sae bulk

transportation

in suitable containers

Environmentally-

sound practice/

technology

Environmentally-

sound practice

Environmentally-

sound practice/

technology

Roles and

Responsibilities

Consumer/

Householder

Consumer/

Householder

Authorised

drop-o centre

owner/manager

Authorised

transporter

Authorised service

provider

Licensed acility

owner or

manager

Licensed acility

owner or

manager

Relevant

Legislation

Relevant bylaws,

NEMA and Waste Bill

Reer separate

legislative

overview

Reer separate

legislative

overview

Reer separate

legislative overview

Reer separate


Reer separate


Reer separate


Communication

Requirements

Extensive general education and awareness regarding waste and recyc ling. Specic communication support including labeling o packaging and clear signage

o premises. Collaboration and integration with relevant stakeholders are essential.

M&V

RequirementsNone None

Type and volumes

received

Volumes

transportedVolumes treated Volumes landlled Volumes recycled

Not required Not required Required Required Required Required Required

An overview o the chain o activities that orms part o the management o CFL waste, rom point o generation at the household to eventual

disposal or recycling, is summarised at a high level below. Further detail and clarication o concepts are covered in the respective subsections

(reer colour-coded sections) o this guide.


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Keeping CFLs out o the general waste bin3

The outgrowth of conservation,

the inevitable result, is national efficiency.- Gifford Pinchot


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Consumer Responsibilities

Consumer

Objective

Best Practice Additional Inormation

No CFLs are to be disposed o at a landll or general

household waste.

General landll sites are not designed to accommodate the

release o mercury. Mercury needs to be treated (encapsulated

in concrete or similar) to prevent leaching and release into the

environment (e.g. atmosphere or groundwater).

Legislation

Minimum Requirements or Hazardous Waste

Disposal (www.dwa.gov.za/Dir_WQM/docs/Pol_

Hazardous.pd) and any relevant municipal bylaws.

The Minimum Requirements state that hazardous waste must

go to a hazardous landll site. Check with the local municipalitys

department o solid waste management or suitable local

requirements or solutions or hazardous household waste.

What to

do with

your CFLs

Do not throw CFLs away with your domestic waste.

Keep CFLs separate until you can saely take them to

a drop o/collection point.

Ideally CFLs should not be broken and should be placed in their

original packaging or wrapped in a plastic bag.

In the event o breakage, special care must be taken

to clean up and contain mercury powder and

glass shards.

Advice on cleaning up broken fuorescent lamps is reely

available on the Internet and also on Eskoms website at:

http://www.eskomdsm.co.za/?q=CFL_Recovery.

Where to

take your

CFLs

CFLs can be taken to participating retailers and

collection points in your area.

At present Woolworths and Pick n Pay stores oer CFL

collection points. Pick n Pay also accepts household batteries

or disposal and recycling. Check with your local council or

any other options or disposal o household hazardous wastes

such as empty containers or letover thinners, paints, poisons,

batteries, etc.

How to

store your

Spent CFLs should ideally arrive at a drop-o point

unbroken. The lamps should thereore be securely

It is recommended that packaging in which CFLs are bought

is kept and used or this purpose. Alternatively, packaging o

Because CFLs are ragile, and broken glass and the mercury content present a health and saety risk,

recovery rom the waste stream ater disposal is not easible. CFLs should thereore not be thrown into

the regular waste bin, but rather be kept separate and stored saely until an opportunity or disposal isavailable. The success o a CFL recovery initiative is entirely dependent on participation by the householder

or residential consumer. A guideline or sae and eective householder participation is provided here:

Intact CFLs emit no mercury and

pose absolutely no health risk. In

the case o accidental breakage,

the amount o mercury inside

an individual lamp is too small

to cause any health risk, but it is

still good practice to minimise

any unnecessary exposure to

mercury, as well as risk o cutsrom glass ragments. A very

inormative and detai led

discussion on risks o broken

CFLs can be ound at:

www.treehugger.com/

les/2007/05/ask

_treehugger_14.php

Personal health

Separationat source


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Municipal Responsibility5

The recovery o most household hazardous wastes rom the waste stream ater disposal is a challenge and

presents the risk o repeat exposure to any person tasked with extraction o recyclable waste (whether at

a material recovery acility or less ormally rom bins on sidewalks or at a landll). Municipalities should leadthe drive to encourage a culture o separation o waste at the home or ALL wastes or which a recovery

solution is being oered or a market exists. Establishing a habit o waste separation among South Aricans

is essential or any waste minimisation and recycling eorts in uture.

Municipality

Objective


Prevent disposal at the local general

landll acility.

Municipalities should proactively encourage separation at source o allrecyclable and hazardous household wastes including specically CFLs.CFLs must be kept away rom other waste

at point o generation by the homeowner.

Legislation

Municipal unctions are guided by the

Municipal Systems Act, NEMA and the

Minimum Requirements or general landll

and hazardous waste.

Waste separation is an important step in the Government drive or

waste minimisation and key to achieving the waste hierarchy:

Reduce, Re-use, Recycle.

How toimplement

in your

municipal area

Educate and create awareness among the

public regarding the need or waste sepa-

ration and specically the need or separat-

ing CFLs and other hazardous wastes rom

the waste stream.

Have available and provide inormation (e .g. with billing inormation

and/or on enquiry) o local recycling and recovery initiatives suchas paper and glass banks, recycling collection ser vices, eWASTE

collection points or initiatives and particularly participating retailers

that accept CFLs (reer to drop-o centre component

o this guideline).

