The WEEE regulations continue to evolve and broaden their scope to encompass more products. Ernest Magog of Lumicom explains the latest additions and flags up some key pointers for successful waste management.
There’s no doubt that the building services industry has had to contend with more than a few new regulations and guidelines in the last few years, ranging from building design through to waste management. Nor is the situation likely to change in the next few years as existing regulations are modified to make them stricter or to address areas where the original drafts were unclear.
Waste disposal is a case in point and the Waste Electrical and Electronic Equipment (WEEE) Directive is a good example of this. Since it was first introduced it has undergone a number of iterations, most notably with the introduction of more categories of products to its scope, along with guidelines from the regulating bodies on how to deal with them.
This puts an onus on anyone involved in managing waste from specification of new products through to disposal of old products during refurbishment or demolition projects to keep up to speed with the latest amendments. There is also an onus on compliance schemes such as our own to ensure we can help with clarifying these regulations.
Different situations
For example, last year the Environment Agency (EA) brought a number of items into the scope of the WEEE regulations, accompanied by guidance on how to interpret different situations. These include components such as ballasts, photoelectric cells and igniters used in lighting products, and fire alarm systems. The EA also issued guidance on how to manage products that can be used for both household and non-household applications.
Electrical components are an interesting case, as they may be incorporated into finished items or they may be put on the market in their own right for use in repairs and maintenance. So when the ballasts, photoelectric cells and igniters referred to above are supplied to a manufacturer for incorporation into, say, a new street lighting lantern, the component manufacturer is not classified as a producer – it is the manufacturer of the finished item that bears this burden. However, when those same items are sold as ‘spare parts’ it is the manufacturer of the components that is classified as a producer.
In such cases, the lantern falls within Category 5 of the WEEE regulations, while photocelectric cells, ballasts and igniters come under Category 9. The lighting column is not covered by the regulations and rolls of cable are only covered if they are complete with connectors.
So all of this has implications for managing waste on site. For example, street lanterns are dealt with through a scheme that has been developed in conjunction with the Association of Signals, Lighting and other highway Electrical Contractors (ASLEC). This scheme is tailored to meet the needs of different types of projects. For the disposal of relatively small numbers of lanterns (in the order of a few hundred a month) hessian bags are supplied to street lighting depots and these are then collected on a ‘milk round’ basis. For greater quantities, as might be encountered in a PFI project for example, there are differing arrangements. Training of staff is also available through ASLEC.
Specifiers and refurbishment project managers may also come into contact with domestic lighting products that are used in commercial premises – for instance bedside lighting in hotels. In fact, as the hospitality sector tends to refurbish more frequently than many other sectors this is probably quite a common occurrence. From a waste management point of view, the waste products need to be disposed of through the commercial waste management chain, so that the cost of disposal falls to the manufacturer.
Consequently, this also needs to be taken into account at the specification stage by ensuring that evidence of non-household use is in place. This will typically be in the form of a contract between the producer and a business user/reseller. Specifiers should also ensure that the supplier is a member of an appropriate compliance scheme so there are no complications and additional costs when those products reach the end of their life.
Sorting it out
As these examples clearly illustrate, the key to managing waste on site effectively is to be clear who is responsible for the disposal of which waste products – as well as being aware of how the waste should be separated on site prior to collection. To that end, lighting products are often the most complex to deal with because they incorporate so many different components.
So in the case of a luminaire, the luminaire body needs to be separated from lamps, control gear components and any emergency lighting batteries as these all need to be dealt with separately. Lamps themselves may need to be separated further, as low and high intensity discharge lamps (fluorescent, sodium, metal halide etc.) are classified as hazardous waste, whereas incandescent lamps are not classified as hazardous. Importantly, any discharge lamps stored on site need to be dealt with in compliance with the Control of Substances Hazardous to Health (COSHH) regulations.
It’s also worth noting that the classification of interchangeable LED light sources has been changed so that these now count as lamps. LED light sources are further differentiated to allow better assessment of WEEE costs and more accurate analysis by compliance schemes. Thus, LED lamps containing an internal driver, designed to fit and operate within an existing type of socket are classified as retrofit LED lamps. LED light sources that operate by way of a separate driver, requiring hard-wiring to the lighting circuit, are classified as LED modules.
A helping hand
As noted earlier, I believe the compliance schemes have a duty to make compliance with these regulations as easy as possible. This is achieved not just by providing guidance but also through practical measures such as making key documents downloadable, so that the paperwork side runs smoothly. For instance, while projects disposing of large volumes of luminaires will qualify for a skip, smaller volumes will need to be transported to a local collection point. Being able to download and print the relevant delivery note saves a lot of time and hassle.
In parallel, compliance schemes cover the disposal costs for products supplied by manufacturers, so this needs to be factored in from the early design stages. Specifying lighting products from a number of different companies that belong to different compliance schemes is simply storing up administrative headaches for the future. Selecting manufacturers that belong to the same compliance scheme pro-actively prevents those headaches, so an important element of the specification process is to ensure that suppliers can provide a valid certificate confirming their membership of a compliance scheme.
Safeguard the future
Since the Directive was introduced thousands of lighting products have been diverted from landfill and the benefit to the environment is significant. Around 95,000 tonnes of lighting equipment are placed on the market each year. If all of these products are processed responsibly some 47,000 tonnes of steel, 21,000 tonnes of aluminium, 7,000 tonnes of glass, and 10,500 tonnes of plastic can all be recovered for re-use. So getting to grips with waste management isn’t just about compliance, it’s also about safeguarding the future.