SHEDDING LIGHT ON MERCURY RISKS FROM CFL BREAKAGE - PREPARED BY EDWARD GROTH, PHD FOR THE MERCURY POLICY PROJECT FEBRUARY 2008

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SHEDDING LIGHT ON MERCURY RISKS FROM CFL BREAKAGE - PREPARED BY EDWARD GROTH, PHD FOR THE MERCURY POLICY PROJECT FEBRUARY 2008
Shedding Light on
Mercury Risks from CFL Breakage
          Prepared by Edward Groth, PhD
                       For
            The Mercury Policy Project
                  February 2008
SHEDDING LIGHT ON MERCURY RISKS FROM CFL BREAKAGE - PREPARED BY EDWARD GROTH, PHD FOR THE MERCURY POLICY PROJECT FEBRUARY 2008
SHEDDING LIGHT ON MERCURY RISKS FROM CFL BREAKAGE - PREPARED BY EDWARD GROTH, PHD FOR THE MERCURY POLICY PROJECT FEBRUARY 2008
Acknowledgments

The Mercury Policy Project would like to thank the following people for their assistance with the
research, writing and/or editing of this report:

                   • Edward Groth, PhD, Groth Consulting Services, Pelham, NY
                   • Alicia Culver, Green Purchasing Institute and
                   • Eric Uram, Headwater Consulting / Sierra Club – National Environmental
                     Quality Strategy Team.

  The Mercury Policy Project would like to thank the John Merck Fund for their generous support.

                                 Co-releasers of the Report include:

                                       Mercury Policy Project
                                  Illinois Environmental Council
                              Vermont Public Interest Research Group
                        Clean Water Action (Massachusetts and Rhode Island)
                                       Sierra Club - California

             This report is available on the world wide web at: www.mercurypolicy.org

                                       Mercury Policy Project
                                          1420 North St.
                                        Montpelier, VT 05602
                                       www.mercurypolicy.org

                                   ©2008 Mercury Policy Project
SHEDDING LIGHT ON MERCURY RISKS FROM CFL BREAKAGE - PREPARED BY EDWARD GROTH, PHD FOR THE MERCURY POLICY PROJECT FEBRUARY 2008
S      ummary: Compact fluorescent
        lights (CFLs) are important energy-
        savers and are being widely substituted
for less-efficient incandescent light bulbs.
                                                              However, CFLs also contain realtively small
                                                              amounts of mercury. Some may contain as
                                                              much as 30 milligrams (mg), others as little
                                                              as 1 mg of this toxic metal element. The
But CFLs also contain small amounts of                        amount of mercury in some CFLs is less than
elemental mercury. Much of this mercury                       in the past, and the lighting industry continues
is released when a CFL is broken. Several                     to work toward reducing it further (NEMA
studies of mercury releases from broken                       2007). Some US manufacturers have pledged
fluorescent bulbs suggest that, under certain                 to use 5 to 6 mg or less of mercury in their
conditions, CFL breakage can pose a health                    CFLs, and a few companies are now offering
risk, especially to an infant or young                                  bulbs they claim contain only 1 mg.
child who spends time near the site of                                  The current limit in Europe is 5 mg,
the breakage. While this risk raises                                    and a proposed Green Seal standard
valid public-health concerns, there                                     for the U.S. calls for 3 mg or less.
is no reason for consumers either to
avoid using CFLs or to panic if one                                      A mercury-free CFL is not possible
is broken. However, parents should                                       with current technology; some mer-
consider avoiding using CFLs in situ-                                    cury is required for the lights to work.
ations where breakage is likely, espe-                                   Mercury vapor inside the tube is
cially in infants’ or toddlers’ rooms.                                   excited by electric current and emits
To prevent breakage and to increase                                      ultraviolet light, which excites com-
recycling of CFLs at the end of their                                    pounds painted on the inside of the
useful life, consumers need more and                                     glass, making them emit visible light.
better information about risks posed                                     Alternative energy-efficient lighting
by broken lamps, clear and consistent                                    technologies, such as light-emitting
instruction on safe clean-up and dis-                                    diodes (LEDs), are very long-lasting
posal of a broken CFL, and guidance                                      and contain no mercury. LEDs are
to help find energy-efficient light                                      not yet practical choices for many
bulbs with minimal mercury content.                                      lighting applications, but their use is
                                                                         growing as they become more avail-
Introduction: Risks and Benefits of            CFLs help reduce the      able and prices drop.
                                               emissions coming from
CFLs, An Overview                              coal-fired power plants
                                                                       The presence of mercury in CFLs
CFLs convert power into light more                                     (and in more traditional, linear fluo-
efficiently and last longer than incandescent                 rescent light tubes) raises several risk issues.
bulbs do. They are therefore widely promoted                  Workers may be exposed to mercury when
as an important energy-conservation technol-                  manufacturing, transporting, installing, recy-
ogy. Indeed, greatly expanded use of CFLs                     cling or disposing of fluorescent lights. While
will reduce carbon dioxide emissions, a major                 no mercury is released during normal opera-
contributor to global warming, and other air                  tion, consumers can be exposed to mercury if
pollution, including mercury emissions, from                  a fluorescent tube or CFL is broken. And as
coal-fired power plants. Consumers are ap-                    the number of fluorescent lights in use grows,
propriately being encouraged by governments,                  so does the amount of mercury that can be ac-
utilities, and public-interest organizations to               cidentally released in homes and can enter the
buy and use CFLs.                                             waste stream.

Shedding Light on Mercury Risks from CFL Breakage — 
The National Electrical Manufacturers As-               the lamp, and a small amount may exist as
sociation (NEMA) estimated that 670 million             tiny liquid droplets. Mercury vapor, which is
used fluorescent bulbs were disposed of in              readily dispersed in air and absorbed through
2003, and the number has doubtless continued            the lungs, is the most immediate health
to grow since then. While a small fraction              concern. But liquid mercury, especially if it
are recycled, most end up in landfills or trash         is absorbed into a carpet or an upholstered
incinerators, where they are almost certain             surface, can remain in place and vaporize
to be broken (if they haven’t been broken               over time, contributing to ongoing indoor
earlier in the disposal process). Broken                exposure.
fluorescent lights release an estimated 2 to 4
tons of mercury vapor into the environment
each year in the U.S. (Aucott et al. 2004)

This report focuses on the emerging risk
issues associated with CFL breakage in the
home. Wider environmental impacts of CFLs
throughout the product life cycle, analyses of
alternative energy-efficient lighting choices,
and strategies for addressing such broader
issues are generally outside the scope of this
paper. Many of these issues have recently
been addressed by the Sierra Club (2008),
among others (see Appendix for the Sierra
Club Guidelines, and Resources section for              Different CFL designs may be more or less prone to break-
                                                        age and can contain different amounts of mercury.
further information).