The City o Cape Town, Cleanest

City in South Arica 2007,

has done extensive work on

waste related education and

awareness eorts (e.g. WasteWise

campaign) that could be o value to

other Municipalities. You may nd

inormation on their website (www.

capetown.gov.za/en/solidwaste)or can direct enquiries to: Solid

Waste Management Department

+27 (0)860 103 089 or email

[email protected]

Relevant contacts

Separationat source


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Industry Responsibility

A communication strategy is part o the requirements o an Industry Waste Management Plan as described

in the Waste Management Bill (pending enactment, expected early 2009). Any Industry Waste Management

plan or fuorescent lamps would rely heavily on participation, and hence the awareness o homeowners.The lighting industry would thereore have an obligation to collaborate with other stakeholders in creating

awareness and educating the public about waste separation.

Se lect industry p layers are

actively addressing lighting waste

internationally and some have

already taken an active lead in

the CFL recovery eorts in South

Arica. You can obtain inormation

rom these suppliers directly or

read more on their websites:

Philips: +27 (0)87 940 4194

or+27 (0)11 471 5065

orwww.philips.com/about/

sustainability/recycling

or reer to page 14 or others.

Industry activity

Separationat source

Industry

Objective


Prevent the disposal o CFLs and other

fuorescent lamps with other households

waste in order to acilitate recovery.

Legislation

Industrys involvement will be most

eectively governed under the pending

Waste Management Bill, a subset o the

National Environmental Management

Act (NEMA).

Although the Extended Producer Responsibility principle is already

entrenched in existing legislation, the enactment o the Waste

Management Bill and a Government request or an Industry

Waste Management Plan will orce active industry involvement

with lighting waste.

What to

do with CFLs

CFL packaging should be labeled

appropriately to educate consumers

regarding mercury content and handling

o CFL waste.

Dierent graphics with supporting text could be used to educate the

consumer about mercury content and requirements or sae disposal

or recycling as appropr iate. Labels should be clearly visible

and understandable.

Call centre details to be provided on

packaging and call centres should be

empowered to deal with enquiries relating

to sae disposal and handling o CFL waste.

A collaborative eort among lighting suppliers can address all these

calls or alternatively existing call centres can be brieed to deal

with these questions.

Labeling should ideally highlight the

opportunity or re-use o packaging material

(assumed optimal ormat to prevent

breakage o lamps).

Consumers should be encouraged to re-use packaging material or sae

storage and transport o spent CFLs.


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Department o Environmental Aairs and Tourism (DEAT) Responsibility7

National Government support or a nationwide CFL recovery mechanism is critical to the success o the

initiative. More generally, the encouragement o separation at source will promote the shit towards more

sustainable waste management strategies and practices, and place emphasis on the reduction, re-use andrecycling o wastes:

Relevant DEAT Directorates and

contacts include, among others:

1. Directorate:

Waste Stream Management,

Ms Dee Fisher

+27 (0)12 310 3527,

[email protected]

2. Directorate:

Waste Policy & Inormation

Management, Mr Obed Baloyi

+27 (0)12 310 3833,

[email protected]

Relevant contacts

Separationat source

DEAT

Objective


To encourage thorough legislation and

regulations and to enorce separation atsource o all recyclable and particularlyhazardous household waste.

Separation at source is an essential component o all recycling initiativesand should be widely encouraged.

Legislation

DEATs involvement is governed by the

national legislative ramework including:

the Constitution, National EnvironmentalManagement Act and Municipal

Systems Act.

Where toenorce

separationat source

Encourage and support the inclusion o the

concept into Municipal Integrated WasteManagement Plans and the development obylaws to enorce separation at sourceby homeowners.

Emphasis should be placed on the importance o appropriate handlingo hazardous household waste among all role players and every entityunder legal obligation to comply.

How tosupport

separationat source

A national education campaign. Generaleducation must be provided to thepublic to improve their knowledge o the

impact o mercury bearing lamps on

the environment. Support should also beprovided to provincial departments and

local municipalities in the orm o inormationsharing, education and empowerment.

Overall education relating to waste , recycling and hazardous household

waste has been identied during public consultation as an imperative

since existing awareness levels are extremely low. Education with regardto the benets o using energy saver lamps should also orm part

o communications.

Communication supportComprehensive and collaborative communication, education andawareness support is required by all stakeholders, including: package labeling; municipal communication

through all available media including billing runs and a national education and awareness campaign.


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Delivery o CFLs at Collection Points


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Muncipal Responsibility

Where separate collection services or household hazardous waste are not provided, collection days or

collection events held regularly at suitable locations have become very popular among local municipalities

internationally. Municipalities have implemented pilot studies or separate sidewalk collection services o

select wastes, including recyclables, across South Arica. The ollowing guideline is thereore aimed at guiding

any municipalities that do get involved in the collection and transport o household hazardous waste,

including CFLs.

The use o mobile units is a

solution employed internationally

which makes use o mobile

containers that collect hazardous

household waste rom residential

areas on a regular basis. Feasible

implementation is dependent on

provision o the service or a

broad range o hazardous waste

types to benet rom economies

o scale and logistical synergies.

Mobile Units

Small scaleTransportation

Municipality

Objective

Best Practice Additional Information

To ensure sae transportation o spent CFLs

to a drop-o centre or mobile unit.

LegislationMinimum Requirements or Hazardous Waste

Disposal, National Transpor tation Act.

