CFL Recovery, Recycling & Disposal

Implementation Guideline
 CFL Waste Management
Implementation Guidelines
An overview of best practice to ensure compliance with relevant
legislative requirements for the responsible handling of spent
Compact Fluorescent Lamps (CFLs).
Waste handling activities
Best practice for CFL waste management
Separation at Source:
The need for an environmentally acceptable, yet cost effective,
Separate CFLs from normal waste stream
spent Compact Fluorescent Lamp (CFL) management programme
has become one of the environmental priorities in South Africa.
Private Transportation:
Homeowner delivery to collection point
The main objective of this document is to provide practical guidelines
Drop off Centres: for the best available technologies and practices to all stakeholders
Centrally-located CFL collection points conducting any activities related to both the disposal or recycling of
spent CFLs.
Transport:
Bulk transport of CFLs Environment considered
Storage and Treatment: Increasing environmental consciousness,
Temporary storage and treatment (if required) the prominence of climate change
concerns and energy constraints globally
Disposal: have prompted an intensified focus on
Disposal at an H:H-permitted landfill facility energy efficiency measures, resulting in a
significant increase in the usage of CFLs.
Recycling:
Recovery of components and mercury for re-use

Fund and Administration Oversight:

Proposed function to oversee all aspects of CFL recovery
 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 (long-
term 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 mercury released
Minimum No CFLs to general No mercury released No mercury No mercury
No mercury released No mercury released and no contaminated
Requirement landfill in transport released in storage released in transport
components

Safe bulk Environmentally- Environmentally-

Implementation Safe keeping to Suitable container Safe intermediate Environmentally-
transportation sound practice/ sound practice/
Guideline prevent breakage to prevent breakage storage sound practice
in suitable containers technology technology

Authorised Licensed facility Licensed facility

Roles and Consumer/ Consumer/ Authorised Authorised service
drop-off centre owner or owner or
Responsibilities Householder Householder transporter provider
owner/manager manager manager

Refer separate Refer separate

Relevant Relevant bylaws, Refer separate Refer separate Refer separate Refer separate
legislative legislative
Legislation NEMA and Waste Bill legislative overview legislative overview legislative overview legislative overview
overview overview

Communication Extensive general education and awareness regarding waste and recycling. Specific communication support including labeling of packaging and clear signage
Requirements of premises. Collaboration and integration with relevant stakeholders are essential.

M&V Type and volumes Volumes

None None Volumes treated Volumes landfilled Volumes recycled
Requirements received transported

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
 3
Keeping CFLs out of the general waste bin

The outgrowth of conservation,

the inevitable result, is national efficiency.
- Gifford Pinchot
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:

Consumer
Separation Best Practice Additional Information
at source Objective No CFLs are to be disposed of at a landfill for general
General landfill sites are not designed to accommodate the
release of mercury. Mercury needs to be treated (encapsulated
household waste. in concrete or similar) to prevent leaching and release into the
Personal health environment (e.g. atmosphere or groundwater).

