CFL Recovery, Recycling & Disposal Implementation Guideline

CFL Waste Management

Implementation Guidelines
An overview of best practice to ensure compliance with relevant legislative requirements for the responsible handling of spent Compact Fluorescent Lamps (CFLs).

Waste handling activities

Separation at Source: Separate CFLs from normal waste stream Private Transportation: Homeowner delivery to collection point Drop off Centres: Centrally-located CFL collection points Transport: Bulk transport of CFLs Storage and Treatment: Temporary storage and treatment (if required) Disposal: Disposal at an H:H-permitted landfill facility Recycling: Recovery of components and mercury for re-use Fund and Administration Oversight: Proposed function to oversee all aspects of CFL recovery

Best practice for CFL waste management

The need for an environmentally acceptable, yet cost effective, spent Compact Fluorescent Lamp (CFL) management programme has become one of the environmental priorities in South Africa. The main objective of this document is to provide practical guidelines for the best available technologies and practices to all stakeholders conducting any activities related to both the disposal or recycling of spent CFLs.

Environment considered
Increasing environmental consciousness, the prominence of climate change concerns and energy constraints globally have prompted an intensified focus on energy efficiency measures, resulting in a significant increase in the usage of CFLs.

Roles and Responsibilities

Distinct roles and responsibilities arise for all stakeholders conducting any management activities related to both the disposal of spent CFLs to a hazardous landfill (short-term intervention) or to a recycling facility (longterm intervention). The short-term interventions include separation at source, drop-off centres, collection, storage and treatment, then transportation to a hazardous landfill for disposal, as an immediate solution. Long-term interventions, which in time should replace short-term activities, will instead of disposal require the recycling of as many of the constituent materials of the spent CFLs as possible and setting out the relevant responsibilities. Each of these steps is set out on the next page, and the key roles and responsibilities of the parties concerned with the managementof spent CFL waste, are discussed.

How to use this document

The steps and activities for safe management of CFL waste, from separation at source to ultimate disposal at a hazardous landfill site or to a recycling facility, are outlined in the various sections on the next page. Each section is colour-coded in accordance with the specific identifying icon, for ease of reading. Within each of the steps the various stakeholders involved and their responsibilities are tabulated separately. As an EXAMPLE, a representative from a local municipality interested in initiating retail drop-off centres in the municipal area would: STEP 1: Identify from the list of icons (refer cover page) the relevant one for drop-off centres. STEP 2: The blue-grey colouring of the identified icon indicates the colour of the section of the document that deals with drop-off centres. STEP 3: Locate within the identified section tabulated guidelines specific to a local municipality.

CFL Waste Management

An overview of the chain of activities that forms part of the management of CFL waste, from point of generation at the household to eventual disposal or recycling, is summarised at a high level below. Further detail and clarification of concepts are covered in the respective subsections (refer colour-coded sections) of this guide.

Minimum Requirement Implementation Guideline Roles and Responsibilities Relevant Legislation

No CFLs to general landfill Safe keeping to prevent breakage Consumer/ Householder

No mercury released No mercury in transport released in storage Suitable container to prevent breakage Consumer/ Householder Safe intermediate storage Authorised drop-off centre owner/manager Refer separate legislative overview

No mercury released in transport Safe bulk transportation in suitable containers Authorised transporter Refer separate legislative overview

No mercury released Environmentallysound practice/ technology Authorised service provider Refer separate legislative overview

No mercury released No mercury released and no contaminated components Environmentallysound practice Licensed facility owner or manager Refer separate legislative overview Environmentallysound practice/ technology Licensed facility owner or manager Refer separate legislative overview

Refer separate Relevant bylaws, legislative NEMA and Waste Bill overview

Communication Requirements M&V Requirements

Extensive general education and awareness regarding waste and recycling. Specific communication support including labeling of packaging and clear signage of premises. Collaboration and integration with relevant stakeholders are essential. Type and volumes received Volumes transported

None

None

Volumes treated

Volumes landfilled

Volumes recycled

Not required

Not required

Required

Required

Required

Required

Required

* Indication of the responsibilities and involvement foreseen for a funding and administration oversight entity Hg = mercury

Keeping CFLs out of the general waste bin

The outgrowth of conservation, the inevitable result, is national efficiency. - Gifford Pinchot

Consumer Responsibilities
Because CFLs are fragile, and broken glass and the mercury content present a health and safety risk, recovery from the waste stream after disposal is not feasible. CFLs should therefore not be thrown into the regular waste bin, but rather be kept separate and stored safely until an opportunity for disposal is available. The success of a CFL recovery initiative is entirely dependent on participation by the householder or residential consumer. A guideline for safe and effective householder participation is provided here:

Separation at source
Personal health
Intact CFLs emit no mercury and pose absolutely no health risk. In the case of accidental breakage, the amount of 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 of cuts from glass fragments. A very infor mative and detailed discussion on risks of broken CFLs can be found at: www.treehugger.com/ files/2007/05/ask _treehugger_14.php

Consumer Best Practice Objective No CFLs are to be disposed of at a landfill for general household waste. Additional Information General landfill sites are not designed to accommodate the release of mercury. Mercury needs to be treated (encapsulated in concrete or similar) to prevent leaching and release into the environment (e.g. atmosphere or groundwater). The Minimum Requirements state that hazardous waste must go to a hazardous landfill site. Check with the local municipalitys department of solid waste management for suitable local requirements or solutions for hazardous household waste. Ideally CFLs should not be broken and should be placed in their original packaging or wrapped in a plastic bag. Advice on cleaning up broken fluorescent lamps is freely available on the Internet and also on Eskoms website at: http://www.eskomdsm.co.za/?q=CFL_Recovery. At present Woolworths and Pick n Pay stores offer CFL collection points. Pick n Pay also accepts household batteries for disposal and recycling. Check with your local council for any other options for disposal of household hazardous wastes such as empty containers or leftover thinners, paints, poisons, batteries, etc.