Can a Broken CFL Create a Household                     Critical issues in a risk assessment for this
Health Hazard?                                          potential mercury exposure include:

CFLs, like other light bulbs, tend to be fragile;       •   Who is likely to be exposed to airborne
most designs use relatively unprotected, thin               mercury after a CFL breaks?
glass tubes. Given normal human foibles,                •   Who is most vulnerable to possible harm?
some CFLs will be broken. People may drop               •   What adverse effects could this mercury
a CFL or apply too much force when                          exposure have on household residents?
installing or removing it. Lamps occasion-              •   What is a “safe” level of mercury in in-
ally get knocked over, especially in homes                  door air, as defined by expert agencies?
with children and pets. And when a CFL’s                •   Can CFL breakage produce air mercury
useful life is over and it is thrown away, it               levels above those safety limits?
may get broken in the trash before it even              •   If so, how high are the levels and how
leaves the house.                                           long do elevated air mercury levels per-
                                                            sist?
The mercury in a broken CFL can escape and
contaminate the site of the breakage. Most
of the mercury in a CFL is in vapor form;
some may be adsorbed onto surfaces inside

Shedding Light on Mercury Risks from CFL Breakage — 
We will attempt to answer each of these                   damage from elemental mercury has been
questions below. One obvious conclusion is                well documented in animal studies.
that much remains uncertain and unknown;
there are not yet clear scientific answers                Babies and other small children are also
on many of the issues. However, enough is                 more vulnerable to airborne mercury expo-
known to support concerns about the nature                sures, because their small body sizes and
and general magnitude of the risks, and to                more rapid respiration rates give them a
offer common-sense advice to consumers.                   larger dose of mercury than an adult gets
                                                          from inhaling air with the same mercury
(1) Why are children at greatest risk from                concentration. Mercury vapor is heavier than
mercury vapor?                                            air, and mercury concentrations in indoor
                                                          air tend to be higher near the floor. Infants
When a CFL breaks, anyone in the house-                   and toddlers who crawl, sit, walk, play and
hold may be exposed to mercury vapor. But                 breathe on or close to the floor are thus
the public health concern is currently                            likely to be most heavily exposed
focused on circumstances                                                 to the mercury vapor from a
where infants, small                                                          broken CFL.
children or pregnant
women can inhale                                                                       Historically, a
mercury vapor.                                                                          specific form of
This concern                                                                             mercury poisoning
is based on                                                                              called acrodynia
strong scientific                                                                        has occurred in
evidence that the                                                                       some children who
very young and                                                                         inhaled mercury
the fetus are much                                                                   vapor, often when a
more sensitive than                                                              device that contained
older groups in the popu-                                                    mercury such as a thermom-
lation are to the potential toxic                                     eter or a thermostat was broken.
effects of mercury.                                       Acrodynia is characterized by loss of appe-
                                                          tite, irritability, sensitivity to light, profuse
During fetal development and early child-                 sweating that often produces a rash, and
hood, up to the age of six years or so, the               reddened, peeling skin on the hands and
human brain grows and changes rapidly.                    feet. Acrodynia has also been associated
This dynamic developmental process is                     with mercury vapor emitted into indoor air
vulnerable to the disruptive effects of toxic             from certain latex paints that historically
exposures. Young children, infants and                    contained mercury fungicides (Hirschman et
fetuses have been shown to be highly sus-                 al. 1963, Agocs et al. 1990).
ceptible to developmental effects associated
with methylmercury in fish in their (and                  One published clinical report has described a
their mothers’) diets (Debes et al., 2006).               case of acrodynia in a toddler who played in
There is no comparable body of epidemio-                  a shed where a box of fluorescent light tubes
logical evidence on the effects of mercury                had been broken five months earlier (Tun-
vapor in the very young, but an analogous                 nessen et al. 1987). In that case, the affected
hypersensitivity of the developing brain to               child had two older siblings who played in

Shedding Light on Mercury Risks from CFL Breakage — 
the same mercury-contaminated area. Like                mercury doses than any that can cause acro-
the patient, both siblings had elevated uri-            dynia, but such neuro-developmental effects
nary mercury levels, indicating substantial ex-         are difficult to observe and to associate with
posure to mercury vapor. But neither sibling            exposure. Because of justified concern about
developed acrodynia. The authors noted that             potential developmental effects, the issue
historically, only a small fraction of thou-            of short-term spikes of exposure, discussed
sands of children exposed to mercury vapor              in Section 3, below, takes on added impor-
have actually developed acrodynia. They                 tance.
suggest that acrodynia may be an allergic or
hypersensitivity reaction to mercury toxicity           		               (2) What is a “safe” level of
in highly susceptible                                                          mercury vapor in air?
individuals (Tunnessen
et al. 1987).                                                               Mercury concentrations
                                                                            in rural, unpolluted
Acrodynia can take                                                          ambient air are typically
weeks or months after                                                       about 1 to 2 ng/m3. (The
initial exposure to                                                         units are nanograms, or
develop, which makes                                                        billionths of a gram, per
it difficult or impos-                                                      cubic meter of air.) By
sible to determine                                                          contrast, the lowest lev-
exposure levels that                                                        els that are currently of
caused the disease. The                                                     health concern are about
medical literature does                                                     100 times greater than
not include adequate                                                        this background level.
measurements of the
airborne mercury con-                                                         Two federal agencies
centrations to which children with acrodynia            and several states have developed guidelines
from inhaling mercury vapor were exposed.               for “safe” chronic (long-term) exposure to
We do not know what level of mercury in air             mercury vapor in air. The US Environmental
causes acrodynia, or conversely, the highest            Protection Agency (EPA) has established
level that poses no risk of causing this ef-            a Reference Concentration (RfC) of 300
fect. It is not possible to estimate how many           ng/m3 (Rice 2007). The Agency for Toxic
children might fall into a sensitive subgroup           Substances and Disease Registry (ATSDR),
that could develop acrodynia if exposed to              a branch of the Centers for Disease Control,
mercury vapor, and there is no basis to pre-            has adopted a Minimal Risk Level (MRL) of
dict which children might be susceptible, if            200 ng/m3 (ATSDR 2006). Some states have
acrodynia is indeed a hyper-sensitivity reac-           adopted the EPA RfC, while others have
tion. These all remain critical uncertainties.          developed their own MRLs. Notable among
                                                        the latter is California’s chronic Reference
Finally, although acrodynia is the best                 Exposure Level (REL) of 90 ng/m3 (Califor-
known and best documented effect of                     nia DTSC 2002).
exposure to elemental mercury in children,
it is not necessarily the one we should be              These guidelines describe levels of expo-
most concerned about. Toxic effects on the              sure to mercury vapor that are believed to
developing brain may well occur at lower                pose no appreciable health hazard, even if

