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

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

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 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