Legislation

Minimum Requirements for Hazardous Waste Disposal (www.dwaf.gov.za/Dir_WQM/docs/Pol_ Hazardous.pdf) and any relevant municipal bylaws. Do not throw CFLs away with your domestic waste. Keep CFLs separate until you can safely take them to a drop off/collection point. In the event of breakage, special care must be taken to clean up and contain mercury powder and glass shards.

What to do with your CFLs

Where to take your CFLs

CFLs can be taken to participating retailers and collection points in your area.

How to store your CFLs

Spent CFLs should ideally arrive at a drop-off point It is recommended that packaging in which CFLs are bought unbroken. The lamps should therefore be securely is kept and used for this purpose. Alternatively, packaging of packaged in a safe container for storage and transport. replacement lamps can be used if readily available.

Municipal Responsibility
The recovery of most household hazardous wastes from the waste stream after disposal is a challenge and presents the risk of repeat exposure to any person tasked with extraction of recyclable waste (whether at a material recovery facility or less formally from bins on sidewalks or at a landfill). Municipalities should lead the drive to encourage a culture of separation of waste at the home for ALL wastes for which a recovery solution is being offered or a market exists. Establishing a habit of waste separation among South Africans is essential for any waste minimisation and recycling efforts in future.
Municipality Best Practice Prevent disposal at the local general landfill facility. CFLs must be kept away from other waste at point of generation by the homeowner. Municipal functions are guided by the Municipal Systems Act, NEMA and the Minimum Requirements for general landfill and hazardous waste. Additional Information

Separation at source
Relevant contacts
The City of Cape Town, Cleanest City in South Africa 2007, has done extensive work on waste related education and awareness efforts (e.g.WasteWise campaign) that could be of value to other Municipalities. You may find information 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
wastewise.user@capetown.gov.za

Objective

Municipalities should proactively encourage separation at source of all recyclable and hazardous household wastes including specifically CFLs.

Legislation

Waste separation is an important step in the Government drive for waste minimisation and key to achieving the waste hierarchy: Reduce, Re-use, Recycle.

How to implement in your municipal area

Educate and create awareness among the public regarding the need for waste separation and specifically the need for separating CFLs and other hazardous wastes from the waste stream.

Have available and provide information (e.g. with billing information and/or on enquiry) of local recycling and recovery initiatives such as paper and glass banks, recycling collection services, eWASTE collection points or initiatives and particularly participating retailers that accept CFLs (refer to drop-off centre component of this guideline).

Industry Responsibility
A communication strategy is part of the requirements of an Industry Waste Management Plan as described in the Waste Management Bill (pending enactment, expected early 2009). Any Industry Waste Management plan for fluorescent lamps would rely heavily on participation, and hence the awareness of homeowners. The lighting industry would therefore have an obligation to collaborate with other stakeholders in creating awareness and educating the public about waste separation.

Separation at source
Industry activity
Select industr y player s are actively addressing lighting waste internationally and some have already taken an active lead in the CFL recovery efforts in South Africa.You can obtain information from these suppliers directly or read more on their websites: Philips: +27 (0)87 940 4194 or +27 (0)11 471 5065 or www.philips.com/about/ sustainability/recycling or refer to page 14 for others.

Industry Best Practice Objective Prevent the disposal of CFLs and other fluorescent lamps with other households waste in order to facilitate recovery. Industrys involvement will be most effectively governed under the pending Waste Management Bill, a subset of the National Environmental Management Act (NEMA). CFL packaging should be labeled appropriately to educate consumers regarding mercury content and handling of CFL waste. Call centre details to be provided on packaging and call centres should be empowered to deal with enquiries relating to safe disposal and handling of CFL waste. Although the Extended Producer Responsibility principle is already entrenched in existing legislation, the enactment of the Waste Management Bill and a Government request for an Industry Waste Management Plan will force active industry involvement with lighting waste. Different graphics with supporting text could be used to educate the consumer about mercury content and requirements for safe disposal or recycling as appropriate. Labels should be clearly visible and understandable. A collaborative effort among lighting suppliers can address all these calls or alternatively existing call centres can be briefed to deal with these questions. Additional Information

Legislation

What to do with CFLs

Labeling should ideally highlight the opportunity for re-use of packaging material Consumers should be encouraged to re-use packaging material for safe (assumed optimal format to prevent storage and transport of spent CFLs. breakage of lamps).

Department of Environmental Affairs and Tourism (DEAT) Responsibility

National Government support for a nationwide CFL recovery mechanism is critical to the success of the initiative. More generally, the encouragement of separation at source will promote the shift towards more sustainable waste management strategies and practices, and place emphasis on the reduction, re-use and recycling of wastes:
DEAT Best Practice Objective To encourage thorough legislation and regulations and to enforce separation at source of all recyclable and particularly hazardous household waste. DEATs involvement is governed by the national legislative framework including: the Constitution, National Environmental Management Act and Municipal Systems Act. Encourage and support the inclusion of the concept into Municipal Integrated Waste Management Plans and the development of bylaws to enforce separation at source by homeowners. A national education campaign. General education must be provided to the public to improve their knowledge of the impact of mercury bearing lamps on the environment. Support should also be provided to provincial departments and local municipalities in the form of information sharing, education and empowerment. Additional Information Separation at source is an essential component of all recycling initiatives and should be widely encouraged.

