CMA Ecocycle submission in response to A National Waste Policy:
Managing Waste to 2020 Consultation Paper.
Waste Policy Taskforce
Department of the Environment, Water, Heritage and the Arts.
CMA Ecocycle appreciates the opportunity to make this written submission as
part of the consultation process on the development of the National Waste
Policy (NWP).
We seek to draw the attention of the NWP Taskforce to the current practices
and issues relating to the management of Mercury containing lighting waste
and Dental Amalgam waste and to explore opportunities, to manage Mercury
containing lighting and dental waste more effectively for better environmental
outcomes and community health benefits.
Mercury containing lighting waste.
Australia generates about 70 Million units of such waste P.A, consisting of
approx. 50 Million Fluorescent Tubes and 20 Million HIDs and at this stage,
small number of CFLs.
More than 90% of all lighting waste originates in the commercial and industrial
sectors (street lighting, factories, offices, public buildings, sporting facilities,
public car parks, etc). And less than 10% of the total comes from the domestic
sector.
The main reason for the large discrepancy between the volumes of waste
generated by the industrial and commercial sectors, compared to the
domestic sector is the fact that commercial and industrial sectors carry out
regular re-lamping, every 2-3 years, while in the domestic sector, the lights
are only changed when they burn out. Also, at this stage the main source of
light in the domestic sector is the Incandescent type, which does not contain
Mercury.
Currently only about 2% of this waste is being recycled. The rest is land filled.
The reason for such a poor recycling performance is the fact, that currently
this type of waste can legally be disposed into landfills. Landfill disposal costs
about 3c/kg, while recycling costs about $2.50/kg, so recycling companies,
such as our company, CMA Ecocycle, cannot compete with landfill. Just our
company alone, has invested in excess of $10 Million into plant and recycling
machinery, which is totally under-utilized.
Countries of the European Community, all of Scandinavia, Canada, most of
USA, Japan, New Zealand, even Korea, Philippines, Taiwan, Vietnam and
many others have or are in the process of banning Mercury containing lighting
waste from landfill disposal and have mandated recycling.
Mercury is a potent neurotoxin, especially harmful to children and young
women. 1 gram of Mercury can contaminate a Million litters of water to above
safe levels, yet we are dumping about 2 tones of it into our environment in the
form of Fluorescent tubes, HIDs and CFLs, every year.
.
Broken down into material components, the 70 Million units of lighting
waste each year generated in Australia represents:
18,400 t Glass
500 t Aluminium
500 t other metals
700 t Phosphor powder
2,3t Mercury
Apart from the fact that this waste is the main source of Mercury
contamination of our landfill sites, we are also discarding valuable, energyintensive raw materials, which if collected and recycled would annually
account for 27,500 t of Greenhouse gas reduction, and the energy saved
would represent 5,620 cars off the road or electricity sufficient to power 6,200
average households.
These quantities will be increased further by additional 83-86 Million units of
CFLs following the Government's intended phase out of incandescent lights,
in 2010.
This will add: 2,800 t of waste to the current level, or broken down into its
individual waste components:
980- 1,260 t Glass
1,540-1820 t Ballast
56-84 t Phosphor powder
415-430 kg Mercury
However, because of the average 5 year working life expectancy of CFLs, this
waste will not be generated till 5 years after the Incandescent lights phase
out.
In view of the fact that the domestic sector is only a minor contributor to the
total lighting waste, we believe that the situation would be much more
manageable and that the task of the Government in mandating recycling and
banning Mercury containing lighting waste from landfill would be made much
easier, if the Government delayed legislating on the household, domestic
sector, till the issues of collection and financing are resolved, through such
initiatives as the current Flashback project run by Sustainability Victoria,
Detox Your Home, etc.
However we would urge our Governments to immediately mandate recycling
and landfill ban for Mercury containing lights used in the commercial and
industrial sectors. Such action would take care of more than 90% of the
problem. The domestic sector should be delayed till the commencement of
the incandescent lights phase out. Delaying the inclusion of the domestic
sector in the recycling legislation would give the private sector stake holders (
CMA Ecocycle, Lighting Council Australia,, other waste management
companies such as SITA, Veolia, TPI , etc. involved in the collection of
Mercury containing lights) time to demonstrate to the Government that it has
the plant, the technology, the resources and the structure for a nation-wide,
efficient and a cost effective collection and recycling system, into which the
domestic sector could be smoothly integrated when ready.
Our experience as a recycler shows that Australian businesses and
organizations are quite happy to budget and pay for the waste they generate
and we have not encountered any resistance to our recycling fees. This is
especially true for ISO 14 001 accredited companies and organizations, which
under their charter, have to recycle their waste if a practical and a cost
effective method is available to them.
