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The Dark Side of Green Lighting

In 2009, the Government of India found that the penetration of CFLs for household lighting was only about 5-10%, while over 70% of the remaining lights were incandescent bulbs1. In a bid to reduce electricity consumption in lighting, the government launched the Bachat Lamp Yojna, which would provide CFLs at Rs. 15 instead of Rs. 90 to households all over the country2. This was part of an UNFCCC CDM (Clean Development Mechanism) project, where the reduction in carbon emissions could be traded in the market. The scheme made economic sense back in 2009 due to a high price of carbon credits, and it was taken up enthusiastically by several state governments.
 
However, energy savings and subsequent reduction of carbon emissions presented only the good side of the picture.
It soon became apparent that there were very few rules, guidelines or standards for CFL production or disposal in the country. But why would CFLs need such rules, guidelines or standards?

CFLs use Mercury Vapour which is a highly toxic element

CFLs contain mercury vapour that is essential to their working. The vapourized mercury activates the phosphor, which in turn, emits light. 
 
Mercury in the air and particularly, in water (which then contaminates sea-food) can have severe neurological impacts on humans who are exposed to chronic mercury poisoning. (see Box)

 Why is Mercury in the Environment dangerous?

Elemental and methylmercury are toxic to the central and peripheral nervous systems.

The inhalation of mercury vapour can produce harmful effects on the nervous, digestive and immune systems, lungs and kidneys, and may be fatal.

The inorganic salts of mercury are corrosive to the skin, eyes and gastrointestinal tract, and may induce kidney toxicity if ingested.

- Source: World Health Organization3

Figure 1: Permissible Limits of Mercury; Source: World Health Organization 

How much mercury do our CFLs have?

The Bureau of Indian Standards (BIS) does not prescribe any standards for mercury content in CFL bulbs. A study carried out by Toxic Links show that CFLs in India carry anywhere between 3- 21.5 mg of Mercury4. The European Union sets a benchmark of 1.23 mg per bulb, with a limit of 2.5 mg per bulb being enforced since 2013.5 India’s E-Waste Rules, which came into effect in 2012 recommend a limit of 5mg of Mercury per bulb6, but according to the Toxic Links Study, till 2011, most companies had numbers that were 5-10 times that limit.
Table 1- Amount of Mercury in CFLs and Fluorescent Tube Lights, and their permissible limits: Sources: Toxic Links7, MoEF8, Minamata Convention9
 
India’s CFL use has been growing at over 20% annually. At the same time, a lack of awareness amongst domestic consumers and informal recyclers has led to disposal of CFLs in a potentially dangerous manner.
Figure 2- Annual production of CFLs and mercury used for CFL production in India; Data from ELCOMA (Electric Lamp and Component Manufacturers Association of India), Toxic Links; Analysis by Sustainability Outlook
 
It is estimated that the CFL industry alone uses about 3 tonnes of mercury every year.  India sold 300 million CFLs in 2010, and considering that the average life of a CFL in India is 4 years10, about 300 million CFLs would have entered the waste stream in 2014 alone. 
 
From Figure 2, it is quite apparent, that while 1066 million CFLs would have been disposed of by 2014, in the next 2 years, another 748 million CFLs will enter the waste stream. The huge impact of this waste can still be addressed and mitigated to a large extent, by enabling or incentivizing CFL recycling in the country. 
 
Even then, the mounting pile of CFLs that have already been introduced in the market needs to be dealt with. However, there aren’t too many recyclers who provide that service.

What happens to the Mercury in CFLs?

End-of-life CFLs can be recycled by separating the glass and the base. The base can be reused for other CFLs, but the glass has a mercury coating and cannot be reused directly. After the mercury has been separated from the glass, the glass can be reused for other purposes, while the mercury can be sold to manufacturers who may need it.
 
Crushed CFLs release Mercury vapour, which is negligible in quantity. However, if the glass has a mercury coating and may end up in landfills, unless sold to a CFL recycler. Once the mercury seeps into the soil, it contaminates ground water and surrounding water-bodies, eventually finding its way into the human body in the form of fish and other seafood.
 
Some large corporates do recycle their CFLs, or at least hand them over to recyclers. However, even then, many of the CFLs end up in landfills. Due to lack of many alternative options, CFLs from households are most commonly disposed in dustbins, where they are either scavenged, crushed, and the remnants again, end up in landfills.
 
“There are only 2 or 3 end-to-end recyclers of CFLs in India”, says Sumit Jugran of Noida-based Greentek Reman. Greentek Reman is one of the few companies currently providing a CFL recycling service in India. They currently recycle between 60 and 70 metric tonnes of CFLs annually, while the national production is estimated to be about 48,000 metric tonnes (400 million CFLs).
 
Attero, one of India’s prominent e-waste recyclers, also recycles CFLs. However, a majority of the CFLs processed by Attero is discarded by large corporates or bulk e-waste generators rather than those discarded by domestic consumers.
 
