CFL Recovery, Recyling & Disposal
Implementation Guideline
CFL Waste Management
Implementation Guidelines
Waste handling activities
Separation at Source:
Separate CFLs from normal waste stream
Private Transportation:
Homeowner delivery to collection point
Drop off Centres:
Centrally-located CFL collection points
Transport:
Bulk transport of CFLs
Storage and Treatment:
Temporary storage and treatment (if required)
Disposal:
Disposal at an H:H-permitted landfill facility
Recycling:
Recovery of components and mercury for re-use
Fund and Administration Oversight:
Proposed function to oversee all aspects of CFL recovery
An overview of best practice to ensure compliance with relevant
legislative requirements for the responsible handling of spent
Compact Fluorescent Lamps (CFLs).
Best practice for CFL waste management
The need for an environmentally acceptable, yet cost effective,
spent Compact Fluorescent Lamp (CFL) management programme
has become one of the environmental priorities in South Africa.
The main objective of this document is to provide practical guidelines
for the best available technologies and practices to all stakeholders
conducting any activities related to both the disposal or recycling of
spent CFLs.
Environment considered
Increasing environmental consciousness,
the prominence of climate change
concerns and energy constraints globally
have prompted an intensified focus on
energy efficiency measures, resulting in a
significant increase in the usage of CFLs.
1
Roles and Responsibilities
Distinct roles and responsibilities arise for all stakeholders conducting any management activities related to
both the disposal of spent CFLs to a hazardous landfill (short-term intervention) or to a recycling facility (longterm intervention).
The short-term interventions include separation at source, drop-off centres, collection, storage and treatment,
then transportation to a hazardous landfill for disposal, as an immediate solution. Long-term interventions,
which in time should replace short-term activities, will instead of disposal require the recycling of as
many of the constituent materials of the spent CFLs as possible and setting out the relevant responsibilities.
Each of these steps is set out on the next page, and the key roles and responsibilities of the parties
concerned with the managementof spent CFL waste, are discussed.
How to use this document
The steps and activities for safe management of CFL waste, from
separation at source to ultimate disposal at a hazardous landfill
site or to a recycling facility, are outlined in the various sections
on the next page. Each section is colour-coded in accordance with
the specific identifying icon, for ease of reading. Within each of the
‘steps’ the various stakeholders involved and their responsibilities
are tabulated separately.
As an EXAMPLE, a representative from a local municipality
interested in initiating retail drop-off centres in the municipal
area would:
STEP 1: Identify from the list of icons (refer cover page) the relevant
one for drop-off centres.
STEP 2: The blue-grey colouring of the identified icon
indicates the colour of the section of the document that deals with
drop-off centres.
STEP 3: Locate within the identified section tabulated guidelines
specific to a local municipality.
CFL Waste Management
An overview of the chain of activities that forms part of the management of CFL waste, from point of generation at the household to eventual
disposal or recycling, is summarised at a high level below. Further detail and clarification of concepts are covered in the respective subsections
(refer colour-coded sections) of this guide.
No CFLs to general
landfill
No mercury released No mercury
in transport
released in storage
No mercury
released in transport
No mercury released
No mercury released
No mercury released and no contaminated
components
Implementation
Guideline
Safe keeping to
prevent breakage
Suitable container
to prevent breakage
Safe intermediate
storage
Safe bulk
transportation
in suitable containers
Environmentallysound practice/
technology
Environmentallysound practice
Environmentallysound practice/
technology
Roles and
Responsibilities
Consumer/
Householder
Consumer/
Householder
Authorised
drop-off centre
owner/manager
Authorised
transporter
Authorised service
provider
Licensed facility
owner or
manager
Licensed facility
owner or
manager
Refer separate
legislative
overview
Refer separate
legislative overview
Refer separate
legislative overview
Refer separate
legislative overview
Refer separate
legislative overview
Minimum
Requirement
Relevant
Legislation
Communication
Requirements
M&V
Requirements
Refer separate
Relevant bylaws,
legislative
NEMA and Waste Bill
overview
Extensive general education and awareness regarding waste and recycling. Specific communication support including labeling of packaging and clear signage
of premises. Collaboration and integration with relevant stakeholders are essential.
None
None
Type and volumes
received
Volumes
transported
Volumes treated
Volumes landfilled
Volumes recycled
Not required
Not required
Required
Required
Required
Required
Required
* Indication of the responsibilities and involvement foreseen for a funding and administration oversight entity Hg = mercury
Keeping CFLs out of the general waste bin
The outgrowth of conservation,
the inevitable result, is national efficiency.
- Gifford Pinchot
3
Consumer Responsibilities
Because CFLs are fragile, and broken glass and the mercury content present a health and safety risk,
recovery from the waste stream after disposal is not feasible. CFLs should therefore not be thrown into
the regular waste bin, but rather be kept separate and stored safely until an opportunity for disposal is
available. The success of a CFL recovery initiative is entirely dependent on participation by the householder
or residential consumer. A guideline for safe and effective householder participation is provided here:
Separation
at source
Consumer
Best Practice
Additional Information
No CFLs are to be disposed of at a landfill for general
household waste.
General landfill sites are not designed to accommodate the
release of mercury. Mercury needs to be treated (encapsulated
in concrete or similar) to prevent leaching and release into the
environment (e.g. atmosphere or groundwater).
Minimum Requirements for Hazardous Waste
Disposal (www.dwaf.gov.za/Dir_WQM/docs/Pol_
Hazardous.pdf) and any relevant municipal bylaws.
The Minimum Requirements state that hazardous waste must
go to a hazardous landfill site. Check with the local municipality’s
department of solid waste management for suitable local
requirements or solutions for hazardous household waste.
Do not throw CFLs away with your domestic waste.
Keep CFLs separate until you can safely take them to
a drop off/collection point.
Ideally CFLs should not be broken and should be placed in their
original packaging or wrapped in a plastic bag.
In the event of breakage, special care must be taken
to clean up and contain mercury powder and
glass shards.
Advice on cleaning up broken fluorescent lamps is freely
available on the Internet and also on Eskom’s website at:
http://www.eskomdsm.co.za/?q=CFL_Recovery.
Where to
take your
CFLs
CFLs can be taken to participating retailers and
collection points in your area.
