Proposed code of practice for management of end-of-life lamps containing mercury: chapter 4


4. Collection and Storage

The collection and segregation of end-of-life mercury-containing lamps for proper recycling and treatment prior to disposal diverts them from the general waste stream. This in turn reduces the amount of mercury going to municipal landfills or incineration, where it is difficult and expensive to address mercury releases to air, leachate and waste water effluent. The lamps should be properly and securely collected and stored, using the best practices that follow, until they are sent for processing, treatment and/or disposal at an authorized waste management facility.

4.1. Collection Mechanisms

Convenient collection services make it easier for consumers to return lamps, which improves diversion rates for lamp recycling programs. Examples of collection mechanisms used in Canada include:

Municipal collection stations or drop-off depots for household hazardous waste or special wasteFootnote4: Designated collection facilities owned and operated by municipalities accept end-of-life mercury-containing lamps for proper management. Municipal household hazardous waste depots located at the landfill are the most typical municipal drop-off locations. Other drop-off locations include municipal buildings and collection events. Accessibility of drop-off locations and frequency of service can vary from one municipality to the next depending on factors such as the size and population distribution of the municipality. Smaller municipalities are more likely to hold collection campaigns or event days rather than have permanent drop-off locations.

Retail take-back programs: Retail take-back programs offer users an easy and convenient location to drop off spent lamps for proper recycling. Collection containers are typically placed near the store’s entrance, and drop off is free of charge. This option is often found in provincial jurisdictions with regulated extended producer responsibility programs. It is common for retailers to only accept compact fluorescent lamps (CFLs), although some offer collection services for fluorescent tubes and other lamps as well.

Pick-up services: Waste generators call their local municipality or supplier to schedule a pick-up of their spent lamps. Many of the regulated extended producer responsibility programs offer this service free of charge to residential and commercial users since the recycling fee is paid when the lamps are purchased. In Canadian jurisdictions without such regulated programs, service providers provide pick-up of spent lamps for a fee for commercial users.

Pre-paid shipping service: A consumer purchases a box designed to store and ship spent lamps for recycling. The recycling service and shipping costs are included in the cost of the box. When the box is full, the user seals the box and ships it directly to the recycler. Pre-paid shipping boxes are convenient for small waste generators and, in particular, those in northern or remote locations with limited transportation options.

Procurement programs: Commercial users recycle spent lamps via the procurement and acquisition of goods or services in a reverse logistics collection program. First, businesses include end-of-life management in their request for proposals or purchasing contracts for replacing spent lamps. Consequently, the cost of lamp recycling is part of the purchase price. Then, when the service provider replaces the mercury-containing lamps, they remove and transport the spent lamps, using the same truck used to transport the new lamps to the user, back to their warehouse where the lamps are stockpiled before being transported to an authorized lamp processor. A reverse logistics collection model improves efficiency by distributing and collecting lamps in the same trip.

4.2. Collection Sites and Facilities

There are three main types of collection and storage facilities: primary collection sites, intermediate consolidation storage facilities, and warehousing and commercial consolidation storage facilities.

Immediately following the collection from residents or businesses, end-of-life mercury-containing lamps are usually held at a primary collection site. These collection sites include municipal waste depots, municipal buildings, retail locations and private collection sites. Primary collection sites should have sufficient space to sort and separate different types of lamps, as certain processors require lamps to arrive at their facility pre-sorted. These sites should also have adequate capacity to store lamps separately from other materials to prevent the mixing of incompatible materials and to maintain the integrity of the tracking system.

From the primary collection site, end-of-life lamps may be sent to an intermediate consolidation facility where they are added to other lamps prior to being sent to the processor. The requirements for managing end-of-life lamps at these facilities depend on the requirements of the Canadian jurisdiction and whether end-of-life lamps are considered hazardous waste under the provincial or territorial legislation in which the facilities operate. In some cases, spent whole lamps are exempted from provincial or territorial waste management legislation, and they can be managed in a manner similar to new lamps, as long as they are destined for a recycling facility. Crushed lamps are typically subject to provincial or territorial hazardous waste management regulations, and therefore may be subject to specific management requirements for such waste.

