Definition

‘Collectors’ means companies and other arrangements for collection of waste mercury-containing lamps including retail outlets and service clubs.

A Collector provides a service for the collection of waste mercury-containing lamps.

Examples are:

• a company that specialises in waste collection
• a local council or other form of waste management authority that provides dedicated collection points for waste mercury-containing lamps
• a company that collects waste as part of its business, eg an electrical contractor or a builder

  Example An electrical contractor might relamp a building, collect the waste lamps and take them to a dedicated waste collection point for recycling. That electrical contractor could belong to two Categories – ‘Contractors’ and ‘Collectors’.

• a retail outlet such as a hardware store or supermarket that provides a collection bin for waste mercury-containing lamps to be deposited by the public and ensures that the waste lamps are recycled

  Where a retail outlet provides collection bins, it is preferable it is also a Signatory as a Commercial User, and recycles all of the lamps used in its premises. Even better, the retail outlet that provides information to customers about the importance of recycling waste mercury-containing lamps can also be a Signatory as a Supplier. Becoming a Signatory as a Collector, a Supplier and a Commercial User builds credibility as a recycler.

• a wholesaler of mercury-containing lamps that provides a collection bin for waste lamps to be deposited by customers and ensures that the waste lamps are recycled

  This means that a Signatory in the Supplier category can also be a Collector.

• a service club that provides collection points for a community to deposit waste mercury-containing lamps and ensures the waste lamps are recycled, eg as part of a community waste collection day.

Additional Commitments

Signatories in this Category need to meet the commitments that apply to all Facilitators.

In addition, Collectors are required to meet the following commitments which are explained below:

• Encourage customers and potential customers to take appropriate action to become Signatories to the scheme.

  This commitment relates to the Action Plan

• Liaise with the Administrator on the verification of information provided by Applicants as to recycling action being taken.

  This commitment is to allow the Administrator to check the information related to an application from a business or organisation that is seeking Signatory status as a Commercial User.

  Applications for Commercial User status

  There are two types of applications for Commercial User status.

  In summary, the application form for Commercial Users needs to include either:

  • copies of relevant documentation, eg contracts, invoices or receipts, as evidence that all waste mercury-containing lamps are being recycled from the specified sites (a Type A application), or
  • a plan setting out the steps to be taken to have arrangements in place for the collection and recycling of all waste mercury-containing lamps from the specified sites (a Type B application).

  Where a business or organisation is not already recycling all of its mercury-containing lamps when it applies (a Type B application), there is an extra requirement to be met within 6 months of becoming a Signatory. This requirement is that the Signatory needs to demonstrate that arrangements are in place for the collection and recycling of all waste lamps from the specified sites.

  The Administrator may wish to verify the information or the documentation that is provided in an application for status as a Commercial User. The Administrator may also wish to verify the information provided 6 months after a business or organisation is awarded Signatory status as a Commercial User. In these instances, the Administrator may contact the collection or recycling companies named in the application.

  To carry out the verification, the Administrator may approach Collectors (ie collection companies that are also Signatories) on an ad hoc basis when each application is being assessed. That is, the Administrator may ask Collectors about individual applications. Alternatively, Collectors may wish to respond to batches of requests for verification on, say, a monthly basis. The timing of these batched requests can be negotiated with the Administrator.

• For the purposes of reporting on the performance of FluoroCycle, provide the following information to the Administrator:

  • the number of clients who are Signatories, and
  • the total amount of waste mercury-containing lamps received from clients who are Signatories.   

  This commitment requires Collectors to provide information to assist in measuring the effectiveness of FluoroCycle as a scheme. The information required relates to clients that are Signatories, ie Commercial Users or other Collectors.

  At the beginning of the scheme, the expectation is that the Commercial Users that are already recycling their waste mercury-containing lamps will become Signatories. It is acknowledged that this recycling activity pre-dates FluoroCycle and cannot be attributed to FluoroCycle. This will be taken into account when reporting on the performance of the scheme.

  Number of Signatory clients

  Collectors are required to provide information on the number of clients that are Signatories and the total amount of waste mercury-containing lamps that is collected from these clients.

  It should be straightforward to identify clients that are Signatories. The Collector will know which Signatories it recruited. Another source of information on Signatories is the FluoroCycle website.

  Collectors may find it useful to include a column for Signatory status in their client databases.

  Data on the number of clients who are Signatories will give a general indication of the uptake of FluoroCycle and may help to indicate the geographical distribution of that uptake. Where gaps are identified, strategies can then be developed to promote FluoroCycle in these areas.

