Environmental Management

Environmentally sound management incorporates the concept of a product’s full lifecycle. It begins from raw materials used in manufacturing through to end-of-life recovery and recycling. This approach gives regulators a suitable framework to analyze and manage the performance of the impact of goods and services on the environment. 

When lifecycle management principles are applied to lighting products and equipment, the assessment concentrates on the following three stages:

• Production: focuses on the raw materials and production techniques involved in manufacturing the product, including hazardous substances. The production phase is a natural point of intervention for hazardous substance regulators in the product life cycle, for example, the level of mercury in CFLs.
• Usage: focuses on the environmental impact of lamps during the use phase (i.e., from power plant-related emissions). It can also include health and safety aspects of lighting, such as the steps to take in case of lamp breakage.
• End-of-Life: focuses on the end-of-life management of lighting products, highlighting current regulatory frameworks; examples of best practices in establishing, managing, and financing end-of-life collection, recycling; and environmentally sound management and disposal.

Lifecycle assessments conducted on lighting products have concluded that the ‘usage‘ stage is the most important from an environmental impact point of view. Researchers have also pointed out that as the energy efficiency of lighting products improves, the usage stage still dominates. However, other aspects of the life cycle, including production and end-of-life, become more important.

Optimization across these stages requires minimizing the environmental impacts during each step. The phase-out of inefficient lighting is an effective intervention from a ‘use’ point of view. It can significantly reduce energy consumption and prevent climate change through avoided CO2 emissions and mercury pollution from coal-fired power stations. In all aspects of a lamp’s life cycle, reducing energy consumption is by far the most significant and positive change to be made. 

This approach includes maximizing energy efficiency and lamp life and minimizing toxicity at the design and manufacturing stages while ensuring the sustainable management of spent lamps. This is consistent with global international policies that reduce and safely manage hazardous waste, such as the Minamata Convention on Mercury which seeks to “make Mercury history.” In addition, several national and regional collection systems have been mandated by law in the last few years to facilitate the recycling of materials and the safe disposal of hazardous substances.

The implementation of environmentally sound management requires that the following elements are taken into account:

1. Policy and legal framework
2. Collection schemes and related awareness-raising activities
3. Transportation, storage, and recycling programs
4. Financial mechanisms to cover the running costs

• Policy and Legal Framework

To have a national program that is required and enforceable, governments should consider establishing a legal framework for electronic waste and hazardous waste management and setting requirements for zero mercury in lighting. This encourages the development of initiatives in the country or region and will help advance the objectives of relevant international conventions. 

Given the technological advancements made in LED lighting, policymakers should consider regulations that eliminate mercury from lighting as there is no longer a need to tolerate this hazardous substance in every fluorescent lamp. LED retrofit lamps are now widely available and are designed to be compatible with existing fluorescent fixtures and ballasts and thus can be installed directly into the same fixtures. These mercury-free LED lamps use half the energy and last 2-3 times longer than the fluorescent lamps they are replacing.   

• Collection Schemes

Improper handling, collection, storage, transportation, or disposal of hazardous materials and waste can lead to releases of pollution that persist in the atmosphere, soil, and water. Waste consisting of elemental mercury or waste containing or contaminated with mercury should be treated to recover the mercury or immobilize it in an environmentally sound manner. Collection and recycling programs for fluorescent and high-intensity discharge lamps and luminaires are important because they: 

• Promote the recovery of other materials found in end-of-life mercury-added lamps such as glass, ferrous and non-ferrous metals, and phosphors that contain mercury. Some of these materials may be sold to lamp and glass businesses. Reuse of waste glass may offer secondary commercial opportunities in developing countries that decide to implement collection and recycling systems. Mixed glass is used, either directly or after appropriate pre-treatment, for glass products with lower purity requirements or as an aggregate material in industrial processes.
• Many fluorescent lamps contain rare earth oxides in their phosphors. Collection and recycling programs may be able to offer waste back to the industry for reuse. For example, European collection and recycling organizations have been approached by “up-cyclers” to supply them with CFL waste.
• Although it is not hazardous, used LED lamps contain electronic waste, which like all e-waste, should be collected and disposed of in an environmentally sound manner. Having a separate LED waste stream that contains no mercury residues and enhances recovery rate is possible.

Raising awareness among consumers about high-quality, low mercury lighting products guides their purchasing decisions. Ensuring good quality lamps in the market and verifying their compliance with maximum mercury limits will minimize health and safety risks. When introducing new lighting-related laws, regulators should ensure adequate compliance with existing health and safety laws.

• Recycling Programs

Approaches for the environmentally sound management of spent lamps should be coupled with technologies that capture and securely contain mercury vapor and residues. Further processing to recover mercury and recycle other lamp components is not only manageable but also affordable under the appropriate system. Regulators should explore and adopt approaches that encourage the collection and recycling of mercury-added lamps. These approaches should be adapted to national conditions. If effectively designed and managed, they can also create jobs in collection and recycling.

Mercury emissions from spent lamps can be virtually eliminated. This can be achieved by following the Basel Convention Technical Guidelines for the Environmentally Sound Management of Wastes consisting of elemental mercury and wastes containing or contaminated with mercury. In addition, extended producer responsibility systems where all stakeholders share in the responsibility have proven to be most cost-effective. These systems can be funded in various ways, depending on country conditions and resources. 

• Financing Environmentally Sustainable Management 

Decision-makers address policy questions related to designing collection schemes. These schemes address when, to what extent, and in what manner consumers pay. Regulators should look at the market and decide which stakeholders will support the program. 

Many regulatory initiatives exist to stipulate the collection and recycling of mercury-added lamps and lamps in line with extended producer responsibility norms. They require producers to set up the system to facilitate the collection and recycling of lighting products.

In a non-regulated system, the costs for collection and recycling are not assigned. However, to ensure lamps are sustainably collected and recycled, regulations should account for economies of scale and minimize the end-users costs. Information to purchasers and transparency of system finance costs on collection and recycling is also essential for the effective development of these systems. Consumers aware that a product needs to be recycled tend to change their behavior resulting in increased collection rates.

Principal financing mechanisms include:

• Full cost internalization – reflecting individual producer responsibility, this mechanism establishes a direct incentive for competition and design improvement. Costs are passed to the end-user, but a company that can reduce its internal costs through process redesign can gain a market advantage.
• Advance disposal fee systems – industry manages fees in a so-called ‘eco-fee.’ In this system, a small portion of the purchase price of a product supports an end-of-life management system.
• Deposit-refund systems – some countries choose the traditional deposit-refund system, where consumers pay a deposit at the time of purchase. They receive the same amount as a refund when they return the used product to the collection system.
• Last-owner-pays – this collective scheme establishes and sets flat fees to be charged to the last owner, the consumer. This last owner pays and returns the used lamp simultaneously; however, this scheme is avoidable by simply throwing the lamps directly into the municipal waste system.
• Regional systems – establishing regional systems can be the optimal solution in cases where national approaches are not financially viable to support the recycling of lamps in one country.