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

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

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