End of the line for luminaires
June 1st 2008

End users involved in refurbishment or demolition projects need to understand their responsibilities in relation to old luminaires, as well as the more widely publicised arrangements for lamps. Ernest Magog of Lumicom explains

While many building operators are aware of the special arrangements required for the disposal of used discharge lamps, the arrangements for the luminaires themselves are not as widely understood.

Under the WEEE (Waste Electrical and Electronic Equipment) Directive all of the components of a light fitting, including the luminaire body itself, have to be disposed of in compliance with the legislation. In the case of discharge lamps, these are now classified as hazardous waste and have to receive special treatment. And while the luminaire bodies are not hazardous they still need to be sent for recycling rather than to landfill.

As with other forms of waste, the building operator has a responsibility to ensure that this is carried out by whichever contractors or sub-contractors are involved. In most cases, there will be no costs incurred as the responsibility for disposal will fall to the luminaire manufacturers supplying replacement fittings, or a body representing them, such as the notfor- profit organisation Lumicom.

However, if there are no replacements, such as in a demolition project, then the responsibility for disposal falls to the end user if the products were installed before 13th August 2005 (see below).

For these reasons it’s important to be clear what needs to be done, even if the work is being handed over to a contractor.

As far as the WEEE Directive is concerned there are two categories of waste – historic waste and future waste. Historic waste refers to products installed before 13th August 2005; future waste refers to products installed after this date.The latter will bear the WEEE mark – a crossed out wheelie bin.

In the case of 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 bears this responsibility. In the context of lighting this effectively means that lighting manufacturers are responsible for the disposal of the majority of discarded light fittings from refurbishment and refit projects.

It’s also worth noting that light fittings using filament lamps are not included. Similarly, very small quantities of fittings (perhaps just one or two units being replaced) are treated in the same way as household waste so they could be taken to a local recycling centre.

Another important point is that recycling of the various elements that make up a light fitting are recycled in different ways, so the components have to be separated before being sent for recycling. Some waste disposal contractors will collect the entire fitting and separate the components themselves,while others will require you or your contractor to carry out the separation.

The three most important components that need to be handled separately are lamps, batteries in self-contained emergency luminaires and power factor correction capacitors. Ensuring this separation is carried out is very important.

For example, the majority of discarded luminaires are shredded into small pieces of metal and plastic and sold as raw material – much of which ends up in the Far East and goes back into manufacturing. If the hazardous components were not separated first the entire batch could be contaminated.This would significantly increase the cost of disposal and could lead to legal action under hazardous waste regulations.

While these principles are all very straightforward, it could also become very complex in a project using a range of fittings from different manufacturers – because which one do you make responsible for the discarded luminaires? For that reason, the majority of the leading manufacturers and suppliers have joined together within compliance schemes such as Lumicom – thus far the only scheme to have an infrastructure in place.

A further benefit of compliance schemes is that they will ensure all waste disposal in compliance with legislation, backed by a full audit trail. So building operators can help themselves by specifying products from companies that are members of a suitable compliance scheme – and by ensuring that all suppliers of electrical equipment have a WEEE registration number.

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