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
The Minimum Requirements state that hazardous waste must
Minimum Requirements for Hazardous Waste
go to a hazardous landfill site. Check with the local municipalitys
Legislation Disposal (www.dwaf.gov.za/Dir_WQM/docs/Pol_
department of solid waste management for suitable local
Hazardous.pdf) and any relevant municipal bylaws.
requirements or solutions for hazardous household waste.
Do not throw CFLs away with your domestic waste.
Ideally CFLs should not be broken and should be placed in their
Keep CFLs separate until you can safely take them to
What to original packaging or wrapped in a plastic bag.
a drop off/collection point.
do with
In the event of breakage, special care must be taken Advice on cleaning up broken fluorescent lamps is freely
your CFLs
to clean up and contain mercury powder and available on the Internet and also on Eskoms website at:
glass shards. http://www.eskomdsm.co.za/?q=CFL_Recovery.
At present Woolworths and Pick n Pay stores offer CFL
Where to
collection points. Pick n Pay also accepts household batteries
CFLs can be taken to participating retailers and for disposal and recycling. Check with your local council for
take your
collection points in your area. any other options for disposal of household hazardous wastes
CFLs
such as empty containers or leftover thinners, paints, poisons,
batteries, etc.
How to Spent CFLs should ideally arrive at a drop-off point It is recommended that packaging in which CFLs are bought
store your unbroken. The lamps should therefore be securely is kept and used for this purpose. Alternatively, packaging of
CFLs packaged in a safe container for storage and transport. replacement lamps can be used if readily available.
 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 Separation
Best Practice Additional Information at source
Prevent disposal at the local general
Objective landfill facility.
Municipalities should proactively encourage separation at source of all
Relevant contacts
CFLs must be kept away from other waste recyclable and hazardous household wastes including specifically CFLs. The City of Cape Town, Cleanest
at point of generation by the homeowner. City in South Africa 2007,
has done extensive work on
Municipal functions are guided by the
Waste separation is an important step in the Government drive for
waste related education and
Municipal Systems Act, NEMA and the awareness efforts (e.g.WasteWise
Legislation waste minimisation and key to achieving the waste hierarchy:
Minimum Requirements for general landfill campaign) that could be of value to
Reduce, Re-use, Recycle.
and hazardous waste.
other Municipalities. You may find
information on their website (www.
Have available and provide information (e.g. with billing information
Educate and create awareness among the capetown.gov.za/en/solidwaste)
How to and/or on enquiry) of local recycling and recovery initiatives such
implement
public regarding the need for waste sepa-
as paper and glass banks, recycling collection services, eWASTE
or can direct enquiries to: Solid
ration and specifically the need for separat- Waste Management Department
in your collection points or initiatives and particularly participating retailers
ing CFLs and other hazardous wastes from +27 (0)860 103 089 or email
municipal area that accept CFLs (refer to drop-off centre component
the waste stream.
of this guideline). 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 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:
Industry
Best Practice
Objective
Prevent the disposal of CFLs and other
fluorescent lamps with other households
waste in order to facilitate recovery.
Industrys involvement will be most
effectively governed under the pending
Legislation Waste Management Bill, a subset of the
National Environmental Management
Act (NEMA).
CFL packaging should be labeled
appropriately to educate consumers
regarding mercury content and handling
of CFL waste.
Additional Information
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.
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.

Philips: +27 (0)87 940 4194 Call centre details to be provided on

or +27 (0)11 471 5065
or www.philips.com/about/
sustainability/recycling
or refer to page 14 for others.
A collaborative effort among lighting suppliers can address all these
What to packaging and call centres should be
calls or alternatively existing call centres can be briefed to deal
empowered to deal with enquiries relating
do with CFLs with these questions.
to safe disposal and handling of CFL waste.
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).
 7
Department of Environmental Affairs and Tourism (DEAT) Responsibility

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 Additional Information

Objective
To encourage thorough legislation and
regulations and to enforce separation at Separation at source is an essential component of all recycling initiatives
Separation
source of all recyclable and particularly
hazardous household waste.
and should be widely encouraged. at source
DEATs involvement is governed by the

Legislation
national legislative framework including:
the Constitution, National Environmental
Relevant contacts
Management Act and Municipal Relevant DEAT Directorates and
Systems Act.
contacts include, among others:
Encourage and support the inclusion of the
Where to
concept into Municipal Integrated Waste Emphasis should be placed on the importance of appropriate handling
enforce
separation
Management Plans and the development of of hazardous household waste among all role players and every entity 1. Directorate:
bylaws to enforce separation at source under legal obligation to comply. Waste Stream Management,
at source
by homeowners.
Ms Dee Fisher
A national education campaign. General +27 (0)12 310 3527,
education must be provided to the
Overall education relating to waste, recycling and hazardous household dfisher@deat.gov.za
How to public to improve their knowledge of the
waste has been identified during public consultation as an imperative
support impact of mercury bearing lamps on
since existing awareness levels are extremely low. Education with regard
separation the environment. Support should also be
at source provided to provincial departments and
to the benefits of using energy saver lamps should also form part 2. Directorate:
of communications. Waste Policy & Information
local municipalities in the form of information
sharing, education and empowerment. Management, Mr Obed Baloyi
+27 (0)12 310 3833,
obaloyi@deat.gov.za
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.
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 Additional Information Private
Objective To ensure safe transportation of spent CFLs
Transportation
to a drop-off centre or mobile unit.
Relevant contacts
Minimum Requirements for Hazardous Usually applicable to bulk carriers of hazardous materials. Safe eWaste service providers
Legislation
Waste Disposal, National Transportation Act. keeping of small quantities to prevent breakage required. and recycling companies
provide collection services that
sometimes include hazardous
Ideally CFLs should not be broken during It is suggested that CFLs be placed in their original packaging or empty
How to transit. CFLs must be transported carefully packaging of replacement lamps or wrapped in a sealable (heavy/thick) household waste . Ser vice
transport in a manner that will prevent breakage and plastic bag. Transport household hazardous waste in the rear of provider s or participants in
your CFLs minimise the risk to handlers for delivery to the vehicle, ideally packed securely in the vehicle to prevent crushing your area may be listed with:
a suitable disposal or collection point. and do not store in the vehicle for extended periods.

