Working with WEEE

Since the Waste Electrical and Electronic Equipment (WEEE) Directive came into force in January 2007 it has certainly met with a mixed reception from different parts of the supply chain. And while it’s true to say that some have chosen to treat it as a nuisance, others have embraced this opportunity to take control of the construction industry’s waste disposal processes and improve what has historically been a pretty abysmal track record.

I would certainly support the latter view and see a great opportunity for anyone in a project management role to make a significant contribution to minimising environmental impact. This is true for in-house engineers managing projects for their organisations or for consultants and contractors who are, or should be, helping their end customers to reduce their carbon footprint.

In order to gain maximum advantage from this opportunity, it’s important to understand the implications of the WEEE Directive in relation to projects where older plant and equipment is being replaced – or in demolition projects. Lighting, which is one of the most challenging waste streams to deal with, provides a good example.

As well as understanding how to manage this waste stream, it’s also important to ensure that building operators understand their obligations and responsibilities under the WEEE Directive. In most cases they will not bear any financial responsibility for disposal but there is a duty of care to ensure light fittings and their components are disposed of in compliance with the legislation.

To that end, the WEEE Directive divides waste into two main categories. There is historic waste, installed before 13 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 will bear this responsibility when the time comes. This effectively means that lighting manufacturers are responsible for the disposal of the majority of discarded light fittings from refurbishment and refit projects.

In many cases these lighting manufacturers will be members of not-for-profit compliance schemes such as Lumicom, so it is the operators of the scheme that deal with the waste. An early stage of planning, therefore, is to determine whether the manufacturer of the fittings is a member of such a scheme as this will greatly facilitate disposal as the project proceeds. Just as importantly, if the new fittings are manufactured by members of the same compliance scheme, then there will only be a single point of contact in the future when those fittings reach the end of their life.

The other important issue with light fittings is that any discharge light sources, such as fluorescent tubes, compact fluorescent lamps and sodium, metal halide or mercury lamps are classified as hazardous waste. This is because of the small amounts of mercury used in their manufacture. Similarly, any batteries used for emergency lighting fall within the hazardous category.

This means that the hazardous elements have to be separated from the light fittings themselves before disposal, and stored separately before collection, or delivery to a collection point. Failing to separate the waste can contaminate the light fittings, prevent their being recycled and result in decontamination costs and, possibly, fines under environmental legislation. It’s also important to bear in mind that any separated hazardous waste needs to be stored on site in compliance with the Control of Substances Hazardous to Health (CoSHH) regulations.

With the Lumicom scheme, if there are around 1000 luminaires being disposed of, the site will be eligible for a skip, which will be placed on site for 14 days free of charge – so scheduling of the project is important. For fewer luminaires (or if the skip has insufficient space) site operators are able to download a delivery note from the Lumicom website and take this with the luminaires to the nearest collection point, so they are not charged for using the facility. The nearest collection point can be identified by entering the postcode of the site on our website.

As noted above, there is a duty of care to ensure compliant disposal of all WEEE, so it is also important to ensure that there is a paper trail, should proof be needed in the future.

For all of these reasons, I would urge any BSEE readers involved in managing such projects to consider this issue early on in the planning stages and arrive at a schedule that will facilitate the management of waste, rather than hinder it.