Usually applicable to bulk carriers o hazardousmaterials. Sae-keeping o small quantities to prevent

breakage is required.

How totransport

CFLs

A municipality may be involved in the

transportation o spent CFLs by implementing a

contract with a private company. It is essential that

the private company makes use o specifc crates

which prevent the breakage o spent CFLs.

Spent CFLs must be transported in such a manner that

the breakage o CFLs is prevented and that, in the case

o breakage, no mercury leakage emanates rom the

transportation containment.

Vehicles must be roadworthy and appropriate

and in accordance with the National Trafc Act

(GNR. 225) requirements.

The applicable TREM decals must be displayed on

the vehicles and provide correct details.

The driver(s) o the vehicle(s) must be qualifed,

trained and hazardous waste certifed to transport

hazardous goods.

In the event o breakage or spillage, all personnel

must leave the vehicle immediately and contact

the incident team. Personnel must wear

Personal Protective Equipment (PPE) at all times.


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Waste Contractor Responsibility11

Environmental consciousness is intensiying and, particularly among high-income households and in urban

centres, the demand or collection services or recyclable material has resulted in seemingly sustainable

business opportunities. In select instances service providers are extending the collection oering to include

household hazardous wastes such as batteries, etc. The ollowing ramework is thereore aimed at guiding

any private waste/recyclables collection contractors that do get involved in the collection and transport o

household hazardous waste, including CFLs.

No serv ice prov iders are

currently known to provide

collection services or CFLs rom

households, but service providers

that collect rom commercial

properties may be available to

assist at a ee.

The ollowing service providers

are active in the commercial

market:

1. Nova Lighting

2. Lumino

3. Actebis

Reer to Treatment Section o this

guideline or the contact details.

Relevant contacts

PrivateTransportation

Waste Collection Contractor

Objective


To ensure sae transportation o spent CFLs to a drop-

o centre or mobile unit (or other appropriate storageor treatment acility).

Service providers may cut out the collection points andtransport CFLs directly to a storage or treatment acility.

In that case please reer directly to bulk transport and

waste treatment and storage implementation guidelines.

LegislationNational Transportation Act, Minimum Requirement or

Hazardous Waste Disposal.

Usually applicable to bulk carriers o hazardous materials.

Sae keeping o small quantities to prevent breakageis required.

How totransport

CFLs

I a private waste contractor would like to be involvedin the transportation o spent CFLs, it is essential thatspecic crates which prevent the breakage o spent

CFLs be used.

Suitable packaging and containers/crates are particularlyimportant i transported with other wastes that can crush

the CFLs in transit.

Vehicles must be roadworthy and appropriate and inaccordance with the National Trac Act (GNR. 225)requirements.

The applicable TREM decals must be displayed on thevehicles and provide correct details.

The driver(s) o the vehicle(s) must ideally be qualied,

trained and hazardous waste certied to transporthazardous goods.

I very small quantities are transported with other

wastes, it is recommended that the driver is at leasttrained to deal with breakages or spillage o hazardousmaterials including CFLs.

In the event o breakage or spillage, all personnel mustleave the vehicle immediately and contact the incident

team. Personnel must wear Personal ProtectiveEquipment (PPE) at all times.

Ensure ventilation o the area o breakage and ensurea spill kit is available. A single breakage can be cleanedup and addressed as or a private vehicle (reer toconsumer guideline).


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Hosting CFL Collection Points/Drop-o Centres


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Consumer Responsibility13

The sustainability o a collection point network or spent CFLs in South Arica is dependent on the level

o participation by the public. South Aricans are thereore encouraged to make use o the acilities provided

by retailers and any other participants and also to use these acilities responsibly.

The practices described below are thereore aimed at guiding participation by consumers.

The ollowing collection points are

available to consumers wanting

to participate:

1. Pick n Pay stores nationwide.

Contact Pick n Pay or your

closest store on

+27 (0)800 11 22 88

or visit their website:

www.picknpay.co.za

2. Select Woolworths stores

nationwide. Contact

Woolworths or par ticipating

stores on +27 (0)860 100 987

or visit their website:

www.woolworths.co.za

Relevant contacts

Drop-oCentres

Consumer Responsibility

Objective


Saely deposit all ailed CFLs at

participating collection points

or drop-o centres.

LegislationMinimum Requirements orHazardous Waste Disposal,

any relevant municipal bylaws.

How to use

a drop-o

centre

Deliver CFLs intact to

participating collection points

or drop-o centres and

deposit into the dedicated

container provided.

Ideally the spent CFL should arrive unbroken and in its original packaging or

wrapped/sealed in a plastic bag. Deposit CFLs into the collection bin which should

be clearly marked and secure unless specically instructed otherwise at the specic

drop-o centre. Handle spent CFLs careully to prevent breakage. Children should

be kept away rom the collection bins and discouraged to play with or around

these acilities. Replace ailed CFLs with a suitable replacement.

warm white or cool white) or alternatively can

be coloured lighting/glass, such as red or blue.

- The appropriate tting i.e. screw-in or bayonet.

- Whether the lamp should be dimmable

or not and whether it should unction

with a motion sensor (oten required

or external or security applications).

CFL Selection

The choice o a new CFL requires

some consideration:

- Required brightness o the light

(represented by the wattage).

- The desired colouring o the lamp (represented

by the Kelvin value and described as either


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Current legislation requires:

1. Permitting o a collection/

drop-o acility to act

as a temporary waste

storage acility.

