Development of a national strategy for disposal of lamps containing mercury: discussion issues
To ensure that lamps containing mercury throughout Canada are disposed in a safe and environmentally sound manner, proper management at each step of end-of-life management is required, as well as communication up and down the management chain. The key steps are collection, transport, storage, processing, treatment, and final disposal or recycling (Figure 4). This section provides an overview of the current status of these actions in Canada and potential goals for a National Strategy. Information included in this section helps inform practices for safe and environmentally sound disposal and guidelines for facilities where these activities are carried out, as suggested in the Act.
Figure 3: Life cycle of a lamp containing mercury
The life cycle of a lamp containing mercury is represented as a closed loop with an arrow at the tail end going back into the loop. An image of a linear fluorescent lamp (LFL) and a compact fluorescent lamp (CFL) is shown in the middle of the circle. Each step in the life cycle is shown as a circle with a representative image inside. The steps are as follows:
- Manufacturing; the image is lamps in a factory
- Purchase; the image is lamps in a shopping cart
- Use of lamp; the image is lamps in an office building and a home
- Collection; the image is lamps in a recycling bin
- Transportation; the image is lamps in a truck
- Processing; the image is lamps going into a funnel and a pool of mercury beside it
- Recycling/Disposal; the image is a drum and a recycling symbol
Collection and short-term storage
A number of actions have been taken in Canadian jurisdictions to establish easily-accessible collection networks for the residential and industrial, commercial, and institutional (ICI) sectors. Information about collection sites (location, types of lamps collected, and sectors they accept lamps from) is available online through the Product Care website for the provinces it operates in (British Columbia, Manitoba, Quebec, Prince Edward Island), while in Nova Scotia this information is found on the Efficiency Nova Scotia website.Footnote 36 Footnote 37
In other provinces and the territories, this information may be available online (e.g. on recycling council websites), but collection sites tend to be fewer in number and sometime less accessible to the public, particularly for residents of rural, northern, remote, and Indigenous communities. In these jurisdictions, some municipalities may operate collection programs for lamps and some retailers may offer voluntary take-back programs, primarily for the residential sector. In addition, in some jurisdictions, collection sites may charge for drop-off of lamps, further reducing incentives to return spent lamps.Footnote 38
Collection and storage of lamps in northern, remote and Indigenous communities is often a challenge due to a lack of collection programs and designated facilities for storage. By implementing best practices, lamps can be safely received and temporarily stored at a convenient drop-off point, such as a retail store or community centre. A National Strategy could seek to identify practical options for collection and storage of end-of-life lamps in these communities, potentially by linking with existing household hazardous waste programs. A National Strategy could also consider training needs for individuals responsible for collection and storage of these lamps.
Another option for northern and remote communities that may be preferred is to accelerate the transition to more energy efficient LED lighting and simultaneously seek to collect all lamps containing mercury. A so-called LED swap out initiative may be more feasible in communities that currently have the resources to segregate and store spent lamps.
Potential goal for a National Strategy:
- All people living in Canada have easy access to programs, services or events that collect and store lamps temporarily.
Provinces and territories generally follow the federal Transportation of Dangerous Goods Regulations to classify spent, broken, or crushed lamps and mercury-rich phosphor for transport, however some provincial and territorial regulations specify how to classify lamps in these different forms.
In Ontario, a special exemption exists for “common mercury waste”, which includes intact or damaged lamps among other items.Footnote 39 A transporter of common mercury waste does not need to be registered for carrying hazardous waste as long as the lamps are being transported to a “common mercury recovery facility”. This exemption works to facilitate programs such as “Take Back the Light”. A similar designation exists in the U.S. under the Universal Waste Rule for lamps that would otherwise be classified as hazardous waste.Footnote 40
The transportation of hazardous waste out of northern, remote and Indigenous communities should be considered a high priority as these communities often do not have access to proper storage or processing facilities. A National Strategy could seek to identify practical solutions for transporting lamps containing mercury out of these communities. Such initiatives could draw from examples of successful past actions by the public or private sector, or could be tied into related existing or planned initiatives for the shipment out of other hazardous wastes or materials. Some lamp processors directly pick up lamps from remote communities and some offer a courier service whereby a pre-paid shipping container, generally a sturdy cardboard box containing a thick plastic liner, is sent to a community along with instructions on how to seal the liner and box to safely prepare it for shipping.