The cost of recycling Mercury containing lighting is only about 2.0 % of the
retail value for CFLs and about 7.5% for Fluorescent Tubes and if the labour
component for their installation and removal was also included, the recycling
cost would be even lower and we expect that with increased volume, the cost
of recycling would also come down.
While we do not support across the board recycling levy, we do see a merit in
imposing a recycling levy at a point of sale at retail outlets. Such levy, by its
nature would exempt industrial and commercial sectors and would only apply
to the domestic consumption, because industrial and commercial users do not
source their lighting products from retail outlets.
A point of retail outlets levy would be equitable, because all suppliers who sell
into the Australian market would be treated equally, it would be easy to
administer and the revenue from it could be used to finance collection
programs by the retailers themselves or by local councils.
Australia will not attain any significant levels of recycling this type of waste,
unless action is taken which will stop the current uncontrolled and unregulated
landfill disposal of it
The cost of landfill disposal is only about 3c/kg, compared to the cost of
recycling, which is about $ 2.0-$2.50/kg. The gap is simply too wide. As long
as the landfill disposal option is there, unscrupulous waste management
companies will always take it, in preference to recycling. There are many
companies, who pay a recycling fee of $ 2.50/kg for the lighting waste yet it
ends
up in landfill, because there is more money to be made that way.
It is also important that the generators of such waste demand a copy of a
Mercury waste recycling license and a recycling certificate from the waste
management company contracted to dispose of their lighting waste.
.
We need a national action on this. Banning landfill disposal and mandating
recycling by individual states (S.A. and ACT) is welcomed and
commendable but unless there is uniformity of action in all of Australia, such
unilateral initiatives will only shift the problems to other states, where landfill
disposal is still legal.
While we welcome Government action, we also caution against overregulation, which is counter productive to collection and recycling of Mercury
containing lighting waste. An example of this is the current situation in ACT
Fluorescent tubes, CFLs, etc. can be picked up and transported to NSW for
landfill disposal without any regulation. However, if such waste is picked up
and transported to a recycling facility in NSW, the transporters must obtain an
agents approval from EPA, for the movement of controlled waste between
States and Territories under the NEPM, a valid consignment authorization
number must be obtained prior to any interstate movement, transport
certificate must accompany the transported waste, every 3 months, ACT EPA
must be supplied with a summary report showing the clients name, type and
quantity of waste collected, and the date of each collection. The waste can
then be processed and recycled on premises, which are subject to additional
licensing and compliance conditions and regulations. All this, to control and
regulate those who are trying to do the right thing, while dumping Mercury
polluting waste into landfill can go on unhindered.
We are encouraged by National Waste Policy development, which we hope
will also address the Mercury containing lighting waste issues. We do
understand that lighting waste contributes a relatively insignificant volume of
waste currently going to landfill, but that small volume (20,000 tones/P.A.) is
the biggest source of Mercury pollution of our landfills,
annually contributing 2000-2,300 kg Mercury into our environment.
Mercury Amalgam waste generated by the Dental industry.
The Dental Industry is currently the biggest source of Mercury pollution of our
trade waste water and of our water treatment plants.
The 11,000+ Australian dentists discharge about 4-6t of Mercury in the form of
amalgam waste, into our trade waste systems. Subsequently, biosolids
produced by many of our water treatment plants are heavily contaminated
with Mercury, to the extent that they are classified hazardous.
The Mercury discharge problem from the dental industry could be solved be
dentists installing Amalgam separators, which collect a minimum of 95.0%
of the Amalgam waste.
Currently, waste water discharged by dentists is treated as domestic
discharge. If the Government made Amalgam separator installations by
dentist and the recycling of the collected waste mandatory, the problem could
be solved by changing the dental discharge classification from domestic to
industrial and making the discharge license conditional on the installation of a
serviced Amalgam and make separator.
Dentists in all of Europe, Scandinavia, Canada, Japan, most of USA and in a
number of Asian countries are required to have Amalgam separators installed.
Overseas studies and projects demonstrate, that doing nothing more than
equipping dentists with Amalgam separators, will, by the process of dilution,
render heavily Mercury polluted biosolids non hazardous, within 2-3 years.
Mandating Amalgam separators by dentists would not only benefit our health
and our environment and would bring Australia in line with the rest of the
developed World, but it would also ad value to large volumes of biosolids
generated by our water treatment plants and turn them from a liability to a
valuable resource which could be utilized in horticulture, agriculture or as a
high calorific value fuel for use in cement kilns.
Thanking you,
Yours Sincerely.
Peter Bitto