Shedding Light on Mercury Risks from CFL Breakage — 
a person were exposed to that level for an                that is certain is that the margin between
extended time. Both federal guidelines are                their actual exposure and the harmful level
based on a study that measured adverse ef-                has been reduced.
fects of inhaled mercury on the nervous sys-
tem of adult men exposed in the workplace.                What is less clear is the level of exposure at
The California REL aims to prevent mercury                which harm, especially subtler effects than
damage to the developing brain, and is based              those that occurred in workers or heavily-
on animal toxicity data.                                  exposed rats, might begin to occur. Even
                                                          within a sensitive subgroup like young
Several states have also adopted guidelines               children, some individuals are much more
for acute (short-term) exposure to mercury                susceptible to toxic effects than the aver-
vapor (Rice 2007). California’s acute REL,                age person is. It is far from certain that the
for example, is 1,800 ng/m3, averaged over                margins of exposure built into the various
one hour. There is no federal acute RfC for               guidelines provide adequate safety for such
mercury vapor. However, the ATSDR                              sensitive individuals.
has set a “reoccupancy level” (a
guideline for when it is safe to let                                 Further uncertainties arise when
people re-enter a building that has                                    people are exposed to mercury
been contaminated with mercury)                                         vapor concentrations moderately
at 1,000 ng/m3.                                                          greater than the guideline lev-
                                                                         els, for periods of a few min-
Each of these guidelines in-                                              utes to a few hours. Scientists
cludes an “uncertainty fac-                                               classify this as acute or sub-
tor” (for example, 30-fold in                                             acute exposure. In theory, brief
both the EPA’s RfC and the                                                exposure should pose smaller
ATSDR’s chronic MRL), which                                              risks than long-term exposure,
provides a margin of exposure                                            because less mercury should
between a level of mercury vapor                                        be absorbed. The guidelines
in air that had clear-cut adverse                                      for acceptable acute exposure
effects in the studies on which the                                  to mercury vapor are generally
limit is based, and the permitted ex-                              designed to prevent adverse effects
posure level                                                   that become obvious soon after expo-
                                                          sure; just as for the chronic guidelines, acute
(3) Is exposure to mercury vapor at levels                limits include uncertainty factors.
above these guidelines harmful?
                                                          However, here too, there are large knowl-
Not necessarily, but it could be. As just                 edge gaps. Acute exposure can have delayed
explained, the various guidelines all provide             or chronic effects. In particular, a short-term
a margin (e.g., 30-fold, in the federal chronic           “spike” or series of spikes of exposure might
guidelines) between the acceptable level and              affect key developmental processes, if a
higher levels that are known to cause ad-                 child or fetus were exposed during a crucial
verse effects. When a person is chronically               developmental phase, producing long-term
exposed to airborne mercury at levels higher              damage to the brain and learning ability, for
than, say, 90 to 300 ng/m3, but still below               instance. The relative hazards of chronic
levels that have caused detectable harm, all              versus spike exposures have not been well

Shedding Light on Mercury Risks from CFL Breakage — 
characterized by toxicology in general,                 ing the brand (manufacturer), when it was
and this lack of basic knowledge limits our             made (newer bulbs generally have less
ability to precisely assess mercury exposure            mercury), and how much it has been used
risks. It is therefore not possible to conclude         (mercury vapor levels decline with use).
confidently that even brief exposure to mer-            The more time that passes between breakage
cury vapor levels above current guidelines              and clean-up and the higher the tempera-
poses no significant health risks.                      ture where the breakage occurs, the more
                                                        mercury will be released, other things being
Among the most important uncertainties                  equal. When breakage occurs on a carpet,
is the lack of adequate information on the              a rug or upholstered furniture, liquid mer-
level of mercury in indoor air that is safe for         cury that escapes can be absorbed by textile
infants, children, or pregnant women. All               fibers. This mercury can later vaporize if the
of the studies that have associated adverse             textile items are agitated by being walked
human health effects with specific levels of            on, swept, brushed or vacuum-cleaned.
mercury in air have involved adults, mostly
men. There is                                                                      The amount of
essentially no                                                                     mercury in a typi-
good epide-                                                                        cal CFL is small.
miological                                                                         However, mag-
evidence on                                                                        nitude is relative,
mercury ef-                                                                        as this illustrative
fects on the                                                                       example shows.
sub-popula-                                                                        Chandrasekhar
tions believed                                                                     (2007) modeled
to be at high-                                                                     the dispersal of
est risk.                                                                          mercury in the air
                                                                                   in a room after a
Some might                                                                         CFL is broken. He
argue that the                                                                     made some reason-
margins in                                                                         able assumptions:
current fed-                                                                       That a broken CFL
eral and state                                                                     contains 5 mg
guidelines for exposure to mercury vapor                (5,000,000 ng) of mercury vapor; that the
are wide enough to protect everyone, includ-            volume of air in the room is about 33 m3;
ing fetuses, babies and other children. In the          that all the mercury in the lamp is in vapor
absence of well-designed studies measuring              form, and that it all escapes on breakage and
the effects of mercury vapor exposure on                diffuses through the air in the room within a
those specific populations, that argument               few minutes. With those starting points, he
rests on faith more than on science.                    calculated that the mercury vapor concentra-
                                                        tion in the room a few minutes after a CFL
(4) What level of mercury vapor exposure                was broken could exceed 150,000 ng/m3.
can result from a broken CFL?
                                                        Aucott et al. (2004) at the New Jersey De-
Several factors can affect the amount of                partment of Environmental Protection took
mercury released by a broken CFL, includ-               a more experimental approach. They broke

Shedding Light on Mercury Risks from CFL Breakage — 
fluorescent tubes in a 32-gallon plastic bar-           and found a mercury concentration of 1,939
rel, then periodically removed and replaced             ng/m3 in the air directly above the spot on
the barrel’s cover (simulating normal use               the carpet where the bulb had broken. On a
of a garbage can), and measured mercury                 second visit, two months later, the investiga-
levels in the air inside the closed barrel to           tor found no levels above Maine’s state RfC
estimate the rate of mercury release. They              of 300 ng/m3 anywhere in the home, even at
found that 17 to 40 percent of the mercury              the site of the breakage.
in a broken bulb was released into the air
within two weeks after breakage, and one-               The initial reading of 1,939 ng/m3 and the
third of the total release occurred during              likelihood that CFL breakage occurs fairly
the first 8 hours. Higher temperatures led to           often spurred the Maine agencies involved
more rapid and greater releases of mercury.             to seek better data on potential exposure to
The release rate declined over time, and a              airborne mercury following such breakage.
significant amount of mercury re-                                      They carried out a study in
mained adsorbed on surfaces     …a broken CFL                             which CFLs were broken
of the broken tubes.
                              can produce mer-                                under controlled condi-
                                                                                  tions and mercury
Aucott et al.’s
results suggest
                          cury vapor levels well in                                  levels in air in
                                                                                       the room where
a smaller total        excess of current state and fed-                                the bulbs were
mercury vapor
release than that pre-
                           eral guidelines, at least                                 broken were mea-
                                                                                 sured. The results are
dicted by Chandrasekhar’s      for brief periods.                            consistent with the two
“worst case” model. With the                                              studies just described and
same assumed 5 mg of mercury                                          reinforce the conclusion that a
vapor and the same size room as in Chan-                broken CFL can produce mercury vapor lev-
drasekhar’s model, the NJDEP data suggest               els well in excess of current state and federal
that a broken fluorescent light could produce           guidelines, at least for brief periods (Rice
air mercury levels in the range of 8,000 to             2007). It appears that in Maine’s judgment,
20,000 ng/m3 within 8 hours after breakage,             these elevated mercury levels represent a
if the room were not ventilated and the bro-            public-health concern, especially for house-
ken bulb were not removed. These projected              holds with infants or young children.
levels are high enough to justify public
health concerns about potential exposure                A technical report on Maine’s breakage
of residents to mercury vapor from broken               tests is about to be published, but was not
fluorescent lights.                                     available when our report was being writ-
                                                        ten. Based on the growing body of evidence
The State of Maine became interested in this            that CFL breakage may pose risks to health
problem when a resident who had broken a                under certain conditions, several other states
CFL on a carpet in her home sought as-                  will also address these risk issues. Readers
sistance from the state government (Maine               may wish to check the states’ web sites in
DEP 2007). A toxic-spill investigator visited           coming weeks for the most current adviso-
the home two days after the CFL break-                  ries on the subject (see Resources section for
age had occurred (and two days after the                links.)
consumer had cleaned up the broken bulb)