1. eWASA (National):
If during transit a CFL does break, open
+27 (0)11 312 3605
Also wipe the car with a damp cloth and dispose of any remaining or www.ewasa.org
What if your windows immediately and pull over at
glass fragments at your earliest convenience. Containment of the
CFLs break the nearest safe location. Once air has been
lamps in a plastic bag will contain any pieces and will greatly simplify 2. Urban Sprout Eco-Directory:
during transit circulated, put CFL in a plastic bag and drop
the cleaning up. www.urbansprout.co.za
off at the nearest drop-off centre.
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 Municipality

Transportation Objective
Best Practice
To ensure safe transportation of spent CFLs
Additional Information

to a drop-off centre or mobile unit.

Mobile Units
The use of mobile units is a
Legislation
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.
Usually applicable to bulk carriers of hazardous
Minimum Requirements for Hazardous Waste
materials. Safe-keeping of small quantities to prevent
Disposal, National Transportation Act.
breakage is required.
A municipality may be involved in the
transportation of spent CFLs by implementing a
Spent CFLs must be transported in such a manner that
the breakage of CFLs is prevented and that, in the case
contract with a private company. It is essential that
of breakage, no mercury leakage emanates from the
the private company makes use of specific crates
transportation containment.
which prevent the breakage of spent CFLs.
Vehicles must be roadworthy and appropriate
and in accordance with the National Traffic Act
How to (GNR. 225) requirements.
transport
The applicable TREM decals must be displayed on
CFLs
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 Private

Best Practice Additional Information
Service providers may cut out the collection points and
Transportation
Objective To ensure safe transportation of spent CFLs to a drop-
transport CFLs directly to a storage or treatment facility.
off centre or mobile unit (or other appropriate storage
or treatment facility).
In that case please refer directly to bulk transport and
waste treatment and storage implementation guidelines.
Relevant contacts
Usually applicable to bulk carriers of hazardous materials. No ser vice provider s are
National Transportation Act, Minimum Requirement for
Legislation
Hazardous Waste Disposal.
Safe keeping of small quantities to prevent breakage currently known to provide
is required. collection services for CFLs from
If a private waste contractor would like to be involved
Suitable packaging and containers/crates are particularly households, but service providers
in the transportation of spent CFLs, it is essential that
specific crates which prevent the breakage of spent
important if transported with other wastes that can crush that collect from commercial
the CFLs in transit. properties may be available to
CFLs be used.

Vehicles must be roadworthy and appropriate and in

accordance with the National Traffic Act (GNR. 225)
requirements.
How to The applicable TREM decals must be displayed on the
transport vehicles and provide correct details.
CFLs
The driver(s) of the vehicle(s) must ideally 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.
assist at a fee.
The following service providers
are active in the commercial
market:
If very small quantities are transported with other
wastes, it is recommended that the driver is at least 1. Nova Lighting
trained to deal with breakages or spillage of hazardous
materials including CFLs.
2. Lumino
3. Actebis
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 Refer to Treatment Section of this
consumer guideline). guideline for the contact details.
Hosting CFL Collection Points/Drop-off Centres

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
Safely deposit all failed CFLs at
participating collection points
or drop-off centres.
Minimum Requirements for
Legislation Hazardous Waste Disposal,
any relevant municipal bylaws.
Deliver CFLs intact to
How to use participating collection points
a drop-off or drop-off centres and
centre deposit into the dedicated
container provided.
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
13
Additional Information
Drop-off
Centres
Relevant contacts
The following collection points are
available to consumers wanting
to participate:
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
1. Pick n Pay stores nationwide.
be clearly marked and secure unless specifically instructed otherwise at the specific
drop-off centre. Handle spent CFLs carefully to prevent breakage. Children should Contact Pick n Pay for your
be kept away from the collection bins and discouraged to play with or around closest store on
these facilities. Replace failed CFLs with a suitable replacement.
+27 (0)800 11 22 88
or visit their website:
www.picknpay.co.za
warm white or cool white) or alternatively can
be coloured lighting/glass, such as red or blue. 2. Select Woolworths stores
- The appropriate fitting i.e. screw-in or bayonet. nationwide. Contact
Woolworths for participating
- Whether the lamp should be dimmable stores on +27 (0)860 100 987
or not and whether it should function or visit their website:
with a motion sensor (often required www.woolworths.co.za
for external or security applications).
 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 Centre Facilities
Best Practice Additional Information
Drop-off To host a clearly marked and safe drop-off facility.