2. At least a Basic Assessment

is done towards a ull EIA.

Indications rom DEAT are thatthe Waste Management Act and

related regulations will make

allowance or temporary storage

and recovery activities handling

small quantities o hazardous

waste to be exempted rom the

requirements or a license

(see page 18 or details).

Permissible storage

Drop-oCentres

The responsibilities and requirements relevant to hosting a collection acility or drop-o centre areairly signicant but mainly require sensible caution, similar to that necessary or handling a wide varietyo household hazardous goods (e.g. paint, poisons, batteries, etc.) generally sold by retail and hardwarestores. A detailed guideline is provided below to guide anyone interested in hosting a collection point ordrop-o centre.

Drop-o Centre/Collection Facility Responsibility

Drop-off Centre Facilities

Objective


To host a clearly marked and sae drop-o acility.

To ensure that CFLs are temporarily stored in a mannerthat is not harmul to the individual housholder, the public

or the environment.

To provide a convenient point or the consumer to return theirspent CFLs.

To provide a permanent or temporary point or waste

transporter s to collect spent CFLs enmasse.

It is anticipated that drop-o points will orm part o an

ever expanding network o CFL collection inrastructure.

LegislationMinimum Requirements or Hazardous Waste Disposal new

EIA Regulations.

Reer to the legal overview or specic acts, clauses and

regulations o interest.

What isrequired othe acility?

A suitable container o sucient size that can saely accommo-date the volumes o CFL waste dropped o.

A sucient area o foor space to accommodate the containerand to allow access and ventilation i required.

Typically a minimum o 1m2 space is required.

Drop-o containers should be positioned in a prominent andeasily accessible location that is clearly marked.

Location in a store would ideally be either at the salespoint or new CFLs, at the till or close to the exit as parto a recycling street that also enables consumers toreturn other waste items such as plastic bottles etc.

Additional overfow storage capacity needs to be provided by

drop-o centre hosts or the sae storage o ull containers.

Additional storage is required to accommodate anydelays or the pick-up o the spent CFLs by specialised

treatment, disposal or recycling service providers.

The correct permit/license or exemption rom such a licensemust be obtained where applicable (i.e. where waste volumes

exceed the permissible concentrations and maximumallowed weights).

Whilst there is ongoing engagement with DEAT toresolve possible exemptions, it is suggested that in the

interim, acilities are managed responsibly in accordancewith these guidelines.


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Drop-o Centre/Collection Facility Responsibility15

Hazmat provides a national24-hour spill response service.Hazmat can be contacted incaseo emergency toll ree at:

0800 00 58 17 or or enquiriescontact the head oce at+27 (0)33 386 2264or email: [email protected] visit their website at:

www.24hourspillresponse.co.za.

Relevant contacts

Drop-oCentres

Drop-off Centre Facilities

How to

manage a

drop-o

centre


The collection point should preerably only

accept intact CFLs and no breakage shouldoccur during the drop-o or temporary

storage process.

The public and employees o the collection acility should be educated.

Quantities o CFL waste collected and stored

must be saely manageable at all times.

Regular emptying o containers to avoid overfow and thus breakage

and regular removal rom collection points is strongly recommended.

Collection points must be clearly demarcated

and labelled and containers must be labelled

with clear instructions on the type o

lamps accepted and how the lamps have

to be returned.

Communication, education and awareness creation are critical. Every

opportunity should be used to encourage participation and to remind

the public to drop o unbroken CFLs, preerably in original packaging

or wrapped/sealed in a suitable plastic bag.

The temporary storage area or ull containers

must be sae and easily accessible when lampsare picked-up.

Collection requency must be commensurate

with the volumes o CFL waste actually dropped

o and generated within the retail store.

Collection requency can either be based on an actual needs base

(when bin is ull) or can be at regular intervals throughout the collection

period (e.g. every ortnight).

The drop-o centre/collection acility may not

be let unattended at any time. At least one

employee should be present on site/in-store

and should be identied as the individual

responsible or CFL collection.

Drop-o centres cannot take the ormat o a glass bank let unattended

in a parking area. The delegated responsibility is par ticularly impor tant in

the case o spillage or breakage.

How to

saely

store CFLs

Containers must be inspected regularlyor level and other problems e.g. mercury

contamination rom broken bulbs and their

overall unctionality.


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(Continued rom page 15)

Lighting suppliers that have

demonstrated commitment to

the management o the ull

product lie cycle o CFLs,

locally or globally:

1. Osram: www.osram.co.za

2. Eurolux: +27 (0)21 528 8400

or+27 (0)11 608 2970

www.eurolux.co.za

Permissible storage

Drop-oCentres

The voluntary initiation o CFL collection points by retailers in South Arica is an important step towards a

national CFL recovery network. Maintaining the momentum created by these initiatives should be a priority

or all stakeholders, including the lighting industry.

Operating collection centres will constitute a key component o a unctional Industry Waste Management

Plan and hence would be o particular interest to the lighting industry.

It is not expected that industry players will host their own drop-o points but should any lighting supplier

be interested in hosting such a acility, the guidelines or drop-o acilities (reer to preceding section) will

be relevant. The guideline below is aimed at industry in their role as supporter o drop-o centres.

Industry Responsibility

Industry

Objective


Support the establishment o sae, convenient and

legally compliant drop-o centres that will acilitate the

recovery o CFLs.

Ensure the sustainability o drop-o centre or CFLs.

