This Web Exclusive comes from Lisa Brosseau, ScD, CIH, Associate Professor, University of Minnesota School of Public Health, Division of Environmental Health Sciences.
Today’s facility managers are tasked not only with keeping management expenses low, but also with ensuring energy efficiency and, of course, a safe work environment for the facility’s employees. When it comes to selecting lighting, all of these aspects must be factored in.
Fluorescent lamps have long been the best lighting option for small to large facilities, due to their significant energy savings—providing four to six times higher efficiency than incandescent lights—and long working life. However, these lamps contain hazardous mercury and, from installation to disposal, they must be carefully handled, stored, and transported.
While the amount of mercury used in an individual fluorescent bulb has decreased over the years, 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 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 (along with 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.
Recent legislation has begun to address the issue of safe packaging for fluorescent lamps and other mercury-containing products, and facility managers must not only work to comply with these regulations, but also ensure the safety of all personnel in addition to protecting the environment.
Selecting a package to contain mercury vapor
Universal waste containers that could be transported by common carrier were first introduced in 1998, and the first containers were primarily used to ship fluorescent lamps. 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˚F, packaging improvements were needed to address the issue of potential mercury vapor release in the event of breakage during accumulation and transport.
A study conducted by the research team from the University of Minnesota indicated that emissions from packages not designed to contain mercury vapor represent a real health and safety concern. In the study, which was published in the March 2009 issue of the Journal of the Air & Waste Management Association, the team tested single-layer cardboard boxes, packages that added a plastic bag to this design, as well as packages that added a second layer of cardboard along with the plastic bag. [“Preventing Mercury Vapor Release from Broken Fluorescent Lamps during Shipping,” by Tracy T. Glenz, Lisa M. Brosseau, and Richard W. Hoffbeck, Journal of the Air & Waste Management Association 59 (2009): 266-72.] A package design that featured a double box with a thicker, tape sealed plastic bag performed better than the previous configurations, but the only package that kept mercury vapor emissions below permissible exposure levels, as defined by state and federal authorities, was a double box with a zip closure foil-plastic laminate bag between the cardboard layers.
These findings indicated that all three layers of the last packaging configuration were important in effectively containing mercury vapor. The first cardboard layer provided structure to the configuration, protecting contents from outside elements. The inner layer of cardboard prevented glass shards from puncturing the bag, which actually contains the mercury vapor.
Safety and health risks, and additional concerns
Containing mercury vapor is important because, although it is one of the most useful heavy metals, it is also one of the most deadly. When carelessly handled or improperly disposed of, mercury can get into drinking water, lakes, rivers, and streams, posing a critical threat to human health and 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% 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. [Pathways of Mercury in Solid Waste Disposal, by S.E. Lindberg, and J. Owens, PaMSWaD, Lockheed Martin Energy Research Corporation (LMER) (1999) 6.]
The data indicate a preliminary mercury loss rate of ~25µg/hr 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/hr on the eighth day following breakage.
If not properly recycled, mercury is not only a threat to quality of life, but 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, cleanup, transportation, and disposal of hazardous wastes, including products which contain mercury.
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.
Stricter state regulations
While recycling fluorescent lamps is important, many states are realizing that if proper precautions are not taken, the lamps can emit mercury vapor en route and negate many recycling benefits. Most notably, a new law in the State of Washington requires that many lamps be managed in containers that prevent the loss of mercury vapors. 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—such as the foil-plastic laminate bag with a zip closure tested in the University of Minnesota study—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 has debated new 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.”
Plus, several other states have tackled this health issue with their own, more stringent regulations regarding fluorescent lamp disposal. Minnesota, Massachusetts, California, and Vermont disallow disposal of all mercury product waste in landfills. New York has a comparable ban, with an exemption for households and businesses with 100 or less employees disposing of 15 or less non-hazardous waste lamps per month.
While these new regulations help to encourage proper recycling of used fluorescent lamps, there is still a need for a more universal set of packaging standards to ensure safety of personnel and the environment. It is up to facility managers not only to select energy efficient lights, but also to make certain they remain a safe and green solution by ensuring proper storage and transportation of fluorescent lamps.
Dr. Lisa M. Brosseau has conducted research and published in the areas of respiratory protection, aerosol exposures, hazardous materials and safety interventions in small businesses. She serves on the editorial review board of the Journal of Occupational and Environmental Hygiene and is currently the vice chair of ACGIH, a globally recognized organization committed to developing scientific guidelines for workplace safety and health.