One Broken Bulb: The Health and Safety Risks

One broken four-foot fluorescent lamp in a small room or vehicle can release enough mercury vapor to exceed the OSHA mercury exposure eight-hour limit—posing significant health and safety risks to handlers and consumers. Plus, mercury vapor can be emitted for weeks after a single bulb is broken, continually polluting the air in consumers’ homes. When carelessly handled or improperly disposed of, mercury can get into drinking water, lakes, rivers and streams, posing a critical threat to human health, as well as the environment. Recent studies have linked mercury exposure to increased risk of heart attack in men, to mental retardation and neurological disorders in children, and dangerous levels of mercury in the blood of women of childbearing age.

Despite these health concerns, the EPA estimates that approximately 75 to 80 percent of fluorescent lamps are not recycled and are usually placed in dumpsters or trash containers, presenting a considerable risk. One study found that mercury is "strongly and persistently" emitted from dumpsters that contain broken fluorescent lamps.(1) Broken fluorescent lamps need to be properly recycled to prevent the release of mercury vapor. Learn how to clean up a broken bulb or how to safely package and recycle fluorescent lamps by reading our Layers of protection: Packaging used fluorescent lamps post.

1. Lindberg, S.E.; Owens, J. PaMSWaD (Pathways of Mercury in Solid Waste Disposal); Lockheed Martin Energy Research Corporation (LMER). 1999. 6.

Brad Buscher
Chairman and CEO
VaporLok Products LLC

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Most mercury pesticides have been withdrawn from the U.S. market, and many countries banned ocean dumping of mercury and other pollutants in 1972.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

One Broken Bulb: The Health and Safety Risks

One broken four-foot fluorescent lamp in a small room or vehicle can release enough mercury vapor to exceed the OSHA mercury exposure eight-hour limit—posing significant health and safety risks to handlers and consumers. Plus, mercury vapor can be emitted for weeks after a single bulb is broken, continually polluting the air in consumers’ homes. When carelessly handled or improperly disposed of, mercury can get into drinking water, lakes, rivers and streams, posing a critical threat to human health, as well as the environment. Recent studies have linked mercury exposure to increased risk of heart attack in men, to mental retardation and neurological disorders in children, and dangerous levels of mercury in the blood of women of childbearing age.

Despite these health concerns, the EPA estimates that approximately 75 to 80 percent of fluorescent lamps are not recycled and are usually placed in dumpsters or trash containers, presenting a considerable risk. One study found that mercury is "strongly and persistently" emitted from dumpsters that contain broken fluorescent lamps.(1) Broken fluorescent lamps need to be properly recycled to prevent the release of mercury vapor. Learn how to clean up a broken bulb or how to safely package and recycle fluorescent lamps by reading our Layers of protection: Packaging used fluorescent lamps post.

1. Lindberg, S.E.; Owens, J. PaMSWaD (Pathways of Mercury in Solid Waste Disposal); Lockheed Martin Energy Research Corporation (LMER). 1999. 6.

Brad Buscher
Chairman and CEO
VaporLok Products LLC

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

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

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

CFL Usage and What You Should Do If a CFL Breaks in Your Home

As a result of a growing green movement and new government regulations—including an Act of Congress to cease the manufacture of incandescent lamps by 2013—the use of more energy efficient lights, such as CFLs, continues to increase. Like all fluorescent lights, CFLs contain hazardous mercury vapor, which is emitted when these fragile bulbs break and causes significant health and safety issues, as well as environmental concerns.

What should you do if a CFL breaks in your home? A Maine Compact Fluorescent Lamp Breakage Study found that mercury concentration in a room can exceed permissible exposure levels, even from the breakage of a single CFL. For a clean-up guide, click here: http://www.maine.gov/dep/rwm/homeowner/cflreport/appendixe.pdf

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

Compounding Mercury Vapor Exposure

Along with the common uses of mercury vapor in fluorescent lamps and compact fluorescent lamps, mercury compounds also have many uses. Calomel (mercurous chloride, Hg2Cl2) is a standard in electrochemical measurements and in medicine as a purgative. Mercuric chloride (corrosive sublimate, HgCl2) is an insecticide, a rat poison, and a disinfectant. Mercuric oxide is used in skin ointments. Mercuric sulfate is a catalyst in organic chemistry. Vermilion, a red pigment, is mercuric sulfide; another crystalline form of the sulfide (also used as a pigment) is black. Mercury fulminate, Hg(CNO)2, is a detonator. Mercury forms many organic compounds. Mercurochrome (in 2% aqueous solution) is used in medicine as a topical antiseptic. Whatever the usage, any products that can emit dangerous levels of mercury should be stored and transported in a packaging configuration proven to contain mercury vapor. 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

