Keeping pace with regulatory change can be a major challenge to electrical engineers but it is important to understand the implications of such change. Ernest Magog of Lumicom shines a light on the changes in the WEEE regulations that impact on lighting products

At times it may seem the regulations which direct our working lives never seem to stand still long enough for us to draw breath. Which can be seen as an irritant, a distraction or an opportunity to make things better. I prefer the latter option.

One example that will be very much in the minds of Electrical Review readers is Amendment 1 of the 17th Edition Wiring Regulations. There’s quite a bit of change to get to grips with but the changes are there to improve the overall quality and safety of electrical design and installation.

The same is true of the Waste Electrical and Electronic Equipment (WEEE) Directive, which has evolved considerably since it was first introduced. Again, some of the changes may seem like a bit of a nuisance, but in reality they are there to clarify what was initially quite a confusing situation for many. In addition, new products have been brought within the remit of the Directive – which means more products are recycled and less waste goes to landfill – and that has to be positive.

The key here is to understand the implications of such changes and steer a course that provides the best solution for the end client. For example, it is now well accepted the specifier needs to take account of maintenance issues in the design of the system, helping to reduce cost of ownership. Since the WEEE regulations were introduced this responsibility to the end client also extends to facilitating disposal of end-of-life electrical products.

In the case of lighting, this is achieved by specifying products from manufacturers that are members of the same compliance scheme, so there is only one point of contact for disposal when the lighting is replaced. Therefore, it also makes sense to choose a compliance scheme that has a wide range of members that offer the types of luminaires required for the project. In fact, many end clients are now aware of this issue and are already advising their specifiers accordingly.

Ringing the changes
As mentioned earlier, there have been a number of key changes to the WEEE regulations. For example, in 2010 the Environment Agency added the ballasts, photoelectric cells and igniters used in lighting products to the regulations, as well as fire alarm systems.

To understand the implications of these changes it’s important to understand how waste and producers of waste are classified under the Directive. 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 bears this responsibility.

This classification applies to all of the electrical and electronic products that fall within the remit of the Directive but lighting products tend to be particularly challenging. There are two reasons for this. Firstly, a wide range of components are used in lighting products and these need to be separated before they enter the waste stream. Secondly, these components may be incorporated into finished items or they may be put on the market in their own right for use in repairs and maintenance. This was one of the areas of confusion when the Directive was first published but the situation has now been ‘illuminated’.

So this is how it works. When ballasts, photoelectric cells and igniters 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 responsibility. 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 WEE regulations, while photoelectric 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.

Consequently, any electrical engineers taking a project management role in refurbishment projects where old light fittings are being removed need to be aware of the implications and sort their waste accordingly.

The Environment Agency has also clarified the situation relating to ‘domestic’ lighting products that are being used in commercial premises, such as hotels. The rules are different for domestic lighting products but when used in a hotel, for example, they have to be disposed of through the commercial waste management chain.

The key factor here is in the commercial waste management chain the cost of disposal falls to the manufacturer. Consequently it is important for the end client to ensure there is evidence of non-household use in place. This will typically be in the form of a contract between the producer and a business user/reseller.

Street lanterns
Electrical engineers may also find themselves dealing with end-of-life street lanterns. These are dealt with through a scheme that has been developed in conjunction with the Association of Signals, Lighting and other highway Electrical Contractors (ASLEC) – which also offers training of staff.
Because of the wide range of project types in this sector, the scheme is designed to be very flexible. If the numbers of lanterns are relatively low, just a few hundred a month perhaps, 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.

The devil’s in the detail
In all cases of end-of-life lighting products the fundamental requirement for effective and compliant waste management is to have a clear understanding of who is responsible for what. This understanding influences all subsequent actions from the moment the old luminaires are removed and how the various components are sorted and stored.

Luminaire bodies need 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.

At one point interchangeable LED light sources were not classified as lamps, but now they are; and they fall into two categories. LED light sources that operate by way of a separate driver, requiring hard-wiring to the lighting circuit, are classified as LED modules. LED lamps containing an internal driver, designed to fit and operate within an existing type of socket are classified as retrofit LED lamps.

Choosing the right partners
One of the key roles of a compliance scheme is to facilitate the collection and responsible disposal of these products by making it easy for end clients and project managers to comply with the regulations. As well as offering the ability to source different manufacturers’ products from within the same compliance scheme there are also features to look out for that make day-to-day management of waste easier.

These include provision of guidance and downloadable documents that will ease the administration. 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.

As I mentioned at the beginning of this article, regulations can be viewed in either a positive or negative light, depending on how full or empty your half-glass is. However, around 95,000 tonnes of new lighting equipment enter the UK market every year and at some time in the future these will need to be disposed of responsibly. So I would argue having regulations such as the WEEE Directive, facilitated by professional compliance schemes that understand the practical issues, is a very positive thing for the future of the environment.