Separation at source
Relevant contacts
Relevant DEAT Directorates and contacts include, among others:

Legislation

Where to enforce separation at source

Emphasis should be placed on the importance of appropriate handling of hazardous household waste among all role players and every entity under legal obligation to comply.

How to support separation at source

Overall education relating to waste, recycling and hazardous household waste has been identified during public consultation as an imperative since existing awareness levels are extremely low. Education with regard to the benefits of using energy saver lamps should also form part of communications.

1. Directorate: Waste Stream Management, Ms Dee Fisher +27 (0)12 310 3527, dfisher@deat.gov.za 2. Directorate: Waste Policy & Information Management, Mr Obed Baloyi +27 (0)12 310 3833, obaloyi@deat.gov.za

Communication support Comprehensive and collaborative communication, education and

awareness 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.

Delivery of CFLs at Collection Points

Consumer Responsibility
In the absence of a separate sidewalk collection service, consumer participation will necessarily include transportation of CFLs to a local collection point. This is aligned with international practice where residential consumers are generally required to deliver spent CFLs and other hazardous household wastes (e.g. batteries) to central locations including participating retailers and collection bins. Suggested practices for safe transportation are provided below:
Consumer Best Practice Objective To ensure safe transportation of spent CFLs to a drop-off centre or mobile unit. Additional Information

Private Transportation
Relevant contacts
eWaste service providers and recycling companies provide collection services that sometimes include hazardous household waste . Ser vice provider s or participants in your area may be listed with: 1. eWASA (National): +27 (0)11 312 3605 or www.ewasa.org 2. Urban Sprout Eco-Directory: www.urbansprout.co.za 3. Faithful to Nature Eco-Directory: www.faithful-to-nature. co.za/ directory

Legislation

Minimum Requirements for Hazardous Usually applicable to bulk carriers of hazardous materials. Safe Waste Disposal, National Transportation Act. keeping of small quantities to prevent breakage required.

How to transport your CFLs

Ideally CFLs should not be broken during transit. CFLs must be transported carefully in a manner that will prevent breakage and minimise the risk to handlers for delivery to a suitable disposal or collection point.

It is suggested that CFLs be placed in their original packaging or empty packaging of replacement lamps or wrapped in a sealable (heavy/thick) plastic bag. Transport household hazardous waste in the rear of the vehicle, ideally packed securely in the vehicle to prevent crushing and do not store in the vehicle for extended periods.

What if CFLs break during transit

If during transit a CFL does break, open your windows immediately and pull over at the nearest safe location. Once air has been circulated, put CFL in a plastic bag and drop off at the nearest drop-off centre.

Also wipe the car with a damp cloth and dispose of any remaining glass fragments at your earliest convenience. Containment of the lamps in a plastic bag will contain any pieces and will greatly simplify the cleaning up.

Muncipal Responsibility
Where separate collection services for 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 for separate sidewalk collection services of select wastes, including recyclables, across South Africa.The following guideline is therefore aimed at guiding any municipalities that do get involved in the collection and transport of household hazardous waste, including CFLs.

Small scale Transportation

Mobile Units
The use of mobile units is a solution employed internationally which makes use of mobile containers that collect hazardous household waste from residential areas on a regular basis. Feasible implementation is dependent on provision of the service for a broad range of hazardous waste types to benefit from economies of scale and logistical synergies.

Municipality Best Practice Objective To ensure safe transportation of spent CFLs to a drop-off centre or mobile unit. Minimum Requirements for Hazardous Waste Disposal, National Transportation Act. A municipality may be involved in the transportation of spent CFLs by implementing a contract with a private company. It is essential that the private company makes use of specific crates which prevent the breakage of spent CFLs. Vehicles must be roadworthy and appropriate and in accordance with the National Traffic Act (GNR. 225) requirements. The applicable TREM decals must be displayed on the vehicles and provide correct details. The driver(s) of the vehicle(s) must be qualified, trained and hazardous waste certified to transport hazardous goods. In the event of 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. Usually applicable to bulk carriers of hazardous materials. Safe-keeping of small quantities to prevent breakage is required. Spent CFLs must be transported in such a manner that the breakage of CFLs is prevented and that, in the case of breakage, no mercury leakage emanates from the transportation containment. Additional Information