To facilitate storage and transport, some communities and organizations make use of drum-top lamp crushing devices to significantly reduce the volume of spent lamps. Though they are useful for this purpose, these devices require careful use, maintenance, and training for operators to ensure they are not exposed to mercury. In addition, crushed lamps may be classified as hazardous waste in some jurisdictions, which increases the cost of transportation. The Code of Practice provides best practices for their use; however, when possible lamps should be stored and transported intact to processing facilities in order to minimize the potential for mercury exposure to workers during shipping, transportation, and receiving. Another consideration for these devices is that they may not function optimally at the low temperatures they are often exposed to, particularly in Northern communities where a heated storage area is unavailable.
Potential goal for a National Strategy:
- Consider mechanisms to facilitate transportation of lamps between collection and processing facilities.
Processes for crushing the lamps, separating the component parts (glass, metal, plastic, mercury-rich phosphor powder), and disposing or recycling each component are well-established in Canada. The Code of Practice is a source for guidance specific to the separation and fate of mercury, while acceptable and unacceptable practices for disposal or recycling of each component of lamps are listed in requirements for lamp processors in Ontario.Footnote 41 Existing processing technologies are able to recover close to 100% of the material weight. In Ontario, processors must demonstrate an annual diversion rate of greater than 90% (by weight) of lamps and lamp packaging material.
A “common mercury waste recovery facility” in Ontario can process lamps without the need to register as a hazardous waste generator, but cannot dispose of them.Footnote 39 These exemptions exist to increase the number of facilities handling certain common hazardous wastes while reducing regulatory burden.
There are a number of facilities in Canada that separate mercury-rich phosphor powder from other components of the lamps using vacuum-sealed systems that capture any airborne mercury. There is at least one facility each in six provinces, all of which are located close to or within major metropolitan areas. Processing of lamps that are not coated with phosphor (e.g. some UV lamps) can only be done at some of these facilities due to the higher elemental mercury content in these lamps. Separation of the phosphor from the glass is done by mechanical agitation and filtration or through solvent extraction.
In general, processing facilities do not treat the lamp components (e.g. glass) to remove any potential remaining mercury contamination after separating the phosphor powder. This contamination may be minor but not insignificant for human or environmental exposure depending on how these components are later processed or used.
Treatment of the phosphor powder to remove and capture the mercury from lamps is generally done through thermal treatment (retort; other methods such as solvent extraction have been reported). This method is not known to occur in Canada for lamps, though one facility is known to retort other mercury waste. In addition, there are currently no facilities in Canada that purify mercury waste (through multiple distillations) to a commercial grade so that it can be reused in new lamps or other products. Instead, a significant amount of mercury waste, including phosphor powder from lamps, is sent to the U.S. for this purpose.
Potential goal for a National Strategy:
- All mercury from lamps is recovered during processing for reuse or environmentally sound disposal to prevent releases of mercury to the environment and minimize risks to human health.
Recycling or long-term storage/Disposal of mercury wastes
In Canada, some mercury waste, such as contaminated soil or fly ash, is processed into a solid material using a stabilization/solidification (S/S) process prior to final disposal in a hazardous waste landfill. This process produces a stable, water-insoluble material that meets provincial leachate requirements for disposal in these engineered landfills (see below). S/S processes are known to be carried out at two facilities in Canada, while another facility uses a chemical process to stabilize mercury wastes prior to shipment to the U.S. for further treatment.
Only a few provinces have regulations specifically addressing spent lamp disposal, and those that do have variable requirements. Wastes containing mercury are generally classified using the US EPA’s Toxicity Characteristic Leaching Procedure.Footnote 42 Most provinces have set a limit of 0.1 mg/l for leachate from mercury waste that would be considered hazardous, and some provinces have higher leachate limits for disposal in hazardous waste facilities. Some, mostly older, lamps produce a leachate in excess of 0.2 mg/l, while newer lamps generally produce a leachate below 0.1 mg/l.Footnote 43 Some U.S. states have implemented disposal bans (i.e. non-hazardous waste landfills) on all lamps containing mercury.Footnote 44 Some Canadian municipalities have also implemented disposal bans.Footnote 45 The quantity of mercury entering landfills due to lamps has been reduced from the 1150 kg estimated in 2001 to an estimated 200-400 kg, however information on end-of-life management is incomplete. A National Strategy could seek to update this information and report on progress.