  Amount of waste mercury-containing lamps collected from Signatories

  Collectors will provide information to the Administrator about the amount of waste mercury-containing lamps received from Signatories. This information could be in kilograms or in total numbers of different types of waste lamps.

  Information on the numbers of particular types of waste lamps collected would be useful. However, given the wide variety of lamps, there may be occasions when it is not practical to provide a number for every single type of waste lamp collected. In such cases, the Collector could record the total number of lamps and provide a short description of the mixture of lamps.

  Collectors should seek the Administrator’s advice on the reporting of waste lamps collected if there are any unforeseen difficulties.

  The information you provide as a Collector will help to improve understanding of the effectiveness and uptake of the scheme. It will also help to identify gaps in collection and opportunities for increasing recycling.

  The calculation of the national recycling rate for mercury-containing lamps is based on information provided by the Recycling companies.

• Treat information relating to Applicants and Signatories, and designated by them as confidential, that is received from, and provided to, the Administrator as private and confidential.

  The Administrator will provide information about Applicants and Signatories to Collectors to verify and the Collectors will provide information to the Administrator. Collectors must treat any information that applicants and Signatories have identified as private or confidential in an appropriate fashion and not share it with any party other than the Administrator.

  This means that Collectors need to have appropriate measures in place to ensure that information marked ‘private’ or ‘confidential’ is protected appropriately. The assumption is that such measures would already in place to satisfy the confidentiality requirements in contracts with current clients.

The additional commitments apply only where they are relevant to the business or organisation in the Collector Category.

Example:

Some Collectors such as service clubs, retail outlets and local councils may collect significant quantities of waste mercury-containing lamps from householders. These Collectors do not hold information on ‘customers or potential customers’ and are not in a position to provide the information the Administrator requires

On the other hand, waste collection companies and larger electrical contractors do collect commercial quantities of waste lamps and have documentation identifying their customers. These companies are in a position to meet the additional commitments.

Action Plan

The Action Plan needs to take account of the topics that apply to all Facilitators.

There are audit requirements that apply to all Facilitators.

The Action Plan for Collectors also needs to include the actions to be taken to ‘encourage customers or potential customers to take appropriate action to become Signatories to the scheme’. The sorts of action that could be taken include:

• promoting FluoroCycle and providing information and FluoroCycle materials at least annually to established customers who are not recycling their mercury-containing lamps
• providing information about FluoroCycle to potential customers and including the costs for recycling mercury-containing lamps when quotes are given
• having recycling of waste mercury-containing lamps as a standard clause in any contracts, where possible, or encouraging customers to include such a clause in relevant contracts.

Audit Requirements

There are audit requirements that apply to all Facilitators.

In addition, Collectors may be asked to provide documentation that demonstrates that waste mercury-containing lamps that clients intended to be recycled have, in fact, been recycled. Documentation could be in the form of invoices from the Recycling companies.

Definition

‘‘Contractors’ are electrical contractors’, particularly electrical contractors who do relamping. Relamping is the process of replacing used lamps with new ones on a periodic basis.

For the purposes of FluoroCycle, it is important to ensure that all waste lamps are recycled, including those that result from ad hoc replacement when they reach their end of life.

Contractors have an important role in FluoroCycle because they have direct access to the businesses and organisations that generate waste mercury-containing lamps and are potential Commercial Users in the scheme.

Commonly, the lamps used for public lighting along streets and roads, or in buildings such as office blocks and shopping centres, are all replaced periodically, eg every 12 to 18 months. Recruiting Signatories from these businesses or organisations will make a significant contribution to the success of FluoroCycle.

Additional Commitments

Signatories in this Category need to meet the commitments that apply to all Facilitators.

In addition, Contractors are required to meet the following commitments:

• Encourage clients to include a requirement in relevant contracts for the recycling of waste mercury-containing lamps, thereby assisting clients to become eligible as a Signatory of FluoroCycle.

  Contractors are expected to encourage their clients to recycle all of their waste mercury-containing lamps. This can be done by suggesting how collection for recycling can be carried out to ensure that all waste lamps are collected and recycled, including waste that arises from ad hoc replacement.

  Contractors that offer a collection service should include this in their own promotional material and advertisements, eg in the Yellow Pages.

• Where a contract requires recycling, ensure that all waste mercury-containing lamps generated through relamping are recycled.

  Contractors can also be Signatories as Collectors and they are strongly encouraged to belong to both of these Categories.

