Mercury vapor exposure risks dictate recycling practices for fluorescent lamps
by LISA BROSSEAU, ScD, CIH

Fluorescent lamps have been used for decades in commercial and industrial facilities – and remain a popular lighting option today due to the substantial energy savings and environmental advantages they provide. Once these lamps reach the end of their usable lives, it is the responsibility of the user to ensure they remain environmentally-friendly through proper lamp recycling practices. Fluorescent lamps contain mercury and, if broken, can release hazardous levels of mercury vapor, posing a risk to the environment as well as any personnel involved in the transportation and disposal process. To prevent this from occurring, used fluorescent lamps should be housed in packaging designed to contain mercury vapor in case of breakage.

As of today, proper recycling practices are recommended but not mandated by federal law. Some standards exist to regulate transportation and disposal of mercury-containing products; however, recent research indicates the need for more stringent legislation to specifically address fluorescent lamps. When Governor Chris Gregoire signed Senate Bill 5543 on March 19, Washington became the first state to confront this issue directly – addressing 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 the public becomes more aware of mercury vapor risks.

History and hazards of mercury

Mercury is a valuable element contained in many common products, such as thermometers, thermostats, button cell batteries, dental fillings, switches and fluorescent lamps, as well as many additional industrial and medical products. While mercury is a naturally occurring element, it becomes an environmental pollutant when agricultural, industrial, commercial and household products and wastes containing mercury are not properly managed. Mercury vapor escapes into the atmosphere and waterways, where it is converted to methyl mercury and can enter the food chain through fish. Methyl mercury causes damage to the central nervous system and it is also thought to be a possible human carcinogen.

Mercury is not only a threat to our quality of life when it is not recycled properly, but it can also have direct health detriments if not properly handled. Exposure typically results from inhaling mercury vapors. For many, fluorescent lamps present the single greatest risk of mercury exposure in the workplace. A 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.”

Federal packaging requirements for fluorescent lamps

Federal environmental and transportation regulations include packaging requirements for fluorescent lamps. The federal environmental requirements and most state requirements for lamp packaging are similar. They were established by the Environmental Protection Agency (EPA) in 1999 but are silent on the loss of mercury vapor. The regulations require lamps to be managed in containers designed to prevent breakage. Additionally, the packages must remain closed and lack evidence of leakage, spillage or damage that could cause leakage under reasonably foreseeable conditions. However, neither federal nor state regulations require the container to be designed to prevent the loss of mercury vapor.

In 2005, federal regulations were established to specifically require that “mercury-containing equipment” be managed in containers designed to prevent the loss of mercury vapors. The requirements apply to mercury wastes such as mercury switches, thermostats and thermometers, but they do not apply to used fluorescent lamps.

Federal transportation requirements publicized by the United States Department of Transportation (USDOT) also provide packaging standards for fluorescent lamps. These regulations require that shipments of lamps be contained in packaging that prevents the escape of mercury.

In practice, however, the USDOT packaging requirements rarely apply to packages containing used fluorescent lamps. Based on the rules and the mercury content of used lamps, the USDOT standards only apply to packages containing more than 250 typical compact fluorescent lights (CFLs) or low-mercury fluorescent lamps, or 100-200 fluorescent lamps. Most used lamps are transported in far smaller quantities.

Additionally, most generators of used lamps are unlikely to comply with one specific requirement of USDOT regulations. According to these regulations, a shipper of used lamps must provide a “shipping paper” that indicates the quantity of mercury contained in the package. However, this requirement does not exist under federal and state Universal Waste Rules – which specifically exempt lamp generators and transporters from this type of record keeping in hopes of encouraging lamp recycling.

Finally, USDOT regulations allow transport of small quantities of used lamps in the original manufacturers’ packaging for a lamp, even though that packaging is almost certainly not designed to prevent the loss of mercury vapors.

New research indicates a need for stricter packaging regulations

Recent research studying the packaging employed to transport used fluorescent lamps has indicated the need for much stricter legislation to prevent the release of mercury vapor from used lamps. This research, published in the March 2009 issue of the Journal of the Air & Waste Management Association, revealed the need for proven vapor-containing packaging. The results indicated that four out of five commonly used packages – including a single-layer cardboard box designed to resemble original manufacturers’ packages – failed to minimize mercury emission levels below acceptable occupational exposure limits, as defined by state and federal regulations and guidelines.

There was a significant difference in how effective the five packaging configurations were in containing mercury vapors from broken fluorescent lamps, according to the study. Mercury vapor concentrations in the test chamber with the single cardboard box were higher than The Federal Occupational Health and Safety Administration (OSHA) permissible exposure level (PEL) by nearly 10 times. Concentrations were 40 times higher than the more stringent California OSHA PEL.

While other configurations performed slightly better than the single-layer cardboard box, the only package of those tested that kept airborne concentrations below occupational exposure limits was a cardboard box layered with a patent-pending vapor-resistant bag and second cardboard box. This packaging configuration – which is also used to store, ship and recycle other mercury-containing products including batteries, ballasts, electronic devices and dental wastes – lowered mercury vapor concentrations by 99.7 percent compared to the single layer cardboard box.

These results imply that all three layers of this packaging configuration are critical to the effective containment of mercury vapor. The first cardboard layer offers structure to the configuration, also protecting contents from external elements. The bag, which must feature a suitable material and tight seal, contains the mercury vapor, and the inner layer of cardboard ensures the bag’s integrity by preventing broken glass from puncturing it.

States act to protect against mercury vapor emissions

Due to deficiencies of most current packaging configurations utilized for shipping used fluorescent lamps, the new law in Washington requires that lights and other mercury-containing devices be shipped in packaging that will minimize the release of mercury into the environment. The law also states that packages should include mercury vapor barrier materials if transported by the United States postal service or a common carrier, or collected via curbside programs and mail-back businesses.

The State of Wisconsin also recently considered legislation that would apply the newer EPA mercury-containing equipment packaging standard 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 fluorescent 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. The EPA’s container requirements for mercury-containing equipment provide a simple and effective standard for states to extend to mercury containing lamps.