At present Woolworths and Pick ’n Pay stores offer CFL
collection points. Pick ‘n Pay also accepts household batteries
for disposal and recycling. Check with your local council for
any other options for disposal of household hazardous wastes
such as empty containers or leftover thinners, paints, poisons,
batteries, etc.
How to
store your
CFLs
Spent CFLs should ideally arrive at a drop-off point
It is recommended that packaging in which CFLs are bought
unbroken. The lamps should therefore be securely
is kept and used for this purpose. Alternatively, packaging of
packaged in a safe container for storage and transport. replacement lamps can be used if readily available.
Objective
Personal health
Intact CFLs emit no mercury and
pose absolutely no health risk. In
the case of accidental breakage,
the amount of mercury inside
an individual lamp is too small
to cause any health risk, but it is
still good practice to minimise
any unnecessary exposure to
mercury, as well as risk of cuts
from glass fragments. A very
infor mative and detailed
discussion on risks of broken
CFLs can be found at:
www.treehugger.com/
files/2007/05/ask
_treehugger_14.php
Legislation
What to
do with
your CFLs
5
Municipal Responsibility
The recovery of most household hazardous wastes from the waste stream after disposal is a challenge and
presents the risk of repeat exposure to any person tasked with extraction of recyclable waste (whether at
a material recovery facility or less formally from bins on sidewalks or at a landfill). Municipalities should lead
the drive to encourage a culture of separation of waste at the home for ALL wastes for which a recovery
solution is being offered or a market exists. Establishing a habit of waste separation among South Africans
is essential for any waste minimisation and recycling efforts in future.
Municipality
Best Practice
Objective
Prevent disposal at the local general
landfill facility.
CFLs must be kept away from other waste
at point of generation by the homeowner.
Legislation
How to
implement
in your
municipal area
Additional Information
Municipalities should proactively encourage separation at source of all
recyclable and hazardous household wastes including specifically CFLs.
Municipal functions are guided by the
Municipal Systems Act, NEMA and the
Minimum Requirements for general landfill
and hazardous waste.
Waste separation is an important step in the Government drive for
waste minimisation and key to achieving the waste hierarchy:
Reduce, Re-use, Recycle.
Educate and create awareness among
the public regarding the need for waste
separation and specifically the need for
separating CFLs and other hazardous
wastes from the waste stream.
Have available and provide information (e.g. with billing information
and/or on enquiry) of local recycling and recovery initiatives such
as paper and glass banks, recycling collection services, eWASTE
collection points or initiatives and particularly participating retailers
that accept CFLs (refer to drop-off centre component
of this guideline).
Separation
at source
Relevant contacts
The City of Cape Town, Cleanest
City in South Africa 2007,
has done extensive work on
waste related education and
awareness efforts (e.g.WasteWise
campaign) that could be of value to
other Municipalities. You may find
information on their website (www.
capetown.gov.za/en/solidwaste)
or can direct enquiries to: Solid
Waste Management Department
+27 (0)860 103 089 or email
wastewise.user@capetown.gov.za
Industry Responsibility
A communication strategy is part of the requirements of an Industry Waste Management Plan as described
in the Waste Management Bill (pending enactment, expected early 2009). Any Industry Waste Management
plan for fluorescent lamps would rely heavily on participation, and hence the awareness of homeowners.
The lighting industry would therefore have an obligation to collaborate with other stakeholders in creating
awareness and educating the public about waste separation.
Separation
at source
Industry
Best Practice
Objective
Industry activity
Select industr y player s are
actively addressing lighting waste
internationally and some have
already taken an active lead in
the CFL recovery efforts in South
Africa.You can obtain information
from these suppliers directly or
read more on their websites:
Philips: +27 (0)87 940 4194
or +27 (0)11 471 5065
or www.philips.com/about/
sustainability/recycling
or refer to page 14 for others.
Legislation
What to
do with CFLs
Additional Information
Prevent the disposal of CFLs and other
fluorescent lamps with other households
waste in order to facilitate recovery.
Industry’s involvement will be most
effectively governed under the pending
Waste Management Bill, a subset of the
National Environmental Management
Act (NEMA).
Although the Extended Producer Responsibility principle is already
entrenched in existing legislation, the enactment of the Waste
Management Bill and a Government request for an Industry
Waste Management Plan will force active industry involvement
with lighting waste.
CFL packaging should be labeled
appropriately to educate consumers
regarding mercury content and handling
of CFL waste.
Different graphics with supporting text could be used to educate the
consumer about mercury content and requirements for safe disposal
or recycling as appropriate. Labels should be clearly visible
and understandable.
Call centre details to be provided on
packaging and call centres should be
empowered to deal with enquiries relating
to safe disposal and handling of CFL waste.
A collaborative effort among lighting suppliers can address all these
calls or alternatively existing call centres can be briefed to deal
with these questions.
Labeling should ideally highlight the
opportunity for re-use of packaging material Consumers should be encouraged to re-use packaging material for safe
(assumed optimal format to prevent
storage and transport of spent CFLs.
breakage of lamps).
Department of Environmental Affairs and Tourism (DEAT) Responsibility
7
National Government support for a nationwide CFL recovery mechanism is critical to the success of the
initiative. More generally, the encouragement of separation at source will promote the shift towards more
sustainable waste management strategies and practices, and place emphasis on the reduction, re-use and
recycling of wastes:
DEAT
Best Practice
Objective
Legislation
Where to
enforce
separation
at source
How to
support
separation
at source
To encourage thorough legislation and
regulations and to enforce separation at
source of all recyclable and particularly
hazardous household waste.
DEAT’s involvement is governed by the
national legislative framework including:
the Constitution, National Environmental
Management Act and Municipal
Systems Act.
Encourage and support the inclusion of the
concept into Municipal Integrated Waste
Management Plans and the development of
bylaws to enforce separation at source
by homeowners.
A national education campaign. General
education must be provided to the
public to improve their knowledge of the
impact of mercury bearing lamps on
the environment. Support should also be
provided to provincial departments and
local municipalities in the form of information
sharing, education and empowerment.
Additional Information
Separation at source is an essential component of all recycling initiatives
and should be widely encouraged.