In 2015, 55 tonnes of mercury and its compounds were disposed on-site at facilities in Canada (mostly at two hazardous waste landfills), 50 tonnes were disposed off-site or treated prior to off-site disposal, and 24 tonnes were sent for off-site recycling (primarily metal recovery, in the U.S.).Footnote 46 Tracking how the mercury recovered from lamp waste is ultimately disposed or re-used is challenging due to its consolidation with other types of mercury waste and cross-border shipments (Canada also receives mercury waste from the U.S. for disposal). The re-use of mercury recovered from waste for new lamps and other products could be considered as part of closing the loop on this toxic material. As Canada does not have facilities to purify mercury to commercial grade or to store elemental mercury, development of such a facility could also be considered.
Potential goals of a National Strategy:
- Information is updated and made available on the quantity of mercury entering non-hazardous waste landfills from lamps
- Disposal of lamps containing mercury in non-hazardous waste landfills and all incinerators is prevented
Public awareness, education and participation
A key element of a National Strategy could be efforts to increase participation in end-of-life lamp programs from all sectors by increasing awareness and education of the hazards associated with lamps containing mercury, the importance of end-of-life management, and the programs, services, sites, and events available to return spent lamps.
Even when returning lamps is free, some users may choose not to because they may be unaware of the presence or hazards of mercury. In 2015 only 43% of Canadian households reported returning their spent lamps (LFLs and CFLs) to a depot or retailer, while 41% put them in the garbage and 18% still had them.Footnote 47 Comparable information for the ICI and CRD sectors is not available.
In provinces with extended producer responsibility (EPR) for lamps, Producer Responsibility Organizations are responsible for informing users of the hazards associated with lamps containing mercury as well as the availability of programs for the collection of lamps at end-of-life. In some provinces, public awareness campaigns have been comprehensive in using products such as advertising on TV and in public spaces such as transit, community events, displays at point of sale and point of return, hotlines, and informational webpages. Several provinces also set targets for and measure consumer awareness.
Provinces and territories without EPR for lamps, as well as many municipalities, may conduct public awareness programs for lamp recycling. Additional information on the scope and costs of these programs, as well as their impact on capture and diversion rates, would help inform development of a National Strategy. A National Strategy could use successful programs as a guide to designing a potential broad public awareness campaign.
Potential goal for a National Strategy:
- All Canadians are aware of the hazards associated with lamps and other products containing mercury, the importance of recycling them, and the programs, services, sites, and events available to return spent lamps.
Measurement and reporting
In provinces with legislated EPR for lamps, the capture rate is defined as the amount of lamps collected, divided by a baseline that is calculated slightly differently by each of the provinces.Footnote 48 In BC and Manitoba, the baseline is the amount collected as a percentage of the quantity of lamps available to collect in the same year based on prior sales and expected lamp lifespan. In Quebec, the quantity collected is compared to sales in a reference year (e.g. 2014 sales for the 2016 capture rate), and in PEI the comparison is to sales in the same year as collection. In the European Union, this metric is called the collection rate and the reference is the average volume put on the market over the last 3 years. The targets set for lamp capture rates vary between the provinces with EPR.
