Proposed code of practice for management of end-of-life lamps containing mercury: chapter 14


14. Options for the Diversion and Management of End-of-life Mercury-containing Lamps in Northern and Remote Areas

The best practices presented in the previous sections should be applied to the management of end-of-life mercury-containing lamps by facilities and operators who handle, collect, store, transport and process these materials in Canada. However, recognizing that northern and remote regions often face unique challenges that can make it difficult to collect and manage end-of-life mercury-containing lamps, including limited storage facilities, absence of local recycling facilities, high cost of freight to southern markets, limited transportation options, and lack of regulatory or financial incentives for private industry to develop markets and infrastructure for recycling, the code of practice includes additional information for the implementation of the best practices that takes into consideration these challenges. This section presents information on options for the collection, storage and transportation of end-of-life management of mercury-containing lamps in northern and remote communities which can be used to facilitate the implementation of the best practices.

14.1. Collection and Storage

Generally, northern and remote communities are isolated from each other as well as from lamp collection and processing facilities. As such, end-of-life lamps could be dropped off at small primary collection locations established within each community when regional collection points may not be feasible. Once the accumulated quantities warrant it, the end-of-life lamps can be transported to a processor. Alternatively, end-of-life lamps may be sent directly from the waste generator to a lamp processor using pre-paid shipping boxes for recycling.

In areas where the quantity of end-of-life lamps generated is small compared with the quantity of hazardous and other special wastes generated, it may be more economical to consolidate collection services for a variety of hazardous or special waste products in order to reduce collection costs. For example, collection services for end-of-life lamps could be combined with the collection for batteries, small electronics, other mercury-added products, or other waste products or recyclables. Additionally, users may be more likely to take advantage of these services since they may drop off several waste products in one convenient location. 

An alternative to long-term or permanent collection sites is scheduled collection days at temporary locations or mobile collection stations that travel from community to community to pick up and consolidate end-of-life lamps. Care would need to be taken to prevent accidental breakage and releases of mercury during collection and storage by using the most appropriate best practices identified in this code of practice.

A large part of the overall recycling costs in northern and remote areas is the transportation cost; therefore, to determine collection and storage needs, factors to consider will be the location of the processor and available transportation options. In general, the further the distance from the processor, the higher the transportation cost. Controlling overall costs may mean less frequent shipments to the processor and, hence, the capacity to store larger quantities of materials between shipments. Consolidating lamp materials for storage from many waste generators provides an opportunity to share the costs of their management.

Due to limited storage capacity and high transportation costs, facilities in northern and remote communities may choose to employ DTC devices. The use of DTC devices is an allowed practice by many provincial and territorial jurisdictions; however, it is important that DTC devices are equipped with mercury particle and vapour capture systems and are used properly to minimize potential risks to human health and prevent releases to the environment. Subsection 4.3 of the code of practice provides information on best practices and considerations for the use of DTC devices.

14.2. Transportation

Transportation costs are typically the most significant cost for managing end-of-life lamps, and are often barriers to removing these lamps from northern and remote communities. Remote communities that are beyond the road-line may be accessed by air, rail, seasonal roads or boat. All of these modes of transportation are subject to weather constraints, which can further limit access to these communities. Various types of partnerships may provide ways to reduce these costs, including partnerships between communities, with large commercial operators, or by adding lamp collection to existing local recycling programs. 

End-of-life lamps could be shipped by one of these modes of transportation to a partner community that has access to a road or greater transportation network. Once the material has reached a road or railhead, it can be shipped to a processing facility; for example, remote communities that are accessible by infrequent barge or air transport could ship end-of-life lamps to a partner community to be consolidated and transported by road or rail to a processor.

There are a number of large year-round commercial operations, such as mining facilities, in various parts of northern Canada that may be able to provide access to their transportation providers for the removal of end-of-life lamps. These commercial operations could act as intermediate storage sites prior to the material being sent to a processor or could support transport of spent materials out of the communities.

It may be feasible to take advantage of existing local recycling programs (i.e., stewardship or collection efforts for other hazardous or special waste products) to coordinate the collection of lamps with other types of materials or wastes for shipment to processing or intermediate storage facilities. Northern and remote communities often receive new goods by road, air or barge. Opportunities to partner with shipping companies or retailers to leverage backhaul options could reduce costs as well as the number of transport trips required to bring end-of-life lamps to a processor.  

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