Attn: Guy Crittenden, Editor RE: Blog post: “Dim Bulbs: stewardship dispute generates more heat than light”
Dear Mr. Crittenden,
On behalf of Recycling Council of Ontario (RCO), I appreciate both the opportunity to clarify the nature of our Take Back the Light program, and to address the decision of Ontario Lamp Recyclers (OLR) to not participate in it.
When we started the program, there were no standards specific to lamp recycling in Ontario (or anywhere else in North America, for that matter). Though there are certain health and environmental safety requirements as part of the Ontario Ministry of the Environment Certification Approvals process, those requirements do not require the maximization of material extraction. In fact, applicable regulations do not even define “recycling”.
RCO saw an opportunity to create a unique program to achieve positive environmental results through a market-driven approach backed by standards that are specific to lamp recycling.
We believe that market competition is a critical driver of efficiency; and that standards foster innovations and continued improvement that are vital to the resource recovery industry.
To that end, Take Back the Light established a materials management standard that is specific to mercury-containing lamps and was developed through extensive stakeholder consultation by the Bureau du Normalization de Quebec (BNQ), an independent professional standards development organization.
Dealers and manufacturers who pay a registration fee and are part of Take Back the Light must commit to taking back spent lamps from their buyers as a value-added service, and must deliver those lamps to processors that meet developed lamp recycling standards. These standards are available on www.takebackthelight.ca.
Processors that receive lamps through the program must also commit to a certain transparency in their recycling processes, which includes a materials management audit. RCO’s role is to verify, as an independent administrator, that every spent lamp processed through the program is managed responsibly through to final disposition. We aim to ensure that, from generation to disposition, each and every lamp is managed to maximize material recovery.
The transparency requirements and recycling standards for Take Back the Light are considerable, and not every prospective participant or lamp processor will qualify. Those who do qualify, however, are entitled to publicize their participation in the program in order to promote their business and raise their market profile.
RCO, as a non-profit organization, uses registration fees and processor royalties to further its mission to minimize society’s impact on the environment by eliminating waste, which includes raising awareness of and expanding the program, improving recycling standards, and publicizing those who choose to participate in Take Back the Light.
To date, two companies—Aevitas and Veolia—are approved processors for Take Back the Light. They both passed a materials management audit and are subject to the program’s transparency requirements. Though RCO was in discussions with OLR for a lengthy period, ultimately, OLR chose to break off active negotiations with RCO.
As to the letter that we sent out, and which was included in your blog post, it was circulated in response to numerous inquiries that RCO received, from both participants and potential participants, asking whether OLR had joined, or was going to join, Take Back the Light. We wanted to ensure that there was no confusion in the marketplace about which processors had joined Take Back the Light, and were subject to the requirements of that program, and which had not.
We are, of course, open to further discussions with OLR, and we hope that OLR will become an approved processor under Take Back the Light.
Jo-Anne St. Godard
Executive Director Recycling Council of Ontario
215 Spadina Ave., Suite 225 : Toronto, ON M5T 2C7 : 416.657.2797 : www.rco.on.ca