Most E-waste recyclers agree that one of the reasons that CFL recycling hasn’t taken off at a large scale is that CFL Recycling is not profitable for recyclers, even if recyclers receive discarded CFLs free of cost. Hence, corporate or domestic consumers with end-of-life CFLs have to bear the cost of recycling. Further, it is not clear if manufacturers of CFLs have Extended Producer Responsibilities to take-back and properly dispose of CFLs (see ‘Where are the Laws?’ section below). One of Greentek Reman’s major clients, OSRAM (a manufacturer of CFLs) is choosing to act on its Extended Producer Responsibility for CFL recycling, but in the absence of mandatory laws and clear guidelines, such companies are few and far in-between. 

Where is the risk greatest?

Some states in particular saw great success of the Bachat Lamp Yojna. These states, where millions of CFLs were sold under government schemes, are particularly at risk. This is because many of the CFL bulbs sold under the scheme will be reaching their end-of-life in 2014.  It must be noted that additional CFLs have also been sold without government support in the open market. However, exact sales figures are not available.
Figure 3- States that will produce a very high amount of CFL Waste in the near future and need to have proper disposal mechanism; Data from BEE; Analysis by Sustainability Outlook
 
The states which saw the greatest success of the Bachat Lamp Yojna scheme were Kerala and Haryana where 126 million and 56 million CFLs were sold respectively under the scheme.

Requirement for CFL Disposal:

  • Urgent /High Requirement for CFL Disposal Mechanism: States with the largest sale of CFLs face the greatest risk from Mercury poisoning due to improper disposal practices and have an urgent requirement for putting CFL disposal mechanisms in place. It is also in these states that the largest number of people will be affected by improper CFL disposal practices. 
  • High Requirement for CFL Disposal Mechanism: States like Punjab, Delhi, and Andhra Pradesh sold lesser number of CFLs under the government's Bachat Lamp Yojna, but still had relatively high volumes. They are the next in the priority list of states that need a proper CFL recycling mechanism.
  • Medium Requirement for CFL Disposal Mechanism:  Maharashtra, Haryana and Chattisgarh saw much lesser consumption of CFLs, but despite that, over 13 million CFLs were sold in these states, just uunder the Bachat Lamp Yojna. These CFLs need to be disposed of in a safe manner, and adequate processes should be facilitated by the state governments who pushed the Bachat Lamp Yojna without planning effectively for their safe disposal.

Where are the laws?

In 2008, before the Bijli Bachat Yojna was rolled out, a Task Force by the Ministry of Environment and Forests was set up to recommend rules for proper handling of CFLs. The Task Force recommended framing standards for mercury content in CFLs in 200811. Six years later, standards for the proper handling for CFLs still haven’t been framed. 
 
Aside from standards on the proper handling of CFLs, the disposal of CFLs is a major issue and India does not clearly recognize CFLs as either Hazardous waste or as E-Waste. The e-waste rules are ambiguous and while CFLs are included as e-waste according to the definition, CFLs are missing from the list of specified e-waste appliances and devices, which would impute extended responsibility on the manufacturers for recycling and disposal.12

India is now a part of the Minamata Convention and Needs to take action on Curbing Mercury Use

The Minamata Convention, named after a horrific incident (in which over 50,000 people were severely affected in the Japanese town of Minamata due to continued mercury poisoning from sea-food when the water was contaminated by mercury) is an international treaty curbing the use of mercury. India joined it on September 30th, 201413, which means that India has to stop producing CFLs that exceed the permissible 5mg of Hg by 2020.14
 
But how do we regulate the Mercury content in our bulbs if we do not have effective standards and labeling programs as well as testing provisions for CFLs?
 
“What we need is a complete list of commodities that can be classified as E-Waste and strict liabilities for infringements of the policy”, Mr. Jugran says.

How do we overcome the issue?

The good news is that influx of LEDs in the market, and the very recent government declaration of selling LEDs at Rs. 10 (instead of Rs. 400)15 , will go a long way in discouraging the sales of CFLs. Even industry bodies say that manufacturers are now moving away from CFLs towards LEDs which are far less environmentally challenging  but also have much longer lives, leading to lower waste generation in the long run.16  Sustainability Outlook Analysis indicates that growth of CFL production in India would stall post 2015-2016.
 
In the mean-time, there is a need to develop a more robust framework for dealing with the potentially hazardous CFL waste. In order to realize this, there have to be efforts made by policy makers, e-waste recyclers, manufacturers as well as consumers. 
 
In particular, consumers must be made aware of the hazards of mercury poisoning, and encouraged to recycle their CFLs. Access to such recycling facilities need to be improved.
 
More CFL recycling facilities are needed with profitable business models.  In 2008, the MoEF task force had recommended that the cost of CFL recycling should be borne by the manufacturers and the money may be raised through the taxes on CFLs. That could be one of the solution elements to meet the high cost of safe disposal and in turn make the recycling venture financially sustainable.
 
Additionally, there are a number of policy parameters that could go a long way in minimizing or at least mitigating this hazard. These include:

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Endnotes
[4] “Toxics in the Glow”, Toxic Links, September 2011, http://toxicslink.org/docs/CFL-Booklet-Toxics-in-That-Glow.pdf
[7] “Toxics in the Glow”, Toxic Links, September 2011, http://toxicslink.org/docs/CFL-Booklet-Toxics-in-That-Glow.pdf
[14] “Study on EU Implementation of the Minamata Convention on Mercury”, COWI, BiPro, ICF International and Garrigues Ambiental, June 2014
[16] Statistics of Indian Lighting Industry, ELCOMA, 2013