However it is measured, the rapid transition to LEDs has resulted in uncertainty in setting a capture rate, with many users bringing back lamps before end-of-life, resulting in capture rates sometimes exceeding 100% for some categories in some years in BC and Manitoba. For this reason, Product Care Association is moving away from capture rate targets as they renew their stewardship plans with provinces. They are instead intending to measure absolute collection by regional district, and to measure program success with targets for other metrics such as accessibility (see below) and awareness.Footnote 49
Another key metric to measuring end-of-life management is the diversion rate, also known as the recycling rate or the recovery rate. It is the measurement of the amount (by weight) of material received by a processor that is ultimately diverted from landfill. In Ontario, lamp processors must demonstrate an annual diversion rate of 90% of lamps and lamp packaging. The EU has an 80% lamp diversion rate target and a requirement to recover 100% of the mercury from those lamps.Footnote 50
Capture rates tend to correlate with accessibility of lamp users to collection sites or pick-up services. BC’s stewardship organizations measure and set targets for accessibility for residents to collection points for materials subject to EPR legislation. The accessibility standard applies to communities of more than 4000 people, and is met when a collection site lies within a 30 or 45 minute drive from a household, depending on whether the resident lives in an urban or rural area, respectively. The accessibility targets are set at 95% for both commercial and residential sources, and as of 2016 the targets were exceeded.Footnote 51 In Quebec, accessibility to collection site is prescribed in legislation and is based on the size of a community. For example, at least one seasonal collection site (open at least one day per season) is required for a community with less than 15,000 inhabitants, while 3 full-time collection site, plus an additional collection site for each 50,000 inhabitants, is required for a community with more than 100,000 residents.Footnote 52
Stewardship organizations for other products subject to provincial EPR regulations report using additional or different metrics. Electronic waste is a more complex sector than lamps in that the products have variable lifetimes, weight, and a vast repair and reuse market. Therefore, stewardship for this waste stream is focused on improving accessibility to and awareness of the program. Some EPR programs focus on increasing the number of product categories consumers can return. Tire stewardship programs in some provinces track the type of processing used after being returned, with targets for increasing the use of the most environmentally-sound processes. Other measurements and targets for EPR products include the cost per capita to recycle a product, the weight of a product collected per capita, the number of collection events, and the number of participating stewards, among others.
Northern, remote, and Indigenous communities
It is challenging to precisely estimate the number of lamps containing mercury currently in use in Northern, remote, and Indigenous communities throughout Canada. In the territories, for example, based on per capita U.S. data,Footnote 53 the current estimated use of CFLs and LFLs is each around 800,000 to 900,000, and between 10,000 and 100,000 HID and specialty lamps are expected to be in use, which collectively contain around 10 to 15 kg of mercury.
Northern, remote, and Indigenous communities have a range of access (or no access) to collection and storage options for spent lamps, depending on the community. Collection and storage is often a challenge due to a lack of resources, facilities for storage, waste management workers, and collection programs. Where hazardous waste segregation and storage facilities do not exist, lamps are very likely to be disposed in the community landfill.
The transportation of hazardous waste out of northern, remote, and Indigenous communities is a necessity for environmentally sound disposal as all lamp processing facilities in Canada are located in southern Canada. In provinces with EPR, stewardship organizations running programs for various materials (e.g. electronic waste) often pool together resources to conduct collection events of multiple materials from these communities. Producer Responsibility Organizations in Alberta and BC have been known to work with waste management or stewardship organizations in Northwest Territories and Yukon to bring materials to processing facilities. However, there is currently a lack of information on the frequency and effectiveness of these collection programs.
To facilitate storage and transport, some communities make use of drum-top lamp crushing devices to significantly reduce the volume of LFLs and with some drum-top crusher models other lamps are also crushed. A typical device can store over 1000 lamps in a single drum and are useful for facilitating transport. These devices require careful use, maintenance, and training for operators to ensure they are not exposed to mercury. Northern, remote, and Indigenous communities may face a lack of access to replacement parts and trained operators, which increases the risk of mercury exposure to workers and the environment. In addition, these devices may not function optimally at low temperatures. This is problematic, particularly in Northern communities, where a heated storage area is often unavailable, and the extreme range of temperatures may increase wear and tear of these devices.
A National Strategy could seek to identify practical options for collection and storage of end-of-life lamps in these communities, potentially by linking with existing household hazardous waste programs, and by considering training needs for individuals responsible for collection and storage of these lamps. By implementing best practices, lamps can be safely received and temporarily stored at a convenient drop-off point, such as a retail store or community centre. Transportation out will depend on the community but could include working with Producer Responsibility Organizations to facilitate collection of lamps and other materials (even if lamps are not covered by EPR legislation in that jurisdiction). Other options include courier services and an LED swap out initiative.
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