LegislationMinimum Requirements or Hazardous Waste

Disposal new EIA regulations, Waste Management Bill.

Reer to legal overview or specic acts, clauses and

regulations o interest.

How to

support

drop-o

centres

Assist with creating public awareness in terms o CFL

drop-o centres.


legally compliant drop-o centres that will acilitate

the recovery o CFLs.

Financial, logistical and administrative suppor t are all required

to ensure a sustainable solution.

Encourage the use o drop-o centres.

Several oportunities arise such as linked sales promotions

and discounts on replacement CFLs linked to the return

o ailed lamps.


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Local Muncipality Responsibility17

In the US, local governments havereached out to local retailers to

host collection points. Inormation

and examples o bins, posters and

collection points can be ound on

the websites o:

- IKEA

- Wal-Mart

- Sears Stores

- Ace Hardware

- Home Depot

International experience

Drop-oCentres

Hosting o a drop-o acility or CFLs at council premises would ollow the same guidelines as or other

drop-o acilities (reer to preceding section or drop-o centres). The guideline below is to assist local

municipalities interested in having collection points established in the municipal area.

Local Muncipality

Objective



legally compliant drop-o centres that will acilitate the

recovery o CFLs in municipal areas.

Encourage participation by residents in the

municipal area.

Prevent the disposal o CFLs in general landlls.

LegislationMunicipal Systems Act, Minimum Requirements or

General Landll.

How to

get acilities or

CFL

collection

The municipality may host CFL drop-o acilities at suit-

able municipal premises.

Possible options or collection points include utility oces,

public libraries, community centres or manned reuse

drop-o centres.

Engage local retailers or other suitable acilities to host

CFL drop-o centres.

Hardware stores, lighting suppliers, general retailers,

24-hour convenience stores at petrol stations can all be

considered or participation.

How to

support

drop-o

points

Assist with education and creation o public awareness

regarding the need or and participation in CFL drop-o

centres. Empower interested participants.

Communicate details o participating drop-o acilities

in municipal publications and communications.


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Two onerous legislative

requirements will prohibit the

participation o retailers and

others in establishing a

comprehensive recovery

mechanism or CFLs.

Indications rom DEAT are

that new waste regulations will,in uture, partly address the

temporary storage constraints

but EIA requirements will have

to be aligned to acilitate and

encourage recovery, responsible

handling and recycling o CFLs.

Enabling/Supporting

Legislation

Drop-oCentres

A national recovery network or CFLs via central collection points is a signicant improvement on the status

quo where all CFLs are disposed o at the general landll. A simplied mechanism or possibly exemption

rom EIA requirements and waste acility licensing with consideration o the tools established under

the pending Waste Management Act, is strongly recommended. Support and voluntary involvement by

retailers and other collection points are needed to govern the collection mechanism as a whole.

Department o Environmental Aairs and Tourism (DEAT) Responsibility

DEAT

Objective


To encourage the use o drop-o centres

and to support drop-o centres.

A ormalised and appropriately managed collection mechanism or

CFLs is a signicant improvement on the status quo.

LegislationMinimum Requirements or Hazardous

Waste Disposal, new EIA regulations.

How to

support CFL

collection

Exemption should be considered and

supported or the listed activity as per

regulation 386: The temporary storage

o hazardous waste.

Emphasis should be placed on the importance o appropriate handling

o hazardous household waste among all role players and every

entity under legal obligation to comply. Alignment o EIA and Waste

Management requirements to support CFL recovery is essential.

Request/enorce (as appropriate) the

development o a Lighting Industry Waste

Management Plan.

Whilst relaxation is proposed, alternate mechanisms such as an

Industry WMP is required to ensure that CFL recovery is structured

and responsible through a ormal waste management plan and an

oversight/audit unction.

Communication Support Comprehensive and collaborative communication, education and awarenesssupport is required by all stakeholders, including:

Clear demarcation, signage and branding of collection points. Package labeling. Guidelines for facility

use (pamphlets, posters and signage). Muncipal communication through available media including

billing runs. Education and awareness campaign among Muncipal residents. National education and

awareness campaign.


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Bulk Transportation19


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Waste contractors that are required to collect CFLs rom drop-o centre acilities should take cognisance

o the hazardous nature o CFLs and the requirements or handling and transportation. The need or waste

inormation management and tracking is also introduced at this stage o waste handling. These guidelines

are aimed at assisting with best practice or bulk transport o CFLs.

Relevant contacts

Bulk transportation

No service providers are currentlyknown to provide collection ser-

vices or CFLs rom households,

but service providers that col-

lect rom commercial properties

may be available to assist at a ee.

The ollowing service providers are

active in the commercial market:

1. Nova Lighting

2. Lumino

3. Actebis

Reer to Treatment Section or

contact details.

Waste Contractor Responsibility

Waste Contractor

Objective


To ensure sae transpor tation o spent CFLs to a landll

site or recyc ling acility.

LegislationMinimum Requirements or Hazardous Waste Disposal,

National Transportation Act.

How to

transport

your CFLs

I a private waste contractor would like to be involved in

the transportation o spent CFLs it is essential that specic

crates which prevent the breakage o spent CFLs be used.

Spent CFLs must be transported in such a manner that

the breakage o CFLs is prevented and that in the case

o breakage no mercury leakage emanates rom the

transportation containment.

Vehicles must be roadworthy and appropriate and

in accordance to the National Trac Act


The applicable TREM decals must be displayed on the

vehicles and provide correct details.