Shedding Light on Mercury Risks from CFL Breakage — 7
What Should I Do If I Break a CFL in My                          The three most important points
Home?                                                            are: (1) Don’t panic; (2) Ventilate
                                                                 the area; and (3) Clean up the
Although it should go without saying, an
important strategy is to avoid breaking a                        breakage promptly, but do not use a
CFL in the first place. For example, when                        vacuum cleaner, broom or dustpan.
installing or removing a CFL, turn it by
gripping the base; where possible, don’t                         First, don’t panic. While there is some risk
twist the glass tubes. Also, be aware of the                     from exposure to the mercury vapor a CFL
risks of breakage when a CFL’s useful life                       breakage can release, the risk is comparatively
is over and it is ready for disposal. A CFL                      small, and promptly and properly cleaning up
that is simply thrown in the trash can eas-                      the broken bulb can greatly reduce or eliminate
ily break—in an indoor wastebasket, for                          the risk.
example, which could result in household
exposure to mercury vapor. Recommenda-                           Second, ventilate
tions for proper end-of-life disposal appear                     the breakage area
at the end of this report. This section focuses                  immediately. Open
on cleaning up after a more typical acciden-                     a window, or all
tal breakage.                                                    the windows, in the
                                                                 room and let the
The advice given here is based on guidance                       air flow out, taking
offered by various state and federal agencies                    mercury vapor with
(Weiss 2007, Chandrasekhar 2007) and by                          it. If the air is cold,
the US EPA (2007). The advice is evolving                        heating the room will increase the rate at which
as better data are developed, and the EPA                        mercury vaporizes and speed its removal. But
has stated that it intends to update its advice                  if you have a forced hot air furnace, use plastic
frequently. This report synthesizes current                      bags and duct tape to cover the vents in the
advice; if you have further questions, we                        room, to keep air flow from spreading mercury
suggest you contact your state health de-                        vapor throughout the building. Use a table fan
partment or environmental agency or visit                        or pedestal fan to blow air out the window.
their web sites (see Resources section for                       If the room has only one window, keep the
examples).                                                       door open a crack, to let clean air in to replace
                                                                 the contaminated air flowing out. If the room
It makes                                                         where the breakage occurred has multiple
sense to                                                         windows, open them all, and close the door to
anticipate                                                       keep air flow from spreading mercury to other
that you may                                                     rooms.
break a CFL
now and                                                          Most expert agencies say to ventilate for at
then, and to                                                     least 15 minutes. Chandrasekhar’s modeling
keep clean-                                                      exercise (2007) found that with even a mini-
up guide-                                                        mally effective fan to increase air flow, this
lines handy,     Chandrasekhar (2007) showed that opening
                                                                 strategy should reduce mercury vapor levels
just in case.    a window and using a fan can reduce mer-        to below the ATSDR MRL within 12 minutes,
                 cury vapor to safe levels in about 12 minutes   and to background levels after 20-25 minutes.

Shedding Light on Mercury Risks from CFL Breakage — 
He suggested that ventilating for longer times          pat the carpet or floor with duct tape or mask-
could provide an additional margin of safety,           ing tape (wrapped around a piece of cardboard,
but no more than 45 minutes was needed in               sticky-side-out), to pick up small particles.
any case.                                               When you have removed all visible particles,
                                                        wipe the affected area down carefully with a
Third, once you have begun ventilating the              moist paper towel or commercial wet-wipe.
area, clean up the debris from the bro-
ken CFL promptly. If you are pregnant,                  Place the pieces of the broken CFL in a con-
or think you might be pregnant, though,                 tainer that can be tightly sealed, such as glass
we recommend opening a window,                          or plastic jar with a screw-on lid. Items that
then leaving the room, closing the door,                won’t fit into a jar and don’t have sharp edges
and asking someone else to carry out                    (such as used gloves, paper towels and tape-
the rest of the clean-up steps described                wrapped cardboard) can be sealed inside a pair
below.                                                  of zip-lock plastic bags, one inside the other.
                                                        Wash your hands (and any tweezers or other
Children, pets and other family mem-                    tools you may have used) thoroughly, with
bers should be kept away from the area where            soap or detergent.
the breakage occurred until it has been cleaned
up, to avoid exposure to mercury and to keep            In most areas, the debris from a single broken
them from tracking mercury into other parts             CFL, in its sealed container(s), can safely be
of the house. Pick up broken glass pieces and           disposed of in the household trash (but make
other debris, using disposable rubber gloves            sure this is allowed under your state’s laws).
(sold in supermarkets) if you have them. You            If you have multiple broken bulbs, or if state
can also use tweezers to pick up glass shards,          law requires it for even a single bulb, take the
or they can be gently swept onto a stiff piece of       debris to a local hazardous-household-waste
paper or cardboard, using another piece of pa-          collection site.
per or similar disposable object.
                                                          If the breakage occurred on a carpet, a rug
DO NOT USE A VACUUM                                       or upholstered furniture, avoid subsequent
CLEANER. Vacuuming the                                       vacuuming of the spill area, which is likely
spill site will vaporize any                                  to retain mercury for some time. If the
liquid mercury present and                                     contaminated textile item is is in a child’s
spread it through the air in                                   or pregnant woman’s room, consider
the room. It can also con-                                    removing or replacing it, or if that is not
taminate the vacuum cleaner,                                 feasible, moving the person’s sleeping and
which could then disperse                                  play areas to another room.
mercury in other parts of your
home. For the same reason, don’t clean up with          This advice errs on the side of caution, which
a broom, a brush, a dustpan or a mop, which             is appropriate, given the large scientific un-
could also get contaminated and transfer mer-           certainties involved in assessing this risk.
cury to other surfaces. Use disposable objects          Remember, the risk is relatively small to begin
to sweep up the smaller pieces.                         with, and if you follow these clean-up proce-
                                                        dures, you should feel confident that you have
When pieces that can be gathered up by the              reduced the risk substantially or virtually elimi-
methods described above have been collected,            nated it.

