PSI Fluorescent Lighting National Dialogue Meeting © Product Stewardship Institute, Inc. April 2008 Fluorescent Lighting Product Stewardship Initiative

PSI Fluorescent Lighting National Dialogue Meeting

© Product Stewardship Institute, Inc.April 2008

Fluorescent Lighting Product Stewardship Initiative

April 23-24, 2008

Salt Lake City, UT



What is the What is the Product Stewardship Institute?Product Stewardship Institute?

Non-Profit, based in Boston, founded in 2000 Membership

44 State members 51 Local agency members 20 Adjunct Council members

Board of Directors: 7 states, 4 local agencies Multi-stakeholder product stewardship network Adjunct Council: Business, Environmental/Organizational

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PSI Full and Affiliate State Members

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Why was the Product Stewardship Institute Created?

Unified voice: State and Local Governments Fiscal relief for government on waste issues Objective data for decision-making Forum for collaboration with industry Nationally coordinated systems/harmonized

regulations


© Product Stewardship Institute, Inc.April 2008 5

PSI Projects Fluorescent lamps

Mercury Thermostats

Paint

Medical Sharps

Pharmaceuticals

Electronics

Radioactive Devices

Telephone books

Gas Cylinders

Tires

Beverage containers

Packaging

Batteries

Motor oil



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What is Product Stewardship?“Product Stewardship" is a principle that directs all those involved in the life cycle of a product to take shared responsibility for reducing the health and environmental impacts that result from the production, use, and end-of-life management of the product.



PSI Role in Sustainable Lighting Dialogue Research

Facilitate/mediate dialogue meetings

Implement Projects & Initiatives

Evaluate projects



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PSI’s “Agenda”

• Promote product stewardship solutions• Reduce product impacts• Forge partnerships that share responsibility

– Product Management– Sustainable Financing

• Get results – not just discussion



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Meeting Objectives• General Agreement On:

– Stakeholder roles/process– Issue statement– Dialogue goals

• Confirm road map



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Meeting Objectives• Learn from presentations and research• Explore priority issues and strategies• Establish work groups on 2 priority strategies• Determine next steps

– Meeting date/location– Stakeholder assessment



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Priority Issues and Strategies

• Issue #1: Source Control

• Issue #2: Collection, Consolidation, and Transportation Infrastructure – small generators/residential– large generators/commercial



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Priority Issues and Strategies

• Issue #3: Information and Motivation for Recycling – small generators/residential– large generators/commercial

• Issue 4: Financing (introduction)



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Stakeholder Roles• Authorized to represent company, agency, or organiz.• Attend 4 meetings (or via phone).• Active participation between meetings.• Jointly develop agreement.• Ensure your interests/others’ interests are met.• Participation in dialogue does not preclude legislative

activity.• Negotiate in good faith.



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Consensus

• All participants can live with decision and no one will actively block or undermine decision.

• The greater the stakeholder agreement, the greater the likelihood that the agreement will be sustainable.



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Consensus• Consensus is preferable for broad initiatives:

– Technical standards– Policies– Legislation

• Consensus is NOT needed for pilot projects or individual initiatives.



Road Map

MEETING 2

MEETING 3

MEETING 1

AGREEMENTS

START

April 2008 July 2008 October 2008 January 2008

•2 Workgroups•Develop findings•Draft work plans

•Refine draft agreements

•Refine Workgroups •Develop Findings•Draft work plans

Discuss Priority Issues/Strategies

•Present Workgroup findings/plans

• Full financing discussion•Discuss additional strategies

• Present Workgroup findings/plans• Discuss additional strategies

• Start to develop draft agreements

MEETING 4

• Finalize agreements

• Develop Implementation Plan

Dialogue Meeting

Workgroup Activity



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Possible Dialogue Outcomes

• Pilot projects with measurable results• Demonstration project to test comprehensive

program• Model state policies (e.g., procurement)• National standards



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Possible Dialogue Outcomes

• Business innovations/profitability studies (e.g., reverse logistics potential)

• Model state or federal legislation• Model state or national education campaign• National sustainable financing system for the

management of spent lamps



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Possible Mechanisms for Agreements

• Letter of agreement between those involved in pilot project

• Memorandum of agreement between stakeholders stating intent to perform certain activities



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What do we want to avoid?