  If Contractors do not offer a collection service, they need to ensure that the waste lamps that they collect are in turn collected by a company that has appropriate arrangements in place to ensure they are recycled.

Action Plan

The Action Plan needs to take account of the topics that apply to all Facilitators.

For Contractors, the Action Plan should also include strategies for encouraging clients to recycle all waste mercury-containing lamps. For old clients that are not recycling their waste mercury-containing lamps, an annual approach encouraging them to do so would be appropriate. Any new clients should be encouraged from the start.

Audit Requirements

There are audit requirements that apply to all Facilitators.

In addition, an audit of a Contractor is likely to require evidence of standard wording in contracts and examples of any flyers or advertising used by the Contractor to promote FluoroCycle.

The audit may also require certificates from Collectors and Recycling companies demonstrating that recycling took place. Contractors are usually in a good position to know which of their customers required waste lamps to be recycled and the paper trail for those waste lamps would consist of documents such as invoices to the clients and certificates from Collectors and Recycling companies.

Definition

‘Government’means portfolios, departments and agencies in Australian, state, territory and local governments.

Additional Commitments

Signatories in this Category need to meet the commitments that apply to all Facilitators.

In addition, this Category is required to meet the following commitments where are explained below:

• Encourage establishment and implementation of a policy to recycle waste mercury-containing lamps generated in government-owned or -leased buildings and street or road lighting.

  Government agencies at all levels of government (Commonwealth, state, territory and local) are in a position to put policies in place – and implement them – to ensure all waste mercury-containing lamps from premises that they own or lease are recycled. These policies may be included in the Environmental Management Systems that apply to agencies or the sites they are responsible for – or they may be adopted as standalone policies. Implementation occurs through any contracts, or other arrangements, that are in place, requiring the recycling to occur.

• Contribute to the Outreach Strategy by providing information and encouraging other agencies to establish and implement policies to recycle waste mercury-containing lamps.

  At the Commonwealth level, the Government Agency Environmental Network (GAEN) provides an ideal forum for promoting FluoroCycle to agencies, encouraging them to become Signatories.

  Agencies can promote their activities through inclusion in annual reporting on the sustainability of their operations.

  All agencies, but particularly environment agencies, are encouraged to be pro-active in promoting FluoroCycle to other government agencies in their jurisdictions.

• Contribute to the Outreach Strategy by providing information, resources and/or funding to encourage organisations and businesses in relevant networks to recycle mercury-containing lamps and to become Signatories to FluoroCycle.

  Jurisdictions are encouraged to initiate or support programs or projects that increase recycling of waste mercury-containing lamps in all sectors.

Action Plan

The Action Plan needs to take account of the topics that apply to all Facilitators.

For the Government Category, the Action Plan should include an outline of the strategies they plan to undertake to address the additional commitments outlined above.

Audit Requirements

There are audit requirements that apply to all Facilitators.

In addition, Signatories in the Government Category should be able to provide copies of relevant policies and reports and documents that encourage other agencies as well as businesses and organisations to develop and implement such policies.

Definition

‘Media partners’ means media outlets that promote the scheme through, eg, editorial comment, articles that promote the scheme or free advertisements.

For this Category, it is important that the application and accompanying Action Plan includes a description of the media outlet (eg radio, television, newspaper, trade journal or magazine) and the nature and size of its target audience.

Media partners could include television stations and networks; radio stations and networks; newspaper companies; and businesses and organisations that produce trade journals or other publications, including newsletters.

Additional Commitments

Signatories in this Category need to meet the commitments that apply to all Facilitators.

In addition, Media partners are required to ‘make a significant contribution to the promotion of the scheme’.

The Administrator assesses whether the contribution to the promotion of FluoroCycle is significant and warrants Signatory status, taking into account the size and nature of the media outlet and its target audience.

If a quarterly trade journal targeting electrical contractors includes a short advertisement for FluoroCycle in each edition and a major article once or twice a year, then this would make a significant contribution to the promotion of FluoroCycle, reaching potential Signatories in the Contractor Category.

If a television or radio station has one news item on FluoroCycle, this would not be considered significant.

A newspaper could be considered for Signatory status if it promotes FluoroCycle in items during the year and publishes feature articles or supplements that target businesses and organisations that are relevant to FluoroCycle, eg the owners or managers of facilities, and promotes recycling of waste lamps.

Action Plan

The Action Plan needs to take account of the topics that apply to all Facilitators.

