Origins of the Phrase “Mad As a Hatter”

Mercury has long been known to be toxic. The phrase "mad as a hatter" refers to the 19th-century occupational disease that resulted from prolonged contact with the mercury used in the manufacture of felt hats. Along with felt hats, mercury has been taken out of many manufacturing processes and products—as the dangers of mercury exposure become more well known.

Most mercury pesticides have been withdrawn from the U.S. market, and many countries banned ocean dumping of mercury and other pollutants in 1972. Production of mercury-containing interior and exterior paints in the United States was phased out in 1991. Mercury, which has been used in medicines for hundreds of years, continues to be used in various folk remedies that can cause mercury exposures. The use of mercury in dental amalgam for tooth fillings has stirred escalating controversy in recent years. Most other medical uses have been banned or are being phased out.

Despite these changes, some workers today, especially laboratory technicians, nurses, and machine operators, continue to be exposed to mercury on the job. Elemental mercury (the silver liquid familiar in thermometers) is a common occupational source of exposure. Fragile fluorescent lamps and compact fluorescent lamps if broken represent another mercury exposure risk as they are handled by manufacturers, transporters, distributors, retailers, consumers and installers, as well as recycling or waste handlers. There are currently no universally enforced packaging standards designed to protect these people. There now exists a proven packaging design with a vapor resistant and zip seal bag that should be mandated to protect people who work with or near fluorescent lamps, as well as for protecting the surrounding environment.

Brad Buscher
Chairman and CEO
VaporLok Products LLC

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

Why is it Important to Recycle Used Fluorescent Lamps?

According to EPA estimates, only 20% to 25% of used fluorescent lamps are recycled, These lamps are commonly sent to a recycler in bulk or in pre-paid shipping recycling boxes. The 75% to 80% of fluorescent lamps that are not recycled usually end up in dumpsters or trash containers and, ultimately, in landfills. One study indicates dumpsters that contain broken fluorescent lamps “strongly and persistently” emit mercury.(1) Another study on mercury release from broken fluorescent lamps found that between 17% to 40% of the mercury in broken low-mercury fluorescent lamps is released to the air during the two-week period after breakage.(2) Of this mercury, one-third of the release takes place during the first eight hours following breakage, potentially exposing personnel in the vicinity to unsafe levels of mercury vapor. Using this estimated release rate and an estimated 620 million lamps discarded annually in the United States, broken used fluorescent lamps release approximately two to four tons of mercury each year into the environment.

Used fluorescent lamps need to be properly handled during shipping and recycling. Safe packaging reduces the threat of mercury vapor emitted from broken lamps.

Brad Buscher
Chairman and CEO
VaporLok Products LLC

What Mercury?

While the amount of mercury used in an individual fluorescent bulb has decreased over the past years, one broken 4-foot fluorescent lamp in a small room or vehicle can release enough mercury vapor to exceed the OSHA mercury exposure 8-hour limit—posing a significant occupational health risk. Plus, mercury vapor can be emitted for weeks after a single bulb is broken.

In their lifetime, fragile fluorescent lamps are handled by manufacturers, transporters, distributors, retailers, consumers and installers, as well as recycling or waste handlers. Although the lamps could break anywhere down this line and expose workers and the environment to hazardous mercury vapors, there are no universally enforced packaging standards designed to protect these people.

While some steps have been taken to encourage safe recycling and disposal of fluorescent lamps, this fact remains: although a variety of containers are marketed for transportation of fluorescent lamps, many don't provide necessary levels of protection against mercury vapor in the occurrence of breakage. Using a proven packaging design with a vapor resistant lining is vital to ensuring the safety of persons who work with or near fluorescent bulbs, as well as for protecting the surrounding environment, especially as fluorescent lighting continues to grow in popularity and practicality. Currently, only one package design, which includes a vapor resistant and zip seal bag, has proven effective in containing mercury vapor.

Brad Buscher
Chairman and CEO
VaporLok Products LLC

How Can You Easily Recycle Used Fluorescent Bulbs?

Products containing mercury, including fluorescent lamps, need to be handled and recycled properly to effectively contain and prevent mercury vapor from releasing into the environment. Mercury-containing waste that isn't properly recycled poses a serious environmental and health concern and can be regulated more stringently.

Fluorescent lamps can easily be recycled or disposed if burned out. Available recycling methods include:

• Use Mercury VaporLok® Bags for safely accumulating spent fluorescent lamps for recycling.
• Waste Management LampTracker®: The prepaid program includes recycling containers, shipping both ways via UPS or FedEx ground, recycling of the wastes and complete online documentation of every container ordered and recycled.
• State Collection Sites: Check with you local and/or state regulators and use Earth911.com to find a drop-off near you. Also note that many National retailers accept spent lamps for recycling.