• Avoid multiple state solutions

• Avoid unilateral state or federal regulation



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Potential Stakeholder Contributions

• Manufacturers• Retailers• Government • Utilities/EE Groups• Environmental Groups• Recyclers



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Potential Manufacturer Contributions

• Reduce amount of mercury in each fluorescent lamp.• Continue to develop and promote more

environmentally-preferable lighting products to replace less efficient, shorter-lived, and higher-mercury products.

• Increase public awareness of the importance of, and opportunities for, recycling lamps through packaging/labeling and other means.



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Potential Manufacturer Contributions

• Cover the cost of collection and recycling of lamps. • Include the cost of lamp collection and recycling in

product purchase price.• Provide incentives for the collection and recycling of

lamps.



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Potential Retailer Contributions• Inform customers of importance of recycling lamps

and where to recycle.• Collect spent lamps on site. • Provide coupons as incentive to recover spent lamps

and increase customer traffic.• Provide recycling only with purchase of new lamp(s).• Promote environmentally-preferable lighting

products and stop selling less efficient, shorter-lived, higher-mercury products.



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Potential Retailer Contributions• Inform customers of importance of recycling lamps

and where to recycle.• Collect spent lamps on site. • Provide coupons as incentive to recover spent lamps

and increase customer traffic.• Provide recycling only with purchase of new lamp(s).• Promote environmentally-preferable lighting

products and stop selling less efficient, shorter-lived, higher-mercury products.



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Potential Utilities/Energy Efficiency Groups Contributions

• Increase public awareness of the importance of, and opportunities for, recycling lamps. Provide financial support for collection and recycling of lamps (interim or long-term).

• Establish specifications for lighting equipment or give rebates that address mercury content, lamp life, and/or other environmental attributes

• Facilitate and participate in lamp recycling projects



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Potential Local, State, and Federal Government Contributions

• Coordinate recycling, procurement, or other projects locally, state-wide, or nationally.

• Increase public awareness of the importance of, and opportunities for, recycling lamps. Recognize companies/groups taking leadership roles.



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Potential Local, State, and Federal Government Contributions

• Procure environmentally-preferable lighting options.

• Regulation/enforcement to level playing field and maintain fairness.

• Program planning, including establishing performance goals. paint.



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Potential Environmental Organizations Contributions

• Increase public awareness of the importance of, and opportunities for, recycling lamps.

• Promote environmentally-preferable lighting options.• Coordinate recycling, procurement, or other projects.• Recognize company leaders and laggards.



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Process for Developing Action Plan• Draft Problem Statement and Goals• Issues/Strategies• Interviews/input from over 40 stakeholders• Input incorporated into Action Plan • Draft Action Plan/comments• Input on 2nd Draft Action Plan – due 2 weeks• NOT PSI’s Issue Statement and Goals



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Fluorescent Lighting Issue Statement• Contain mercury, a harmful neurotoxin. • Poor awareness about mercury in lamps and

problems it can cause.• Large and small generators of spent lamps are

subject to different regulations and typically use different lamps.



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Fluorescent Lighting Issue Statement• About 30 percent of lamps used by business

and industry, and 2 percent of CFLs were estimated to be recycled in 2003, although this estimate has much uncertainty.

• Inadequate collection infrastructure (including convenient locations for residential consumers).



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Fluorescent Lighting Issue Statement• Patchwork of regulations.• Lack of enforcement.• Insufficient motivation for recycling• Significant costs to collect/recycle. • Bulb breakage causes extra risk.