For Media partners, the Action Plans will vary considerably, given the wide range of potential Media partners. They need to outline what activities are planned to make a significant contribution to the promotion of FluoroCycle.

Audit Requirements

There are audit requirements that apply to all Facilitators.

Media partners would need to provide evidence that they had made a significant contribution to the promotion of FluoroCycle as set out in their Action Plans and provide copies of relevant materials such as articles or recordings.

Definition

‘Peak bodies’are associations and other bodies that have a representative role in the private sector.

Examples of peak bodies closely associated with FluoroCycle are Lighting Council Australia, the Property Council of Australia and the Facility Managers Association.

Peak bodies in sectors related to the purpose of the scheme can apply for Signatory status.

Additional Commitments

Signatories in this Category need to meet the commitments that apply to all Facilitators.

The additional commitment for Peak bodies emphasises their key role by restating the requirement for them to ‘encourage members to take appropriate action to become Signatories to the scheme’.

Peak bodies have an important role in FluoroCycle, particularly those that represent the owners or managers of facilities such as office blocks, apartment blocks, road and street lighting, sporting venues, industrial sites, airports and institutions such as hospitals and libraries.

Action Plan

The Action Plan needs to take account of the topics that apply to all Facilitators.

In addition, include strategies for encouraging their members to become Signatories to FluoroCycle.

Strategies could include:

• circulars, newsletters and journals
• presentations at board meetings, conferences or seminars
• incorporating the recycling of all waste mercury-containing lamps into the commitments for achieving status as a ‘green’ building.

Audit Requirements

There are audit requirements that apply to all Facilitators.

Documents relevant to an audit of Peak bodes would be examples of presentations and copies of templates or actual leases or contracts for property management.

Definition

‘Recycling companies’ are companies that are licensed under applicable legislation to process waste mercury-containing lamps and separate the lamp components for re-use in other products.

Pre-requisite

When applying for Signatory status as a Facilitator, a recycling company makes a statement that it is licensed to recycle mercury-containing waste and that it operates under the relevant licence conditions. The Administrator can ask the recycling company to provide certified copies of relevant documentation, if required.

There is no pre-requisite for other Facilitators.

Additional Commitments

Signatories in this Category need to meet the commitments that apply to all Facilitators.

The following additional commitments apply to Recycling companies:

• Encourage customers and potential customers to take appropriate action to become Signatories to the scheme.

  The customers of Recycling companies are already taking steps to recycle their waste mercury-containing lamps – and may be eligible to become Signatories to FluoroCycle as either Commercial Users or Collectors .

  Recycling companies are in a position to advise customers, and potential customers, about the requirements of the FluoroCycle Guidelines, providing copies of FluoroCycle materials and guiding them on what they need to do to apply. Commercial Users need to recycle all of their waste lamps and, if the customers are not already doing this, they may need advice on how to do it.

  Example:

  A customer recycles the waste lamps resulting from the periodic relamping of an entire site, such an office block, but waste lamps resulting from ad hoc replacement are disposed of to landfill. In order to recycle all of the waste lamps from this site, the customer may need to have a dedicated collection box installed in an appropriate location where waste lamps arising from ad hoc replacement of expired lamps can be deposited and stored, to be collected for recycling as required.

• Operate in compliance with licence conditions.

  This commitment complements the pre-requisite for Recycling companies and reinforces the need to comply with the law that applies in the jurisdiction/s the companies operate in.

• Recycle all collected mercury-containing lamps and do not dispose of any such lamps to landfill.

  This commitment is essential to the integrity of the scheme.

• To the extent that it is practical and cost effective, ensure that all materials recovered from recycled mercury-containing lamps are reused.

  Waste mercury-containing lamps are fully recyclable.

  The materials recovered by processing waste mercury-containing lamps are: mercury, phosphor, metals and glass – and these materials can all be reused.

  The mercury is used in dental amalgam; the phosphor is reused in fertiliser; the metals are used in the manufacture of new products; and the glass is used in the manufacture of products such as insulation.

  The value of these materials is relatively low and can vary considerably over time, depending largely on the demands and markets for them. Recycling companies are required to use their best endeavours to ensure that the materials that are recovered from mercury-containing lamps, particularly mercury, are reused and not disposed of to landfill.

• Liaise with the Administrator on the verification of information provided by Applicants as to recycling action being taken.

  This commitment is to allow the Administrator to check the information related to an application from a business or organisation that is seeking Signatory status as a Commercial User.

