Making light work of waste
The WEEE Directive is a complex piece of legislation that everyone in the electrical industry needs to
understand. Ernest Magog of Lumicom explains its implications for lighting.
When the much delayed Waste Electrical and Electronic Equipment (WEEE) Directive came into force in
January 2007 it was immediately apparent that several aspects of it are open to different interpretations. In the intervening period specialist organisations such as our own have been able to clarify these issues and help those at the ‘sharp end’ understand how it affects them.
The Directive covers the majority of equipment that has a power supply and one of the most challenging areas to get to grips with is lighting. This is because waste lighting products often include components that are classified as hazardous waste, so handling end-of-life light fittings on site requires special care and attention.
As well as understanding how to manage this waste stream, it’s also important that electrical contractors
understand their obligations and responsibilities under the WEEE Directive. In fact, in most cases, the
contractor bears no financial responsibility as the lighting industry itself is responsible for facilitating compliant disposal.
The WEEE Directive divides waste into two main categories. There is historic waste, installed before 13th
August 2005, and future waste, installed after that date. Future waste is marked with a crossed out wheelie bin to indicate that it cannot be consigned to the general landfill waste stream.
With historic waste, the producer of any replacement equipment is responsible for facilitating an infrastructure that will accept historic waste. In the case of future waste, it is the producer of the discarded waste that bears this responsibility. This effectively means that lighting manufacturers are responsible for the disposal of the majority of discarded light fittings from refurbishment and refit projects.
Similarly, suppliers of lighting equipment for current new-build projects will be responsible for disposing of those products when they are removed in the future. In most cases this will be through an accredited scheme such as the notfor- profit organisation Lumicom.
However, if there are no replacements, such as in a demolition project, then the responsibility for disposal falls to the end user if the products were installed before 13th August 2005.
Very small quantities of fittings (perhaps just one or two units being replaced) are treated in the same way as household waste so they could be taken to a local recycling centre.
So one of the important things here is to be clear about who is doing what before the project starts and ensure the end client understands their responsibilities. For example, once the light fittings have been separated into their various components (see below) it will usually be necessary to transport the waste to special ‘bulking up’ points. This will involve additional transportation costs and, if the contractor takes on this
responsibility as part of the contract, these extra costs need to be reflected in the price.
Beyond these practicalities it will also be helpful to the end client if the contractor is able to provide advice that will ease any future disposal. For instance, most projects use a range of light fittings from different suppliers so when the time comes to dispose of the fittings building owners could find themselves trying to
deal with half a dozen companies.
A simpler approach is to ensure that the various companies supplying light fittings are all members of the same disposal scheme, so that there is a single point of contact and a single contract for disposal. Clearly, it’s important to select a scheme that includes the major lighting manufacturers and has an infrastructure for disposal in place.
In addition, any lighting suppliers used for the project should be able to provide a WEEE registration number so you know they are geared up for responsible disposal in compliance with the Directive.
Separating the waste
As mentioned above, the contractor may also bear the responsibility for managing waste light fittings on site. In particular, any fittings that use discharge light sources (fluorescent, metal halide, sodium, mercury vapour) need to have the lamps separated from the light fittings before they are sent for disposal.
This is because discharge lamps contain small amounts of mercury and are classified as hazardous waste – requiring special disposal procedures to be carried out by an accredited waste company. While on site, these lamps are also subject to special handling and storage requirements. “Storing discharge lamps on site introduces a number of Duty of Care considerations, such as the Control of Substances Hazardous
to Health (CoSHH) regulations,” explains Bryan Neill of Mercury Recycling. “Any such lamps need to be stored in secure containers that have been designed for the purpose and accompanied by the necessary
warning signage,” he adds.
The choice of waste contractor for lamps is also important as discharge lamps are among the most
complex of products to recycle, requiring specialist equipment only available at a few locations in the UK. “For the glass to be re-used after crushing the phosphors have to be stripped off, and these phosphors are then subjected to very high temperatures (around 800ºC) to distil the mercury and reclaim it as a pure liquid. Sodium is also reclaimed and any ferrous and non-ferrous metals are also separated and sent for re-use,” Bryan Neill continues.
As well as lamps, other components that need to be separated include batteries in self-contained emergency luminaires. Some waste disposal contractors will be prepared to take away whole fittings and carry out the separation themselves but others will require that work to be carried out on site prior to collection.
Failing to separate waste properly can be very expensive as the majority of discarded luminaires are shredded into small pieces of metal and plastic and sold as raw material – much of which ends up in the Far East and goes back into manufacturing. If the hazardous components were not separated first the
entire batch could be contaminated. This would significantly increase the cost of disposal and could lead to legal action under hazardous waste regulations.
As with all such legislation-driven requirements there is also a need to be able to prove that regulations have been complied with through a thorough audit trail that documents all of the actions that have been taken. In wider-ranging projects that involve more than removal of lighting products this will need to fit into other waste management activities on site. For example, the Department of Environment, Food and Rural Affairs (DEFRA) has recently issued guidance to construction companies, requiring them to minimise the waste they generate and make plans for safe and responsible disposal of waste that cannot be avoided. They must also produce a proposal detailing how they will adhere to those plans.
For all of these reasons it’s important to be familiar with the regulations relating to disposal of light fittings and other WEEE products. Just as importantly, it makes sense to work with an established compliance scheme that has the necessary infrastructure in place, can take care of the complexities and provide a full audit trail. You are then left to get on with your core business.
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