Mercury Lamp Recycling Information for Canadians

Management Options for Commercial Quantities of Spent Lamps

Fluorescent lamps The Government of Canada strongly encourages the recycling of all spent fluorescent lamps (including compact fluorescent lamps) as the preferred approach to managing them at the end of their life cycle.  There are a number of ways in which large quantities of whole (unbroken) lamps can be sent to, delivered to, or picked up by recyclers (depending on the recycler and where you are located). More information on collection options and recycling, as well as on the use of drum-top crushers, is provided in some of the other fact sheets.

The U.S. Environmental Protection Agency’s Fluorescent Lamp Recycling document (PDF, 234 kb) provides an excellent outline of the steps to take when planning a recycling program in your place of business. Its recommended seven steps are as follows:

Step 1: Assess Your Facility – Assessing your facility is a key initial step. Consider the following questions: How many fluorescent lamps are in the facility? Where are they located? How often do you change your lamps? How many spent lamps are you generating each month/year? How are you handling and storing the spent lamps? Do all employees know who to call if a lamp burns out?

Step 2: Become Knowledgeable About Provincial, Territorial and Federal Requirements for Managing Fluorescent Lamps – Consult your provincial or territorial solid waste and hazardous waste regulations (which may include extended producer responsibility) for region-specific requirements for managing fluorescent lamps that may apply to your facility. In some provinces and territories, reference must be made to the federal Transportation of Dangerous Goods Regulations. Lamp recyclers will be aware of government requirements and should be able to provide assistance in this area. If the lamps are ground (like in a drum-top crusher), the mercury-phosphorous powder is considered to be a hazardous waste or dangerous good and must be managed accordingly.

Step 3: Select a Recycler – Select a recycling contractor that will best serve your needs and provide you with assurance that your spent lamps will be properly managed. Your lamp supplier (“re-lamper”) may also offer a recycling service. A number of companies offer this “one-stop shopping” service to their customers. To assist you in selecting a recycler, some general criteria are provided:

  • Service – Important items include responsiveness, timeliness, program flexibility and customization, whether there will be intermediates (e.g., brokers or lighting contractors), the capabilities of the firm, and the equipment it will be using. If you wish to use a drum-top crusher for storage and pick-up purposes, you should confirm that the recycler will accept crushed lamps.
  • Risk management – The responsibility for hazardous wastes or hazardous recyclables (like crushed fluorescent lamps) may reside with whoever is “in possession”; therefore, to minimize risk, the generator should use an approved or certified hauler/recycler. Failure to do so may shift the liability back to the generator. Where the collection, storage, shipment, processing, and classification of hazardous waste are concerned, the business generator has a duty to consult with the relevant provincial/territorial authority (refer to the Key Contacts fact sheet).

    Important questions to consider when evaluating recyclers include:
    1. Do they have government permits and approvals for facility operation or transportation?
    2. Do they meet insurance requirements for general and pollution liability?
    3. What indemnities or other assurances do they offer clients?
    4. What is their environmental record and compliance history?
    5. Does the recycler maintain debris- and dust-free public areas?  (Good housekeeping practices are an important component of good environmental practices.)

Ask potential recycling contractors for references. If possible, check with the appropriate provincial agency that regulates recycling facilities to see if they have compliance history information. There is some concern that companies may claim to be recyclers but, instead, are disposing of collected lamps in landfills. For a list of facilities in Canada that recycle mercury-containing lamps, refer to the Key Contacts fact sheet.  In some jurisdictions, the movement of hazardous recyclables can be tracked through the manifest system. Do not hesitate to ask for copies of these manifests as part of your due diligence.

Step 4: Establish a Process for Handling and Storing Spent Lamps – Lamps should be handled and stored in a way that prevents breakage. Designate an area where lamps are stored prior to recycling.  Refer to the fact sheet entitled “How to Handle and Store Spent Lamps in a Commercial Setting” for more information.

Step 5: Procedures for Getting Spent Lamps to the Recycler – There are several options to consider when recycling spent lamps:

  • Moving crushed lamps – As noted above, if the mercury-containing lamps have been crushed, as in a drum-top crusher, the generator is typically obligated to hire a hauler that has been certified or approved by the province or territory. The drum-top crusher vendor may also provide or arrange for a collection service. Shipments of full drums may have to be manifested; again, check with your regulator. If a shipment is inter-provincial, then federal legislation applies in the form of the Interprovincial Movement of Hazardous Waste Regulations and the Transportation of Dangerous Goods Regulations.
  • Pick-up service for whole/unbroken lamps – The type and frequency of pick-up required are important to determine prior to selecting a recycler. Pick-up options will be determined by the size of the facility and the number of spent lamps generated. The options include:
    • Milk run – This is the most common type of pick-up. A milk run is a route in which the recycler schedules pick-ups from your facility. Milk-run collections are usually run on a set schedule; the frequency of the collection should be determined with the recycler at the time of contract negotiations (but seek flexibility if volumes vary). The number and frequency of spent lamps generated by an individual company and its own on-site storage capacity will determine the collection rate.
    • Dedicated pick-up – When a facility generates enough spent lamps to fill a truck, it may be cost-effective to contract for a dedicated pick-up (either once a month or upon request).
  • Mail-in or box program – This option is generally more cost-effective if you generate a relatively small amount of spent lamps or if you are remotely located. In this type of program, a recycler can provide a container to fill with spent lamps. When the container is full, it can be sent to the recycler via a prepaid ground mail shipment program. If you are interested in this option, you should work with your lamp recycler to ensure that proper packaging, labeling, and shipping requirements are met.
  • Self-transport – If you generate a small amount of spent lamps, have the capacity to transport them, or are located in close proximity to the recycler, you may choose to transport the spent lamps yourself to the recycler. Lamp recyclers can provide boxes that are designed to reduce breakage during transport to a recycling facility; however, this option may not be available in all areas.  Provincial or territorial regulatory agencies should be consulted to ensure that self-transport is permissible (ask whether a “small-quantity exemption” applies).

Step 6: Educate Employees – Inform your employees about the dangers of mercury, the importance of minimizing the release of mercury, and your decision to recycle all spent fluorescent lamps. Employees should be trained in accordance with applicable provincial and federal requirements.  Educate employees about the Workplace Hazardous Materials Information System (WHMIS) coordinated by Health Canada. Also, the Canadian Centre for Occupational Health and Safety is a not-for-profit federal department corporation that can provide relevant support in this context.

Step 7: Record and Track Data – The recycler should provide legitimate documentation that the spent lamps have been properly recycled (e.g., a receipt or a certificate of recycling). Some due diligence regarding the authenticity of recycling claims should be considered.