You may have heard about California bill AB 2208, the fairly new regulation signed into law by Governor Gavin Newsom on September 19, 2022, that will ban the sale and distribution of fluorescent lamps in the state by 2024 and 2025. It aims to protect Californians and the environment from the hazards of mercury-containing lamps, which can pose health and safety risks to people installing and maintaining them. It also aims to reduce energy consumption and greenhouse gas emissions by promoting the use of more efficient lighting alternatives, such as light emitting diodes (LEDs), which produce the same illumination as fluorescents but use far less electricity.
This regulation could have significant implications for your building’s budget, liability, and sustainability. Allow me to explain what it entails, what it means for your building, and what you need to do to prepare for it.
What does the regulation entail?
The regulation prohibits the sale and distribution of fluorescent lamps, including compact fluorescent lamps (CFLs) and linear fluorescent lamps (LFLs), starting from January 1, 2024 for screw or bayonet base type CFLs, and January 1, 2025 for pin-base type CFLs or LFLs. The regulation exempts some specialty lamps that meet specific criteria used mainly in the medical field, however.
The regulation does not require you to remove or replace existing fluorescent lamps in your building, but it does prevent you from buying new ones after the ban takes effect. This means that you will have to find alternative sources of lighting for your building once your current stock of fluorescent lamps runs out or burns out. Should you stock up now? Probably not.
What does the regulation mean for your building?
The regulation will affect your building in several ways, depending on the type and quantity of fluorescent lamps you use, the size and layout of your building, and the preferences and expectations of your occupants. Here are some of the potential impacts of the regulation on your building:
- Budget: Replacing fluorescent lamps with LED lamps will require an initial investment, but it will also result in long-term savings in your operations and maintenance budget. Replacing fluorescent lamps with LED lamps can result in significant energy savings, lower maintenance costs, longer life, and improved lighting quality. A recent study by the ACEEE found that by 2030, California properties could save over $1 billion annually on electricity bills, achieve annual electricity savings of about 5,600 gigawatt hours, and avoid the release of 950,000 metric tons of CO2 per year. However, the exact amount of energy savings will depend on the LED type, power, the lighting controls, and the hours of operation of your lighting system, then subject to your area’s electricity rates.
- Liability: Using fluorescent lamps in your building exposes you to the risk of mercury exposure or contamination, which can result in legal or regulatory consequences. Mercury is a toxic metal that can harm the nervous system, the brain, the kidneys, the lungs, and the immune system. Exposure to mercury can occur when fluorescent lamps are broken, improperly or carelessly handled, stored, or disposed of. According to the Environmental Protection Agency (EPA), fluorescent lamps are regulated under the Universal Waste Rule, which is a set of standards for managing certain types of hazardous waste in a way that reduces the regulatory burden and promotes recycling. Under this rule, businesses that generate or handle spent lamps can choose to manage them as universal waste, instead of hazardous waste, so long as they comply with the requirements for labeling, storage, transportation, and disposal of the lamps. The universal waste rule also provides guidance on how to deal with broken lamps, which are considered accidental releases of mercury. Failure to comply with the universal waste rule or failure to follow proper procedures for cleaning up broken lamps can result in fines or penalties from the EPA or the California Department of Toxic Substances Control. Moreover, you may be liable for any damages or injuries caused by mercury exposure or contamination to your occupants, employees, or the environment. By switching to LED lamps, which do not contain mercury or other hazardous substances, you can eliminate this risk and protect yourself from potential liability.
- Sustainability: Continuing to use fluorescent lamps in your building contributes to the global problem of mercury pollution, which affects the health and well-being of humans and wildlife. Mercury is a persistent pollutant that can travel long distances in the air and water, and can accumulate in the food chain. Mercury emissions from fluorescent lamps account for about 3% of the total mercury emissions in the U.S., and about 1% of the global mercury emissions. By switching to LED lamps, which do not contain mercury and reduce electrical sourced greenhouse gases, you can reduce your environmental footprint and support the global efforts to phase out mercury-based lighting. Side note: This regulation follows the global trend of phasing out mercury-based lighting, as evidenced by the European Union’s ban of 2023 and the Minamata Convention on Mercury’s phase out of CFLs by 2025.