Shedding Light on Mercury Risks from CFL Breakage — 
Recommendations                                            recycling options offered by manufactur-
These recommendations are for consumers                    ers or retailers in your area, and work with
who face potential risks from CFL break-                   government, utilities and others to expand
age in their homes, and for others concerned               the availability of CFL recycling.
with that problem. Additional recommen-                  V Where CFL recycling is not available, try
dations on wider issues like making prog-                  to dispose of CFLs in an environmentally
ress toward low mercury and mercury-free                   responsible manner. Specifically, do not
                                                           throw CFLs down trash chutes (in apart-
energy-efficient lighting technologies and
                                                           ment buildings), do not put them out with
improving the availability of environmen-
                                                           other glass objects for local recycling pick-
tally sound disposal and recycling of spent                ups, and find out whether local law permits
CFLs, can be found on linked sites listed in               them to be put in the trash, or requires
the Resources section.                                     them to be taken to a hazardous household
                                                           waste pick-up site. When they are put in
Consumers should:                                          the trash, try to protect them from break-
V Choose CFLs as energy-saving devices                     age (say, by putting them inside a sturdy
   without fear of the mercury they contain,               container.)
   while informing themselves
   about the nature of risks in-
   volved and the appropriate
   cautions and countermeasures
   to follow when breakage does
   occur.
V Avoid using a CFL in a lamp
   that is reasonably likely to
   fall down or be knocked over,
   especially if such a lamp is in a
   child’s room.
V Handle CFLs with care to avoid
   breakage, including when dis-
   posing of spent bulbs.
V Keep guidelines for cleaning up
   a broken CFL handy, just in case
   one breaks.                                           The lighting industry should:
V Try to buy CFLs with the lowest mercury                v Continue its efforts to develop lower-mer-
   content, which currently is about 1 mg.                  cury, longer-lasting CFL technologies, and
   If those are not locally available, look                 get their products certified by Green Seal
   for bulbs made by companies that have                    and other independent third parties.
   pledged to keep mercury content below 5               v Test the comparative breakage resistance
   mg (see NEMA link in Resources).                         of different CFL designs, make the results
V Choose CFL designs that are less likely                   public, and phase out designs particularly
   to break, e.g., those where the fluorescent              prone to breakage.
   tube is enclosed inside a plastic shield.             v Continue its efforts to make high-effi-
V Demand that manufacturers and retailers                   ciency, mercury-free lighting systems such
   provide information on mercury content of                as LEDs more widely available and more
   CFLs, on labels, at the point of sale and on             price-competitive for a wider range of
   web sites.                                               lighting needs.
V Take advantage of available local CFL                  v Pursue a long-term goal of phasing out

Shedding Light on Mercury Risks from CFL Breakage — 10
CFLs in favor of more sustainable lighting              cury-containing CFLs as more acceptable
    technologies.                                           alternative high-efficiency lighting tech-
v   Include information about the mercury                   nologies become available and affordable.
    content of their fluorescent lamp products,           v Collaborate with the lighting industry and
    at the point of sale, on packaging, and on              others on research to develop better data
    web sites.                                              for exposure assessments related to break-
v   Insert information about possible mercury               age of CFLs and other fluorescent lamps,
    exposure from breakage and about safe                   in homes and in trash processing.
    clean-up procedures in CFL packages.
v   Collect and disseminate up-to-date infor-             Environmental NGOs and the public-inter-
    mation and advice in several languages                est community should:
    for consumers about the risks from CFL                V Pursue long-term energy-saving lighting
    breakage and proper clean-up methods,                     strategies that minimize toxic releases
    via brochures, web sites, poison-control                  throughout product life cycles, minimize
    centers, and other media.                                 resource consumption, emphasize recy-
v   Ensure that all CFL giveaways include                     cling over disposal, promote closed-loop
    information on breakage, safe clean-up                    processes for end-of-product life issues
    procedures and recycling programs.                        and manufacturer- or retailer-funded recy-
v   Collaborate with government and aca-                      cling programs.
    demic researchers to collect more exten-              V Develop and disseminate consumer infor-
    sive data on potential exposure to mercury                mation on risk-benefit trade-offs of CFL
    vapor from CFL breakage.                                  use, and promote increased community
v   Work with their distributors to develop                   involvement in energy choices.
    an industry-financed recycling system for             V Consider adopting and encourage other
    spent fluorescent bulbs.                                  organizations and utilities involved in CFL
                                                              giveaway programs to adopt the Sierra
Governments and electric power utilities should:              Club’s Guidelines for Environmentally-
v Collect and disseminate up-to-date infor-                   Preferable Light Bulbs (appended to this
  mation and advice in several languages                      report).
  for consumers about the risks from CFL
  breakage and proper clean-up methods,                   Image credits:
  via brochures, web sites, poison-control
  centers, and other media.                               p.1 Eric Uram - Headwater Consulting 2005
v Develop consistent advice to the extent                 p.2 http://www.maine.gov/dep/rwm/hom-
  possible on these issues, to avoid consumer             eowner/fluorescent.htm
  confusion.
                                                          p.3 http://www.123rf.com/photo_715631.html
v Develop incentives to promote adoption
  of the lowest-mercury, most breakage-re-                p.4 Jim Gathany - CDC 2003
  sistant and longest-lasting CFL designs,                p.5 http://upload.wikimedia.org/wikipedia/
  through government purchasing or large-                 commons/thumb/a/ae/Question_mark_3d.png/
  scale utility CFL-distribution programs.                310px-Question_mark_3d.png
v Adopt guidelines for CFL-giveaway pro-                  p.6 http://www.mercvt.org/images/hglamp.jpg
  grams that include strong environmental
  standards.                                              p. 8 http://www.dep.state.fl.us/waste/quick_
v Require CFL giveaways to include infor-                 topics/publications/shw/mercury/Mercury_
                                                          CFL_Dynamics-final.pdf
  mation on breakage, safe clean-up proce-
  dures and recycling programs.                           p. 10 http://www.mercvt.org/dispose/lampre-
v Consider requiring the phase-out of mer-                cycleproject.htm