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Overall Dialogue Goal

• Promote use of energy efficient lighting while eliminating or reducing the amount of mercury and other toxins entering the environment during the lifecycle of fluorescent lamps.



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Specific Dialogue Goals• Reduce environmental impact of manufacture

of fluorescent lighting.• Increase manufacture and procurement of

environmentally preferable lighting.• Maximize safe collection and recycling of

spent lamps from households and businesses.• Develop nationally-coordinated system that is

financially sustainable.



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Purpose of Presentations

• Educate attendees on basics• Outline current boundaries of knowledge• Illustrate product stewardship• Show potential for collaboration• Portray possibilities



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Issue/Strategy Discussions• Background technical information• Clarify Issue and Strategies• Additional strategies• Prioritize strategies• Workgroups at end of 2nd day – top 2

strategies



Issue #1 Source Control

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Issue #1: Source Control Mercury is required for the efficient function of

fluorescent lamps.

Different lamps have different amounts of mercury, based on size, wattage, and manufacturer.

Mercury is also released through the manufacturing process, although some manufacturing methods are more efficient in their use of mercury than others.

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Source Control: Background• Mercury content & role of mercury in lighting• Manufacturing

– NAFTA countries (primarily non-CFL)– China (almost all CFL, other lamps too)

• Manufacturing process– Mercury released during manufacturing– Varies w/ type of bulb and process (“capsule” method more

efficient and safer for workers)

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Source Control: Background• Lighting choices made by consumers: “green

procurement”– Government, corporate, and institutional policies (LEED,

bid specs,other guidelines)– Opt for less toxic, longer-lasting, more efficient products– Retailer promotion– Consumer education through labeling/branding efforts

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Source Control: Solution

Reduce the amount of mercury used in the manufacture of fluorescent lamps, including the amount per lamp and the amount released during manufacture.

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Source Control: StrategiesA) Identify and encourage/mandate use of most effective method for

mercury insertion to ensure accurate/minimal dosage in lamp manufacturing.

B) Encourage/mandate manufacturers to reduce amount of mercury per lamp.

C) Mandate mfrs to improve life span and efficiency of lamps.

D) Encourage (including through procurement) manufacturers to improve life span and efficiency of lamps by promoting use of the lamps with the lowest possible mercury content and greatest possible efficiency.

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Issue #2: Collection and Transportation

Infrastructure (Small generators/Residential)

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Issue #2: Infrastructure (Small generators/Residential)

There is currently uneven and inadequate infrastructure for the collection of spent lamps for recycling for residences/small generators.

Efficient consolidation and transportation may require lamp crushing, but the safety of these systems is questioned.

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• Residential sector = 22% of fluorescent lamps• Recycling opportunities minimal (HHW)

– Location– Hours

• Safety concerns

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• Multiple efforts to provide more convenient collection opportunities– Retailers– Public facilities: libraries, fire departments– Utilities, government, recyclers, environmental orgs

• Models– Mail back from home (USPS box)– Ship via common carrier from collection location– Reverse distribution, collection by HHW

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• Regulations specific to recycling infrastructure:

– Retailers must collect lamps for recycling if they sell them (Dane County, WI)

– Utilities w/ over 200,000 customers must provide for convenient recycling (Minnesota)

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Infrastructure: Solution (Small generators/Residential)

Increase convenient and cost-effective opportunities for the collection, consolidation, and transportation of spent lamps for recycling.

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Infrastructure: Strategies(Small generators/Residential)

A) Study existing infrastructure and new infrastructure needed to provide convenience for collection and lower system costs for small generators/residential consumers.

C) Develop collection and recycling performance targets and a methodology for measuring them.

(Strategy B refers only to large generators/commercial)

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Issue #2: Collection & Transportation Infrastructure

(large generators/commercial)

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Issue #2: Infrastructure (Large generators/Commercial)

Efficient consolidation and transportation may require lamp crushing, but the safety of these systems is questioned.

(Recycling infrastructure is considered adequate and will grow with market demand.)