Brad Buscher
Chairman and CEO
VaporLok Products LLC

How Many Fluorescent Lamps are Recycled?

According to the EPA, recycling rates of fluorescent lamps are estimated at only 20 to 25 percent, leaving the majority to be placed in dumpsters and eventually end up in landfills—where they may emit hazardous mercury vapor into the environment. The consumer recycling rate has been estimated to be even lower—possibly at less than 2 percent.

Mercury-containing waste that isn’t properly recycled poses a serious environmental and health concern. However, taking waste to a recycling center may not always be the most efficient solution. Consumers can use a recycling box to ship bulbs instead. If consumers choose this option, it is important to select a packaging configuration that effectively contains mercury vapor. A recent study conducted by the University of Minnesota tested the effectiveness of various packages in containing mercury vapor emitted from broken fluorescent lamps. The study found that many packages do not sufficiently contain mercury vapor, such as single-layer cardboard boxes (representing the original manufacturer’s box or container) as well as single layer boxes with a sealed plastic bag. Just one configuration—consisting of a zip-closure plastic-foil laminate bag layered between two cardboard boxes—minimized exposure levels below acceptable occupational limits, as defined by state and federal regulations and guidelines. Find out more about this proven packaging method at: http://vaporlok.blogspot.com/2010/05/layers-of-protection-packaging-used.html. If a bulb breaks, consumers can learn more about clean-up procedures here: http://www.epa.gov/cfl/cflcleanup-detailed.html

Brad Buscher
Chairman and CEO
VaporLok Products LLC

Understanding Mercury Waste Regulations

Mercury waste regulations are important to ensure a healthy and safe environment. Local and state environmental regulations and EPA enforcement of the Resource Conservation and Recovery Act (RCRA) and the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA), regulate the generation, treatment, storage, handling, clean-up, transportation and disposal of hazardous wastes, including products which contain mercury. Mercury-containing lamps, batteries, and medical and electrical equipment and devices are regulated as Universal Wastes. Find out more at these United States Environmental Protection Agency Sites:

Federal Mercury Regulations

State Mercury Legislation and Regulations

State Universal Waste Regulations

Federal Universal Waste Regulations

State Mercury Medical & Dental Waste Programs

1997 Mercury Report to Congress

Brad Buscher
Chairman and CEO
VaporLok Products LLC

Banning Elemental Mercury

A new government regulation that goes into effect in 2013 effectively bans the exportation of elemental mercury—unless it has a legitimate use. The Mercury Export Ban Act of 2008, introduced by Barack Obama when he was an Illinois senator, was signed on October 14, 2008. The act will prohibit the transfer of elemental mercury by federal agencies, ban U.S. export of elemental mercury by 2013, and requires the Department of Energy to designate and manage an elemental mercury long-term disposal facility.

The United States is currently one of the world’s leading exporters of elemental mercury, and large amounts of mercury-containing waste have been shipped over the border to Canada and other countries. The Mercury Export Ban Act of 2008 will help prevent other industries and countries that do not have the same protections as we do from receiving the mercury and letting it proliferate right back into the system and the environment.

Brad Buscher
Chairman and CEO
VaporLok Products LLC

Packaging Used or Broken Fluorescent Bulbs

How do you effectively package used or broken fluorescent bulbs to prevent hazardous mercury vapor from emitting into your home or office? Is there a right or wrong way? Before you think about simply throwing that old bulb in the trash, read this post!

According to research studies, three layers of packaging are needed to sufficiently contain mercury vapor found in fluorescent lamps. The first is a cardboard layer, which provides structure to the configuration and protects contents from outside elements. The second layer consists of a bag—which should feature a suitable material and tight seal—which is used to contain the mercury vapor. The last, inner layer is also cardboard, which prevents broken glass from puncturing the bag and rendering it ineffective.

Next time you have a broken or burned out fluorescent bulb, use the above method to ensure you aren’t harming yourself or others with mercury vapor.

Brad Buscher
Chairman and CEO
VaporLok Products LLC

Consequences of Mercury Vapor Pollution and Exposure

Despite increasing awareness of the safety and environmental hazards of mercury vapor emitted from used fluorescent lamps, most are still not recycled. In fact, the EPA estimates the recycling rate of fluorescent lamps at only 20 to 25 percent, with the rest ending up in dumpsters and, eventually, in landfills—where they may continue to emit hazardous mercury vapor into the environment.

Mercury does not break down over time. It can get into drinking water, lakes, rivers and streams, posing a critical threat to human health, as well as the environment. Mercury is a known neurotoxin and it can bioaccumulate as it goes up the food chain. Recent studies have linked mercury exposure to increased risk of heart attack in men, mental retardation and neurological disorders in children, and to dangerous levels of mercury in the blood of women of childbearing age.