Shedding Light on Mercury Risks from CFL Breakage -— 11
Resources                                                 General Information on Energy-Efficient Lighting
                                                          Choices:
If you have further questions, we suggest                 www.energystar.gov/index.cfm?c=cfls.pr_cfls
you contact your state health department or
                                                          http://www.lrc.rpi.edu/
environmental agency or visit their web sites
                                                          www.bulbamerica.com/Indoor-Reflectors-429-cat.htm
Gov’t Advice on CFL Safety and Clean-Up
                                                          http://www1.eere.energy.gov/femp/procurement/eep_
Maine www.maine.gov/dep/rwm/homeowner/fluores-            fluor_tips.html
cent.htm
                                                          www.wattmanledlamp.com/index.php?main_
Massachusetts www.mass.gov/dep/toxics/stypes/hgres.       page=index&cPath=73
htm#dispose
                                                          sev.prnewswire.com/oil-energy/20080219/
Minneapolis www.ci.minneapolis.mn.us/environment/         AQTU01019022008-1.html
fluorescent.asp
                                                          www.popularmechanics.com/blogs/home_journal_
Minnesota www.pca.state.mn.us/waste/lightbulbs.html       news/4217864.html
Vermont www.mercvt.org/PDF/cflampfactsheet.pdf            www.informinc.org/fact_P3fluorescentlamps.php
Florida www.dep.state.fl.us/waste/categories/mercury/     www.newdream.org/consumer/cfl.php
California www.ciwmb.ca.gov/WPIE/HazSub/Mercury.
htm                                                       US NGO Information Resources on CFLs:

USEPA www.epa.gov/mercury/spills/index.                   www.sierraclub.org/policy/conservation/cfl-guidelines.
htm#flourescent                                           pdf
                                                          www.responsiblepurchasing.org/purchasing_guides/
Information on Recycling Programs for CFLs:               lighting/
www.zerowaste.org/publications/CFL/CFL_case_stud-         blogs.consumerreports.org/home/2007/06/qa_are_
ies.htm                                                   there_an.html
www.savingcivilization.org/recycling-light-bulbs.html     blogs.consumerreports.org/home/2007/03/a_darker_
www.ikea.com/ms/en_US/about_ikea/social_environ-          side_o.html
mental/environment.html                                   blogs.consumerreports.org/home/2007/10/cfl-recycling.
www.epa.gov/epaoswer/hazwaste/id/univwast/lamps/in-       html
dex.htm                                                   www.environmentaldefense.org/page.cfm?tagid=609
www.nema.org/lamprecycle/recyclers.html
                                                          Lighting Manufacturers’ Statements:
www.tcpi.com/recycle.aspx
                                                          www.nema.org/gov/ehs/committees/lamps/cfl-mercury.cfm
www.almr.org/
                                                          www.tcpi.com/corp
Third-Party Certification Programs for                    www.gelighting.com
Energy-Efficient Lighting:
                                                          www.osram.com
http://www.greenseal.org/certification/gs-5proposed_re-
                                                          www.lighting.philips.com
vised_standard.pdf
                                                          www.lightsofamerica.com/
www.greenerchoices.org/eco-labels/productIndex.cfm
www.greenseal.org/index.cfm                               European Programs Related to CFLs and Mercury
                                                          Risks:
www.gen.gr.jp/index.html
                                                          www.elcfed.org/documents/070420_ELC_Q&A_on_
home.howstuffworks.com/fluorescent-lamp2.htm
                                                          Domestic_Lighting.pdf.
www.epa.gov/epaoswer/hazwaste/id/univwast/lamps/
lamps.htm                                                 http://eur-lex.europa.eu/LexUriServ/LexUriServ.
www.govpro.com/Issue/Article/38657/Issue                  do?uri=CELEX:32002L0095:EN:HTML

http://www.ecologo.org/en/seeourcriteria/details.
asp?ccd_id=239

Shedding Light on Mercury Risks from CFL Breakage — 12
References Cited                                         Maine Department of Environmental Protec-
                                                         tion, 2007. The Department of Environmen-
Agency for Toxic Substances and Disease                  tal Protection (DEP) Facts Regarding the
Registry, 2006. Mercury. Chemical Agent                  Prospect, Maine Compact Fluorescent Lamp
Briefing Sheet. January, 2006. http://www.               Breakage. May 18, 2007. http://maine.gov/
atsdr.cdc.gov/cabs/mercury/index.html.                   dep/rwm/homeowner/prospecthistory.doc.

Agocs, M.M., Etzel, R.A., Parrish, R.G., Pas-            National Electrical Manufacturers Association,
chal, D.C., Campagna, P.R., Cohen, D,S., Kil-            2007. NEMA Lamp Companies Announce
bourne, E.M., and Hesse, J.L., 1990. Mercury             Commitment to Cap CFL Mercury Content.
exposure from interior latex paint. New Eng-             Press release, March 13, 2007. http://www.
land Journal of Medicine 323(16):1096-1101.              nema.org/media/pr/20070313a.cfm.

Aucott, M., McLinden, M. and Winka, M.,                  Rice, D., 2007. Health Issues Associated with
2004. Release of Mercury From Broken Fluo-               Exposure to Elemental mercury from Compact
rescent Bulbs. Environmental Assessment and              Fluorescent Bulbs. Presentation at a Workshop
Risk Analysis Element, New Jersey Depart-                on Clean-Up Advice for Compact Fluorescent
ment of Environmental Protection. Research               Lamps, sponsored by the Northeast Waste
Project Summary, February 2004. http://www.              Management Officials Association, held at
state.nj.us/dep/dsr/research/mercury-bulbs.pdf           University of Southern Maine, Portland, No-
                                                         vember 7, 2007.
California Department of Toxic Substances
Control. Mercury Report, Final. Sacramento,              Sierra Club, 2008. Sierra Club Guidelines for
August 2002.                                             Selecting, Distributing and Recycling Environ-
http://www.dtsc.ca.gov/loader.cfm?url=/com-              mentally-Preferable Light Bulbs During Mass
monspot/security/getfile.cfm&pageid=13123                Giveaways. February 2008. http://www.sierra-
                                                         club.org/policy/conservation/cfl-guidelines.pdf
Chandrasekhar, T.M., 2007. Remediation
of Indoor Airborne Mercury Released from                 Tunnessen, W.W., McMahon, K.J. and Baser,
Broken Fluorescent Lamps. Florida Dept.                  M., 1987. Acrodynia: Exposure to Mercury
of Environmental Protection, June 15, 2007.              From Fluorescent Light Bulbs. Pediatrics
http://www.dep.state.fl.us/waste/quick_topics/           79(5):786-789.
publications/shw/mercury/Mercury_CFL_Dy-
namics-final.pdf                                         U.S. Environmental Protection Agency (2007).
                                                         Frequently Asked Questions: Information on
Debes, F., Budtz-Jørgensen, E., Weihe, P.,               Compact Fluorescent Bulbs (CFLs) and Mer-
White, R.F., Grandjean, P., 2006. Impact of              cury. August 2007.
methylmercury exposure on neurobehavioral                http://www.energystar.gov/ia/partners/promo-
function at age 14 years. Neurotoxicology and            tions/change_light/downloads/Fact_Sheet_
Teratology 28:363-375.                                   Mercury.pdf

Hirschman, S.Z., Feingold, M. and Boylen, G.,            Weiss, J., 2007. Comparison of Clean-Up
1963. Mercury in House Paint as a Cause of               Advice and Working Towards Alignment. Pre-
Acrodynia. Effect of Therapy With N-Acetyl-              sentation at a Workshop on Clean-Up Advice
D,L-Penicillamine. New England Journal of                for Compact Fluorescent Lamps, sponsored
Medicine 269:889-893.                                    by the Northeast Waste Management Officials
                                                         Association, held at University of Southern
                                                         Maine, Portland, November 7, 2007.