Legislation

How to transport CFLs

Waste Contractor Responsibility

Environmental consciousness is intensifying and, particularly among high-income households and in urban centres, the demand for collection services for recyclable material has resulted in seemingly sustainable business opportunities. In select instances service providers are extending the collection offering to include household hazardous wastes such as batteries, etc. The following framework is therefore aimed at guiding any private waste/recyclables collection contractors that do get involved in the collection and transport of household hazardous waste, including CFLs.
Waste Collection Contractor Best Practice Objective To ensure safe transportation of spent CFLs to a dropoff centre or mobile unit (or other appropriate storage or treatment facility). National Transportation Act, Minimum Requirement for Hazardous Waste Disposal. If a private waste contractor would like to be involved in the transportation of spent CFLs, it is essential that specific crates which prevent the breakage of spent CFLs be used. Vehicles must be roadworthy and appropriate and in accordance with the National Traffic Act (GNR. 225) requirements. How to transport CFLs The applicable TREM decals must be displayed on the vehicles and provide correct details. The driver(s) of the vehicle(s) must ideally be qualified, trained and hazardous waste certified to transport hazardous goods. In the event of 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. If very small quantities are transported with other wastes, it is recommended that the driver is at least trained to deal with breakages or spillage of hazardous materials including CFLs. Ensure ventilation of the area of breakage and ensure a spill kit is available. A single breakage can be cleaned up and addressed as for a private vehicle (refer to consumer guideline). Additional Information Service providers may cut out the collection points and transport CFLs directly to a storage or treatment facility. In that case please refer directly to bulk transport and waste treatment and storage implementation guidelines. Usually applicable to bulk carriers of hazardous materials. Safe keeping of small quantities to prevent breakage is required. Suitable packaging and containers/crates are particularly important if transported with other wastes that can crush the CFLs in transit.

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Private Transportation
Relevant contacts
No ser vice provider s are currently known to provide collection services for CFLs from households, but service providers that collect from commercial properties may be available to assist at a fee. The following service providers are active in the commercial market: 1. Nova Lighting 2. Lumino 3. Actebis Refer to Treatment Section of this guideline for the contact details.

Legislation

Hosting CFL Collection Points/Drop-off Centres

Consumer Responsibility
The sustainability of a collection point network for spent CFLs in South Africa is dependent on the level of participation by the public. South Africans are therefore encouraged to make use of the facilities provided by retailers and any other participants and also to use these facilities responsibly. The practices described below are therefore aimed at guiding participation by consumers.
Consumer Responsibility Best Practice Objective Safely deposit all failed CFLs at participating collection points or drop-off centres. Minimum Requirements for Hazardous Waste Disposal, any relevant municipal bylaws. Deliver CFLs intact to participating collection points or drop-off 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 specifically instructed otherwise at the specific drop-off centre. Handle spent CFLs carefully to prevent breakage. Children should be kept away from the collection bins and discouraged to play with or around these facilities. Replace failed CFLs with a suitable replacement.

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Additional Information

Drop-off Centres
Relevant contacts
The following collection points are available to consumers wanting to participate: 1. Pick n Pay stores nationwide. Contact Pick n Pay for 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 for participating stores on +27 (0)860 100 987 or visit their website: www.woolworths.co.za

Legislation

How to use a drop-off centre

CFL Selection
The choice of a new CFL requires some consideration: - Required brightness of the light (represented by the wattage). - The desired colouring of the lamp (represented by the Kelvin value and described as either

warm white or cool white) or alternatively can be coloured lighting/glass, such as red or blue. - The appropriate fitting i.e. screw-in or bayonet. - Whether the lamp should be dimmable or not and whether it should function with a motion sensor (often required for external or security applications).

Drop-off Centre/Collection Facility Responsibility

The responsibilities and requirements relevant to hosting a collection facility or drop-off centre are fairly significant but mainly require sensible caution, similar to that necessary for handling a wide variety of household hazardous goods (e.g. paint, poisons, batteries, etc.) generally sold by retail and hardware stores. A detailed guideline is provided below to guide anyone interested in hosting a collection point or drop-off centre.

Drop-off Centres
Permissible storage
Current legislation requires: 1. Permitting of a collection/ drop-off facility to act as a temporary waste storage facility. 2. At least a Basic Assessment is done towards a full EIA. Indications from DEAT are that the Waste Management Act and related regulations will make allowance for temporary storage and recovery activities handling small quantities of hazardous waste to be exempted from the requirements for a license (see page 18 for details).

Drop-off Centre Facilities Best Practice To host a clearly marked and safe drop-off facility. To ensure that CFLs are temporarily stored in a manner that is not harmful to the individual housholder, the public or the environment. To provide a convenient point for the consumer to return their spent CFLs. To provide a permanent or temporary point for waste transporters to collect spent CFLs en masse. Legislation Minimum Requirements for Hazardous Waste Disposal new EIA Regulations. A suitable container of sufficient size that can safely accommodate the volumes of CFL waste dropped off. A sufficient area of floor space to accommodate the container and to allow access and ventilation if required. Drop-off containers should be positioned in a prominent and easily accessible location that is clearly marked. Additional overflow storage capacity needs to be provided by drop-off centre hosts for the safe storage of full containers. The correct permit/license or exemption from such a license must be obtained where applicable (i.e. where waste volumes exceed the permissible concentrations and maximum allowed weights).

Additional Information

Objective

It is anticipated that drop-off points will form part of an ever expanding network of CFL collection infrastructure. Refer to the legal overview for specific acts, clauses and regulations of interest.

Typically a minimum of 1m2 space is required. Location in a store would ideally be either at the sales point for new CFLs, at the till or close to the exit as part of a recycling street that also enables consumers to return other waste items such as plastic bottles etc. Additional storage is required to accommodate any delays for the pick-up of the spent CFLs by specialised treatment, disposal or recycling service providers. Whilst there is ongoing engagement with DEAT to resolve possible exemptions, it is suggested that in the interim, facilities are managed responsibly in accordance with these guidelines.

What is required of the facility?