  Applications for Commercial User status

  There are two types of applications for Commercial User status.

  In summary, the application form for Commercial Users needs to include either:

  • Type A: copies of relevant documentation, eg contracts, invoices or receipts, as evidence that all waste mercury-containing lamps are being recycled from the specified sites
  • Type B: a plan setting out the steps to be taken to have arrangements in place for the collection and recycling of all waste mercury-containing lamps from the specified sites

  Where a business or organisation is not already recycling all of its mercury-containing lamps when it applies (a Type B application), there is an extra requirement to be met within 6 months of becoming a Signatory. This requirement is that the Signatory needs to demonstrate that arrangements are in place for the collection and recycling of all waste lamps from the specified sites.

  The Administrator may wish to verify the information or documentation that is provided in an application for status as a Commercial User. The Administrator may also wish to verify the information provided 6 months after a business or organisation is awarded Signatory status as a Commercial User. In these instances, the Administrator may contact the collection or recycling companies named in the application.

  To carry out the verification, the Administrator may approach recycling companies that are Signatories on an ad hoc basis when each application is being assessed. That is, the Administrator may ask Recycling companies about individual applications. Alternatively, Recycling companies may wish to receive batches of requests for verification on, say, a monthly basis. The timing of these requests can be negotiated with the Administrator.

• For the purposes of reporting on the performance of FluoroCycle, provide the following information to the Administrator:

  • the number of clients who are Signatories
  • the total amount of waste mercury-containing lamps received from clients who are Signatories, and
  • the total amount of mercury-containing lamps processed to allow the calculation of the national recycling rate.

  This commitment requires Recycling companies to provide information to assist in measuring the effectiveness of FluoroCycle as a scheme. The information required relates to clients that are Signatories. The Signatory clients are Commercial Users or Collectors.

  The Administrator will request the data at least annually and possibly more frequently in the early stages of the scheme.

  At the beginning of the scheme, the expectation is that the Commercial Users that are already recycling their waste mercury-containing lamps will become Signatories. It is acknowledged that this recycling activity pre-dates FluoroCycle and cannot be attributed to FluoroCycle. This will be taken into account when reporting on the performance of the scheme.

  Number of Signatory clients

  Recycling companies are required to provide information on the number of clients that are Signatories and the total amount of waste mercury-containing lamps that is collected from these clients.

  It should be straightforward to identify clients that are Signatories. The Recycling company will know which Signatories it recruited. Another source of information on Signatories is the FluoroCycle website. Recycling companies may find it useful to include a column for Signatory status in their client databases.

  Data on the number of clients who are Signatories will give a general indication of the uptake of FluoroCycle and may help to indicate the geographical distribution of that uptake. Where gaps are identified, strategies can then be developed to promote FluoroCycle in these areas.

  Amount of waste mercury-containing lamps collected from Signatories

  Recycling companies advise the Administrator the amount of waste mercury-containing lamps received from Signatories in kilograms.

  The information provided by a Recycling company will help to improve the understanding of the effectiveness and uptake of the scheme. It will also help to identify gaps in collection and opportunities for increasing recycling.

  Recycling companies should seek the Administrator’s advice on the reporting of waste lamps collected if there are any unforeseen difficulties.

  Total amount of mercury-containing lamps processes

  The Administrator will request information from the Recycling companies about the total annual amount of mercury-containing lamps processed by them, in kilograms. The information provided by each Recycling company will be treated as commercial-in-confidence.

  The formula for the calculation of the national recycling rate will draw on confidential, annual sales data for new mercury-containing lamps. The numbers of mercury-containing lamps sold will be converted to weight, allowing the national recycling rate to be calculated without disclosing any commercial-in-confidence information.

Action Plan

The Action Plan needs to take account of the topics that apply to all Facilitators. with a particular focus on promotion of the scheme to its clients.

Audit Requirements

There are audit requirements that apply to all Facilitators.

The information and data that Recycling companies provide to the Administrator on an ongoing basis will also be available to an audit.

Definition

‘Suppliers’ are the manufacturers of mercury-containing lamps, or their representatives in Australia, as well as the importers, wholesalers and retailers of these lamps. Australia imports all of its mercury-containing lamps at the present time.

Additional Commitments

Signatories in this Category need to meet the commitments that apply to all Facilitators.

In addition, Suppliers are required to provide information about recycling to customers in accompanying documentation.

Action Plan

The Action Plan needs to take account of the topics that apply to all Facilitators.