The driver(s) o the vehicle(s) must be qualied, trained and

hazardous waste certied to transport hazardous goods.

In the event o breakage or spillage all personnel must

leave the vehicle immediately and contact the incident

team. Personnel must wear Personnel

Protective Equipment (PPE) at all times.

Ensure ventilation o the area o breakage and ensure

a spill kit is available. A single breakage can be cleaned

up and addressed as or a private vehicle (reer to

consumer guideline) Hazmat provides 24-hour spill

response in the case o an accident or serious spill o large

volumes o CFLs. Contact details or Hazmat must be

provided to drivers (reer to page 13 or contact details).


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Should either municipalities or industry be interested in, or be required to, collect CFLs rom drop-o centre acilities, the requirements or

handling and transportation o CFLs as per the guidelines or a Waste Contractor will apply. As or waste contractors, the need or waste

inormation management and tracking is a requirement introduced at this stage o CFL waste handling and should be given due consideration. Itis also possible that municipalities and industry players may be involved in the recruiting o waste contractors or a collection and transportation

service. These guidelines are thereore aimed at assisting with appropriate practice when contracting or bulk transport o CFLs.

21

Municipal or Industry Responsibility

Local Municipality or Industry

ObjectiveBest Practice Additional Inormation

To ensure sae transpor tation o spent CFLs to a landll site or recycling acility.

Legislation

Minimum Requirements or Hazardous Waste Disposal, National

Transportation Act.

What to consider

when contractingor the

transportation

o CFLs

Veriy that the contractor complies with the Best Practices described in the

preceding guideline. This will include having suitable crates which prevent the

breakage o spent CFLs.

Spent CFLs must be transported in such a manner that the breakage

o CFLs is prevented and that in the case o breakage no mercury leaks rom

the transportation containment.

Vehicles are roadworthy and comply with the National Trac Act


Applicable and accurate TREM decals are displayed on the service

providers vehicles.

Conrm that driver(s) o the vehicle(s) are qualied and are certied

to transport hazardous goods.

Check that drivers are trained to deal with emergency situations and

that all personnel handling the hazardous waste wear Personal Protective

Equipment (PPE).

Ensure that the transport contractor captures the waste data and submits

completed records and reports to all relevant entities including yoursel and the


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Federal and state regulations in the USA have relaxed the legal requirements or the

transportation o select hazardous waste types to acilitate collection and recovery to

appropriate recycling or disposal acilities.

DEAT Contact details

Bulk transportation

Directorate: Pollution& Waste Management:

Mr Rantsadi Moatshe

+27 (0)12 310 3648

[email protected]

Directorate: Authorisation

& Waste Disposal Management:Ms Kellelo Ntoampe

+27 (0)12 310 3920

[email protected]

Department o Environmental Aairs and Tourism (DEAT) Responsibility

International example: Universal Waste Regulations

The primary requirement or National Government involvement with transportation is or the relaxation

o the legal requirements or transporting select hazardous waste types so as to acilitate recovery and

responsible handling.

DEAT

Objective


To encourage thorough legislation and regulations.

The separation at source o all recyclable, and particularly

hazardous, household waste.

Separation at source is an essential component o all

recycling initiatives and should be widely encouraged.

Legislation

DEATs involvement is governed by the National

legislative ramework including the Constitution, National

Environmental Management Act and Municipal Systems Act.

Where to

enorce

separation

at source

Encourage and support the inclusion o the concept into

Municipal Integrated Waste Management Plans and the

development o bylaws to enorce separation at source

by homeowners.

Emphasis should be placed on the importance o appropri-

ate handling o hazardous household waste among all role

players and every entity under legal obligation to comply.

How to

support

separation

at source

A national education campaign. General education must

be provided to the public to improve their knowledge o

the impacts o mercury bearing lamps on the environment.

Overall education relating to waste, recycling and

hazardous household waste has been identied during

public consultation as an imperative since existing

awareness levels are extremely low. Education with

regards to the benets o using energy saver lamps should

also orm part o communications.

Support should also be provided to provincial depart-

ments and local municipalities in the orm o

inormation sharing, education and empowerment.

23


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Treatment or Storage Facilities or CFLs23


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It is essential that owners o storage acilities understand the risks associated with storing masses o spent CFLs and understand the saety

requirements. These guidelines are aimed at assisting with best practice.

Storage Facilities

Objective


Ensure that CFLs are temporarily stored in a manner which is not harmul to

the environment or humans.

Legislation Minimum Requirements or Hazardous Waste Disposal, new EIA Regulations.

What is required

or storage o CFLs

Suitable containers o sucient size that can contain intact, ailed CFLs and that

will protect the lamps rom breakage.

Sucient foor space to accommodate bulk storage o CFLs in suitable contain-

ers.

How to support

separation at source

A spillage clean-up kit needs to be at hand in case CFLs are

accidentally broken.

All personnel must be trained to deal with spillages and must be well educated

about the risks associated with the mercury bearing lamps.

Ensure ventilation in the area o breakage and ensure a spill kit is available. In

the case o a major event, it is recommended that Hazmat or a similar service

provider be called in.

Personnel must wear Personal Protective Equipment (PPE) at all times.

Treatment Facility

Objective


Ensure that CFLs are crushed, chemically treated (where required) and sealed

in manner that is not harmul to the environment or mankind.

Crushing and treatment into an inert and sealed ormat is essential except

when transpor ting to a recycling acility. Then pre-treatment should not occur.