Drop-off Centre/Collection Facility Responsibility

Drop-off Centre Facilities Best Practice The collection point should preferably only accept intact CFLs and no breakage should occur during the drop-off or temporary storage process. Quantities of CFL waste collected and stored must be safely manageable at all times. Collection points must be clearly demarcated and labelled and containers must be labelled with clear instructions on the type of How to lamps accepted and how the lamps have manage a to be returned. drop-off The temporary storage area for full containers centre must be safe and easily accessible when lamps are picked-up. Additional Information The public and employees of the collection facility should be educated. Regular emptying of containers to avoid overflow and thus breakage and regular removal from collection points is strongly recommended. Communication, education and awareness creation are critical. Every opportunity should be used to encourage participation and to remind the public to drop off unbroken CFLs, preferably in original packaging or wrapped/sealed in a suitable plastic bag.

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Drop-off Centres
Relevant contacts
Hazmat provides a national 24-hour spill response service. Hazmat can be contacted incase of emergency toll free at: 0800 00 58 17 or for enquiries contact the head office at +27 (0)33 386 2264 or email: ian@hazclean.co.za Alternatively visit their website at: www.24hourspillresponse.co.za.

Collection frequency must be commensurate Collection frequency can either be based on an actual needs base with the volumes of CFL waste actually dropped (when bin is full) or can be at regular intervals throughout the collection off and generated within the retail store. period (e.g. every fortnight). The drop-off centre/collection facility may not be left unattended at any time. At least one employee should be present on site/in-store and should be identified as the individual responsible for CFL collection. Containers must be inspected regularly for level and other problems e.g. mercury contamination from broken bulbs and their overall functionality. Drop-off centres cannot take the format of a glass bank left unattended in a parking area. The delegated responsibility is particularly important in the case of spillage or breakage.

How to safely store CFLs

Industry Responsibility
The voluntary initiation of CFL collection points by retailers in South Africa is an important step towards a national CFL recovery network. Maintaining the momentum created by these initiatives should be a priority for all stakeholders, including the lighting industry. Operating collection centres will constitute a key component of a functional Industry Waste Management Plan and hence would be of particular interest to the lighting industry.

Drop-off Centres
Permissible storage
(Continued from page 15) Lighting suppliers that have demonstrated commitment to the management of the full product life cycle of 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

It is not expected that industry players will host their own drop-off points but should any lighting supplier be interested in hosting such a facility, the guidelines for drop-off facilities (refer to preceding section) will be relevant. The guideline below is aimed at industry in their role as supporter of drop-off centres.

Industry Best Practice Additional Information Support the establishment of safe, convenient and legally compliant drop-off centres that will facilitate the recovery of CFLs. Ensure the sustainability of drop-off centre for CFLs. Legislation Minimum Requirements for Hazardous Waste Disposal new EIA regulations, Waste Management Bill. Assist with creating public awareness in terms of CFL drop-off centres. How to support drop-off centres Support the establishment of safe, convenient and legally compliant drop-off centres that will facilitate the recovery of CFLs. Encourage the use of drop-off centres. Financial, logistical and administrative support are all required to ensure a sustainable solution. Several oportunities arise such as linked sales promotions and discounts on replacement CFLs linked to the return of failed lamps. Refer to legal overview for specific acts, clauses and regulations of interest.

Objective

Local Muncipality Responsibility

Hosting of a drop-off facility for CFLs at council premises would follow the same guidelines as for other drop-off facilities (refer to preceding section for drop-off centres). The guideline below is to assist local municipalities interested in having collection points established in the municipal area.
Local Muncipality Best Practice Support the establishment of safe, convenient and legally compliant drop-off centres that will facilitate the recovery of CFLs in municipal areas. Objective Encourage participation by residents in the municipal area. Prevent the disposal of CFLs in general landfills. Legislation Municipal Systems Act, Minimum Requirements for General Landfill. The municipality may host CFL drop-off facilities at suitable municipal premises. Engage local retailers or other suitable facilities to host CFL drop-off centres. Assist with education and creation of public awareness regarding the need for and participation in CFL drop-off centres. Empower interested participants. Possible options for collection points include utility offices, public libraries, community centres or manned refuse drop-off centres. Hardware stores, lighting suppliers, general retailers, 24-hour convenience stores at petrol stations can all be considered for participation. Communicate details of participating drop-off facilities in municipal publications and communications.

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Additional Information

Drop-off Centres
International experience
In the US, local governments have reached out to local retailers to host collection points. Information and examples of bins, posters and collection points can be found on the websites of: - IKEA - Wal-Mart - Sears Stores - Ace Hardware - Home Depot

How to get facilities for CFL collection How to support drop-off points

Department of Environmental Affairs and Tourism (DEAT) Responsibility

A national recovery network for CFLs via central collection points is a significant improvement on the status quo where all CFLs are disposed of at the general landfill. A simplified mechanism or possibly exemption from EIA requirements and waste facility licensing with consideration of 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.

Drop-off Centres
Enabling/Supporting Legislation
Two onerous legislative requirements will prohibit the participation of retailers and others in establishing a comprehensive recovery mechanism for CFLs. Indications from DEAT are that new waste regulations will, in future, partly address the temporary storage constraints but EIA requirements will have to be aligned to facilitate and encourage recovery, responsible handling and recycling of CFLs.