Centres To ensure that CFLs are temporarily stored in a manner

Permissible storage
Current legislation requires:
1. Permitting of a collection/
drop-off facility to act
as a temporary waste
storage facility.
that is not harmful to the individual housholder, the public
Objective or the environment.
To provide a convenient point for the consumer to return their
spent CFLs.
To provide a permanent or temporary point for waste It is anticipated that drop-off points will form part of an
transporters to collect spent CFLs en masse. ever expanding network of CFL collection infrastructure.
Minimum Requirements for Hazardous Waste Disposal new Refer to the legal overview for specific acts, clauses and
Legislation
EIA Regulations. regulations of interest.
A suitable container of sufficient size that can safely accommo-
date the volumes of CFL waste dropped off.

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).
A sufficient area of floor space to accommodate the container
and to allow access and ventilation if required.
Drop-off containers should be positioned in a prominent and
What is easily accessible location that is clearly marked.
required of
the facility?
Additional overflow storage capacity needs to be provided by
drop-off centre hosts for the safe storage of full containers.
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).
Typically a minimum of 1m2 space is required.
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 storage is required to accommodate any
delays for the pick-up of the spent CFLs by specialised
treatment, disposal or recycling service providers.
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 Additional Information
The collection point should preferably only
accept intact CFLs and no breakage should
The public and employees of the collection facility should be educated.
occur during the drop-off or temporary
storage process.
Quantities of CFL waste collected and stored Regular emptying of containers to avoid overflow and thus breakage
must be safely manageable at all times. and regular removal from collection points is strongly recommended.
Collection points must be clearly demarcated
and labelled and containers must be labelled
Communication, education and awareness creation are critical. Every Drop-off
with clear instructions on the type of
opportunity should be used to encourage participation and to remind
the public to drop off unbroken CFLs, preferably in original packaging
Centres
How to lamps accepted and how the lamps have
or wrapped/sealed in a suitable plastic bag.
manage a to be returned.
drop-off The temporary storage area for full containers Relevant contacts
centre must be safe and easily accessible when lamps Hazmat provides a national
are picked-up.
24-hour spill response service.
Collection frequency must be commensurate Collection frequency can either be based on an actual needs base Hazmat can be contacted incase
with the volumes of CFL waste actually dropped (when bin is full) or can be at regular intervals throughout the collection of emergency toll free at:
off and generated within the retail store. period (e.g. every fortnight).
0800 00 58 17 or for enquiries
The drop-off centre/collection facility may not
be left unattended at any time. At least one Drop-off centres cannot take the format of a glass bank left unattended
contact the head office at
employee should be present on site/in-store in a parking area. The delegated responsibility is particularly important in +27 (0)33 386 2264
and should be identified as the individual the case of spillage or breakage. or email: ian@hazclean.co.za
responsible for CFL collection. Alternatively visit their website at:
How to
Containers must be inspected regularly www.24hourspillresponse.co.za.
for level and other problems e.g. mercury
safely
contamination from broken bulbs and their
store CFLs
overall functionality.
 Industry Responsibility
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
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.
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.
Industry
Best Practice Additional Information
Support the establishment of safe, convenient and
legally compliant drop-off centres that will facilitate the
Objective
recovery of CFLs.
Ensure the sustainability of drop-off centre for CFLs.
Minimum Requirements for Hazardous Waste Refer to legal overview for specific acts, clauses and
Legislation
Disposal new EIA regulations, Waste Management Bill. regulations of interest.
Assist with creating public awareness in terms of CFL
drop-off centres.
How to Support the establishment of safe, convenient and
legally compliant drop-off centres that will facilitate
Financial, logistical and administrative support are all required
support
to ensure a sustainable solution.
drop-off the recovery of CFLs.
centres
Several oportunities arise such as linked sales promotions
Encourage the use of drop-off centres. 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 Drop-off
Objective
recovery of CFLs in municipal areas.
Centres
Encourage participation by residents in the
municipal area.
International experience
Prevent the disposal of CFLs in general landfills. In the US, local governments have
reached out to local retailers to
Municipal Systems Act, Minimum Requirements for host collection points. Information
Legislation
General Landfill. and examples of bins, posters and
Possible options for collection points include utility offices, collection points can be found on
The municipality may host CFL drop-off facilities at suit-
How to public libraries, community centres or manned refuse the websites of:
able municipal premises.
drop-off centres.
get facilities for
CFL Hardware stores, lighting suppliers, general retailers, - IKEA
collection Engage local retailers or other suitable facilities to host
24-hour convenience stores at petrol stations can all be
CFL drop-off centres. - Wal-Mart
considered for participation.
How to - Sears Stores
Assist with education and creation of public awareness
support Communicate details of participating drop-off facilities
drop-off
regarding the need for and participation in CFL drop-off
in municipal publications and communications. - Ace Hardware
centres. Empower interested participants.
points
- 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.

