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2014 Northwest Hazardous Materials Conference
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Transcript of 2014 Northwest Hazardous Materials Conference
The Association of Electrical and
Medical Imaging Equipment Manufacturers
2014 Northwest Hazardous
Materials Conference
WASHINGTON H.B. 2246:
MANUFACTURERS’ PERSPECTIVE
MARK A. KOHORST
NATIONAL ELECTRICAL MANUFACTURERS ASSOCIATION
Troutdale, OR
June 2014
The Association of Electrical and
Medical Imaging Equipment Manufacturers
What is NEMA? NEMA and Lamp Recycling Lamp Recycling Legislation The Financing Question HB 2246 Maine, Vermont Where to from here?
Topics
The Association of Electrical and
Medical Imaging Equipment Manufacturers
NEMA Vital Statistics Created 1926, Largest US Trade Association of
Electro-Industry Manufacturers Membership: Appr 450 US Manufacturers Products used in Generation, Transmission,
Distribution, and End-Use of Electricity 8 Industry Divisions, ~52 Product Sections Dry Batteries to Motors to Traffic Signaling Equip to
MRIs, etc. Principally a Standards Organization More than 500 Industry Standards; Internally and With
ANSI and IEC Also Advocacy, Data Collection & Analysis, International
Collaboration, Safety Promotion
The Association of Electrical and
Medical Imaging Equipment Manufacturers
NEMA Lamp Manufacturing Section
Currently 25 companies Large, household name producers (GE, Philips, OSRAM, etc.) Smaller, specialty lamp manufacturers
About $3 billion in lamp shipments covering commercial,
industrial, institutional, residential, automotive, and specialty lighting markets
The Association of Electrical and
Medical Imaging Equipment Manufacturers
NEMA and Lamp Recycling
Manufacturers label every package sold in North America
Created www.lamprecycle.org – one stop center for
recycling information More than 200,000 page views per year Separate pages for state programs
Ongoing education through distribution chain, outreach Encourages enforcement of local, federal, state laws
NEMA Actively Promotes Recycling Hg-added Lamps
The Association of Electrical and
Medical Imaging Equipment Manufacturers
Legislation
Focus on residential market, not commercial/industrial All manufacturers selling in the state must participate “Level playing field”
Must include a “Sunset” Provision Encourages state enforcement on non-compliant companies Provides adequate state antitrust protection For WA law, “state action doctrine” is crucial
Ensures sustainable financing for life of program E.g., “Environmental Handling Charge”
Key Elements of a State Lamp Recycling Law
The Association of Electrical and
Medical Imaging Equipment Manufacturers
Financing MechanismKey Considerations
Spent Hg-added lamps have virtually no residual value Substantial difference from lead-acid batteries, certain
electronics Cost of recycling CFLs, LFs is very high relative to retail
price of new products Package of 8 leading brand CFLs (13w), $10.35 plus shpg on
Amazon EcoSmart 4-pack CFLS (13w), $3.97 at Home Depot Loaded cost of recycling CFLs can approach 50 cents per unit
CFLs have long been “commodity products” – so pricing
flexibility is extremely limited Manufacturers do not “shift” costs between product lines Cost internalization not a viable option for these products
The Association of Electrical and
Medical Imaging Equipment Manufacturers
Environmental Handling Charge
Various precedents exist (e.g., paint, mattresses, tires) Applies to all manufacturers selling in the state, ensuring
level playing field Helps to educate consumers on importance of recycling Uses third party “stewardship organization” for collection,
disbursement Subject to state review and approval If kept low enough, not expected to deter sales Temporary program . . . . Won’t last forever
Not Ideal, but Necessary for a Statewide Program
The Association of Electrical and
Medical Imaging Equipment Manufacturers
H.B. 2246
Expected to provide funds for comprehensive program Provides flexibility concerning remittance of fees Added to price when lamp is sold by producer – producer remits
fee to SO OR
Retailer collects fee from consumers – retailer remits fee to SO Consistent with ‘over the border’ program in British Columbia Enacts a statewide disposal ban for mercury-added lights
Not Ideal, but Good Solution for WA State
The Association of Electrical and
Medical Imaging Equipment Manufacturers
Other State LawsMaine Vermont
Enacted June 2009 Enacted May 2011 Covers “mercury-added
lamps sold or distributed for household use”
A person(?) may recycle any number of CFLs and up to 10 non-CFLs
No antitrust immunity Includes antitrust immunity
Sales ban for non-compliance No sustainable funding mechanism
The Association of Electrical and
Medical Imaging Equipment Manufacturers
Where to from here? FIRST – Get program started successfully in WA SECOND – Observe, evaluate, improve as needed BEYOND WASHINGTON . . . . Each state is different Politics unpredictable Cost challenges remain difficult
MEANWHILE . . . . . Mercury content still falling Transition to next generation lighting continues
75 years of excellence
Thanks for your attention!
Mark A. Kohorst
703-841-3249
703-841-3349 (fax)
NEMA
Suite 900
1300 North 17th
Street
Rosslyn, Va. 22209
www.nema.org