DEAT Best Practice Objective To encourage the use of drop-off centres and to support drop-off centres. Minimum Requirements for Hazardous Waste Disposal, new EIA regulations. Exemption should be considered and supported for the listed activity as per regulation 386: The temporary storage of hazardous waste. Request/enforce (as appropriate) the development of a Lighting Industry Waste Management Plan. Emphasis should be placed on the importance of appropriate handling of hazardous household waste among all role players and every entity under legal obligation to comply. Alignment of EIA and Waste Management requirements to support CFL recovery is essential. Whilst relaxation is proposed, alternate mechanisms such as an Industry WMP is required to ensure that CFL recovery is structured and responsible through a formal waste management plan and an oversight/audit function. Additional Information A formalised and appropriately managed collection mechanism for CFLs is a significant improvement on the status quo.

Legislation

How to support CFL collection

Communication Support Comprehensive and collaborative communication, education and awareness support 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 Transportation

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Waste Contractor Responsibility

Waste contractors that are required to collect CFLs from drop-off centre facilities should take cognisance of the hazardous nature of CFLs and the requirements for handling and transportation. The need for waste information management and tracking is also introduced at this stage of waste handling. These guidelines are aimed at assisting with best practice for bulk transport of CFLs.
Waste Contractor Best Practice Objective To ensure safe transportation of spent CFLs to a landfill site or recycling facility. Minimum Requirements for Hazardous Waste Disposal, National Transportation Act. Spent CFLs must be transported in such a manner that If a private waste contractor would like to be involved in the breakage of CFLs is prevented and that in the case the transportation of spent CFLs it is essential that specific of breakage no mercury leakage emanates from the crates which prevent the breakage of spent CFLs be used. transportation containment. Vehicles must be roadworthy and appropriate and in accordance to the National Traffic Act (GNR. 225) requirements. How to transport your CFLs The applicable TREM decals must be displayed on the vehicles and provide correct details. The driver(s) of the vehicle(s) must be qualified, trained and hazardous waste certified to transport hazardous goods. Ensure ventilation of the area of breakage and ensure a spill kit is available. A single breakage can be cleaned up and addressed as for a private vehicle (refer to consumer guideline) Hazmat provides 24-hour spill response in the case of an accident or serious spill of large volumes of CFLs. Contact details for Hazmat must be provided to drivers (refer to page 13 for contact details). Additional Information

Bulk transportation
Relevant contacts
No service providers are currently known to provide collection services for CFLs from households, but service providers that collect from commercial properties may be available to assist at a fee. The following service providers are active in the commercial market: 1. Nova Lighting 2. Lumino 3. Actebis Refer to Treatment Section for contact details.

Legislation

In the event of 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.

Municipal or Industry Responsibility

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Should either municipalities or industry be interested in, or be required to, collect CFLs from drop-off centre facilities, the requirements for handling and transportation of CFLs as per the guidelines for a Waste Contractor will apply. As for waste contractors, the need for waste information management and tracking is a requirement introduced at this stage of CFL waste handling and should be given due consideration. It is also possible that municipalities and industry players may be involved in the recruiting of waste contractors for a collection and transportation service. These guidelines are therefore aimed at assisting with appropriate practice when contracting for bulk transport of CFLs.
Local Municipality or Industry Objective Legislation Best Practice To ensure safe transportation of spent CFLs to a landfill site or recycling facility. Minimum Requirements for Hazardous Waste Disposal, National Transportation Act. Verify that the contractor complies with the Best Practices described in the preceding guideline. This will include having suitable crates which prevent the breakage of spent CFLs. Vehicles are roadworthy and comply with the National Traffic Act (GNR. 225) requirements. What to consider when contracting for the transportation of CFLs Applicable and accurate TREM decals are displayed on the service providers vehicles. Confirm that driver(s) of the vehicle(s) are qualified and are certified 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 yourself and the Fund administration entity. Spent CFLs must be transported in such a manner that the breakage of CFLs is prevented and that in the case of breakage no mercury leaks from the transportation containment. Additional Information

Department of Environmental Affairs and Tourism (DEAT) Responsibility

The primary requirement for National Government involvement with transportation is for the relaxation of the legal requirements for transporting select hazardous waste types so as to facilitate recovery and responsible handling.
DEAT

Bulk transportation
DEAT Contact details
Directorate: Pollution & Waste Management: Mr Rantsadi Moatshe +27 (0)12 310 3648 rmoatshe@deat.gov.za

Best Practice Objective To encourage thorough legislation and regulations. The separation at source of all recyclable, and particularly hazardous, household waste. DEATs involvement is governed by the National legislative framework including the Constitution, National Environmental Management Act and Municipal Systems Act. Encourage and support the inclusion of the concept into Municipal Integrated Waste Management Plans and the development of bylaws to enforce separation at source by homeowners.

Additional Information Separation at source is an essential component of all recycling initiatives and should be widely encouraged.

Legislation Where to enforce separation at source

Emphasis should be placed on the importance of appropriate handling of hazardous household waste among all role players and every entity under legal obligation to comply.

Directorate: Authorisation & Waste Disposal Management: Ms Kellelo Ntoampe +27 (0)12 310 3920 kntoampe@deat.gov.za

How to support separation at source

Overall education relating to waste, recycling and hazardous household waste has been identified during A national education campaign. General education must public consultation as an imperative since existing be provided to the public to improve their knowledge of awareness levels are extremely low. Education with the impacts of mercury bearing lamps on the environment. regards to the benefits of using energy saver lamps should also form part of communications. Support should also be provided to provincial departments and local municipalities in the form of information sharing, education and empowerment.

International example: Universal Waste Regulations

Federal and state regulations in the USA have relaxed the legal requirements for the transportation of select hazardous waste types to facilitate collection and recovery to appropriate recycling or disposal facilities.