DEAT
Drop-off Best Practice Additional Information

Centres Objective To encourage the use of drop-off centres A formalised and appropriately managed collection mechanism for
and to support drop-off centres. CFLs is a significant improvement on the status quo.

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.
Legislation
Minimum Requirements for Hazardous
Waste Disposal, new EIA regulations.
Exemption should be considered and Emphasis should be placed on the importance of appropriate handling
supported for the listed activity as per of hazardous household waste among all role players and every
regulation 386: The temporary storage entity under legal obligation to comply. Alignment of EIA and Waste
How to
of hazardous waste. Management requirements to support CFL recovery is essential.
support CFL
collection Whilst relaxation is proposed, alternate mechanisms such as an
Request/enforce (as appropriate) the
Industry WMP is required to ensure that CFL recovery is structured
development of a Lighting Industry Waste
and responsible through a formal waste management plan and an
Management Plan.
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

19
Bulk Transportation
 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.

Waste Contractor
Bulk transportation
Relevant contacts
No service providers are currently
known to provide collection ser-
vices for CFLs from households,
but service providers that col-
lect 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.
Best Practice Additional Information
Objective To ensure safe transportation of spent CFLs to a landfill
site or recycling facility.
Minimum Requirements for Hazardous Waste Disposal,
Legislation
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 in 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.
The applicable TREM decals must be displayed on the
How to vehicles and provide correct details.
transport
your CFLs The driver(s) of the vehicle(s) must be qualified, trained and
hazardous waste certified to transport hazardous goods.
Ensure ventilation of the area of breakage and ensure
a spill kit is available. A single breakage can be cleaned
In the event of breakage or spillage all personnel must
up and addressed as for a private vehicle (refer to
leave the vehicle immediately and contact the incident
consumer guideline) Hazmat provides 24-hour spill
team. Personnel must wear Personnel
response in the case of an accident or serious spill of large
Protective Equipment (PPE) at all times.
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

Best Practice Additional Information
Objective
To ensure safe transportation of spent CFLs to a landfill site or recycling facility.

Minimum Requirements for Hazardous Waste Disposal, National

Legislation
Transportation Act.

Verify that the contractor complies with the Best Practices described in the Spent CFLs must be transported in such a manner that the breakage
preceding guideline. This will include having suitable crates which prevent the of CFLs is prevented and that in the case of breakage no mercury leaks from
breakage of spent CFLs. the transportation containment.

Vehicles are roadworthy and comply with the National Traffic Act
(GNR. 225) requirements.

