The First Facility Management Blog

Compact fluorescent lamps (CFLs) and other energy efficient lighting, such as linear fluorescent and high intensity discharge (HID) lamps, contain a very small amount of mercury, an element essential to achieving energy savings. While these lamps help consumers and businesses cut their lighting energy usage and reduce energy costs, it is important that any product containing mercury be properly managed when it becomes waste to protect public health and the environment.

Lighting manufacturers, through their trade association, National Electrical Manufacturers Association (NEMA) have developed a Web site, lamprecycle.org, to provide information to commercial and residential users about recycling lamps. In an exclusive interview with TFM, Mark Tibbetts, who directs NEMA’s recycling initiatives, answered questions about developments in lamp recycling and the role of lamprecycle.org.

TFM: Why has NEMA launched this education campaign on lamp recycling? What are NEMA’s goals for this campaign?

Tibbetts: There are a couple of key reasons. While NEMA has been promoting fluorescent lamp recycling for a decade, there is heightened awareness in light of recent federal energy legislation about the energy conservation benefits of fluorescent lighting and the savings in electric bills. Secondly, several states have banned disposal of fluorescent lamps into the normal waste stream, forcing consumers and businesses to keep waste lamps out of the trash. NEMA feels it is important to provide a unified message about both the economic and environmental benefits of fluorescent lighting, while at the same time showing how easy it is to manage environmental issues at the end of a lamp’s life. NEMA’s lamprecycle.org website does this in one location.

Fluorescent lamps are generally four to five times more efficient than incandescent bulbs; however, energy efficient lighting products such as fluorescent lamps, CFLs, and high intensity discharge (HID) lamps contain small amounts of mercury.

The mercury is contained within the lamp and is not exposed to the environment unless the lamp is broken. The release of mercury is most likely to occur when the lamp is thrown in a garbage truck or a dumpster. While lamps are not a major source of mercury pollution, the improper disposal of large numbers of lamps does add to mercury in the environment. Burning hazardous wastes or incinerating disposed materials, to the extent that an incinerator does not control all mercury emissions, can also release mercury into the environment.

The best way to prevent the release of mercury from lighting is to recycle lamps and not dispose of them in the solid waste stream. Recycling lamps captures the small amount of mercury, allowing it to be reused.

TFM: From your experience, what do you see as the most common and/or “biggest” challenges to facility managers correctly executing a lamp recycling program?

Tibbetts: First, the incorrect perception that lamp recycling will be a significant additional cost is the biggest issue. And second, this is fundamentally about changing behavior, and as we all know, change is hard.

But it is important to note that the downside of not recycling is significant. Depending on the state and/or volume of lamps disposed, the costs associated with an enforcement action by state or federal regulators can dwarf those of implementing a lamp recycling program.

TFM: Can you provide a ballpark figure on how much a facility manager can expect to pay for recycling of fluorescent lamps?

Tibbetts: There are a couple ways of quantifying the costs associated with recycling lamps. First, looking at it from a life cycle perspective, the cost to recycle lamps represents less than 1% of the total life cycle cost, since most of the cost is associated with energy usage. Another figure that is worth citing comes from Trammell Crow Company: “A fluorescent lamp recycling program will impact an average property operating expense budget by less than one-tenth of one percent.”

TFM: Massachusetts and Maine are two states that have passed relatively stringent regulations. What are the states to watch in terms of those that might be passing updated regulations on mercury containing lamps in the near future?

Tibbetts: At least eight states have regulations more stringent than current federal regulations. Additional legislation is most likely in the Northeast, Great Lakes, and Pacific Northwest.

TFM: If a facility’s lamp volume and/or local and state regulations exempt that facility from having to recycle mercury containing lamps, what other reasons should facility managers consider for pursuing a recycling program?

Tibbetts: Simply put, it’s the right thing to do. For instance, 48 states have issued fish consumption advisories for mercury. While mercury containing lamps are not a significant source of mercury, they are an easily controlled source. Mercury is a persistent bio-accumulative toxin that can affect animal and human health, and we all share a responsibility in keeping it from the environment.

TFM: The federal Universal Waste Rule (UWR) differs in a number of ways from state regulations, and regulations vary from state to state. That said, are there any constants in terms of rules contained across the board?

Tibbetts: Used (also known as “spent”) mercury containing lighting products are regulated by the U.S. Environmental Protection Agency (EPA) under the Resource Conservation and Recovery Act (RCRA) in the part known as Subtitle C. Subtitle C is where hazardous waste regulations are addressed. In 1999, the EPA added mercury containing lamps to the list of products that may be managed under the “Universal Waste Rule.”  This is the baseline regulation, and facility managers should familiarize themselves with the rule.

However, states may adopt more stringent regulations, and many have done so. Facility managers should research the specific regulations in the states where they manage properties.

