Proposed code of practice for management of end-of-life lamps containing mercury: chapter 6

6. Tracking and Inventory Systems

Collection facilities, waste management facilities and transporters should implement a tracking and inventory system to ensure that collected lamps are accounted for and reach the processing or disposal facility by following them through every stage of management including the primary collection site, intermediate storage, transportation, and processing and/or disposal.

The responsibility for tracking and maintaining inventory systems is shared among the collector, transporter, processor and waste management facility. Each of them has the responsibility to comply with all federal, provincial and territorial requirements for tracking and maintaining inventory systems.

When designing the tracking and inventory system, it is important to consider whether there is an extended producer responsibility program in the province or territory (which may have its own tracking and reporting mechanism or specific reporting requirements), the complexity of the chain of custody (e.g., the number of intermediate stops the lamps make as they move toward final processing), and whether the lamps are considered hazardous and require movement documents under federal, provincial and/or territorial legislation.

Activity Best Practices
Tracking and inventory systems
  • A tracking and inventory system should record the types and quantities of lamps received, stored on site and shipped off site.
  • Information contained in the tracking and inventory system of each point in the chain of custody should include:
    • date of receipt of the shipment;
    • point of origin of the end-of-life lamps;
    • type and quantity (in units, not weight) of lamps received, stored, shipped;
    • intended point(s) of delivery (materials should be delivered to an authorized receiver);
    • date of delivery;
    • description of the operations or activities to be undertaken at each point in the flow or chain of custody; and
    • name of a contact person for information and/or of the person who certifies that the information is correct.
  • The tracking and inventory system should have the capacity to provide information on the actual number of lamps on site (for facilities) or in a shipping container (for carriers), how long the lamps have been on site or in a shipping container, and where the lamps are located within the facility.
  • The tracking and inventory system should reconcile quantities received and stored with quantities shipped, while also tracking accumulation.
  • To ensure that end-of-life lamps are destined for environmentally sound management, the tracking system should track the flow and handling of lamps from collection points through each downstream processor to the final point(s) of disposition or destination.

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