The need for more stringent packaging regulations

The Environmental Protection Agency (EPA) is one of the organizations challenged with the task of simultaneously encouraging the use of energy-efficient fluorescent lamps, while also protecting the environment and people from harmful mercury vapor. The EPA permits common carrier shipment to recycling facilities, and the federal Universal Waste Rule requires packaging to be compatible with the contents of lamps, structurally sound and adequate to prevent breakage—but this rule does not specifically address mercury vapor release.

In 2005, a provision was added that requires packaging for mercury-containing products to be "reasonably designed to prevent the escape of mercury into the environment by volatilization or any other means." However, fluorescent lamps were excluded from this rule.

This may change. More recent federal regulations applicable to other mercury wastes (like switches, thermostats and thermometers) require management in packaging designed to prevent the loss of mercury vapor. Plus, a new law in the State of Washington requires that many lamps be managed in containers that prevent the loss of mercury vapors, and the State of Wisconsin recently considered language that would require mercury vapor containment for household lamps. Read more about new state legislation in my next post.

Peder Larson
Attorney
Larkin Hoffman

Layers of protection: Packaging used fluorescent lamps

Many customers repurpose the packages fluorescent lamps are sold in—to store used lamps and eventually transport these lamps for disposal or recycling. However, the recent University of Minnesota study I conducted with my team of researchers found that these packages do not contain mercury vapor below permissible workplace exposure levels, as defined by state and federal authorities.

We also tested packaging configurations that enhance this single cardboard layer with a plastic bag, as well as packages that add a second layer of cardboard to the design—with the bags positioned between the two cardboard layers. The latter group contained two package varieties: a double-box with a thicker, tape-sealed plastic bag, and a double box with a foil-plastic laminate bag containing a zip closure. Both of these packages performed better than the other configurations. Yet, only the double box with the foil-plastic laminate bag delivered the necessary levels of protection.

This study indicates that all three layers of the last packaging configuration are critical in the effective containment of mercury vapor. The first cardboard layer provides structure to the configuration and protects contents from outside elements. The bag—which should feature a suitable material and tight seal—contains the mercury vapor, and the inner layer of cardboard prevents broken glass from puncturing the bag and rendering it ineffective.

Lisa Brosseau, ScD, CIH
Associate Professor
University of Minnesota School of Public Health, Division of Environmental Health Sciences

Study documents mercury vapor emission levels and need for safer packaging, storage and transportation of used fluorescent lamps

Results of a recent study conducted by my research team at the University of Minnesota School of Public Health, Division of Environmental Health Sciences suggest that most containers used for storage and transportation of used fluorescent lamps to recycling centers do not provide necessary levels of protection against mercury vapors emitted from broken lamps.

The study, published in the March 2009 issue of the Journal of the Air & Waste Management Association, found that of the five packages tested in the study, just one configuration—consisting of a zip-closure plastic-foil laminate bag layered between two cardboard boxes—minimized exposure levels below acceptable occupational limits, as defined by state and federal regulations and guidelines.

Based on our measurements of mercury vapor from single broken fluorescent bulbs, we determined the need for additional research to quantify emissions from various types of packaging. The results indicate that emissions from packages not designed to contain mercury vapor represent a real health and safety concern.

Lisa Brosseau, ScD, CIH
Associate Professor
University of Minnesota School of Public Health, Division of Environmental Health Sciences

Preventing health and safety hazards from fluorescent lamps

As rising energy costs and environmental concerns become increasingly important factors in consumers’ and businesses’ purchasing selections, fluorescent lamps have increased in popularity. However, fluorescent lamps are fragile and, upon breaking, these lamps release mercury vapor that can be detrimental to handlers' health—from those involved with handling new bulbs to people involved with storing, packaging and shipping used lamps.

