Proposed code of practice for management of end-of-life lamps containing mercury: chapter 5


5. Materials Management and Emergency Response Plans

Collection sites, storage facilities, transporters and waste management facilities should have a material or hazardous waste management plan, with an emergency response plan, to respond to spills, fires and other emergencies that might occur in accordance with federal, provincial, and territorial legislation and requirements.

Activity

Best Practices

Materials management plan
  • Facility or transporter should have a material or hazardous waste management plan in place, with information specific to the handling and management of end-of-life lamps, including:
    • proper and safe storage (see subsection 4.4);
    • spill control, and cleanup protocols and procedures (see subsection 5.1);
    • emergency plan and procedures, and access to emergency response equipment;
    • worker health and safety training (including hazard identification, hazard mitigation, proper use and access of personal protective equipment); and
    • record keeping (see sections 6 and section11).
Emergency response plan
  • Facility should have up-to-date emergency response plan(s). The principal elements of an emergency plan may includeFootnote10:
    • a description of the substance or material which may include: the properties and characteristics of the substance and the maximum expected quantity of the substance at the place at any time during a calendar year; the commercial, manufacturing, processing or other activity in relation to which the plan is to be prepared; the characteristics of the place where the substance is located and of the surrounding area that may increase the risk of harm to the environment or of danger to human life or health; and the potential consequences from an environmental emergency on the environment and on human life or health;
    • the identification of any environmental emergency that can reasonably be expected to occur at the place and that would likely cause harm to the environment or constitute a danger to human life or health, and identification of the harm or danger;
    • a description of the measures to be used to prevent, prepare for, respond to and recover from any environmental emergency identified;
    • a list of the individuals who are to carry into effect the plan in the event of an environmental emergency and a description of their roles and responsibilities;
    • the identification of the training required for the individuals who are to carry into effect the plan;
    • a list of the emergency response equipment included as part of the environmental emergency plan, and the equipment’s location; and
    • a description of the measures to be taken by the facility or persons authorized by the facility to notify members of the public who may be adversely affected by an environmental emergency and to inform them of those measures and of what to do in the event of an environmental emergency.
  • Emergency response plan and equipment should be readily accessible to facility workers and third-party responders.
  • Facility workers and transportation operators should receive training on the emergency response plan and procedures to follow in case of accidental spills.
  • Emergency response plan should be updated and tested at least once a year to ensure that it continues to meet the requirements.
Reporting of emergencies and spills
  • Emergencies and spills that occur during collection, storage, transportation and processing should be reported in accordance with federal, provincial and territorial legislation and requirements.

5.1. Managing Spills and Broken Lamps

Collection sites, storage facilities and transporters should have a protocol for managing broken lamps and spills that may occur during storage or transit. Broken lamps should be cleaned up as soon as possible, and care should be taken during cleanup to minimize potential human health risks from exposure to mercury and prevent releases of mercury to the environment. Information on cleanup procedures for broken fluorescent lamps is published on Health Canada’s website.Footnote11 The United States Environmental Protection Agency also provides information on how to clean up broken lamps containing mercury.Footnote12 Best practices for the cleanup and management of broken lamps include the following.

Activity

Best Practices

Cleanup materials and spill kits
  • Commercially available spill kits specifically designed for cleanup of broken mercury-containing lamps and cleanup materials should be readily available to workers at all locations within the facility where lamps are being handled or stored. 
  • Spill kits should include gloves, storage containers for broken pieces, and paper towels and sticky tape (such as duct tape) to pick up any remaining small glass fragments and powder.
Management of waste contaminated with mercury
  • Broken lamps and associated waste materials should be stored separately from whole lamps. 
  • Broken lamps should be managed as mercury waste and are usually accepted by the same end processors as whole lamps.
  • Broken lamps should be stored in a sealed container (preferably glass or metal) in a cool, dry location and away from high-traffic areas. Containers of broken lamps should be closed at all times and not be opened to add or remove broken lamps. It is advisable that containers of broken lamps are single use; once broken lamp materials are placed in the container, the container should be sealed and disposed of similarly to other mercury wastes.
  • Materials that have become contaminated with mercury (i.e., material used to clean up spills and broken lamps) should be managed and disposed of similarly to other mercury waste, and not with regular garbage.
Reporting of spills
  • Spills that occur during collection, storage, transportation and processing should be reported in accordance with federal, provincial, and territorial legislation and requirements.
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