Tuesday, October 5, 2010

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
Larkin Hoffman

1 comment:

  1. Thank you so much for sharing it.
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