LegislationMinimum Requirements or Hazardous Waste Disposal, pending Waste Manage-

ment Act, Environmental Conservation Act and new EIA regulations.

Would have to comply with the comprehensive legal requirements or permit-

ting o storage, treatment and processing o hazardous (CFL) waste acilities.

Storage Facility responsibility

25


27/36

Treatment Facility

How to

treat CFLs?


All CFLs that will be disposed o at a landll must be

pretreated under controlled conditions in line with

legislative requirements (reer above).

To meet all the legislative requirements and best

practice described, the crushing technology would typi-

cally operate in a vacuum or under negative pressure and

must incorporate a comprehensive lter system.

Any mercury vapour emanating rom any treatment

technology must comply with the OHSA minimum

standards.

All waste and recovered material must be contained and

stabilised by adding mercury immobilising chemicals.

Mercury vapour that orms as a result o crushing

mercury-containing CFLs and tubes as well as any

extracted mercury must be contained as part o anycrushing operation.

Personnel must wear Personal Protective Equipment (PPE)

at all times.

All personnel must be appropriately trained to handle CFL

waste and emergency situations.

Spent CFLs must be placed in air-tight drums during

the treatment process and sealed on completion o the

treatment process

Crushing and treatment are primarily done to acilitate economically easible transportation and recycling

or disposal. Crushing o the lamps thereore constitutes an integral part o the treatment activity with

signicant associated risk potential. These guidelines are not intended to prescribe a specic technology, but

are rather aimed at assisting with appropriate practice to minimise the associated risks. There are various

treatment options but it is important that treatment acilities understand the benets and consequences

o their activities and technologies.

Relevant contacts

Treatmentor storage

The ollowing companies are known

to provide treatment services or

mercury bearing lamps:

1. Nova Lighting.

Tel: +27 (0)21 706 4451,

Email: [email protected]

or web: www.nova.co.za

2. Lumino.Tel: +27 (0)861 111 319


or web: www.lumino.co.za

3. Actebis.

Tel: +27 (0)16 423 7802,

Email: [email protected] or

web: www.tubeandglobeguzzler

25

Treatment Facility Responsibility


28/36

Disposal o CFLs as Hazardous Waste

27


29/36

Disposal at landll

Only three landlls are suitablylicensed or the acceptance

o hazardous wastes, such as

mercury, in South Arica. These

are located in the Western Cape,

Eastern Cape and Gauteng

respectively and details can be

obtained rom DEAT (see earlier

contact details) or rom the

Institute o Waste Management(IWMSA).

Tel: +27 (0)11 675 3462/4


Website: www.iwmsa.co.za

Relevant contacts

Landll operators must be aware o the disposal procedures pertaining to the disposal o mercury bearing lamps,

including spent CFLs. The ollowing guidelines are set out as the best practice in terms o CFL disposal.

Landfill Operator

Objective


In the absence o a suitable/viable recycling option, spent

CFLs should be disposed o at a licensed hazardous

landll site.

Waste disposal should remain a last resort in line with

stated Government objectives and waste hierarchy.

Legislation DWAF Minimum Requirements or Hazardous Waste Disposal.

How to

landll

CFLs

Spent CFLs may only be disposed o at a licensed hazardous

landll site.

All CFLs that are disposed o at a hazardous landll site

must be pre-treated as per these guidelines and Minimum

Requirements (reer to earlier component o this document

and separate minimum requirements).

All treatment must be completed priorto arrival at the

landll site.

The containers in which CFLs are treated and transported

to the landll site may not be opened. The containers must

be disposed o as is on site.

Containers should be clearly labeled according to their

contents.

The hazardous landll site where CFLs are disposed o

must be permitted/licensed and operated as per the DWAF

Minimum Requirements or Hazardous Waste.

In accordance with licensing requirements this should

include the ollowing:

- Regular audits o the acilities as per the

Minimum Requirements.

- A measurement and verication system must bein place whereby all CFLs that arrive at the landll site

must be recorded in terms o mass.

Operating plans at such a hazardous landll site must include

a plan or disposing o spent CFLs.

Operation should include encapsulation

in an impermeable substance, such as concrete.

Landll Operator Responsibility27

The re-opening or downstream chemical treatment o CFL waste with mercury immobilising chemicals is strictly

prohibited. Please also note that the transporter o the waste to the landll should be aware o the requirements

or CFLs and should ensure delivery o pre-treated and crushed lamps in sealed containers or encapsulation.

C C


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Recycling o CFL Components including Mercury

R l R b l29


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Recycling

Reclite is in the process oestablishing a mercury recovery

and recycling acility or lamp

components in South Arica. The

acility will accept a wide variety

o mercury lamps or processing.

Reclite can be contacted at:

Tel: +27 (0) 11 764 4855

Cell: +27 (0) 82 492 7356Email: [email protected]

or you can visit their website at:

www.reclite.co.za

Relevant contacts

Various recycling technologies/methodologies currently exist (including treatment options) but it is important

that recycling acilities understand the benets and consequences o the various technologies including among

others the variability o the number o components that can be recovered through the process. O the available

recycling technologies Closed Loop Recycling is currently the only proven technology with exceptional health,saety, environmental and quality perormance. These guidelines are aimed at assisting with appropriate practice

and utilisation o recycling acilities.

Recycler Responsibility

Recycling Facilities

Objective


Recycle CFLs and all the components in an

environmentally riendly manner whilst ensuring theoperation is environmentally and nancially viable.