Separation
at source
Relevant contacts
Relevant DEAT Directorates and
contacts include, among others:
Emphasis should be placed on the importance of appropriate handling
of hazardous household waste among all role players and every entity
under legal obligation to comply.
Overall education relating to waste, recycling and hazardous household
waste has been identified during public consultation as an imperative
since existing awareness levels are extremely low. Education with regard
to the benefits of using energy saver lamps should also form part
of communications.
Communication support Comprehensive and collaborative communication, education and
awareness support is required by all stakeholders, including: package labeling; municipal communication
through all available media including billing runs and a national education and awareness campaign.
1. Directorate:
Waste Stream Management,
Ms Dee Fisher
+27 (0)12 310 3527,
dfisher@deat.gov.za
2. Directorate:
Waste Policy & Information
Management, Mr Obed Baloyi
+27 (0)12 310 3833,
obaloyi@deat.gov.za
Delivery of CFLs at Collection Points
9
Consumer Responsibility
In the absence of a separate sidewalk collection service, consumer participation will necessarily include
transportation of CFLs to a local collection point. This is aligned with international practice where
residential consumers are generally required to deliver spent CFLs and other hazardous household wastes
(e.g. batteries) to central locations including participating retailers and collection bins. Suggested practices
for safe transportation are provided below:
Consumer
Best Practice
Objective
Additional Information
To ensure safe transportation of spent CFLs
to a drop-off centre or mobile unit.
Relevant contacts
Legislation
Minimum Requirements for Hazardous
Usually applicable to bulk carriers of hazardous materials. Safe
Waste Disposal, National Transportation Act. keeping of small quantities to prevent breakage required.
How to
transport
your CFLs
Ideally CFLs should not be broken during
transit. CFLs must be transported carefully
in a manner that will prevent breakage and
minimise the risk to handlers for delivery to
a suitable disposal or collection point.
What if
CFLs break
during transit
If during transit a CFL does break, open
your windows immediately and pull over at
the nearest safe location. Once air has been
circulated, put CFL in a plastic bag and drop
off at the nearest drop-off centre.
Private
Transportation
It is suggested that CFLs be placed in their original packaging or empty
packaging of replacement lamps or wrapped in a sealable (heavy/thick)
plastic bag. Transport household hazardous waste in the rear of
the vehicle, ideally packed securely in the vehicle to prevent crushing
and do not store in the vehicle for extended periods.
Also wipe the car with a damp cloth and dispose of any remaining
glass fragments at your earliest convenience. Containment of the
lamps in a plastic bag will contain any pieces and will greatly simplify
the cleaning up.
eWaste service providers
and recycling companies
provide collection services that
sometimes include hazardous
household waste . Ser vice
provider s or participants in
your area may be listed with:
1. eWASA (National):
+27 (0)11 312 3605
or www.ewasa.org
2. Urban Sprout Eco-Directory:
www.urbansprout.co.za
3. Faithful to Nature
Eco-Directory:
www.faithful-to-nature. co.za/
directory
Muncipal Responsibility
Where separate collection services for household hazardous waste are not provided, collection days or
collection events held regularly at suitable locations have become very popular among local municipalities
internationally. Municipalities have implemented pilot studies for separate sidewalk collection services of
select wastes, including recyclables, across South Africa.The following guideline is therefore aimed at guiding
any municipalities that do get involved in the collection and transport of household hazardous waste,
including CFLs.
Small scale
Transportation
Municipality
Best Practice
Objective
Mobile Units
The use of mobile units is a
solution employed internationally
which makes use of mobile
containers that collect hazardous
household waste from residential
areas on a regular basis. Feasible
implementation is dependent on
provision of the service for a
broad range of hazardous waste
types to benefit from economies
of scale and logistical synergies.
Legislation
How to
transport
CFLs
Additional Information
To ensure safe transportation of spent CFLs
to a drop-off centre or mobile unit.
Minimum Requirements for Hazardous Waste
Disposal, National Transportation Act.
Usually applicable to bulk carriers of hazardous
materials. Safe-keeping of small quantities to prevent
breakage is required.
A municipality may be involved in the
transportation of spent CFLs by implementing a
contract with a private company. It is essential that
the private company makes use of specific crates
which prevent the breakage of spent CFLs.
Spent CFLs must be transported in such a manner that
the breakage of CFLs is prevented and that, in the case
of breakage, no mercury leakage emanates from the
transportation containment.
Vehicles must be roadworthy and appropriate
and in accordance with the National Traffic Act
(GNR. 225) requirements.
The applicable TREM decals must be displayed on
the vehicles and provide correct details.
The driver(s) of the vehicle(s) must be qualified,
trained and hazardous waste certified to transport
hazardous goods.
In the event of breakage or spillage, all personnel
must leave the vehicle immediately and contact
the incident team. Personnel must wear
Personal Protective Equipment (PPE) at all times.
11
Waste Contractor Responsibility
Environmental consciousness is intensifying and, particularly among high-income households and in urban
centres, the demand for collection services for recyclable material has resulted in seemingly sustainable
business opportunities. In select instances service providers are extending the collection offering to include
household hazardous wastes such as batteries, etc. The following framework is therefore aimed at guiding
any private waste/recyclables collection contractors that do get involved in the collection and transport of
household hazardous waste, including CFLs.
Waste Collection Contractor
Best Practice
Objective
Legislation
To ensure safe transportation of spent CFLs to a dropoff centre or mobile unit (or other appropriate storage
or treatment facility).
Additional Information
Service providers may cut out the collection points and
transport CFLs directly to a storage or treatment facility.
In that case please refer directly to bulk transport and
waste treatment and storage implementation guidelines.
National Transportation Act, Minimum Requirement for
Hazardous Waste Disposal.
Usually applicable to bulk carriers of hazardous materials.
Safe keeping of small quantities to prevent breakage
is required.
If a private waste contractor would like to be involved
in the transportation of spent CFLs, it is essential that
specific crates which prevent the breakage of spent
CFLs be used.
Suitable packaging and containers/crates are particularly
important if transported with other wastes that can crush
the CFLs in transit.
Vehicles must be roadworthy and appropriate and in
accordance with the National Traffic Act (GNR. 225)
requirements.