You May Be Exposed to More Mercury Than You Think

Today, mercury continues to be used in many products, primarily in fluorescent lamps and compact fluorescent lamps (CFLs) in offices, stores and homes. Because of its high density, it is also used in barometers and manometers. Due to its high rate of thermal expansion—which remains fairly constant over a wide temperature range—mercury is also used extensively in thermometers and thermostats. Mercury-vapor lamps, which emit light rich in ultraviolet radiation, are used for street lighting, in water treatment plants as a disinfectant, and in tanning beds. Mercury is used as an electrode in the production of chlorine and sodium hydroxide and in certain electric batteries. Mercury is important as an electrical contact for switches, and mercury conducts the charge in fluorescent lamps.

Exposure typically comes from inhaling mercury vapors. For most of us, fluorescent lamps present the single greatest risk of mercury exposure in the work place. A recent study of exposure to broken "low mercury" lamps by the New Jersey Department of Environmental Protection entitled "Release of Mercury from Broken Fluorescent Bulbs" demonstrated that "elevated airborne levels of mercury could exist in the vicinity of recently broken lamps, and "could exceed occupational exposure limits."

There is currently significant risk in transporting fluorescent lamps and CFLs, as there are no packaging standards and few regulations in place requiring proper packaging for storage and transportation. To protect against mercury vapor exposure from used fluorescent lamps and other mercury-containing devices, these products should be stored and transported in a packaging configuration proven to contain mercury vapor. One current design includes a vapor resistant and zip seal bag and is the only design that has proven effective in containing mercury vapor.

Brad Buscher
Chairman and CEO
VaporLok Products LLC

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

Mercury Waste Regulations: Protecting People, the Environment and Your Companies Best Interests

Not only is mercury a threat to our quality of life when it is not properly recycled, it can also be a significant threat to the overall health of businesses. 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.

If mercury-containing products are improperly recycled, companies may be at risk of severe financial penalties, criminal prosecution and long-term liability. 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

Peder Larson
Attorney
Larkin Hoffman

How Much Mercury Do Fluorescent Lamps Really Contain?

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

The Benefits of Fluorescent Lamps

Incandescent light bulbs emit light by using electricity to heat up a filament that is encased in a protective glass globe to a very high temperature, causing the filament to glow and produce light. The energy required to produce this light is four times the amount of energy required to produce equivalent light in fluorescent lamps. When the fixtures in an average household are counted and multiplied by the number of households in the country, a true sense of the energy needed to produce the light—that many people take for granted—can be realized.

Fluorescent lamps are made up of a sealed glass tube with a phosphor powder coating along the inside of the glass. Inside the tube is a small amount of mercury as well as an inert gas—such as argon—that is maintained under low pressure. Two electrodes on opposite sides of the tube energize the mercury to produce ultraviolet energy. The phosphor coating on the glass tube then absorbs this energy and releases a photon of visible light.

Like incandescent bulbs, fluorescent lamps don't convert 100 percent of the energy they consume into visible light. However, they are four to six times more efficient than incandescent lamps, which in turn reduces the power demand from local utilities. Since most power stations use coal as a source for electrical generation, they are large emitters of both greenhouse gas and mercury, which is naturally occurring in most coal that is used today. The reduced demand for electricity in turn reduces both greenhouse gas and mercury emissions.

Brad Buscher
Chairman and CEO
VaporLok Products LLC

Journey of Recycled Lamps

Recycled lamps are sent to a recycling facility via truck, UPS or FedEx® in bulk or in pre-paid shipping recycling boxes, such as the Waste Management® LampTracker® system, which is specifically designed to accommodate various sized lamps and effectively contain mercury vapor emitted from broken lamps.