Applicable and accurate TREM decals are displayed on the service

What to consider providers vehicles.
when contracting
for the Confirm that driver(s) of the vehicle(s) are qualified and are certified
transportation to transport hazardous goods.
of CFLs
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.
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
Bulk transportation Objective To encourage thorough legislation and regulations.
The separation at source of all recyclable, and particularly
Separation at source is an essential component of all
recycling initiatives and should be widely encouraged.
hazardous, household waste.
DEATs involvement is governed by the National
DEAT Contact details Legislation legislative framework including the Constitution, National
Environmental Management Act and Municipal Systems Act.
Directorate: Pollution
Where to Encourage and support the inclusion of the concept into
& Waste Management: enforce Municipal Integrated Waste Management Plans and the
Emphasis should be placed on the importance of appropri-
ate handling of hazardous household waste among all role
separation development of bylaws to enforce separation at source
Mr Rantsadi Moatshe players and every entity under legal obligation to comply.
at source by homeowners.
+27 (0)12 310 3648
Overall education relating to waste, recycling and
rmoatshe@deat.gov.za hazardous household waste has been identified during
A national education campaign. General education must
public consultation as an imperative since existing
How to be provided to the public to improve their knowledge of
awareness levels are extremely low. Education with
support the impacts of mercury bearing lamps on the environment.
Directorate: Authorisation regards to the benefits of using energy saver lamps should
separation
also form part of communications.
& Waste Disposal Management: at source
Support should also be provided to provincial depart-
Ms Kellelo Ntoampe ments and local municipalities in the form of
information sharing, education and empowerment.
+27 (0)12 310 3920
kntoampe@deat.gov.za
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

23
Treatment or Storage Facilities for CFLs
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 Additional Information
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.

Suitable containers of sufficient size that can contain intact, failed CFLs and that
What is required will protect the lamps from breakage.
for storage of CFLs Sufficient floor space to accommodate bulk storage of CFLs in suitable contain-
ers.
A spillage clean-up kit needs to be at hand in case CFLs are
accidentally broken.
How to support Ensure ventilation in the area of breakage and ensure a spill kit is available. In
separation at source All personnel must be trained to deal with spillages and must be well educated
the case of a major event, it is recommended that Hazmat or a similar service
about the risks associated with the mercury bearing lamps.
provider be called in.
Personnel must wear Personal Protective Equipment (PPE) at all times.

Treatment Facility
Best Practice Additional Information
Objective Ensure that CFLs are crushed, chemically treated (where required) and sealed Crushing and treatment into an inert and sealed format is essential except
in manner that is not harmful to the environment or mankind. 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 permit-
Legislation
ment 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
Treatment Facility
Best Practice Additional Information
or storage
All CFLs that will be disposed of at a landfill must be Relevant contacts
pretreated under controlled conditions in line with
legislative requirements (refer above). The following companies are known
Any mercury vapour emanating from any treatment to provide treatment services for
technology must comply with the OHSA minimum mercury bearing lamps:
standards.
To meet all the legislative requirements and best
All waste and recovered material must be contained and practice described, the crushing technology would typi- 1. Nova Lighting.
stabilised by adding mercury immobilising chemicals. cally operate in a vacuum or under negative pressure and Tel: +27 (0)21 706 4451,
must incorporate a comprehensive filter system. Email: mike@nova.co.za
How to Mercury vapour that forms as a result of crushing
treat CFLs? mercury-containing CFLs and tubes as well as any
or web: www.nova.co.za
extracted mercury must be contained as part of any
2. Lumino.
crushing operation.
Tel: +27 (0)861 111 319
Personnel must wear Personal Protective Equipment (PPE) Email: lamps@lumino.co.za
at all times.
or web: www.lumino.co.za
All personnel must be appropriately trained to handle CFL
waste and emergency situations.
3. Actebis.
Tel: +27 (0)16 423 7802,
Spent CFLs must be placed in air-tight drums during Email: actebis268@lantic.net or
the treatment process and sealed on completion of the
web: www.tubeandglobeguzzler
treatment process.
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

Waste disposal should remain a last resort in line with
CFLs should be disposed of at a licensed hazardous
landfill site.
stated Government objectives and waste hierarchy. Disposal at landfill
Legislation DWAF Minimum Requirements for Hazardous Waste Disposal.
Spent CFLs may only be disposed of at a licensed hazardous
landfill site.
Relevant contacts
All CFLs that are disposed of at a hazardous landfill site
must be pre-treated as per these guidelines and Minimum All treatment must be completed prior to arrival at the Only three landfills are suitably
Requirements (refer to earlier component of this document landfill site. licensed for the acceptance
and separate minimum requirements). of hazardous wastes, such as
The containers in which CFLs are treated and transported mercury, in South Africa. These
Containers should be clearly labeled according to their
How to to the landfill site may not be opened. The containers must
contents. are located in the Western Cape,
landfill be disposed of as is on site.
In accordance with licensing requirements this should
Eastern Cape and Gauteng
CFLs
include the following: respectively and details can be
The hazardous landfill site where CFLs are disposed of - R egular audits of the facilities as per the obtained from DEAT (see earlier
must be permitted/licensed and operated as per the DWAF Minimum Requirements. contact details) or from the
Minimum Requirements for Hazardous Waste. - A measurement and verification system must be
Institute of Waste Management
in place whereby all CFLs that arrive at the landfill site
must be recorded in terms of mass. (IWMSA).
Operating plans at such a hazardous landfill site must include Operation should include encapsulation
a plan for disposing of spent CFLs. in an impermeable substance, such as concrete. Tel: +27 (0)11 675 3462/4
Email: iwmsa@telkomsa.net
Website: www.iwmsa.co.za
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.
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 Facilities
Recycling
Best Practice Additional Information