How to
transport
CFLs
Private
Transportation
Relevant contacts
No ser vice provider s are
currently known to provide
collection services for CFLs from
households, but service providers
that collect from commercial
properties may be available to
assist at a fee.
The following service providers
are active in the commercial
market:
The applicable TREM decals must be displayed on the
vehicles and provide correct details.
The driver(s) of the vehicle(s) must ideally be qualified,
trained and hazardous waste certified to transport
hazardous goods.
If very small quantities are transported with other
wastes, it is recommended that the driver is at least
trained to deal with breakages or spillage of hazardous
materials including CFLs.
In the event of breakage or spillage, all personnel must
leave the vehicle immediately and contact the incident
team. Personnel must wear Personal Protective
Equipment (PPE) at all times.
Ensure ventilation of the area of breakage and ensure
a spill kit is available. A single breakage can be cleaned
up and addressed as for a private vehicle (refer to
consumer guideline).
1. Nova Lighting
2. Lumino
3. Actebis
Refer to Treatment Section of this
guideline for the contact details.
Hosting CFL Collection Points/Drop-off Centres
13
Consumer Responsibility
The sustainability of a collection point network for spent CFLs in South Africa is dependent on the level
of participation by the public. South Africans are therefore encouraged to make use of the facilities provided
by retailers and any other participants and also to use these facilities responsibly.
The practices described below are therefore aimed at guiding participation by consumers.
Consumer Responsibility
Best Practice
Objective
Additional Information
Safely deposit all failed CFLs at
participating collection points
or drop-off centres.
Legislation
Minimum Requirements for
Hazardous Waste Disposal,
any relevant municipal bylaws.
How to use
a drop-off
centre
Deliver CFLs intact to
participating collection points
or drop-off centres and
deposit into the dedicated
container provided.
Drop-off
Centres
Relevant contacts
Ideally the spent CFL should arrive unbroken and in its original packaging or
wrapped/sealed in a plastic bag. Deposit CFLs into the collection bin which should
be clearly marked and secure unless specifically instructed otherwise at the specific
drop-off centre. Handle spent CFLs carefully to prevent breakage. Children should
be kept away from the collection bins and discouraged to play with or around
these facilities. Replace failed CFLs with a suitable replacement.
CFL Selection
The choice of a new CFL requires
some consideration:
- Required brightness of the light
(represented by the wattage).
- The desired colouring of the lamp (represented
by the Kelvin value and described as either
warm white or cool white) or alternatively can
be coloured lighting/glass, such as red or blue.
- The appropriate fitting i.e. screw-in or bayonet.
- Whether the lamp should be dimmable
or not and whether it should function
with a motion sensor (often required
for external or security applications).
The following collection points are
available to consumers wanting
to participate:
1. Pick ‘n Pay stores nationwide.
Contact Pick ‘n Pay for your
closest store on
+27 (0)800 11 22 88
or visit their website:
www.picknpay.co.za
2. Select Woolworths stores
nationwide. Contact
Woolworths for participating
stores on +27 (0)860 100 987
or visit their website:
www.woolworths.co.za
Drop-off Centre/Collection Facility Responsibility
The responsibilities and requirements relevant to hosting a collection facility or drop-off centre are
fairly significant but mainly require sensible caution, similar to that necessary for handling a wide variety
of household hazardous goods (e.g. paint, poisons, batteries, etc.) generally sold by retail and hardware
stores. A detailed guideline is provided below to guide anyone interested in hosting a collection point or
drop-off centre.
Drop-off
Centres
Permissible storage
Drop-off Centre Facilities
Best Practice
To host a clearly marked and safe drop-off facility.
Objective
2. At least a Basic Assessment
is done towards a full EIA.
Indications from DEAT are that
the Waste Management Act and
related regulations will make
allowance for temporary storage
and recovery activities handling
small quantities of hazardous
waste to be exempted from the
requirements for a license
(see page 18 for details).
To ensure that CFLs are temporarily stored in a manner
that is not harmful to the individual housholder, the public
or the environment.
To provide a convenient point for the consumer to return their
spent CFLs.
Current legislation requires:
1. Permitting of a collection/
drop-off facility to act
as a temporary waste
storage facility.
Additional Information
Legislation
To provide a permanent or temporary point for waste
transporters to collect spent CFLs en masse.
It is anticipated that drop-off points will form part of an
ever expanding network of CFL collection infrastructure.
Minimum Requirements for Hazardous Waste Disposal new
EIA Regulations.
Refer to the legal overview for specific acts, clauses and
regulations of interest.
A suitable container of sufficient size that can safely accommodate the volumes of CFL waste dropped off.
What is
required of
the facility?
A sufficient area of floor space to accommodate the container
and to allow access and ventilation if required.
Typically a minimum of 1m2 space is required.
Drop-off containers should be positioned in a prominent and
easily accessible location that is clearly marked.
Location in a store would ideally be either at the sales
point for new CFLs, at the till or close to the exit as part
of a “recycling street” that also enables consumers to
return other waste items such as plastic bottles etc.
Additional overflow storage capacity needs to be provided by
drop-off centre hosts for the safe storage of full containers.
Additional storage is required to accommodate any
delays for the pick-up of the spent CFLs by specialised
treatment, disposal or recycling service providers.
The correct permit/license or exemption from such a license
must be obtained where applicable (i.e. where waste volumes
exceed the permissible concentrations and maximum
allowed weights).
Whilst there is ongoing engagement with DEAT to
resolve possible exemptions, it is suggested that in the
interim, facilities are managed responsibly in accordance
with these guidelines.
15
Drop-off Centre/Collection Facility Responsibility
Drop-off Centre Facilities
Best Practice
The collection point should preferably only
accept intact CFLs and no breakage should
occur during the drop-off or temporary
storage process.
Quantities of CFL waste collected and stored
must be safely manageable at all times.
Collection points must be clearly demarcated
and labelled and containers must be labelled
with clear instructions on the type of
How to
lamps accepted and how the lamps have
manage a
to be returned.
drop-off
The temporary storage area for full containers
centre
must be safe and easily accessible when lamps
are picked-up.
Additional Information
The public and employees of the collection facility should be educated.
Regular emptying of containers to avoid overflow and thus breakage
and regular removal from collection points is strongly recommended.