What do you need to do to prepare for the regulation?
To prepare for the regulation, you need to plan now and determine a schedule for the replacement of fluorescent lamps with LED lamps as early as possible. Not only will this will ensure that you can continually maintain the light levels in your building, but you may realize avoidance of supply and demand pricing hikes if a mad scramble starts to happen when properties realize they can’t get replacement lights anymore. Here are some steps that you need to take to prepare for the regulation:
- Have your building engineers assess your current lighting system and inventory: The first step is to assess your current lighting system and determine the type, quantity, and condition of fluorescent lamps you use in your building. You can do this by conducting a lighting audit, which is a systematic process of collecting and analyzing data on your lighting system, such as the number and location of lamps, the wattage and color temperature of lamps, the hours of operation of lamps, the energy consumption and cost of lamps, and the lighting quality and satisfaction of occupants. A lighting audit can help you identify the areas where you can improve your lighting efficiency, performance, and comfort, and where you can save money and energy by switching to LED lamps and installing or reprogramming lighting controls. You could hire a professional lighting contractor or consultant to do it for you, but call us to help you plan how to collect and analyze the data, and generate reports and recommendations or if you need help doing it.
- Choose the right LED lamps: The next step is to choose the right LED lamps and controls for your building, based on your lighting audit results and your lighting goals and preferences. LED lamps come in various shapes, sizes, colors, and features, and they offer many advantages over fluorescent lamps, such as longer lifespan, lower energy consumption, better lighting quality, dimmability, controllability, and compatibility with smart lighting systems. However, not all LED lamps are created equal, and some may not be suitable for your specific lighting needs or applications. Therefore, when choosing LED lamps, you need to already know key factors, such as the lumen output, the color rendering index, the correlated color temperature, the power factor, the desired warranty, any certifications, and, of course, the price. You can use public online resources, such as the Design Lights Consortium or ENERGY STAR, to compare and select LED lamps that meet your criteria and standards. You can also consult with a lighting expert or a lighting manufacturer to get more guidance and advice on choosing LED lamps. Always talk to your building engineers as your first step to understand the nuances within your specific property that these data sheets can’t provide.
- Replacement: The final step is tactical. Replace your fluorescent lamps with LED lamps, either by your building engineering staff or by hiring a qualified lighting contractor or electrician. Depending on the type and configuration of your existing lighting fixtures, you may need to modify or replace them to accommodate the LED lamps. Many kits are designed to enable easy replacements of many common commercial lighting fixtures with minimal work. You may also need to install additional components, such as sensors or controllers, to ensure the proper operation and performance of the LED lamps. You should follow the manufacturer’s instructions and safety precautions when installing LED lamps, and test them for functionality and compatibility. You should also properly recycle the spent fluorescent lamps, observing proper care and chain of custody if materials manifests are required. You can find a local recycling facility or a lamp management service that can handle the recycling or disposal of your fluorescent lamps and your lighting supply vendor may also provide this service. Whether you decide hire a contractor or perform in-house, try to get your contractor or supplier to agree to proper recycling of your old lighting as part of the contract or order.
By following these steps, you can prepare for the regulation and enjoy the benefits of LED lamps in your building. You can also use this opportunity to upgrade your lighting system and make it more efficient, comfortable, and sustainable.
California’s ban on fluorescent lamps is a major regulation that will affect the lighting industry and the commercial building sector in the state. As a property manager or a maintenance engineer of a commercial office building, you need to be aware of the regulation and its implications for your building. You also need to take action and prepare for the regulation adversely affect you or your tenants by replacing your fluorescent lamps with LED lamps before the deadline. By doing so, you can protect your building’s budget, liability, and sustainability, and provide a better lighting environment for your occupants.
Should you have any questions regarding your building maintenance procedures or need more information, please reach out to me at Wayne.Alldredge@Servi-Tek.net