Proposed code of practice for management of end-of-life lamps containing mercury: chapter 6

6. Tracking and Inventory Systems

Collection facilities, waste management facilities and transporters should implement a tracking and inventory system to ensure that collected lamps are accounted for and reach the processing or disposal facility by following them through every stage of management including the primary collection site, intermediate storage, transportation, and processing and/or disposal.

The responsibility for tracking and maintaining inventory systems is shared among the collector, transporter, processor and waste management facility. Each of them has the responsibility to comply with all federal, provincial and territorial requirements for tracking and maintaining inventory systems.

When designing the tracking and inventory system, it is important to consider whether there is an extended producer responsibility program in the province or territory (which may have its own tracking and reporting mechanism or specific reporting requirements), the complexity of the chain of custody (e.g., the number of intermediate stops the lamps make as they move toward final processing), and whether the lamps are considered hazardous and require movement documents under federal, provincial and/or territorial legislation.