Communication, education and awareness creation are critical. Every
opportunity should be used to encourage participation and to remind
the public to drop off unbroken CFLs, preferably in original packaging
or wrapped/sealed in a suitable plastic bag.
Collection frequency must be commensurate
Collection frequency can either be based on an actual needs base
with the volumes of CFL waste actually dropped (when bin is full) or can be at regular intervals throughout the collection
off and generated within the retail store.
period (e.g. every fortnight).
How to
safely
store CFLs
Emergency
procedures
The drop-off centre/collection facility may not
be left unattended at any time. At least one
employee should be present on site/in-store
and should be identified as the individual
responsible for CFL collection.
Containers must be inspected regularly for level
and other problems e.g. mercury contamination
from broken bulbs and their overall functionality.
A spillage clean-up kit needs to be on hand
in case CFLs are accidentally broken either
by the public, the retail staff or the
downstream collector.
Drop-off centres cannot take the format of a glass bank left unattended
in a parking area. The delegated responsibility is particularly important in
the case of spillage or breakage.
Contact details for Hazmat or similar emergency services should be
visibly displayed in case of a major spillage.
All personnel must be trained to deal with
Personnel should also be trained to deal with major events e.g.
spillages and must be well educated on the risks
evacuation and summoning of emergency services.
associated with the mercury-bearing lamps.
Drop-off
Centres
Relevant contacts
Hazmat provides a national
24-hour spill response service.
Hazmat can be contacted incase
of emergency toll free at:
0800 00 58 17 or for enquiries
contact the head office at
+27 (0)33 386 2264
or email: ian@hazclean.co.za
Alternatively visit their website at:
www.24hourspillresponse.co.za.
Industry Responsibility
The voluntary initiation of CFL collection points by retailers in South Africa is an important step towards a
national CFL recovery network. Maintaining the momentum created by these initiatives should be a priority
for all stakeholders, including the lighting industry.
Operating collection centres will constitute a key component of a functional Industry Waste Management
Plan and hence would be of particular interest to the lighting industry.
Drop-off
Centres
It is not expected that industry players will host their own drop-off points but should any lighting supplier
be interested in hosting such a facility, the guidelines for drop-off facilities (refer to preceding section) will
be relevant. The guideline below is aimed at industry in their role as supporter of drop-off centres.
Permissible storage
(Continued from page 15)
Lighting suppliers that have
demonstrated commitment to
the management of the full
product life cycle of CFLs,
locally or globally:
1. Osram: www.osram.co.za
2. Eurolux: +27 (0)21 528 8400
or +27 (0)11 608 2970
www.eurolux.co.za
Industry
Best Practice
Objective
Additional Information
Support the establishment of safe, convenient and
legally compliant drop-off centres that will facilitate the
recovery of CFLs.
Ensure the sustainability of drop-off centre for CFLs.
Legislation
Minimum Requirements for Hazardous Waste
Disposal new EIA regulations, Waste Management Bill.
Refer to legal overview for specific acts, clauses and
regulations of interest.
Assist with creating public awareness in terms of CFL
drop-off centres.
How to
support
drop-off
centres
Support the establishment of safe, convenient and
legally compliant drop-off centres that will facilitate
the recovery of CFLs.
Financial, logistical and administrative support are all required
to ensure a sustainable solution.
Encourage the use of drop-off centres.
Several oportunities arise such as linked sales promotions
and discounts on replacement CFLs linked to the return
of failed lamps.
17
Local Muncipality Responsibility
Hosting of a drop-off facility for CFLs at council premises would follow the same guidelines as for other
drop-off facilities (refer to preceding section for drop-off centres). The guideline below is to assist local
municipalities interested in having collection points established in the municipal area.
Local Muncipality
Best Practice
Additional Information
Support the establishment of safe, convenient and
legally compliant drop-off centres that will facilitate the
recovery of CFLs in municipal areas.
Objective
Drop-off
Centres
Encourage particiaption by residents in the
municipal area.
International experience
Prevent the disposal of CFLs in general landfills.
Legislation
How to
get facilities for
CFL
collection
How to
support
drop-off
points
Municipal Systems Act, Minimum Requirements for
General Landfill.
The municipality may host CFL drop-off facilities at suitable municipal premises.
Possible options for collection points include utility offices,
public libraries, community centres or manned refuse
drop-off centres.
Engage local retailers or other suitable facilities to host
CFL drop-off centres.
Hardware stores, lighting suppliers, general retailers,
24-hour convenience stores at petrol stations can all be
considered for participation.
Assist with education and creation of public awareness
regarding the need for and participation in CFL drop-off
centres. Empower interested participants.
Communicate details of participating drop-off facilities
in municipal publications and communications.
In the US, local governments have
reached out to local retailers to
host collection points. Information
and examples of bins, posters and
collection points can be found on
the websites of:
- IKEA
- Wal-Mart
- Sears Stores
- Ace Hardware
- Home Depot
Department of Environmental Affairs and Tourism (DEAT) Responsibility
A national recovery network for CFLs via central collection points is a significant improvement on the status
quo where all CFLs are disposed of at the general landfill. A simplified mechanism or possibly exemption
from EIA requirements and waste facility licensing with consideration of the tools established under
the pending Waste Management Act, is strongly recommended. Support and voluntary involvement by
retailers and other collection points are needed to govern the collection mechanism as a whole.
Drop-off
Centres
Enabling/Supporting
Legislation
Two onerous legislative
requirements will prohibit the
participation of retailers and
others in establishing a
comprehensive recovery
mechanism for CFLs.
Indications from DEAT are
that new waste regulations will,
in future, partly address the
temporary storage constraints
but EIA requirements will have
to be aligned to facilitate and
encourage recovery, responsible
handling and recycling of CFLs.
DEAT
Objective
Legislation
How to
support CFL
collection
Best Practice
Additional Information
To encourage the use of drop-off centres
and to support drop-off centres.
A formalised and appropriately managed collection mechanism for
CFLs is a significant improvement on the status quo.
Minimum Requirements for Hazardous
Waste Disposal, new EIA regulations.
Exemption should be considered and
supported for the listed activity as per
regulation 386: The temporary storage
of hazardous waste.