The Action Plan for Suppliers should focus on strategies for promoting FluoroCycle to immediate and downstream customers. Such strategies could include:

• labelling of boxes of mercury-containing lamps
• providing information about FluoroCycle in factsheets or flyers that accompany invoices or consignment notes
• including information about FluoroCycle in product catalogues, and
• providing articles for trade journals.

Audit Requirements

There are audit requirements that apply to all Facilitators.

Specifically, Suppliers should retain examples of how the FluoroCycle logo, publications and specified communication tools have been used.

Definition

‘Trainers’ are educational institutions, businesses and organisations that provide, or facilitate, training to relevant personnel including apprentice electricians, qualified electricians, builders, renovators, retrofitters and demolition workers.

Examples of Trainers are:

• educational institutions, such as technical colleges, or trade associations that deliver training and incorporate the FluoroCycle scheme and its objective into the courses provided for apprentice electricians, qualified electricians and students in other trades that could be expected to be involved with the removal and disposal of mercury-containing lamps.
• businesses or organisations that make sure that relevant staff receive the training offered by the above educational institutions.

Additional Commitments

Signatories in this Category need to meet the commitments that apply to all Facilitators.

In addition, educational institutions that are Trainers are required to provide relevant training that promotes the objective of FluoroCycle and businesses and organisations that are Trainers are required to ensure that all relevant employees receive such training.

Action Plan

The Action Plan needs to take account of the topics that apply to all Facilitators.

In addition, an Action Plan for the Trainer Category should include plans for promotional activities that target relevant students at educational institutions and examples of how FluoroCycle publications can be used.

The Action Plan for an educational institution should:

• name the relevant courses offered
• describe how information related to FluoroCycle is incorporated
• state how often the courses are offered, and
• estimate the number of students per course.

Copies of course material or information from a prospectus could be attached to the Action Plan.

For a business or organisation, the Action Plan should provide the number of relevant employees expected to undergo the sort of training described above, what courses they will attend and the name of the educational institution/s providing the training.

Other activities can be included in the Action Plan, particularly if they strengthen the training relevant to FluoroCycle. For example, a business may consider it appropriate to train a trainer through a higher level, relevant course and this could be included in the Action Plan.

Audit Requirements

There are audit requirements that apply to all Facilitators.

For the purposes of an audit, an educational institution would need to demonstrate that courses described in the Action Plan were conducted and make copies of course material available. Documents that provide information about the numbers of students attending the courses should also be made available for the audit.

Businesses or organisations would need to provide documents that prove relevant staff received such training, eg receipts for attendance at courses or certificates from the educational institutions.

Definition

‘Advocates’ businesses and organisations that actively promote the scheme to other businesses and organisations.

Examples of Advocates are: architects, lighting designers, consultants on the environmental aspects of building design and management; clubs, committees or associations that promote FluoroCycle to their members and to businesses and organisations in the local community; and non-government organisations that promote FluoroCycle through their publications, websites and other media outlets.

Additional Commitments

Signatories in this Category need to meet the commitments that apply to all Facilitators.

Advocates need to meet the commitments that apply to all Facilitators, as set out in Section 9 of FluoroCycle Signatory Manual. The additional commitment for Advocates is to promote the scheme actively to other businesses and organisations.

Action Plan

The Action Plan needs to take account of the topics that apply to all Facilitators.

For Advocates, the Action Plan should focus on strategies for promoting FluoroCycle actively to clients, members, organisations and/or businesses within their networks or supply chain that are potential Signatories to the scheme, as both Facilitators and Commercial Users.

Examples of strategies are:

• promoting FluoroCycle through vehicles such as email newsletters, magazine editorials, banners, packaging, direct-mail, conferences, seminars, in-house training, annual reports, websites and social media, and
• encouraging businesses and organisations that generate waste lamps to become Commercial Users.

Refer to Section 9.2 of the FluoroCycle Signatory Manual for advice to all Facilitators on the Action Plan. For Advocates, the Action Plan should focus on strategies for promoting FluoroCycle actively to clients, members, businesses and/or organisations that are potential Signatories to the scheme.

Audit Requirements

There are audit requirements that apply to all Facilitators.

Refer to Section 9.6 of the FluoroCycle Signatory Manual for advice that applies to all Facilitators in relation to the Action Plan. The Action Plans for Advocates will vary considerably, given the broad scope of this Category. Advocates would need to provide evidence that they had been actively promoting FluoroCycle by providing copies of relevant materials such as fact sheets, website content, media coverage, annual reports and documented decisions.