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Treatment or Storage Facilities for CFLs

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Storage Facility responsibility

It is essential that owners of storage facilities understand the risks associated with storing masses of spent CFLs and understand the safety requirements. These guidelines are aimed at assisting with best practice.
Storage Facilities Best Practice Objective Ensure that CFLs are temporarily stored in a manner which is not harmful to the environment or humans. Minimum Requirements for Hazardous Waste Disposal, new EIA Regulations. Suitable containers of sufficient size that can contain intact, failed CFLs and that will protect the lamps from breakage. Sufficient floor space to accommodate bulk storage of CFLs in suitable containers. A spillage clean-up kit needs to be at hand in case CFLs are accidentally broken. How to support separation at source All personnel must be trained to deal with spillages and must be well educated about the risks associated with the mercury bearing lamps. Personnel must wear Personal Protective Equipment (PPE) at all times. Ensure ventilation in the area of breakage and ensure a spill kit is available. In the case of a major event, it is recommended that Hazmat or a similar service provider be called in. Additional Information

Legislation

What is required for storage of CFLs

Treatment Facility Best Practice Objective Legislation Ensure that CFLs are crushed, chemically treated (where required) and sealed in manner that is not harmful to the environment or mankind. Minimum Requirements for Hazardous Waste Disposal, pending Waste Management Act, Environmental Conservation Act and new EIA regulations. Additional Information Crushing and treatment into an inert and sealed format is essential except when transporting to a recycling facility. Then pre-treatment should not occur. Would have to comply with the comprehensive legal requirements for permitting of storage, treatment and processing of hazardous (CFL) waste facilities.

Treatment Facility Responsibility

Crushing and treatment are primarily done to facilitate economically feasible transportation and recycling or disposal. Crushing of the lamps therefore constitutes an integral part of the treatment activity with significant associated risk potential.These guidelines are not intended to prescribe a specific 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 facilities understand the benefits and consequences of their activities and technologies.
Treatment Facility Best Practice All CFLs that will be disposed of at a landfill must be pretreated under controlled conditions in line with legislative requirements (refer above). Any mercury vapour emanating from 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. How to treat CFLs? Mercury vapour that forms as a result of crushing mercury-containing CFLs and tubes as well as any extracted mercury must be contained as part of any crushing 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 of the treatment process. Additional Information

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Treatment or storage
Relevant contacts
The following companies are known to provide treatment services for mercury bearing lamps:

To meet all the legislative requirements and best practice described, the crushing technology would typically operate in a vacuum or under negative pressure and must incorporate a comprehensive filter system.

1. Nova Lighting. Tel: +27 (0)21 706 4451, Email: mike@nova.co.za or web: www.nova.co.za 2. Lumino. Tel: +27 (0)861 111 319 Email: lamps@lumino.co.za or web: www.lumino.co.za 3. Actebis. Tel: +27 (0)16 423 7802, Email: actebis268@lantic.net or web: www.tubeandglobeguzzler

Disposal of CFLs as Hazardous Waste

Landfill Operator Responsibility

Landfill operators must be aware of the disposal procedures pertaining to the disposal of mercury bearing lamps, including spent CFLs.The following guidelines are set out as the best practice in terms of CFL disposal.
Landfill Operator Best Practice Objective In the absence of a suitable/viable recycling option, spent CFLs should be disposed of at a licensed hazardous landfill site. DWAF Minimum Requirements for Hazardous Waste Disposal. Spent CFLs may only be disposed of at a licensed hazardous landfill site. All CFLs that are disposed of at a hazardous landfill site must be pre-treated as per these guidelines and Minimum Requirements (refer to earlier component of this document and separate minimum requirements). How to landfill CFLs The containers in which CFLs are treated and transported to the landfill site may not be opened. The containers must be disposed of as is on site. All treatment must be completed prior to arrival at the landfill site. Containers should be clearly labeled according to their contents. In accordance with licensing requirements this should include the following: - Regular audits of the facilities as per the Minimum Requirements. - A measurement and verification system must be in place whereby all CFLs that arrive at the landfill site must be recorded in terms of mass. Operation should include encapsulation in an impermeable substance, such as concrete. Additional Information Waste disposal should remain a last resort in line with stated Government objectives and waste hierarchy.

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Disposal at landfill
Relevant contacts
Only three landfills are suitably licensed for the acceptance of hazardous wastes, such as mercury, in South Africa. These are located in the Western Cape, Eastern Cape and Gauteng respectively and details can be obtained from DEAT (see earlier contact details) or from the Institute of Waste Management (IWMSA). Tel: +27 (0)11 675 3462/4 Email: iwmsa@telkomsa.net Website: www.iwmsa.co.za

Legislation

The hazardous landfill site where CFLs are disposed of must be permitted/licensed and operated as per the DWAF Minimum Requirements for Hazardous Waste.

Operating plans at such a hazardous landfill site must include a plan for disposing of spent CFLs.

The re-opening or downstream chemical treatment of CFL waste with mercury immobilising chemicals is strictly prohibited. Please also note that the transporter of the waste to the landfill should be aware of the requirements for CFLs and should ensure delivery of pre-treated and crushed lamps in sealed containers for encapsulation.