Though fluorescent lamps are a valuable resource for large facilities and homes, they must be disposed of properly to provide a truly environmentally conscious solution. Some states are taking steps to regulate mercury-containing wastes, but businesses and consumers alike can act now to protect the environment from these hazards. Taking the initiative to ensure that all used lamps are properly stored, transported and recycled can protect against potential hazards while taking advantage of the benefits fluorescent lamps provide.

Brad Buscher
Chairman and CEO
VaporLok Products LLC

Recycling Fluorescent Lamps

The EPA estimates recycling rates of fluorescent lamps at only 20 to 25 percent, leaving the majority to be placed in dumpsters and eventually end up in landfills—where they may emit hazardous mercury vapor into the environment. The consumer recycling rate has been estimated to be even lower—possibly at less than 2 percent.

According to one study, mercury air emissions could be lowered by 30 percent if recycling rates are increased to 50 percent and improvements in handling are made to lower losses from breakage. (1) Consumers can choose to recycle used lamps in several different ways. Lamps can be sent to a recycling facility via truck, UPS or FedEx® in bulk or through pre-paid shipping recycling box programs—which provide simple online ordering, tracking and compliance documentation for the proper management of mercury-containing items and other types of Universal Waste.

Mercury-containing waste that isn’t properly recycled poses a serious environmental and health concern. Safe recycling facilities exist, but should be encouraged by new rules and regulations. New legislation should also ensure that used fluorescent lamps are packaged in configurations proven to effectively contain mercury vapor emitted from broken lamps.

Reference:
1. 3. Cain, A.; Disch, S.; Twaroski, C.; Reindl, J.; Case, C.R. Substance Flow Analysis of Mercury Intentionally Used in Products in the United States; J. Ind. Ecol. 2007, 11, 61-75.

Brad Buscher
Chairman and CEO
VaporLok Products LLC

Mercury: Exposure Through the Food Chain

Large amounts of mercury become airborne when coal, oil, wood, or natural gas are burned as fuel or when mercury-containing garbage, including improperly discarded fluorescent lamps, is incinerated. This mercury can fall to the ground with rain and snow, landing on soil or in bodies of water, causing contamination. Lakes and rivers are also contaminated when there is a direct discharge of mercury-laden industrial and municipal waste into these waterbodies.

Elemental mercury and mercury salts, although fairly inert when deposited on the bottom of waterways, are converted into organic mercury, typically methylmercury, by microorganisms. Methylmercury then enters the food chain, where it is biomagnified up to 100,000 times in predacious fish. Eagles, turtles, mink, otters and other fish-eating creatures may have mercury introduced into their diets, which can cause early death, weight loss, and problems with their ability to reproduce.

Once mercury accumulates in the tissue of fish and other organisms, it may ultimately reach the dinner table, as most common human exposure to methylmercury is through consumption of contaminated fish or animals that eat fish. This mercury vapor, which can be introduced to human systems through consumption or absorbed through the skin or inhaled, can cause neurological damage to adults, children and fetuses. Read more about potential mercury risks.

Brad Buscher
Chairman and CEO
VaporLok Products LLC

Why is it Important to Recycle Used Fluorescent Lamps?

According to EPA estimates, only 20% to 25% of used fluorescent lamps are recycled, These lamps are commonly sent to a recycler in bulk or in pre-paid shipping recycling boxes. The 75% to 80% of fluorescent lamps that are not recycled usually end up in dumpsters or trash containers and, ultimately, in landfills. One study indicates dumpsters that contain broken fluorescent lamps “strongly and persistently” emit mercury.(1) Another study on mercury release from broken fluorescent lamps found that between 17% to 40% of the mercury in broken low-mercury fluorescent lamps is released to the air during the two-week period after breakage.(2) Of this mercury, one-third of the release takes place during the first eight hours following breakage, potentially exposing personnel in the vicinity to unsafe levels of mercury vapor. Using this estimated release rate and an estimated 620 million lamps discarded annually in the United States, broken used fluorescent lamps release approximately two to four tons of mercury each year into the environment.

Used fluorescent lamps need to be properly handled during shipping and recycling. Safe packaging reduces the threat of mercury vapor emitted from broken lamps.

REFERENCES
1. Lindberg, S.E.; Owens, J. PaMSWaD (Pathways of Mercury in Solid Waste Disposal); Lockheed Martin Energy Research Corporation (LMER). 1999, 6.
2. Aucott, Michael, Michael McLinden and Michael Winka. “Release of Mercury from Broken Fluorescent Bulbs.” Journal of the Air & Waste Management Association, 53 (2003), 143-51.

