Fluorescent Lamp Transportation Regulation

The U.S. Department of Transportation (DOT) provides packaging standards for the transportation of 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.

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.

One broken 48-inch fluorescent lamp in a small room or vehicle can release enough mercury vapor to exceed the Federal OSHA PEL. This 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.

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 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