Safe Fluorescent Lamp Packaging: Protecting Against Harmful Mercury Vapor

On average, CFLs and fluorescent lamps contain about 4 milligrams of mercury. Mercury is dangerous and can be a threat to our safety and health when exposed to it. It is important for consumers to take the necessary precautions when handling, storing or transporting used or broken lamps to protect themselves against any potential harm from released mercury vapor.

According to a study conducted by the University of Minnesota, there is only one proven packaging configuration that effectively contains mercury vapor from broken fluorescent lamps below permissible workplace exposure levels, as defined by state and federal authorities. This configuration consists of an outer cardboard layer, a bag to contain the mercury vapor and an inner layer of cardboard to prevent broken glass from puncturing the bag.


Brad Buscher
Chairman and CEO
VaporLok Products LLC

Earthmate Compact Fluorescent Lights

Waste Management now offers Earthmate compact fluorescent lightbulbs (CFLs) in recyclable packaging that also doubles as a CFL recycling kit. This new product includes Earthmate CFLs packaged in a resealable box lined with the VaporLok™ Products, LLC technology , which is designed to reduce the risk of airborne mercury exposure and environmental contamination from lamps broken during storage and shipping. The box is suitable for storing used CFLs and is approved for shipping by the United States Postal Service. Consumers return their used CFLs in the included postage paid shipping container to the Waste Management lamp recycling center simply by mailing them from home or any of over 34,000 US Post Offices. Learn more here.

Brad Buscher
Chairman and CEO
VaporLok Products LLC

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

In addition to the exceptions listed in the previous two posts, DOT regulations are, in general, relatively lax. They allow transport of used lamps in the original manufacturer’s packaging for a lamp, even though that packaging is almost certainly not designed to prevent the loss of mercury vapors. The DOT standard allows lamps (as long as each lamp contains less than five grams of mercury) to be transported in the “manufacturer’s original packaging” as long as the package contains less than 30 grams of total mercury.

Based on the mercury content assumptions described above, the DOT standard allows a lamp generator to transport any reasonable quantity (up to 1000 typical CFLs or low-mercury lamps) in the manufacturer’s original packaging. Read more about the need for more stringent packaging regulations in the blog post: Layers of Protection: Packaging Used Fluorescent Lamps.

Finally, most generators of used lamps are unlikely to comply with one specific requirement of DOT regulations. A shipper of used lamps must provide a “shipping paper” that indicates the quantity of mercury contained in the package. 49 C.F.R. § 173.164(c)((3)(iii). This requirement does not exist under federal and state universal waste rules that specifically exempt lamp generators and transporters from this type of record keeping in hopes of encouraging lamp recycling. While lamp recycling should be encouraged, it is only an effective method of preventing mercury vapor exposure and pollution when a proven package is utilized for storage and transportation of used lamps. For additional information on the U.S. DOT regulation of fluorescent lamp transportation, read Part 1 and Part 2 in this series.

Peder Larson
Attorney
Larkin Hoffman

U.S. DOT Regulation of Fluorescent Lamp Transportation (Part 2 of 3)

Federal requirements for transporting “hazardous materials” are contained in Title 49 of the U.S. DOT Code of Federal Regulations. Specific packaging standards for shipment of articles containing mercury, including “mercury vapor tubes,” are contained in 49 C.F.R. § 173.164. According to 49 C.F.R. § 173.164(b), the regulations do not apply to packages containing less than 1 gram of mercury: “Manufactured articles or apparatuses, each containing not more than 100 mg (0.0035 ounce) of mercury and packaged so that the quantity of mercury per package does not exceed 1 g (0.035 ounce) are not subject to the requirements of this subchapter.”

According to the EPA, an average CFL contains 4 milligrams of mercury. (Source: USEPA Energy Star July 2008) The Northeast Waste Management Officials’ Organization states that about half of the fluorescent lamps manufactured by the major lighting manufacturers and sold in the United States contain 5 to 10 milligrams of mercury, while a quarter contain 10 to 50. Lamps referred to as “low-mercury” generally contain 3.5 to 4 milligrams of mercury.

Assuming the average CFL or low-mercury lamp contains 4 milligrams of mercury per lamp, packages containing less than 250 CFLs or low-mercury lamps are exempt because the package will contain less than 1 gram of mercury (250 lamps at 4 milligrams/lamp or .004 grams/lamp contain 1 gram of mercury). Similarly, packages containing less than about 100–200 other types of lamps will also be exempt. However, even small quantities of mercury vapor can cause health and safety issues in addition to attributing to environmental problems. Read more about the risks associated with mercury and Part 1 and Part 3 in this series for additional information on the U.S. DOT regulation of fluorescent lamp transportation.

Peder Larson
Attorney
Larkin Hoffman