Shedding Light on Mercury Risks from CFL Breakage — 13
Appendix 1

    Sierra Club CFL Guidelines for
 Selecting, Distributing and Recycling
Environmentally-Preferable Light Bulbs
        During Mass Giveaways
Explore, enjoy, and protect the planet

Guidelines for Selecting, Distributing and Recycling
Environmentally-Preferable Light Bulbs During
Mass Giveaways
Many chapters and groups of the Sierra       been included that will help individuals
Club plan to or have engaged in commu-       select the best lamps when making their
nity-based programs to distribute en-        purchases at retail stores.
ergy-efficient compact fluorescent lamps
(CFLs). These efforts help educate con-
sumers about easy and important ways to      Summary Checklist:
reduce energy consumption. Three times       Specifying CFLs for
more efficient than standard incandes-       Distribution Programs
cent light bulbs, CFLs significantly re-
                                             n Require ENERGY STAR–qualified CFLs
duce mercury, greenhouse gases and
                                             (www.energystar.gov) with a minimum             ditions, culture and language.
other toxic emissions coming from coal-
                                             rated life of 10,000 hours, and with the
fired power plants. At the same time,                                                        n Include instructions about what to do
                                                       highest efficiency (lumens per
concerns have been raised because all                                                        (and not do) if a CFL breaks (see below).
                                                       watt). Look for the Energy Star
CFLs contain mercury and some models
                                                       logo on the packaging.                n Distribute in cooperation with com-
contain lead. The vast majority of CFLs
                                                                                             munity leadership, consistent with Envi-
ends up in landfills or trash incinerators   n Require companies to disclose mercury
                                                                                             ronmental Justice protocols.
where these hazardous substances can get     content (in milligrams - mg) and any
released into the environment.               lead in solder and/or glass.
These Guidelines seek to balance and ad-     n Specify lamps with 5 mg of mercury or         Recommendations for
vance the Sierra Club’s goals of climate     less and favor ones with less than 3 mg.        Individuals Purchasing CFLs
protection, toxics reduction and zero
                                             n Choose lead-free whenever available
waste. The primary purpose of these                                                          n Whenever available, choose
                                             (usually labeled as such).
Guidelines is to help Sierra Club chap-                                                      CFLs in an ENERGY STAR–la-
ters and groups optimize environmental       n Choose manufacturers and distributors         beled package. This will help
benefits of energy-efficient lamp distri-    offering private-sector-financed collec-        ensure you buy a more energy efficient
bution programs in their communities.        tion and recycling programs.                    and higher performing product.
The intention is to design distribution
                                             n Include local recycling information with      n Choose the CFL that meets your needs
programs that pressure corporations to
                                             lamps. Encourage consumers to use local         and has the longest rated life. Look for
provide less-toxic lamps, and create pro-
                                             retail and other private collection systems     products that last at least 10,000 hours.
ducer-funded retail recycling opportuni-
                                             when available. Publicly-funded collection      This information is almost always
ties that make it as easy for customers to
                                             should be promoted as transitional to the       printed on the package.
recycle CFLs as it is to buy them. These
                                             creation of private collection opportunities.
guidelines advocate some actions that go                                                     n Choose the most energy-efficient
beyond the capacity of individual con-       n Prepare consumer-friendly fact sheets         model with the fewest watts to give you
sumers; however, recommendations have        and other materials that respect local tra-     the light output you need. (CFLs tend to