In addition, end-of-life lamps can be collected and temporarily stored at warehousing or commercial consolidation facilities provided that the material is not considered hazardous by the provincial or territorial jurisdiction in which the facility operates. A commercial consolidation facility can be a retail or commercial facility that collects small quantities of lamps from either the general public or other commercial operators.

4.3. Drum Top Lamp Crusher Devices

It is preferred that lamps are kept whole and unbroken during storage and transport in order to minimize potential human exposure to mercury and prevent releases to the environment by containing the mercury within the lamps until they reach the processing facility. However, it may be necessary or practical to store and transport lamps in a crushed state in some circumstances. Where storage space is limited or transportation is so costly (for example, in northern and remote communities) as to make it impractical to store or transport whole lamps, collection and storage facilities could choose to employ drum top crusher (DTC) devices to reduce high volumes of lamps to facilitate storage and transport. 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.

DTC devices can be manual, electrical or air powered. The crushing unit is typically mounted on the lid of a 205-litre drum. All of the crushed materials (glass, phosphor, metal, plastic and mercury) are contained in the drum. Airborne mercury phosphor powder and mercury vapour are captured by a combination of a series of High Efficiency Particulate Arrestor (HEPA) and activated carbon filter systems. The amount of airborne mercury particles that each filter can handle depends on the mercury content of the bulbs and the number of bulbs that are crushed. It should be recognized that older bulbs that are now reaching end of life are likely to have higher mercury content than those currently on the market. The manufacturer’s specifications and instructions should detail handling procedures that minimize human exposure and prevent mercury releases to the environment.

Operators and facilities that employ DTC devices should also be aware that changing mercury-containing bulbs from a whole to a crushed state may result in the material classification changing from a non-hazardous to a hazardous material under provincial, territorial and federal legislation. This change in classification can mean additional requirements for permits, management, transportation and/or disposal for the material. For example, exports and imports of crushed lamps that meet the leachate test criteria for mercuryFootnote5 would be considered hazardous waste or hazardous recyclable material under the federal Export and Import of Hazardous Waste and Hazardous Recyclable Material Regulations and would be subject to the requirements of these regulations. The following are best practices for the use of DTC devices.

Activity

Best Practices

Drum top crushers
  • DTC devices should be used and operated according to the manufacturer’s specifications and instructions, which may include, but are not limited to,
    • handling procedures;
    • a limit on the number of bulbs that can be processed before the filters must be changed;
    • shutdown instructions;
    • drum change instructions;
    • maintenance and filter change schedules;
    • inspection and maintenance procedures;
    • procedures for air quality testing in the immediate operational area on a real-time basis; and
    • information on the use of personal protective equipment such as puncture-resistant gloves, safety glasses, respirators and protective coveralls or clothing.
  • Operators should carefully monitor and record (in a log) the number of lamps crushed to ensure that the containment drum is not overfilled and that the mercury vapour and particle capture systems are working efficiently and within capacity.
  • Filters should be changed once capacity is reached or in accordance with the manufacturer’s instructions and schedule. Spent filters should be managed in accordance with applicable federal, provincial and territorial regulations and requirements, which may include managing them as hazardous waste.
  • Special care should be taken when the containment unit is full and the crushing unit is transferred to a new drum to minimize human exposure to mercury and prevent spills. Special care includes allowing the drum contents to settle before removing the crushing unit (US EPA 2009), wearing personal protective equipment, and handling the drum in a manner that does not tip the drum and cause spillage.
  • Crushed lamps should not be transferred from one container to another, as this could result in increased amounts of mercury becoming airborne. The full drum of crushed lamps should be promptly sealed for shipment to an authorized lamp recycler or disposal facility.
  • Maintenance logs and manufacturer’s manual should be kept with the DTC device (US EPA 2009). 
  • Operators should be fully trained in the operation and use of the DTC device and be aware of the potential health risks from exposure to mercury. See section 12.
  • The United States Environmental Protection Agency’s document on Fluorescent Lamp RecyclingFootnote6 may be consulted for further information on best practices for using DTC devices.