Emphasis should be placed on the importance of appropriate handling
of hazardous household waste among all role players and every
entity under legal obligation to comply. Alignment of EIA and Waste
Management requirements to support CFL recovery is essential.
Request/enforce (as appropriate) the
development of a Lighting Industry Waste
Management Plan.
Whilst relaxation is proposed, alternate mechanisms such as an
Industry WMP is required to ensure that CFL recovery is structured
and responsible through a formal waste management plan and an
oversight/audit function.
Communication Support Comprehensive and collaborative communication, education and awareness
support is required by all stakeholders, including:
• Clear demarcation, signage and branding of collection points. • Package labeling. • Guidelines for facility
use (pamphlets, posters and signage). • Muncipal communication through available media including
billing runs. • Education and awareness campaign among Muncipal residents. • National education and
awareness campaign.
19
Bulk Transportation
19
Waste Contractor Responsibility
Waste contractors that are required to collect CFLs from drop-off centre facilities should take cognisance
of the hazardous nature of CFLs and the requirements for handling and transportation. The need for waste
information management and tracking is also introduced at this stage of waste handling. These guidelines
are aimed at assisting with best practice for bulk transport of CFLs.
Bulk transportation
Waste Contractor
Best Practice
Objective
Relevant contacts
No service providers are currently
known to provide collection services for CFLs from households,
but service providers that collect from commercial properties
may be available to assist at a fee.
The following service providers are
active in the commercial market:
1. Nova Lighting
2. Lumino
3. Actebis
Refer to Treatment Section for
contact details.
Legislation
Additional Information
To ensure safe transportation of spent CFLs to a landfill
site or recycling facility.
Minimum Requirements for Hazardous Waste Disposal,
National Transportation Act.
Spent CFLs must be transported in such a manner that
If a private waste contractor would like to be involved in
the breakage of CFLs is prevented and that is the case
the transportation of spent CFLs it is essential that specific
of breakage no mercury leakage emanates from the
crates which prevent the breakage of spent CFLs be used.
transportation containment.
Vehicles must be roadworthy and appropriate and
in accordance to the National Traffic Act
(GNR. 225) requirements.
How to
transport
your CFLs
The applicable TREM decals must be displayed on the
vehicles and provide correct details.
The driver(s) of the vehicle(s) must be qualified, trained and
hazardous waste certified to transport hazardous goods.
In the event of breakage or spillage all personnel must
leave the vehicle immediately and contact the incident
team. Personnel must wear Personnel
Protective Equipment (PPE) at all times.
Ensure ventilation of the area of breakage and ensure
a spill kit is available. A single breakage can be cleaned
up and addressed as for a private vehicle (refer to
consumer guideline) Hazmat provides 24-hour spill
response in the case of an accident or serious spill of large
volumes of CFLs. Contact details for Hazmat must be
provided to drivers (refer to page 13 for contact details).
21
Municipal or Industry Responsibility
Should either municipalities or industry be interested in, or be required to, collect CFLs from drop-off centre facilities, the requirements for
handling and transportation of CFLs as per the guidelines for a Waste Contractor will apply. As for waste contractors, the need for waste
information management and tracking is a requirement introduced at this stage of CFL waste handling and should be given due consideration. It
is also possible that municipalities and industry players may be involved in the recruiting of waste contractors for a collection and transportation
service. These guidelines are therefore aimed at assisting with appropriate practice when contracting for bulk transport of CFLs.
Local Municipality or Industry
Objective
Legislation
Best Practice
Minimum Requirements for Hazardous Waste Disposal, National
Transportation Act.
Verify that the contractor complies with the Best Practices described in the
preceding guideline. This will include having suitable crates which prevent the
breakage of spent CFLs.
Vehicles are roadworthy and comply with the National Traffic Act
(GNR. 225) requirements.
What to consider
when contracting
for the
transportation
of CFLs
Additional Information
To ensure safe transportation of spent CFLs to a landfill site or recycling facility.
Applicable and accurate TREM decals are displayed on the service
provider’s vehicles.
Confirm that driver(s) of the vehicle(s) are qualified and are certified
to transport hazardous goods.
Check that drivers are trained to deal with emergency situations and
that all personnel handling the hazardous waste wear Personal Protective
Equipment (PPE).
Ensure that the transport contractor captures the waste data and submits
completed records and reports to all relevant entities including yourself and the
Fund administration entity.
Spent CFLs must be transported in such a manner that the breakage
of CFLs is prevented and that in the case of breakage no mercury leaks from
the transportation containment.
Department of Environmental Affairs and Tourism (DEAT) Responsibility
The primary requirement for National Government involvement with transportation is for the relaxation
of the legal requirements for transporting select ‘hazardous’ waste types so as to facilitate recovery and
responsible handling.
DEAT
Best Practice
Additional Information
To encourage thorough legislation and regulations.
The separation at source of all recyclable, and particularly
hazardous, household waste.
Separation at source is an essential component of all
recycling initiatives and should be widely encouraged.
Bulk transportation
Objective
DEAT Contact details
Legislation
DEAT’s involvement is governed by the National
legislative framework including the Constitution, National
Environmental Management Act and Municipal Systems Act.
Where to
enforce
separation
at source
Encourage and support the inclusion of the concept into
Municipal Integrated Waste Management Plans and the
development of bylaws to enforce separation at source
by homeowners.
Directorate: Pollution
& Waste Management:
Mr Rantsadi Moatshe
+27 (0)12 310 3648
rmoatshe@deat.gov.za
Directorate: Authorisation
& Waste Disposal Management:
Ms Kellelo Ntoampe
+27 (0)12 310 3920
kntoampe@deat.gov.za
How to
support
separation
at source
Emphasis should be placed on the importance of appropriate handling of hazardous household waste among all role
players and every entity under legal obligation to comply.
Overall education relating to waste, recycling and
hazardous household waste has been identified during
A national education campaign. General education must
public consultation as an imperative since existing
be provided to the public to improve their knowledge of
awareness levels are extremely low. Education with
the impacts of mercury bearing lamps on the environment.
regards to the benefits of using energy saver lamps should
also form part of communications.
Support should also be provided to provincial departments and local municipalities in the form of
information sharing, education and empowerment.
