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
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