4.4. Handling, Collection, Packaging and Storage

End-of-life mercury-containing lamps should be handled, collected, packaged and stored in a manner that minimizes the potential for human exposure to the hazards associated with the material and prevents accidental breakage or contamination that can lead to releases of mercury to the environment. Effort should be taken to ensure the lamps remain whole and unbroken, which includes using proper storage containers and training staff on the safe handling of lamps. The following are best practices for the collection and storage of end-of-life mercury-containing lamps.

Activity

Best Practices

Collection and handling
  • Operators of collection sites should post information on or near collection bins, boxes or containers with instructions on how the lamps should be deposited to prevent breakage. Instructions should clearly indicate that lamps be carefully placed one at a time into the container, to minimize free fall of the lamp to the extent possible, and to avoid putting a lamp into a full container.
  • Designated containers should be used exclusively for end-of-life lamps and not other waste. Separate containers should be used to collect different types of lamps, e.g., fluorescent tubes should be collected in a separate container from CFLs. Containers for collecting CFLs should minimize free fall by installing soft, cascading baffles or flaps or other means to prevent breakage. Another option is for the consumer to give the lamp to a competent operator of a collection station to place in a container (UNEP 2011).Footnote7
  • Containers should be monitored and replaced with an empty container when full.
  • Containers should be located in a well-ventilated area, and away from high-traffic areas to avoid accidental bumping or tipping of the container.
  • Collection sites should have sufficient space to sort and store lamps. Lamps should be sorted and stored by type, taking into consideration any pre-sorting requirements of the processing or recycling facility to which the lamps will be sent.
Packaging and labelling
  • End-of-life lamps should be packed in a manner that prevents breakage during storage and transit and that provides containment of mercury vapour or airborne mercury-containing particles in the event of breakage. Do not try to fit more lamps than the container can hold or force a container to close. Use appropriate additional packaging material, as needed, to prevent loose lamps from moving freely in a container.
  • End-of-life lamps received at collection sites and storage facilities that are loose or unpackaged should be packed in commercially available containers (e.g., 20-litre pails, 205-litre drumsFootnote8) or alternative packaging that prevents breakage of lamps in transit.
  • Containers for whole lamps should:
    • be durable, structurally sound, undamaged, stay upright when partially and fully packed (i.e., not prone to tipping over) and constructed to provide protection from breakage during storage and transit;
    • be clearly labelled to identify the contents, e.g., “waste lamps containing mercury” or “used lamps containing mercury”;
    • be closed at all times unless lamps are being added to the containerFootnote9; and
    • contain lamps only, and not contain other debris or hazardous material that could break the lamps, contaminate a larger amount of material, and/or hinder proper recycling and treatment.
  • Containers for crushed lamps should:
    • be durable, structurally sound, undamaged and constructed to prevent releases of mercury and mercury-containing materials to the environment (e.g., a steel drum with a secure fitting lid);
    • be clearly labelled to identify the contents, e.g., “crushed lamps containing mercury”;
    • be closed or sealed at all times; and
    • be managed by trained staff.
Storage
  • Lamps should be kept apart from other wastes until they are sent to an authorized processing or waste management facility.
  • Lamps should be stored for a limited period of time (e.g., no longer than one year), and as allowed by municipal, provincial or territorial jurisdictions.
  • Storage containers should be stored in such manner that they will not tip, fall, or be hit or bumped.
  • Lamps should be stored in a location that:
    • is protected from the outdoor elements (ideally in an enclosed or covered facility or structure that is not usually frequented by people), with protective cover, wrapping or packaging to prevent breakage;
    • is well ventilated. For large amounts of lamps, the storage area should be a separate area or room, preferably with a ventilation system segregated from the rest of the building. Crushed lamps should be stored in a sealed container or drum outdoors and under protective cover;
    • prevents exposure to and contamination with incompatible materials; and
    • prevents unauthorized access to the materials.
  • Storage sites should have posted signage indicating the presence of mercury-containing materials.
  • Storage sites should have insurance as required by provincial or territorial jurisdictions to cover potential liability to third parties and for environmental cleanup.
  • Inspection protocols should be implemented on a regular basis to ensure compliance with all proper storage requirements as well as health and safety protocols.
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