Mercury vapor, which can be absorbed through the skin or inhaled, can cause neurological damage to adults, children and fetuses. (1) It is considered a persistent bioaccumulative toxic chemical, since it doesn't degrade in the environment. (2) When mercury vapor gets into water, it is converted to methyl mercury and can enter the food chain through fish. Methyl mercury causes damage to the central nervous system and it is also thought to be a possible human carcinogen. (3)

While a variety of containers are marketed for transportation of fluorescent lamps, many don't provide sufficient protection against mercury vapor emitted from broken lamps. Using a proven packaging design is vital to ensuring the safety of people who handle these lamps, as well as maintaining their green benefits.

1. Mercury Fact Sheet; Agency for Toxic Substances and Disease Registry, 1999; available at http://www.atsdr.cdc.gov/tfacts46.pdf (accessed October 1, 2007).
2. Persistent Bioaccumulative Toxic (PBT) Chemicals; Final Rule. Fed Regist. 1999, 64, 58666-58753.
3. Mercury Compounds Hazard Summary, 2000. Technology Transfer Network Air Toxics web site; U.S. Environmental Protection Agency; available at http://www.epa.gov/ttn/atw/hlthef/mercury.html (accessed November 20, 2007).

Brad Buscher
Chairman and CEO
VaporLok Products LLC

What is mercury and what are the risks?

Mercury—also know as quicksilver—is a naturally occurring element that does not break down. It is found in very small amounts in oceans, rocks, and soil. Mercury becomes airborne when rocks break down, volcanoes erupt and the soil decomposes. It then circulates and is redistributed throughout the environment.

Mercury metal has many uses. Because of its high density, it is used in barometers and manometers. Due to its high rate of thermal expansion, which is fairly constant over a wide temperature range, mercury is commonly used in thermometers and thermostats. Mercury is used as an electrical contact for switches, and it conducts the charge in fluorescent lamps. Plus, mercury-vapor lamps—which emit light rich in ultraviolet radiation—are used for street lighting, in water treatment plants as a disinfectant, and in tanning beds.

Although mercury is one of the most useful heavy metals found in our daily lives, it is also one of the most deadly. When carelessly handled or improperly disposed of, mercury gets into drinking water, lakes, rivers and streams, posing a critical threat to human health, as well as the environment. Recent studies have linked mercury exposure to increased risk of heart attack in men, to mental retardation and neurological disorders in children, and dangerous levels of mercury in the blood of women of childbearing age.

If not properly recycled, mercury is not only a threat to our quality of life, but it can also be a significant threat to the overall health of your business. Local and state environmental regulations and EPA enforcement of the Resource Conservation and Recovery Act (RCRA) and the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA), regulate the generation, treatment, storage, handling, clean-up, transportation and disposal of hazardous wastes, including products which contain mercury. Additionally, we must all take the initiative to properly recycle mercury-containing products.

Brad Buscher
Chairman and CEO
VaporLok Products LLC

Introducing our new VaporLok Products blog

Hello and welcome to the new VaporLok Products blog. Here, you’ll find the latest health, safety and environmental news on overcoming the dangers of handling products that contain mercury—including new studies, legislation and solutions.

As the former owner of Lamptracker®, the nation’s largest recycler of fluorescent lamps (now owned by Waste Management), I have studied the issues of mercury vapor hazards—from used fluorescent lamps and other mercury-containing products—for many years. I am currently the founder and president of VaporLok Products, LLC, which I formed to address this problem.

I will be joined on this blog by fellow posters, including: Peder Larson, an attorney who has specialized in environmental legislation and a former Minnesota Pollution Control Agency (MPCA) Commissioner, and Dr. Lisa Brosseau, an associate professor at the University of Minnesota, who has conducted research and published in the areas of respiratory protection, aerosol exposures, hazardous materials and safety interventions in small business.

For the latest information on this important topic, bookmark this page or add our RSS feed. We welcome your feedback on future posts, as well as suggestions for topics that you’d like to see covered in the future. Stay tuned!

Brad Buscher
Chairman and CEO
VaporLok Products LLC