Current and pending legislation incorporates the Relevant contacts

Objective Recycle CFLs and all the components in an
environmentally friendly manner whilst ensuring the
operation is environmentally and financially viable.
Legislation New EIA Regulations, pending Waste Management Act.
CFLs should ideally be received intact or if crushed, ap-
propriately sealed to prevent the release of any mercury
vapour, but should not be pre-treated with any chemicals.
All mercury should be contained and treated
Recycling
of CFLs
and no mercury emissions should result from the
recycling activities.
Recycled components should be free of any
mercury contamination.
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
Reclite is in the process of
establishing a mercury recovery
to a complete impact assessment with consideration
of the above. and recycling facility for lamp
Comprehensive licensing requirements will apply
components in South Africa. The
facility will accept a wide variety
to recycling facilities.
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
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

Best Practice Additional Information Fund administration
Administrator should be directly involved in all aspects
A management and administration entity to oversee and
Objective of collection, transport, recycling and fund management
manage the implementation of the CFL Recovery
in an oversight capacity. Provides support to all existing
Initiative in accordance with the Minimum Requirements
and interested role players to facilitate participation and Voluntary participation
and Implementation Guidelines.
compliance with best practices.
Participation by participants of the initiative and industry Research findings have shown that
Structured as and compliant with all legislation relevant to shareholders should be on a voluntary basis. Lighting pending legislation has resulted
Legislation a Section 21, non-profit organisation registered as industry participation may become a requirement in
in extended delays in activity in
a Public Benefits Organisation (PBO). the case of an Industry Waste Management Plan being
adopted. anticipation of the detailed legis-
lated requirements. As a result, the
These functions should include the following:
- provide a collaboration platform for CFL manufacturers time required for legislation to be
and importers. promulgated becomes a major bar-
Basic facilitation and support.
- drive awareness, education and communication rier for implementation. Voluntary
for the initiative. participation is therefore the best
- facilitate interaction with Government.
immediate way forward in spite of
Support
Implement fund management activities including fund the obvious limitations.
functions to
collection and disbursements or contracting of services
be provided Management of funding and flow of funding.
as appropriate. Appointment of an auditing entity for fund
management or oversight of fund management.
Appointment and management of all service providers to
Collection and delivery of CFLs.
collect and deliver CFLs and collation of data.
Contracting and management of companies to recycle or
Recycling/disposal activities.
dispose of CFLs and collate data.
Fund Administrator Responsibility

Fund Administrator and Management

Best Practice Additional Information

Flow of An initial kickstart or start-up fund may be required from relevant stakeholders
The optimal solution for continuous flow of funding is through a manufacturers/
funding to initiate a recovery programme prior to the establishment of a levy.
importers levy to the fund administrator from where payments to all collection
The option of an incentive for participation to consumers requires further
entities, transporters, recyclers, etc. are managed.
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
Best Practice Additional Information
Collection
Please do however check that collection services capture the required data
points No data logging required.
when picking up CFLs from your premises.
Required to capture quantities/volumes collected and delivered to any of the
following as applicable:
Information requirements are as per prescription for all transportation of
Waste contractor(s) - Treatment/storage facilities
hazardous wastes.
- Disposal facilities i.e. hazardous landfills
- Recycling facilities
All participants are required to capture the following detailed information:
1. V
 olumes, quantities or weights collected, received, treated, recycled
Storage, treatment, or landflled material.
disposal or recycling 2. Relevant dates such as collection or delivery.
facilities
3. Signature(s) of authorised individual(s) for each facility or vehicle.

4. Confirmation of due process followed.

 33

Project Contacts and Acknowledgements

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, Recycling & Disposal
Implementation Guideline