Once received, the recycler crushes the lamps, along with other contaminated products, devices and debris, to safely exhaust the mercury vapor and extract and reuse the resultant mercury—ensuring mercury is not released into the environment. The remaining debris is then placed in 55-gallon drums and sent to a retort facility—where the drums are heated to high temperatures to eliminate any remaining mercury. Any remaining glass and aluminum is furthered recycled and reused.

This process reduces the potential dangers of mercury vapor emitted from used fluorescent lamps—effectively reducing environmental liability and protecting both handlers and consumers from potential safety hazards and health risks.

Brad Buscher
Chairman and CEO
VaporLok Products LLC

TCLP Tests

According to EPA estimates, approximately 75 to 80 percent of fluorescent lamps are not recycled and are usually placed in dumpsters or trash containers. Fluorescent lamps in dumpsters present a considerable danger. One study found that mercury is "strongly and persistently" emitted from dumpsters that contain broken fluorescent lamps.1 The data indicates a preliminary loss rate of ~25µg/h from one bulb contained in a closed dumpster. The bulb continued to emit mercury at this rate for more than a week, and at ~50 µg/h on the 8th day following breakage.

Federal policies contain exemptions that help keep the recycling rate low. For instance, lamps that pass the Toxic Characteristic Leaching Procedure (TCLP) mercury test are currently exempt from recycling requirements. However, some lamp manufacturers put extraneous additives in the lamps—such as ascorbic acid—that compromise the test and skew the results.

In 2000—following an extensive debate focused on whether or not a disposal ban should apply to lamps that pass the TCLP—the Maine Legislature decided to enact the ban on all mercury-added lamps. New and used lamps from ten popular lamp models were collected and tested for total mercury and TCLP mercury by dedicated testing procedures. Results indicate that lamps that pass the TCLP test contain comparable total mercury results as the corresponding lamps that fail TCLP, suggesting that the disposal ban on all mercury-added lamps is appropriate.2

1. Lindberg, S.E.; Owens, J. PaMSWaD (Pathways of Mercury in Solid Waste Disposal); Lockheed Martin Energy Research Corporation (LMER). 1999. 6.
2. Maine Fluorescent Lamp Study, DRAFT 1.0, November 15, 2001.

Brad Buscher
Chairman and CEO
VaporLok Products LLC

New legislation protects workers and consumers from mercury vapor risks of unsafe fluorescent lamp packaging

When Governor Chris Gregoire signed Senate Bill 5543 on March 19, Washington became the first state to address the dangers of unsafe packaging and transportation of used fluorescent lamps and mercury containing devices. This new legislation is set to be the precursor of future state and federal legislation as awareness of mercury vapor dangers increases.

Due to deficiencies of most current packaging configurations utilized for shipping used fluorescent lamps, the new law requires 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 packages should include mercury vapor barrier materials if lamps are transported by the United States postal service or a common carrier or collected via curbside programs and mail-back businesses.

Additionally, the State of Wisconsin recently considered legislation that would apply newer mercury-containing equipment packaging standards to used lamps from households. If adopted, the law would require those lamps to be managed in containers “designed to prevent the escape of mercury into the environment by volatilization or other means.”

Environmental practitioners know that most federal environmental laws followed the lead of state laws and regulations. Mercury waste regulation is no exception. Today most mercury lamps are not recycled and states are increasingly indicating that they will take action to fix that problem. As those state laws evolve, states will also consider imposing more specific packaging requirements to supplement the minimal requirements imposed by federal regulations. USEPA’s container requirements for mercury containing equipment provide a simple and effective standard for states to extend to mercury containing lamps. Now that one state has taken that step and another is considering it, watch for similar activity in other states.

Peder Larson
Attorney
Larkin Hoffman

The need for more stringent packaging regulations

The Environmental Protection Agency (EPA) is one of the organizations challenged with the task of simultaneously encouraging the use of energy-efficient fluorescent lamps, while also protecting the environment and people from harmful mercury vapor. The EPA permits common carrier shipment to recycling facilities, and 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.

This may change. More recent federal regulations applicable to other mercury wastes (like switches, thermostats and thermometers) require management in packaging designed to prevent the loss of mercury vapor. Plus, a new law in the State of Washington requires that many lamps be managed in containers that prevent the loss of mercury vapors, and the State of Wisconsin recently considered language that would require mercury vapor containment for household lamps. Read more about new state legislation in my next post.

Peder Larson
Attorney
Larkin Hoffman