Proposed code of practice for management of end-of-life lamps containing mercury: chapter 7


7. Transportation

Transportation requirements are prescribed by the authority that has jurisdiction, which is typically the provinces and territories. End-of-life mercury-containing lamps should be transported in such a way as to avoid accidental spills and track the transportation of the waste to its destination. Whether transported between primary collection facilities to intermediate storage facilities or from intermediate storage facilities to final processing facilities, the following are best practices for the transport of end-of-life lamps.

Activity Best Practices
Authorized carrier
  • Transporters of end-of-life mercury-containing lamps may be authorized carriers as required by federal, provincial, or territorial legislation and requirements.
Containers
  • Lamp container labels should be compatible with the tracking and inventory system and be in accordance with all applicable regulations and requirements. The label may include the following information:
    • name and address of shipper;
    • quantity and type of lamp being transported within the container; and
    • name and address of receiver.
  • Where the lamps are considered hazardous under federal, provincial and territorial jurisdictions, the containers with such material may be required to have the following additional information for the purposes of transport:
    • provincial or territorial waste description; and
    • movement document or manifest, if applicable.
  • Where the lamps are considered “dangerous goods” under federal, provincial and territorial jurisdictions, the containers with such material may be required to have the following information for the purposes of transport :
    • appropriate shipping name, class, and packing group and hazard labels in accordance with federal, provincial or territorial transportation of dangerous goods regulations.
  • Lamp containers should not be underfilled or overfilled. If underfilled, the contents can move and cause breakage; overfilled containers may crush the lamps. See subsection 4.4.
  • Lamp containers should be properly secured during transport. Means for securing containers may include, but are not limited to, pallets (commercially available wooden or plastic structures that provide four-way access to material-handling equipment), strapping (either plastic or steel straps, used to hold goods on pallets), and tie-downs or anchor straps (either plastic or steel used to restrain pallets while in transit).
Transporting crushed lamps
  • Crushed lamp materials may be considered “dangerous goods” under the federal Transportation of Dangerous Goods Regulations, and if so, there is a need to comply with these regulations when they are being transported.Footnote13
  • Transboundary and interprovincial movements of mercury wastes defined as hazardous waste or hazardous recyclable material must comply with the requirements of the federal Export and Import of Hazardous Waste and Hazardous Recyclable Material Regulations and the Interprovincial Movement of Hazardous Waste Regulations.
  • Movements of mercury wastes that are considered hazardous would also need to comply with applicable provincial or territorial requirements.
Insurance
  • A carrier transporting end-of-life lamps (whole or crushed) containing or contaminated with mercury may be required to have, in accordance with applicable federal, provincial and territorial regulations, some or all of the following:
    • a minimum amount (e.g., $1,000,000) for commercial liability insurance;
    • a minimum amount (e.g., $250,000) for load insurance;
    • cross-liability for the generator of the materials;
    • emergency response plan;
    • on-board spill kit as part of its service;
    • valid waste transporter permit where required;
    • extended environmental impairment insurance;
    • proof of staff training as required by the Transportation of Dangerous Goods Regulations;
    • proof of staff training as required by environmental regulation;
    • proof of on-vehicle containment; and
    • proof of emergency response capability.
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