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