Sierra Club Headquarters: 85 Second St., Second Floor • San Francisco, CA 94105 • (415) 977-5500
Sierra Club Washington, D.C. Office: 408 C St. NE • Washington, DC 20002 • (202) 547-1141 • www.sierraclub.org/policy
fade over their life; so pick one slightly    els have a rated life of 10,000 hours or     contain some other heavy metals) should
brighter than the incandescent lamp you       more. The ENERGY STAR criteria for           be evaluated for toxicity and considered
are replacing.)                               LEDs was released in September 2007.         for inclusion in Sierra Club’s distribution
                                              As LEDs become more available and af-        programs when they are determined to
n Choose lamps made by companies
                                              fordable, the Sierra Club should include     be efficient, environmentally preferable
pledging to keep mercury content below 5-
                                              them in their distribution programs          and cost-effective for specific applica-
6 mg by going to www.nema.org/gov/ehs/
                                              since they are longer-lasting and mer-       tions.
committees/lamps/cfl-mercury.cfm.
                                              cury-free. ENERGY STAR-qualified LED
                                                                                           The specification of low-mercury, mer-
n Choose CFLs that manufacturers ad-          lights must have a rated life of at least
                                                                                           cury-free, and lead-free lamps protects
vertise as lead-free.                         25,000 hours.
                                                                                           workers manufacturing these products,
n Choose retailers that offer to collect      The specification and distribution of        consumers (especially if the light bulbs
spent CFLs (and other fluorescent             long-lasting CFLs and LEDs minimizes         accidentally break), and the environ-
lamps). While Ikea is the only U.S. re-       environmental impacts by reducing the        ment. Workers are further protected
tailer that recycles burned-out CFLs con-     number of light bulbs that need to be        whenever fluorescent lamps are manu-
sumers bring back to stores, a                manufactured, transported, and ulti-         factured with encapsulated mercury dos-
retailer-financed lamp “take-back” pro-       mately recycled, as well as the number       ing technologies—such as pellets, pills or
gram has been established in Europe.          that may end up in the trash. It also        amalgam – rather than traditional liquid-
Encourage manufacturers/retailers in          drives innovation by supporting compa-       mercury dosing methods. Mercury is a
your community to set up on-going re-         nies that have invested in high-perform-     toxic heavy metal that persists in the en-
cycling programs for their customers.         ance technology.                             vironment, concentrates in the food
                                                                                           chain, and causes nerve and brain dam-
                                              2. Use least-toxic bulbs                     age, heart disease and cancer. Lead, like
Background and Rationale                                                                   mercury, is a persistent, bioaccumulative
                                              Sierra Club commits to distributing          and toxic chemical known to cause seri-
1. Use energy efficient, long-lasting         light bulbs that have the least mercury      ous, long-term health damage, particu-
                                              and lead.                                    larly to children’s brains.
bulbs
                                              While all CFLs currently contain mer-        Sierra Club encourages manufacturers to
Sierra Club commits to distributing
                                              cury, the amount they contain can vary       label their lamps and packaging with in-
only ENERGY STAR-qualified lighting
                                              from 1-30 milligrams (mg), depending on      formation on mercury and lead content
products, including CFLs and Solid
                                              manufacturer and model. Several major        for each model. Mercury content should
State Lighting (SSLs-including light-
                                              manufacturers (including some members        be labeled as a maximum per lamp, not
emitting diodes (LEDs).
                                              of the National Electrical Manufacturers     an average or range. In addition, Sierra
The ENERGY STAR program, which is             Association, www.nema.org/gov/ehs/           Club should consider distributing
jointly run by the US Department of           committees/lamps/cfl-mercury.cfm.)           CFLs/LEDs with separate ballast/trans-
Energy and the US Environmental Pro-          have agreed to cap mercury at 5 mg in        formers, when available, just as in fluo-
tection Agency (EPA), qualifies CFLs,         most models, but some CFLs are avail-        rescent tube lamps. This will decrease the
SSLs and other energy-efficient lighting      able with as little as 1 mg of mercury.      amount of materials in CFLs and LED
products that meet minimum perform-           Sierra Club distribution programs            lamps requiring disposal, help retain
ance standards for efficacy, lamp life, and   should specify CFLs with a maximum of        longer-lived components during their
light quality. Qualified lighting products    5 mg of mercury and give preference to       entire useful life (like solid-state circuit
are listed on the ENERGY STAR website at      CFLs with less than 3 mg of mercury.         boards and transformers), and decrease
www.energystar.gov. CFLs chosen for                                                        purchase, recycling and disposal costs for
                                              Similarly, many CFLs (and other light
mass distribution programs should offer                                                    manufacturers and consumers alike.
                                              bulbs with screw-in bases) are made with
the highest efficiency, which is measured
                                              lead in the solder and glass. Lead-free      These actions are consistent with toxics
in lumens per watt. CFLs tend to fade
                                              CFLs are becoming increasing available       use reduction, right-to-know and pollu-
over time, so it is important to specify
                                              in the marketplace as lead solder is being   tion prevention/zero waste principles in
models that emit about 20-30 percent
                                              banned from other electronic and electri-    Sierra Club’s Environmental Justice Policy
more initial lumens than the incandes-
                                              cal applications in Europe and elsewhere.    as well as in its Environmentally Haz-
cent it is replacing.
                                              Sierra Club encourages its members to        ardous Substances Policy, which discour-
The ENERGY STAR program has set a             distribute lead-free CFLs whenever they      ages use of hazardous substances that
minimum rated life of 6,000 hours for         are available and meet other performance     persist in the environment and tend to be-
all qualified CFLs but the program’s          and environmental criteria. In addition,     come concentrated in living organisms.
website indicates that nearly 1,000 mod-      LEDs (which are mercury-free but may
3. Promote recycling take-back by             bution should direct consumers to use        Model Policy Language for
retailers, vendors and producers.             local retail and other private sector col-   Producer Responsibility as it
Sierra Club commits to promoting
                                              lection sites and methods, in preference     Relates to Hazardous Material
                                              to taxpayer-funded collection programs.      Recovery from Consumer
effective recycling programs and assisting
                                              The Sierra Club supports and will work       Lighting
local governments by supporting
                                              towards enforceable producer responsi-
recycling take-back by retailers, vendors
                                              bility standards for collecting and recy-    Every manufacturer of general purpose
and producers.
                                              cling hazardous lighting products (see       lights sold in ____ state and containing
When the Sierra Club engages in CFL           model criteria below).                       hazardous materials shall be responsible
distribution programs, we have a respon-                                                   for all of the following:
                                              All Sierra Club CFL distribution pro-
sibility to inform consumers of the mer-
                                              grams must include instructions for re-      (a) On and after [date], ensuring that a
cury in fluorescents and potential lead in
                                              cipients about what to do, and not do, if    system is in place to provide for the col-
both incandescents and fluorescents, and
                                              a CFL breaks—such as ventilating the         lection and recycling of any end-of-life
the consequent urgency to recycle them
                                              room but not vacuuming. A US EPA fact        general purpose lights generated in this
at end of life. However, public collection
                                              sheet available at www.energystar.gov/       state.
infrastructure (household hazardous
                                              ia/partners/promotions/change_light/
waste collection centers and events) are                                                   (b) On or before [date], submitting a
                                              downloads/Fact_Sheet_Mercury.pdf . It
not equipped to sustainably address this                                                   plan (the plan) to the [State department]
                                              should be given to all volunteers working
problem. Only about 2% of household                                                        for the collection, recycling, and proper
                                              on the distribution program so that they
fluorescent lamps are recycled in the U.S.                                                 management of end-of-life general pur-
                                              know what to tell people if they ask that
(Association of Lighting and Mercury                                                       pose lights generated in this state.
                                              question. In addition, the Club calls upon
Recyclers, 2004). Local governments
                                              EPA to carefully evaluate its cleanup        (c) The plan shall include all of the fol-
currently pay exorbitant sums to collect a
                                              methods to determine their effectiveness     lowing:
small portion of all retired lamps. Where
                                              on all surfaces including carpets.
local government collection is the only                                                    (1) The methods to be used by the man-
option, simply telling consumers “Please                                                   ufacturer to collect and properly manage
Recycle” is both misleading to con-           4. Serve low-income communities              spent devices generated in xxxx state.
sumers and frustrating to underfunded
                                              Sierra Club volunteers involved in en-       (2) The number and frequency of collec-
and ineffective public sector programs.
                                              ergy-efficient lighting distribution pro-    tion(s).
Ultimately, it should be as easy to recycle   grams should make a good faith effort to
                                                                                           (3) The methods to be used to educate
CFLs as it is to purchase them. This re-      build bridges with low-income commu-
                                                                                           consumers about the opportunities pre-
quires development of convenient pri-         nities where appropriate, in line with En-
                                                                                           sented in the plan.
vate sector collection and recycling          vironmental Justice principles and
opportunities. Sierra Club chapters and       protocols. The Sierra Club should pro-       (4) The funding mechanism(s) to ac-
groups should aggressively support local      vide versions of materials that respect      complish the plan originate from the
government efforts to develop retail and      local traditions and language. Working       manufacturer(s).
vendor take-back programs for mercury-        with community leadership will make
and/or lead-containing lamps, preferably      distribution efforts more welcome.
through producer-funded programs.             Reaching out to low-income populations
Distribution programs should give pref-       will increase the use of energy-efficient
erence to using wholesalers or retailers      products in neighborhoods where resi-
who provide take-back services. Recy-         dents may be the least likely to afford
cling information provided during distri-     them on their own.

                                                                                                                      FEBRUARY 2008
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