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Opinion – Knowing where you stand

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Anyone involved in specifying or installing lighting needs to be aware of who is responsible for what under the WEEE regulations, says Lumicom chief executive Ernest Magog

While the WEEE (Waste Electronic and Electrical Equipment) regulations have introduced a valuable ‘imperative to recycle' that will make a positive contribution to sustainability, they have also created some confusion. In particular, many of the people involved in the procurement and disposal of WEEE such as lighting are often unclear about their own responsibilities.

This is an area where specifiers and installers need to have clarity with regard to their own involvement and can also guide the end user to the most straightforward solutions.
My organisation – Lumicom – is a not-for-profit organisation that has been created to manage the recycling of luminaires under the WEEE Directive. It works closely with Recolight, which is responsible for light sources such as discharge lamps. And while our experience is with lighting products many of the general principles apply to all types of WEEE and serve to help clarify the situation.

As far as the WEEE Directive is concerned there are two categories of waste – historic waste, installed before 13th August 2005, and future waste, installed after that date. Future waste is marked with a crossed out wheelie bin to indicate that it cannot be consigned to the general landfill waste stream.

With historic waste, the producer of any replacement equipment is responsible for facilitating an infrastructure that will accept historic waste. In the case of future waste, it is the producer of the discarded waste that bears this responsibility. This effectively means that lighting manufacturers are responsible for the disposal of the majority of discarded light fittings from refurbishment and refit projects.

Similarly, suppliers of lighting equipment for current new-build projects will be responsible for disposing of those products when they are removed in the future. In most cases this will be through an accredited scheme such as Lumicom. However, if there are no replacements, such as in a demolition project, then the responsibility for disposal falls to the end user if the products were installed before 13th August 2005.

As with other forms of waste disposal, the building operator has a responsibility to ensure that this is carried out by whichever contractors or sub-contractors are involved. This means that while specifiers and installers do not have any direct responsibility for the disposal of light fittings, other than ensuring that waste is sorted properly on site (see below), there is an implied responsibility to the client.

Many would argue that it's reasonable for the client to expect and receive specialist advice on such matters from the experts employed to do the work. There is certainly a benefit to adding value to the service in this way and could be beneficial in terms of future work from that client.

For example, the high proportion of lighting projects will use light fittings from a number of different manufacturers to meet the needs of all the spaces. However, at the end of life of those fittings, which manufacturer will be responsible for disposal? Or will the building operator have to deal with a dozen or so different suppliers to dispose of used fittings. This is one of the reasons for the formation of schemes such as Lumicom as it brings manufacturers together under a single umbrella. So as long as all of the fittings are sourced from members of the same scheme there is still just one disposal body to deal with. Nor should this mean the designer's flexibility is hampered, as any such scheme ought to incorporate a significant number of the key players. Thus far, Lumicom is the only such scheme to have the necessary infrastructure in place.

In all cases, the contractor would be well advised to draw the client's attention to the need to have the discarded equipment transported to bulking up points established by recycling schemes as the cost for doing this will be additional to the stripping out work. If the client or specifier is unwilling to source all luminaires from members of a single scheme, contractors should also protect themselves by amending terms and conditions of trade. In particular, they need to exclude themselves from any WEEE responsibility for either the old luminaires coming out or the new ones going in. Such actions by contractors could have an impact on the design and specification of the lighting scheme, so specifiers also need to be aware of the implications of this.

Sorting on site
Another issue to be aware of is that the key components that make up a light fitting need to be recycled through different waste streams, so these have to be separated before being sent for recycling. Some waste disposal contractors will collect the entire fitting and separate the components themselves, while others will require the separation to be carried out before collection. In the latter case, this has implications for the waste management on site and the project managers responsible for this.

The three most important components that need to be handled separately are lamps, batteries in self-contained emergency luminaires and liquid filled power factor correction capacitors. Ensuring this separation is carried out is very important.

For example, discharge lamps – such as fluorescent, metal halide and sodium sources – are classified as hazardous waste because of the small amounts of mercury they contain. Consequently, not only do they need to be separated, they also have to be stored carefully on site in compliance with the CoSHH (Control of Substances Hazardous to Health) regulations.

Another reason for separation is that the majority of discarded luminaires are shredded into small pieces of metal and plastic and sold as raw material – much of which ends up in the Far East and goes back into manufacturing. If the hazardous components were not separated first the entire batch could be contaminated. This would significantly increase the cost of disposal and could lead to legal action under hazardous waste regulations.

This highlights a further benefit of compliance schemes, namely that they will ensure all waste disposal in compliance with legislation, backed by a full audit trail. Yet another reason for ensuring that lighting suppliers for the project have a WEEE registration number and are members of a suitable compliance scheme.

As the WEEE regulations ‘bed down' and people are coming to accept waste disposal considerations as an integral part of any project, it is also becoming second nature to address these issues as part of the design and installation process. Equally, taking advantage of the schemes that have been put in place to make disposal safe and straightforward is also becoming the obvious and most sensible way forward.

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