Recycling of CFL Components including Mercury

Recycler Responsibility
Various recycling technologies/methodologies currently exist (including treatment options) but it is important that recycling facilities understand the benefits and consequences of the various technologies including among others the variability of the number of components that can be recovered through the process. Of the available recycling technologies Closed Loop Recycling is currently the only proven technology with exceptional health, safety, environmental and quality performance. These guidelines are aimed at assisting with appropriate practice and utilisation of recycling facilities.
Recycling Facilities Best Practice Additional Information Current and pending legislation incorporates the requirement to prove that the resources required for the recycling process do not exceed the recycling benefits. Licensing of a new recycling facility will be subject to a complete impact assessment with consideration of the above. Comprehensive licensing requirements will apply to recycling facilities.

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Recycling
Relevant contacts
Reclite is in the process of establishing a mercury recovery and recycling facility for lamp components in South Africa. The facility will accept a wide variety of mercury lamps for processing. Reclite can be contacted at: Tel: +27 (0) 11 764 4855 Cell: +27 (0) 82 492 7356 Email: patricia@reclite.co.za or you can visit their website at: www.reclite.co.za
Government support/facilitation of a receiving market for recycled material including recovered mercury and particularly glass and metals, will be invaluable to promote CFL recovery and recycling.

Objective

Recycle CFLs and all the components in an environmentally friendly manner whilst ensuring the operation is environmentally and financially viable.

Legislation

New EIA Regulations, pending Waste Management Act.

CFLs should ideally be received intact or if crushed, appropriately sealed to prevent the release of 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 from the recycling activities.

Recycling of CFLs

Recycled components should be free of any mercury contamination.

Fund Administration

Fund Administrator Responsibility

The expectation is that a fund administration and management entity will be established or appointed to oversee the implementation, track progress and manage the flow of funding. A comprehensive investigation into appropriate structures and functions has identified the following as essential/optimal services to be provided for the CFL waste stream:
Fund Administrator and Management Best Practice Objective A management and administration entity to oversee and manage the implementation of the CFL Recovery Initiative in accordance with the Minimum Requirements and Implementation Guidelines. Additional Information Administrator should be directly involved in all aspects of collection, transport, recycling and fund management in an oversight capacity. Provides support to all existing and interested role players to facilitate participation and compliance with best practices. Participation by participants of the initiative and industry shareholders should be on a voluntary basis. Lighting industry participation may become a requirement in the case of an Industry Waste Management Plan being adopted. These functions should include the following: - provide a collaboration platform for CFL manufacturers and importers. - drive awareness, education and communication for the initiative. - facilitate interaction with Government. Implement fund management activities including fund collection and disbursements or contracting of services as appropriate. Appointment of an auditing entity for fund management or oversight of fund management. Appointment and management of all service providers to collect and deliver CFLs and collation of data. Contracting and management of companies to recycle or dispose of CFLs and collate data.

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Fund administration
Voluntary participation
Research findings have shown that pending legislation has resulted in extended delays in activity in anticipation of the detailed legislated requirements. As a result, the time required for legislation to be promulgated becomes a major barrier for implementation. Voluntary participation is therefore the best immediate way forward in spite of the obvious limitations.

Legislation

Structured as and compliant with all legislation relevant to a Section 21, non-profit organisation registered as a Public Benefits Organisation (PBO).

Basic facilitation and support.

Support functions to be provided

Management of funding and flow of funding.

Collection and delivery of CFLs. Recycling/disposal activities.

Fund Administrator Responsibility

Fund Administrator and Management Best Practice Flow of funding The optimal solution for continuous flow of funding is through a manufacturers/ importers levy to the fund administrator from where payments to all collection entities, transporters, recyclers, etc. are managed. Additional Information An initial kickstart or start-up fund may be required from relevant stakeholders to initiate a recovery programme prior to the establishment of a levy. The option of an incentive for participation to consumers requires further consideration but would form part of the functions of this entity.

Participating transporters, storage, treatment, landfill and recycling facilities responsibility

Data collection and management is essential to track progress and inform decision making. For this purpose, all participants would be expected to maintain data and report regularly to the fund administration entity. It is, however, critical that this requirement is not too onerous resulting in reluctance to participate.The following guideline proposes the minimum data requirements that participants would be required to adhere to.
All Participants Collection points Best Practice No data logging required. Required to capture quantities/volumes collected and delivered to any of the following as applicable: - Treatment/storage facilities - Disposal facilities i.e. hazardous landfills - Recycling facilities All participants are required to capture the following detailed information: Storage, treatment, disposal or recycling facilities 1. Volumes, quantities or weights collected, received, treated, recycled or landflled material. 2. Relevant dates such as collection or delivery. 3. Signature(s) of authorised individual(s) for each facility or vehicle. 4. Confirmation of due process followed. Additional Information Please do however check that collection services capture the required data when picking up CFLs from your premises. Information requirements are as per prescription for all transportation of hazardous wastes.

Waste contractor(s)

Project Contacts and Acknowledgements

- City of Cape Town Barry Coetzee and Alison Davison - Department of Environmental Affairs 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 Email: mail@zitholele.co.za Envirosense Susanne Dittke Tel: +27 (0)21 706 9829 Email: envirosense@envirosense.co.za Alakriti Consulting Mari-Louise van der Walt Tel: +27 (0)82 574 6054 Email: mari-louise@alakriti.co.za

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ALL participants in the CFL Recovery Initiative must be acknowledged for their invaluable contribution to the programme and particularly thanked for the input and effort that resulted in this guideline. Key participants that are specifically acknowledged include:

CFL Recovery, Recycling & Disposal Implementation Guideline