U.S. DOT Regulation of Fluorescent Lamp Transportation (Part 1 of 3)

Federal transportation requirements promulgated by the U.S. Department of Transportation (DOT) provide packaging standards for fluorescent lamps (referred to in the regulations as “mercury vapor tubes”). Those regulations require that shipments of lamps be contained in packaging that prevents the escape of mercury.

In practice, however, those DOT packaging requirements will rarely, if ever, apply to packages of used mercury-containing lamps. Based on the rules and the mercury content of used lamps, the DOT standards only apply to packages containing more than 250 typical CFLs or low mercury fluorescent lamps or 100–200 other types of fluorescent lamps. Most used lamps are transported in far smaller containers. Yet even a single broken lamp can emit mercury vapor beyond permissible exposure levels. For more information, read the blog posts: Potential Exposure of Mercury Due to Broken Fluorescent Lamps in the Workplace, Permissible Exposure Limits—Are You Being Exposed to Unsafe Levels of Mercury Vapor, and Part 2 in this series on U.S. DOT Regulation.

Peder Larson
Attorney
Larkin Hoffman

CFL Recycling Information Supplied by Manufacturers: Philips, TESCO and GE

Although consumer awareness of the health and safety risks associated with mercury vapor emitted from broken CFLs has increased, the Environmental Protection Agency (EPA) estimates recycling rates of possibly less than two percent. If not properly recycled, the emitted mercury vapor poses a significant threat to not only the health of consumers, but also to the health of our environment. Mercury-containing products, such as CFLs, need to be properly recycled to truly be considered truly green products. Yet according to a study conducted by Toxic Waste Facts (1), only one of the three top light bulb manufacturers displays significant recycling information on their packaging:

Philips: The packaging of a CFL from Philips contains no specific information on disposal or risks associated with mercury contained in the bulbs. The information on the packaging details the life expectancy, wattage, a recycling symbol and an A rating.

TESCO: The packaging of a CFL from TESCO includes handling and fitting safety instructions, as well as a list of states that ban CFL household waste disposal, with more information available in store or via the website recycle-more.co.uk. Packages also contain the A rating and the crossed-out wheeled bin symbol. However, they do not offer any instructions regarding breakage clean-up or health risks.

General Electric: The packaging of a CFL from General Electric contains no information on disposal, recycling or any risks associated with the bulb. The information on the packaging details the life expectancy, wattage and an A rating.

It is important that consumers are made aware of the risks associated with broken CFLs and other mercury-containing products, and manufacturers should change packaging to better detail risks, usage and disposal methods.

1. An Assessment of Benefits and Potential Health and Environmental Hazards from Compact Fluorescent Lights. Toxic Waste Facts; available at http://toxicwastefacts.com/toxicwaste/an-assessment-of-benefits-and-potential-health-and-environmental-hazards-from-compact-fluorescent-lights

Brad Buscher
Chairman and CEO
VaporLok Products LLC

The End of an Era: Incandescent Light Bulb Factories Closing

The 2007 energy conservation measure passed by Congress set standards to essentially ban incandescent lights by 2013, requiring households to make the switch to more energy efficient lights. According to recent news, the last major General Electric factory in the United States is closing this month, marking an end to a fixture that has been lighting homes since the 1870s. With incandescents out, fluorescent lamps and CFLs continue to grow in popularity, providing energy and greenhouse gas emission savings.

Many consumers are worried about the mercury levels contained in fluorescent lights and the potential health, safety and environmental issues caused by mercury vapor emitted from broken lamps. However, with proper storage, transportation and disposal, fluorescent lights can be a green and safe lighting solution. According to a recent study by the University of Minnesota, only one package design out of the five tested is effective in containing mercury vapor beyond permissible exposure levels. Find out more about this configuration, which includes a vapor resistant and zip seal bag.

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

How Do Incandescent Lights Result in More Mercury Pollution Than Fluorescents?

In addition to carefully recycling products that contain mercury, we can reduce mercury pollution by reducing our energy consumption. Because mercury is a byproduct of burning coal, coal-fired power plants are one of the largest sources of mercury pollution. Because incandescent bulbs use several times more electricity over their lifetimes, they require far more power generation and, ultimately, result in more mercury emission than fluorescents. With the coming “maximal achievable technology” clean air standards, it is fully expected that mercury emissions will have to be severely reduced in order to stop this proliferation. Fluorescent lights are four to six times more efficient than incandescent lamps, significantly reducing the power demand from local utilities. The reduced demand for electricity in turn reduces both greenhouse gas and mercury emissions.

Brad Buscher
Chairman and CEO
VaporLok Products LLC

Part II: Analyzing the Environmental Impact of Different Waste Management Methods: Incineration and Crushing

Incineration is a waste treatment technology that involves the combustion of organic materials or substances.(1) Also known as "thermal treatment", incineration of waste materials converts the waste into incinerator bottom ash, flue gases, particulates and heat. In the past, many municipal waste combustors did not have special controls to reduce mercury emissions. The incineration of mercury-containing lamps, therefore, released up to 90% of the mercury to the air.(2) By the end of 2000, most incinerators were equipped with more stringent EPA-mandated mercury controls, dramatically reducing the amount of mercury that incinerators release from any mercury-containing product. According to the EPA, mercury emissions from municipal solid waste combustors declined from 42 tons of mercury in 1990 to 2 tons in 2001.(3) However, this amount of mercury release can be further reduced by recycling used fluorescent lamps.

Crushing lamps prior to transportation reduces the volume of waste, while utilizing mercury filters and other technology to limit mercury emissions. Crushing can significantly reduce transportation and storage costs for generators. However, the efficacy of lamp crushers is debated, and the practice has been banned by many state pollution control agencies.

Other recycling options, such as the services offered by Mercury Waste Solutions, should be applied to mercury-containing lamps to safely and effectively remove the mercury vapor. Their patented continuous flow retort oven has been designed to process up to 1,000 lbs per hour of flowable mercury-contaminated powders and other solids—effectively recovering mercury from contaminated products and reducing mercury pollution.

1. Knox, Andrew (February 2005). "An Overview of Incineration and EFW Technology as Applied to the Management of Municipal Solid Waste (MSW)" (PDF). University of Western Ontario.
2. “Lamp Industry Product Stewardship: A Record of Accomplishment,” NEMA Lamp Section, October 2004.
3. “Emissions from Large MWC Units at MACT Compliance,” Memorandum from Walt Stevenson, Combustion Group, UAQPS, EPA, June 20, 2002

Brad Buscher
Chairman and CEO
VaporLok Products LLC