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Infrastructure: Background (Large generators/Commercial)

• Commercial sector = 78% of fluorescent lamps

• Lighting contractor services may include recycling

• Lamp crushing (banned/heavily regulated in some states)

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Infrastructure: Solution (Large generators/Commercial)

Increase convenient and cost-effective opportunities for the collection, consolidation, and transportation of spent lamps for recycling.

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Infrastructure: Strategies (Large generators/Commercial)

B) Study existing infrastructure and new infrastructure needed to provide convenience for collection and lower system costs for large generators/commercial consumers.

C) Develop collection and recycling performance targets and a methodology for measuring them.

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Issue #3: Information & Motivation (Small generators/Residential)

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Issue #3: Information & Motivation (Small generators/Residential)

Even where disposal bans/recycling requirements exist, information and enforcement are inadequate.

Lack of understanding of the environmental/health impacts, lack of regulation or enforcement, and lack of incentives to recycle decrease recycling of fluorescent lamps.

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Information & Motivation: Background (Small generators/Residential)

• Disincentives to recycle– Pay to recycle– Not understanding issue/requirements– Inconvenient

• Incentives to recycle – Free or coupon/discount offered– 7 states and 4 local gov’ts ban disposal in MSW– Wanting to do the right thing

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Information & Motivation: Strategies (Small generators/Residential)

1) Develop comprehensive public awareness campaign.

– Clear and consistent messaging on need to buy energy efficient, low-mercury bulbs and recycle them.

2) Encourage all states to ban lamp disposal.3) Provide financial incentives to recycle (coupons,

cash bounty, etc.)

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Issue #3: Information & Motivation(Large generators/Commercial)

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Issue #3: Information & Motivation(Large generators/Commercial)

Even where disposal bans/recycling requirement exist, information and enforcement are inadequate.

Lack of understanding of the environmental/health impacts, lack of regulation or enforcement, and lack of incentives to recycle decrease recycling of fluorescent lamps.

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Information & Motivation: Background(Large generators/Commercial)

Regulated as Universal Waste (under RCRA)

Adopted by states (varying stringency)

Requires recycling of lamps “exhibiting toxicity characteristic” (not all lamps)

Enforcement difficult; many uninformed about requirements

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Large generators/Commercial1) Promote enforcement of existing regulations2) Clarify that all lamps (including green

tips/low mercury) should be recycled.3) Identify enforcement/compliance issues and

develop strategies to overcome those issues4) Evaluate effect of active enforcement on

program performance (including generator education)



Issue #4: Sustainable Financing

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Issue #4: Sustainable Financing

A sustainable financing system is needed to conduct large-scale lamp recycling; current funding of pilot/small-scale projects is not sustainable, particularly in light of the anticipated future increase in the number of fluorescent lamps used.

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Sustainable Financing: Background• Program promotion (education/outreach)• Management, oversight • Collection• Transport, handling• Recycling

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Sustainable Financing: BackgroundToday:• Consumer (all commercial; some residential)• Utilities (rate payers)• State/local government (taxpayers)• Permit fee for waste disposal (residents)

Mix of funding sources makes it difficult to quantify!

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Sustainable Financing: Background

• Producer responsibility – Cost internalization (invisible)

• Advanced recycling fee (visible)



Sustainable Financing: Solution

Develop a financing system that covers the collection, transportation, and recycling costs for fluorescent lamps now and in the future.

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Sustainable Financing: Solution

• What are the 2 main things about financing that you would like addressed in dialogue?

• Additional research/information you need to be prepared to discuss financing at the next meeting?



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Issue 1: Source Control - Strategies1) Study/research: mercury lost in lamp

manufacture, manufacturers and brand owners of lamps (and manufacturing locations)

2) Verification/enforcement of use of Energy Star logo

3) Statement from Lamp Dialogue Group that new Energy Star version should include restrictive mercury content levels



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Issue 1: Source Control - Strategies4) Manufacturer disclosure of mercury content and

verification process5) Model procurement specification

• Specify process for lamp manufacture???• Efficiency, bulb life, take back, low mercury, etc.