Brad Buscher
Chairman and CEO
VaporLok Products LLC

Future Mercury Waste Regulations: The First Step to a Brighter Future

The U.S. Environmental Protection Agency (EPA) promotes recycling of fluorescent lamps by allowing common carrier shipment to recycling facilities. 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.(1)

However, some states are beginning to address the dangers of unsafe packaging and transportation of used fluorescent lamps and mercury containing devices. On March 19, 2010, Washington signed Senate Bill 5543, requiring that lights and other mercury-containing devices are packaged and shipped in material that will minimize the release of mercury into the environment. The law also states that they should include mercury vapor barrier packaging if transported by the United States postal service or a common carrie. This new legislation is set to be the precursor of future state and federal legislation as awareness of mercury vapor dangers increases. Find out more about these types of waste regulations and programs at these United States Environmental Protection Agency Sites.

REFERENCE
1. Standards for Universal Waste Management: Applicability—Lamps. CFR, Part 273.5, Title 40, 2007.

Brad Buscher
Chairman and CEO
VaporLok Products LLC

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

What is the Lighting Industry Doing to Reduce Mercury Use?

The lighting industry has slowly reduced the amount of mercury used in fluorescent lamps over the past 20 years and, according to NEMA surveys, mercury use has been reduced dramatically over the last 7 years.(1) Since 1990, NEMA has conducted a number of surveys, which indicate the total amount of mercury contained in all lamps in the U.S. declined to 17 tons in 1994, 13 tons in 1999, 9 tons in 2001 and 7 tons in 2003—nearly a 90% reduction from previous years.(2) According to this trend, researchers believe this number will continue to decline in future years.

The lighting industry accomplished these dramatic reductions by collectively investing millions of dollars in new lamp manufacturing equipment and processes. However, fluorescent lamps must still be handled, stored and transported to recycling facilities with care. To ensure the safety of people who handle these lamps and the environment, there is a need for better regulations for packaging that controls the release of mercury vapor emitted from broken lamps.

1.“Fluorescent and other Mercury-Containing Lamps and the Environment,” NEMA, March 2005.
2.“Lamp Industry Product Stewardship: A Record of Accomplishment,” NEMA Lamp Section, October 2004.

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

History of Universal Waste Containers and the Development of Packages Designed to Contain Mercury Vapor

Universal waste containers that could be transported by common carrier were first introduced in 1998. The first containers were primarily used to ship fluorescent lighting. Initially, these containers were simple corrugated boxes, with some including a plastic bag inside the box. Since the contents were made of glass, they were designed primarily to contain the contents within the shipping container. However, since mercury begins to vaporize at 70 degrees F, packaging improvements were needed to address the issue of potential mercury vapor release in the event of breakage during accumulation and transport. Read more about packaging designed to contain mercury vapor.

Brad Buscher
Chairman and CEO
VaporLok Products LLC

Additional State Regulations

While the federal government doesn't require recycling of all fluorescent lighting, several states have addressed this health issue with their own, more specific regulations regarding fluorescent lamp disposal. Minnesota, Massachusetts, California and Vermont are among states that prohibit disposal of all mercury-product waste in landfills. New York has a similar ban, with an exemption for households and businesses with 100 or less employees disposing of 15 or less non-hazardous waste lamps per month. Many other states prohibit non-household generators from disposing of any mercury containing fluorescent lamps in solid waste landfills regardless of TCLP test results, including Connecticut, Maine, New Hampshire, Florida and Rhode Island.

Peder Larson
Attorney
Larkin Hoffman

Permissible Exposure Limits—Are You Being Exposed to Unsafe Levels of Mercury Vapor?

The Federal Occupational Health and Safety Administration (OSHA) set a mercury permissible exposure limit (PEL) of 0.1 mg/m3 (8-hr time-weighted average [TWA]).1 Some state OSHA programs regulate a stricter mercury vapor limit of 0.05 mg/m3 (8-hr TWA). Additionally, the American Conference of Governmental Industrial Hygienists (ACGIH) recommends an a guideline of 0.025 mg/m3; this is the same value regulated by California OSHA.2

One broken 48-inch fluorescent lamp in a small room or vehicle can release enough mercury vapor to exceed the Federal OSHA PEL. Mercury vapor concentrations could exceed occupational exposure levels when working with or near broken bulbs, especially when multiple bulbs are stored or shipped in bulk to recycling facilities. Based on measurements of mercury vapor from single broken fluorescent bulbs, there is a need for additional research to quantify emissions from various types of packaging. The results indicate that emissions from packages not designed to contain mercury vapor represent a real health and safety concern to those involved in its storage, transport and disposal, as well as a legal hazard for any businesses that do not adhere to these stipulations. Recent research has shown that only one current package design which includes a vapor resistant and zip seal bag has proven effective in containing mercury vapor.

1. Occupational Health and Safety Standards: Air Contaminants. CFR, Part 1910.1000, Title 29, 2007.
2. Documentation of the Threshold Limit Values and Biological Exposure Indices, 7th ed.; National Institute for Occupational Safety and Health: Cincinnati, OH, 2001.

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