International example: Universal Waste Regulations
Federal and state regulations in the USA have relaxed the legal requirements for the
transportation of select hazardous waste types to facilitate collection and recovery to
appropriate recycling or disposal facilities.
23
Treatment or Storage Facilities for CFLs
23
Storage Facility responsibility
It is essential that owners of storage facilities understand the risks associated with storing masses of spent CFLs and understand the safety
requirements. These guidelines are aimed at assisting with best practice.
Storage Facilities
Best Practice
Objective
Ensure that CFLs are temporarily stored in a manner which is not harmful to
the environment or humans.
Legislation
Minimum Requirements for Hazardous Waste Disposal, new EIA Regulations.
What is required
for storage of CFLs
Additional Information
Suitable containers of sufficient size that can contain intact, failed CFLs and that
will protect the lamps from breakage.
Sufficient floor space to accommodate bulk storage of CFLs in suitable containers.
A spillage clean-up kit needs to be at hand in case CFLs are
accidentally broken.
How to support
separation at source
All personnel must be trained to deal with spillages and must be well educated
about the risks associated with the mercury bearing lamps.
Ensure ventilation in the area of breakage and ensure a spill kit is available. In
the case of a major event, it is recommended that Hazmat or a similar service
provider be called in.
Personnel must wear Personal Protective Equipment (PPE) at all times.
Treatment Facility
Objective
Legislation
Best Practice
Additional Information
Ensure that CFLs are crushed, chemically treated (where required) and sealed
in manner that is not harmful to the environment or mankind.
Crushing and treatment into an inert and sealed format is essential except
when transporting to a recycling facility. Then pre-treatment should not occur.
Minimum Requirements for Hazardous Waste Disposal, pending Waste Manage- Would have to comply with the comprehensive legal requirements for permitment Act, Environmental Conservation Act and new EIA regulations.
ting of storage, treatment and processing of hazardous (CFL) waste facilities.
25
Treatment Facility Responsibility
Crushing and treatment are primarily done to facilitate economically feasible transportation and recycling
or disposal. Crushing of the lamps therefore constitutes an integral part of the treatment activity with
significant associated risk potential.These guidelines are not intended to prescribe a specific technology, but
are rather aimed at assisting with appropriate practice to minimise the associated risks. There are various
treatment options but it is important that treatment facilities understand the benefits and consequences
of their activities and technologies.
Treatment Facility
Best Practice
Additional Information
Relevant contacts
All CFLs that will be disposed of at a landfill must be
pretreated under controlled conditions in line with
legislative requirements (refer above).
Any mercury vapour emanating from any treatment
technology must comply with the OHSA minimum
standards.
All waste and recovered material must be contained and
stabilised by adding mercury immobilising chemicals.
How to
treat CFLs?
Mercury vapour that forms as a result of crushing
mercury-containing CFLs and tubes as well as any
extracted mercury must be contained as part of any
crushing operation.
Personnel must wear Personal Protective Equipment (PPE)
at all times.
All personnel must be appropriately trained to handle CFL
waste and emergency situations.
Spent CFLs must be placed in air-tight drums during
the treatment process and sealed on completion of the
treatment process.
Treatment
or storage
The following companies are known
to provide treatment services for
mercury bearing lamps:
To meet all the legislative requirements and best
practice described, the crushing technology would typically operate in a vacuum or under negative pressure and
must incorporate a comprehensive filter system.
1. Nova Lighting.
Tel: +27 (0)21 706 4451,
Email: mike@nova.co.za
or web: www.nova.co.za
2. Lumino.
Tel: +27 (0)861 111 319
Email: lamps@lumino.co.za
or web: www.lumino.co.za
3. Actebis.
Tel: +27 (0)16 423 7802,
Email: actebis268@lantic.net or
web: www.tubeandglobeguzzler
Disposal of CFLs as Hazardous Waste
27
Landfill Operator Responsibility
Landfill operators must be aware of the disposal procedures pertaining to the disposal of mercury bearing lamps,
including spent CFLs.The following guidelines are set out as the best practice in terms of CFL disposal.
Landfill Operator
Best Practice
Additional Information
Objective
In the absence of a suitable/viable recycling option, spent
CFLs should be disposed of at a licensed hazardous
landfill site.
Waste disposal should remain a last resort in line with
stated Government objectives and waste hierarchy.
Legislation
DWAF Minimum Requirements for Hazardous Waste Disposal.
Spent CFLs may only be disposed of at a licensed hazardous
landfill site.
How to
landfill
CFLs
Disposal at landfill
Relevant contacts
All CFLs that are disposed of at a hazardous landfill site
must be pre-treated as per these guidelines and Minimum
Requirements (refer to earlier component of this document
and separate minimum requirements).
All treatment must be completed prior to arrival at the
landfill site.
The containers in which CFLs are treated and transported
to the landfill site may not be opened. The containers must
be disposed of as is on site.
Containers should be clearly labeled according to their
contents.
The hazardous landfill site where CFLs are disposed of
must be permitted/licensed and operated as per the DWAF
Minimum Requirements for Hazardous Waste.
In accordance with licensing requirements this should
include the following:
- Regular audits of the facilities as per the
Minimum Requirements.
- A measurement and verification system must be
in place whereby all CFLs that arrive at the landfill site
must be recorded in terms of mass.
Operating plans at such a hazardous landfill site must include
a plan for disposing of spent CFLs.
Operation should include encapsulation
in an impermeable substance, such as concrete.
The re-opening or downstream chemical treatment of CFL waste with mercury immobilising chemicals is strictly
prohibited. Please also note that the transporter of the waste to the landfill should be aware of the requirements
for CFLs and should ensure delivery of pre-treated and crushed lamps in sealed containers for encapsulation.
Only three landfills are suitably
licensed for the acceptance
of hazardous wastes, such as
mercury, in South Africa. These
are located in the Western Cape,
Eastern Cape and Gauteng
respectively and details can be
obtained from DEAT (see earlier
contact details) or from the
Institute of Waste Management
(IWMSA).
Tel: +27 (0)11 675 3462/4
Email: iwmsa@telkomsa.net
Website: www.iwmsa.co.za
Recycling of CFL Components including Mercury
29
Recycler Responsibility
Various recycling technologies/methodologies currently exist (including treatment options) but it is important
that recycling facilities understand the benefits and consequences of the various technologies including among
others the variability of the number of components that can be recovered through the process. Of the available
recycling technologies Closed Loop Recycling is currently the only proven technology with exceptional health,
safety, environmental and quality performance. These guidelines are aimed at assisting with appropriate practice
and utilisation of recycling facilities.