TFM: As opposed to sending intact lamps to a recycler, some facilities employ lamp crushing machines on-site and have those materials picked up by a service provider. What is NEMA’s position on that approach?

Tibbetts: NEMA takes no specific position on different approaches to managing spent mercury containing lamps; however, it is important for facility managers to check the regulations in the states where they manage properties, as not all states permit crushing or have additional regulatory requirements.

In addition to directing the National Electrical Manufacturers Association’s (NEMA) recycling initiatives, Tibbetts serves as the executive director for the Thermostat Recycling Corporation (TRC). He was previously the director of site operations and grant programs for PowerUp non-profit. Tibbetts holds his bachelor’s and master’s degrees from the University of Maine. He currently resides in Alexandria, VA.

(Photo: Aleksander Rodic)

The National Electrical Manufacturers Association (NEMA) is supporting President Obama’s February 5, 2009 announcement on the importance of national energy efficiency standards for consumer and industrial equipment regulated by the Department of Energy (DOE).

NEMA President and CEO Evan R. Gaddis says, “President Obama’s has signed a presidential memorandum requesting that DOE set new efficiency standards for common household appliances that will save consumers money, spur innovation, and conserve energy. We have been a strong advocate for a robust national efficiency standards program that sets federal efficiency standards and avoids a patchwork of unworkable state standards. NEMA looks forward to working with Secretary of Energy Steven Chu and his team as they improve the work of the DOE Codes and Standards program.”

NEMA has been at the forefront of federal efficiency standards since 1988 when Congress adopted NEMA’s recommendations for fluorescent lamp ballasts. NEMA developed the first energy efficiency standards for electric motors and distribution transformers, and those NEMA standards serve as the basis for today’s federal standards for those products.

NEMA advocated for significant new standards on general service light bulbs that were adopted in the Energy Independence and Security Act (EISA) of 2007. Those lighting standards, which go into effect over a two-year period beginning January 1, 2012, represent a 30% increase in efficiency of light bulbs while providing consumers with a variety of technologies to choose from.

Presently, NEMA is engaged with DOE and other stakeholders in finalizing new efficiency standards for general service fluorescent lamps (e.g., four-foot fluorescent lamps) and incandescent reflector lamps (e.g., flood and spot bulbs used in recessed lighting applications). Those new standards are to be issued by June 2009. NEMA also successfully advocated for standards for exit signs, compact fluorescent lamps (CFLs), and traffic lights in the Energy Policy Act of 2005, as well as metal halide luminaires (lighting fixtures) in EISA 2007.

The American Society of Heating, Refrigerating, and Air-Conditioning Engineers (ASHRAE), along with nine other organizations, is forming a consortium in response to the U.S. Department of Energy request for consortia to advise the department on high performance building issues. The HighPerformance Commercial Green Building Partnership (HPCGBP) brings together leading organizations from all aspects of the building community to provide guidance and technical leadership on key sustainability issues to the Department of Energy’s Building Technologies Program.

“This partnership will ensure that the voices of the building industry are being heard,” says Bill Harrison, ASHRAE president. “At a time when reducing energy consumption in buildings is paramount, the consortium gives leaders in the built environment and in those industries affecting construction a clear path to offer advice to the DOE on our goals, concerns, and new technologies.”

ASHRAE initiated formation of the partnership and will serve as the group’s secretariat. Other members of the HPCGBP’s steering committee currently includes the Air-Conditioning, Heating and Refrigeration Institute (AHRI), American Institute of Architects (AIA), Alliance to Save Energy (ASE), Building Owners and Managers Association (BOMA), International Code Council (ICC), Illuminating Engineering Society of North America (IESNA), National Association of State Energy Officials (NASEO), National Electrical Manufacturers Association (NEMA), and the U.S. Green Building Council (USGBC).

The partnership intends to be recognized as a “Partnership Consortium” by the Department of Energy as requested in response to the Energy Independence and Security Act of 2007 Section 421. Section 421 is part of the formation of the Net-Zero Commercial Building Initiative, which is intended to develop a research, development, and deployment strategy toward achieving net zero energy commercial buildings.

Partnership participants reflect all disciplines necessary to design and build high performance commercial buildings, including:

• architects and engineers
• the development, construction, financial, and real estate industries
• building owners and operators 
• academic and research organizations
• building code agencies and organizations
• independent high performance green building associations or councils
• experts in indoor air quality and environmental factors
• experts in intelligent buildings and integrated building information systems
• utility energy efficiency programs
• manufacturers and providers of equipment
• public transportation industry experts
• nongovernmental energy efficiency organizations

More than $50 billion is being wasted each year by the owners of 2.8 million U.S. commercial, industrial, and institutional buildings that rely on outmoded lighting systems that waste energy and money, especially when they fail to deliver the array of High-Benefit Lighting® savings otherwise available. In his letter to building industry leaders, Secretary of Energy Samuel W. Bodman wrote, “More than 75% of the nation’s five million commercial, industrial, and institutional buildings were built prior to the introduction of many groundbreaking energy efficient technologies currently available today. These buildings consume nearly 900 billion kilowatt-hours of electricity, at a cost exceeding $115 billion each year. While cost-effective lighting technologies are available now to cut energy costs by up to 50%, only 25% of the buildings have been upgraded.”