6) Move to non-toxic energy efficient lighting as quickly as possible and take steps to get there• Model procurement specifications, etc.???



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Issue 2: Infrastructure(Small generators/household)

• Defined as people with a small number of lamps to recycle at one time

• Other definitions:– Regulated vs. Unregulated– Residential vs. Business



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Issue 2: Infrastructure (Small generators/household)

• Retail as the anchor to an effective collection system to provide consumer convenience in urban/suburban/rural areas.

• Potential Strategies1) Study (including existing programs)2) Potential for demonstration of effective system



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Study: Research/Information Needed• Consumer lamp sales breakdown: Percentage sold at

groceries, pharmacies, hardware stores, large retailers, etc. and number of sales locations these represent.

• GIS mapping of existing and potential future collection locations with overlays – national

• Logistics of different collection methods, including program costs and potential for savings (cost effectiveness)



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Study: Research/Information NeededRetail Collection• Identify obstacles to retail collection from all points

of sale and determine ways to overcome those obstacles (including through existing programs)– Potential for financial incentives/collection

reimbursement to increase retail collection interest



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Study: Research/Information NeededLamp Breakage• Study extent of lamp breakage through various

transportation methods from end user to recycler• Compare various packaging and shipping techniques.• Compare lamp breakage in self service collections vs.

handing to service employee• Develop/promote BMPs for handling/storage,

collection, and transport



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Demonstration Project• Develop a Demonstration Project (not pilot) that

models an effective collection system based on an existing program

– Develop comprehensive program that establishes collection anchor through retail and includes other locations to meet consumer convenience and performance targets.

– GIS mapping of existing and potential future collection locations with overlays



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Demonstration Project• Develop an effective collection system using

an existing program– Start with state/county with disposal ban, retailer

collections (mandatory or voluntary), etc.– Determine baseline collection percentage (agree

on methodology for determining rate)– Determine collection performance goal



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Demonstration Project• Develop an effective collection system using

an existing program (cont.)– Definition of “convenience”/# of collection sites

needed per population – Map retail locations => convenient???– Add collection locations (e.g., mail back from

homeowner, post offices, HHW sites, libraries, etc.) to meet convenience target



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Demonstration Project• Develop an effective collection system using an

existing program – Demonstration Project– Add collection incentive payment for collectors– Add financial incentive for consumer– Add comprehensive consumer education campaign– Promote env’lly preferable lighting– Evaluate program performance and adjust as

needed



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Issue 2: Infrastructure – Strategies (Large generators/commercial)

• Drive commercial lamps into existing infrastructure

1)Map all collection, consolidation, and recycling locations to show adequate infrastructure



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Next Steps• Confirm strategies to further investigate• Set Workgroups

– Workgroup participants/Leader– Tasks



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Workgroup Activities

• Present findings/recommendations at 2nd meeting

• Develop work plan including:• Major tasks and timelines• Potential pilot opportunities• Staffing and funding requirements• Challenges, barriers



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Next Steps• Schedule next meeting

– Potential Dates• July 15-16 (U.S. EPA offices)• July 29-30 (King County offices)

– Location: Washington (WA Dept. of Ecology)– Meeting length– Tours???



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Agenda items for Meeting #2• Invite Home Depot (U.S. and Canada), Ikea,

and Wal-Mart, and Whole Foods to 2nd dialogue meeting

• Report from MA on implementation of law• Report from CA on implementation of law



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Next Steps

• Stakeholder assessment

• Input on 2nd Draft Action Plan – due 2 weeks• Draft/final meeting notes• Post final presentations and attendance list

Documents

PSI Fluorescent Lighting National Dialogue Meeting © Product Stewardship Institute, Inc. April 2008 Fluorescent Lighting Product Stewardship Initiative