Recycling
Recycling Facilities
Best Practice
Additional Information
Objective
Recycle CFLs and all the components in an
environmentally friendly manner whilst ensuring the
operation is environmentally and financially viable.
Current and pending legislation incorporates the
requirement to prove that the resources required for the
recycling process do not exceed the recycling benefits.
Licensing of a new recycling facility will be subject
to a complete impact assessment with consideration
of the above.
Legislation
New EIA Regulations, pending Waste Management Act.
Comprehensive licensing requirements will apply
to recycling facilities.
CFLs should ideally be received intact or if crushed, appropriately sealed to prevent the release of any mercury
vapour, but should not be pre-treated with any chemicals.
Recycling
of CFLs
Reclite is in the process of
establishing a mercury recovery
and recycling facility for lamp
components in South Africa. The
facility will accept a wide variety
of mercury lamps for processing.
Reclite can be contacted at:
Tel: +27 (0) 11 764 4855
Cell: +27 (0) 82 492 7356
Email: patricia@reclite.co.za
or you can visit their website at:
www.reclite.co.za
All mercury should be contained and treated
and no mercury emissions should result from the
recycling activities.
Recycled components should be free of any
mercury contamination.
Relevant contacts
Government support/facilitation of a receiving market
for recycled material including recovered mercury and
particularly glass and metals, will be invaluable to promote
CFL recovery and recycling.
Fund Administration
31
Fund Administrator Responsibility
The expectation is that a fund administration and management entity will be established or appointed to
oversee the implementation, track progress and manage the flow of funding. A comprehensive investigation into
appropriate structures and functions has identified the following as essential/optimal services to be provided for
the CFL waste stream:
Fund Administrator and Management
Objective
Legislation
Support
functions to
be provided
Best Practice
Additional Information
A management and administration entity to oversee and
manage the implementation of the CFL Recovery
Initiative in accordance with the Minimum Requirements
and Implementation Guidelines.
Administrator should be directly involved in all aspects
of collection, transport, recycling and fund management
in an oversight capacity. Provides support to all existing
and interested role players to facilitate participation and
compliance with best practices.
Structured as and compliant with all legislation relevant to
a Section 21, non-profit organisation registered as
a Public Benefits Organisation (PBO).
Participation by participants of the initiative and industry
shareholders should be on a voluntary basis. Lighting
industry participation may become a requirement in
the case of an Industry Waste Management Plan being
adopted.
Basic facilitation and support.
These functions should include the following:
- provide a collaboration platform for CFL manufacturers
and importers.
- drive awareness, education and communication
for the initiative.
- facilitate interaction with Government.
Management of funding and flow of funding.
Implement fund management activities including fund
collection and disbursements or contracting of services
as appropriate. Appointment of an auditing entity for fund
management or oversight of fund management.
Collection and delivery of CFLs.
Appointment and management of all service providers to
collect and deliver CFLs and collation of data.
Recycling/disposal activities.
Contracting and management of companies to recycle or
dispose of CFLs and collate data.
Fund administration
Voluntary participation
Research findings have shown that
pending legislation has resulted
in extended delays in activity in
anticipation of the detailed legislated requirements. As a result, the
time required for legislation to be
promulgated becomes a major barrier for implementation. Voluntary
participation is therefore the best
immediate way forward in spite of
the obvious limitations.
Fund Administrator Responsibility
Fund Administrator and Management
Flow of
funding
Best Practice
Additional Information
The optimal solution for continuous flow of funding is through a manufacturers/
importers levy to the fund administrator from where payments to all collection
entities, transporters, recyclers, etc are managed.
An initial kickstart or start-up fund may be required from relevant stakeholders
to initiate a recovery programme prior to the establishment of a levy.
The option of an incentive for participation to consumers requires further
consideration but would form part of the functions of this entity.
Participating transporters, storage, treatment, landfill and recycling facilities’ responsibility
Data collection and management is essential to track progress and inform decision making. For this purpose, all participants would be expected to
maintain data and report regularly to the fund administration entity. It is, however, critical that this requirement is not too onerous resulting in reluctance
to participate.The following guideline proposes the minimum data requirements that participants would be required to adhere to.
All Participants
Collection
points
Waste contractor(s)
Best Practice
Additional Information
No data logging required.
Please do however check that collection services capture the required data
when picking up CFLs from your premises.
Required to capture quantities/volumes collected and delivered to any of the
following as applicable:
- Treatment/storage facilities
- Disposal facilities i.e. hazardous landfills
- Recycling facilities
Information requirements are as per prescription for all transportation of
hazardous wastes.
All particiapnts are required to capture the following detailed information:
Storage, treatment,
disposal or recycling
facilities
1. V
olumes, quantities or weights collected, received, treated, recycled
or landflled material.
2. Relevant dates such as collection or delivery.
3. Signature(s) of authorised individual(s) for each facility or vehicle.
4. Confirmation of due process followed.
Project Contacts and Acknowledgements
33
ALL participants in the CFL Recovery Initiative must be acknowledged for their invaluable contribution to the programme and particularly thanked for
the input and effort that resulted in this guideline. Key participants that are specifically acknowledged include:
- City of Cape Town
Barry Coetzee and Alison Davison
- Department of Environmental Affairs and Development Planning
Eddie Hanekom
- Eskom
Lodine Redelinghuys (Western Cape), Latetia Venter, Robert Henderson and Iris Cloete
Project team members who may be able to assist with questions:
Zitholele/Golder
Jacqui Hex, Elias Barnard, Jarrod Ball, Leon Bredenhann
Tel: +27 (0)11 254 4901
Email: mail@zitholele.co.za
Envirosense
Susanne Dittke
Tel: +27 (0)21 706 9829
Email: envirosense@envirosense.co.za
Alakriti Consulting
Mari-Louise van der Walt
Tel: +27 (0)82 574 6054
Email: mari-louise@alakriti.co.za
CFL Recovery, Recyling & Disposal
Implementation Guideline