In response to the letter by Bodman, National Lighting Bureau Chair Robert W. Colgan, Jr. noted that “the return on investment that can be generated by upgrading these outmoded systems will never be better.” He added, “The Commercial Building Tax Deduction [CBTD] introduced through the Energy Policy Act of 2005 has been extended through December 31, 2013. The CBTD gives owners a tax benefit of as much as 60¢ per square foot for qualifying lighting systems, effectively lowering the investment required to update or replace an outmoded system. The return—in the form of utility bill savings and the bottom-line benefits of providing better seeing conditions—creates a genuinely huge financial incentive at a time when building owners could really use one.”

Colgan said the upgrade incentives comprise far more than the tax benefits that can significantly offset the capital investment required to improve. “The energy cost savings can be substantial,” he said, noting that, using Department of Energy estimates, lighting upgrades alone could avoid some $50 billion of needless energy expense each year. “But energy savings are only part of the picture,” he added, commenting that most of the buildings in question also pay “demand charges,” that is, fees imposed by electric utilities based on the maximum amount of electricity the buildings use during a given “demand interval,” often a period of 15 consecutive minutes.

Colgan explained, “Although two utility customers may consume the identical amount of electricity in a month, the utility will have to invest far more to meet the demands of a customer that uses that amount all in one day versus the customer that consumes about 3.33% of the amount each day of the month. Demand charges typically are imposed on nonresidential customers as separate elements of the utility bill, and they can in some cases amount to as much as or even more than energy charges.”

Despite the often-substantial savings afforded by lower utility bills, the most significant value likely to be derived from lighting system upgrades comes from what the National Lighting Bureau calls High-Benefit Lighting®; that is, lighting systems designed specifically for the tasks, workers, and spaces involved. According to Colgan, “National Lighting Bureau case histories show that, when new or upgraded lighting is well designed, properly installed, and commissioned to ensure it achieves the design intent, people can perform their tasks faster and with fewer errors. Consider this: A two-shift, 100-person-per-shift manufacturer may spend about $15,000 per year on lighting energy when it operates six days per week. If so, a 70% energy use reduction would yield an energy/cost benefit of $10,500 per year. If that same new lighting were well designed and so improved worker productivity by just 2% per year, the manufacturer would derive an additional benefit worth about $150,000 per year.”

Productivity improvements are not the only benefits of High-Benefit Lighting®, Colgan said. He commented that additional benefits stem from fewer errors, fewer accidents, reduced absenteeism, improved security, increased retail sales, and, in a number of cases, higher resale value for the property involved. And still, that’s not all: “The nation’s number one source of greenhouse gas emissions is coal fired power plants,” Colgan said. “Reducing electrical requirements reduces the amount of coal burned each year and that can have an extremely positive effect on our environment, and can significantly reduce the costs we’d otherwise have to bear to clean up the pollution involved and counteract the warming effects otherwise created.”

Mr. Colgan commented that the CBTD applies to more than lighting and, for that reason, the National Electrical Manufacturers Association - a founder and long-term sponsor of the National Lighting Bureau - has been working with Secretary Bodman in developing a multifaceted, national energy conservation effort. As Secretary Bodman wrote, “I challenged the National Electrical Manufacturers Association (NEMA) to commit to a national building energy efficiency campaign…[and] NEMA has responded with enthusiasm, resources, and dedication…”

“There are so many right reasons for upgrading or replacing outmoded lighting systems right now,” Colgan said. “And the return on one’s investment can be truly spectacular.”

The National Electrical Manufacturers Association (NEMA) has published the following reaffirmed standards:

• CP 1-2000 (R2008) Shunt Capacitors
• ICS 5, Annex B-2002 (R2008) Industrial Control and Systems: Typical Proximity Switch Specifications
• ICS 5, Annex E-2002 (R2008) Industrial Control and Systems: Additional Requirements for Proximity Switches Suitable for Use in Strong Magnetic Fields

The contents and scope of NEMA CP 1-2000 (R2008) may be viewed, and a hard or electronic copy purchased for $76, by visiting NEMA’s Web site. An electronic copy of ICS 5, Annex B-2002 (R2008) may be downloaded at no charge or a hard copy purchased for $50 from this link. And an electronic copy of ICS 5, Annex E-2002 (R2008) may be downloaded at no charge or a hard copy purchased for $50 from this link.