Current and pending legislation incorporates the

requirement to prove that the resources required or the

recycling process do not exceed the recycling benets.Licensing o a new recycling acility will be subject

to a complete impact assessment with consideration

o the above.

Legislation New EIA Regulations, pending Waste Management Act.Comprehensive licensing requirements will apply

to recycling acilities.

Recycling

o CFLs

CFLs should ideally be received intact or i crushed, ap-

propriately sealed to prevent the release o any mercury

vapour, but should not be pre-treated with any chemicals.

All mercury should be contained and treated

and no mercury emissions should result rom the

recycling activities.

Recycled components should be ree o any

mercury contamination.

Government support/acilitation o a receiving market

or recycled material including recovered mercury and

particularly glass and metals, will be invaluable to promote

CFL recovery and recycling.

F d Ad i i i


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Fund Administration

F d Ad i i R ibili31


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Research ndings have shown that

pending legislation has resulted

in extended delays in activity in

anticipation o the detailed legis-

lated requirements. As a result, the

time required or legislation to be

promulgated becomes a major bar-

rier or implementation. Voluntary

participation is thereore the bestimmediate way orward in spite o

the obvious limitations.

Voluntary participation

The expectation is that a und administration and management entity will be established or appointed to

oversee the implementation, track progress and manage the fow o unding. A comprehensive investigation into

appropriate structures and unctions has identied the ollowing as essential/optimal services to be provided or

the CFL waste stream:

Fund Administrator Responsibility

Fund Administrator and Management

Objective


A management and administration entity to oversee and

manage the implementation o the CFL Recovery

Initiative in accordance with the Minimum Requirements

and Implementation Guidelines.

Administrator should be directly involved in all aspects

o collection, transport, recycling and und management

in an oversight capacity. Provides support to all existing

and interested role players to acilitate participation and

compliance with best practices.

Legislation

Structured as and compliant with all legislation relevant to

a Section 21, non-prot organisation registered as

a Public Benets Organisation (PBO).

Participation by participants o the initiative and industry

shareholders should be on a voluntary basis. Lighting

industry par ticipation may become a requirement in

the case o an Industry Waste Management Plan being

adopted.

Support

unctions to

be provided

Basic acilitation and support.

These unctions should include the ollowing:

- provide a collaboration platorm or CFL manuacturers

and importers.

- drive awareness, education and communication

or the initiative.- acilitate interaction with Government.

Management o unding and fow o unding.

Implement und management activities including und

collection and disbursements or contracting o services

as appropriate. Appointment o an auditing entity or und

management or oversight o und management.

Collection and delivery o CFLs.Appointment and management o all service providers to

collect and deliver CFLs and collation o data.

Recycling/disposal activities.Contracting and management o companies to recycle or

dispose o CFLs and collate data

Fund administration

F d Ad i i t t R ibilit


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Fund Administrator Responsibility

Fund Administrator and Management

Flow ounding


The optimal solution or continuous fow o unding is through a manuacturers/importers levy to the und administrator rom where payments to all collection

entities, transporters, recyclers, etc. are managed.

An initial kickstart or start-up und may be required rom relevant stakeholders

to initiate a recovery programme prior to the establishment o a levy.

The option o an incentive or participation to consumers requires urther

consideration but would orm part o the unctions o this entity.

Participating transporters, storage, treatment, landll and recycling acilities responsibility

Data collection and management is essential to track progress and inorm decision making. For this purpose, all participants would be expected to

maintain data and report regularly to the und administration entity. It is, however, critical that this requirement is not too onerous resulting in reluctance

to participate. The ollowing guideline proposes the minimum data requirements that participants would be required to adhere to.

All Participants

Collection

points


No data logging required.Please do however check that collection services capture the required data

when picking up CFLs rom your premises.

Waste contractor(s)

Required to capture quantities/volumes collected and delivered to any o the

ollowing as applicable:

- Treatment/storage acilities

- Disposal acilities i.e. hazardous landlls

- Recycling acilities

Inormation requirements are as per prescription or all transportation o

hazardous wastes.

Storage, treatment,

disposal or recycling

acilities

All participants are required to capture the ollowing detailed inormation:

1. Volumes, quantities or weights collected, received, treated, recycled

or landfled material.

2. Relevant dates such as collection or delivery.

3. Signature(s) o authorised individual(s) or each acility or vehicle.

4. Conrmation o due process ollowed.

P j t C t t d A k l d t33


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ALL participants in the CFL Recovery Initiative must be acknowledged or their invaluable contribution to the programme and particularly thanked or

the input and eort that resulted in this guideline. Key participants that are specically acknowledged include:

- City o Cape TownBarry Coetzee and Alison Davison

- Department o Environmental Aairs and Development Planning

Eddie Hanekom

- Eskom

Lodine Redelinghuys (Western Cape), Latetia Venter, Robert Henderson and Iris Cloete

- Project team members who may be able to assist with questions:

Zitholele/Golder

Jacqui Hex, Elias Barnard, Jarrod Ball, Leon Bredenhann

Tel: +27 (0)11 254 4901


Envirosense

Susanne Dittke

Tel: +27 (0)21 706 9829


Alakriti Consulting

Mari-Louise van der Walt

Tel: +27 (0)82 574 6054


Project Contacts and Acknowledgements


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CFL Recovery, Recycling & Disposal

Implementation Guideline

cfl recovering, recycling and disposal - implementation guideline

Documents