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Mercury (Recycling) Rising

More states are mandating reduced mercury usage and increased recycling.

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On July 28, 2006, Massachusetts became the ninth state to require all “spent” mercury lamps to be recycled. Mercury, a toxic substance, can impair child development, disrupt the nervous system, damage brain function, cause allergic reactions and negatively impact reproduction. Traditionally, it’s been prevalent in thermometers, child vaccinations, measuring instruments, dental fillings and novelties (blinking shoes, toys, greeting cards).

The Environmental Protection Agency (EPA) estimates 263 tons of mercury are released into the U.S. air annually, via coal burning, utilities, incinerators, boilers and mining.

For the on-premise sign industry, mercury is prevalent in fluorescent lamps and much of the neon process.

At the federal level, mercury-containing lighting products are regulated by the EPA, under the Universal Waste Rule, which is a subset of the Resource Conservation and Recovery Act, Subtitle C hazardous-waste regulations. This may be found in the Code of Federal Regulations (40 CFR Part 273) and in the July 6, 1999 Federal Register, Volume 64 Number 128, pp. 36465-38490.

States, of course, may enact more stringent policies; more than half do, regarding mercury-containing lamps. At the municipal level, Duluth, MN and Ann Arbor, MI, banned mercury thermometers in 2000.

Most sign companies are exempt from the UWR, due to the Conditionally Exempt Small-Quantity Generator (CESQG) provision, which absolves generators of less than 220 lbs. of hazardous waste per month. However, nine states (CT, DC, ME, MN, MO, NE, NY, OH, RI and VT) and the District of Columbia don’t allow the CESQG, so all mercury-containing lamps must be recycled. Kansas allows an exemption for less than 55 lamps per month, California for less than 30 lamps, Tennessee for less than 15 and Florida for less than 10. (Ed. Note: Some of these may have changed.)

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The bipartisan National Conference of State Legislatures reports more than 200 mercury-related bills have been introduced in at least 30 state legislatures since 2000. In mid-June, the Northwest Waste Management Officials’ Assn. (NEWMOA) website (www.newmoa.org) said 32 states introduced mercury-product legislation during the 2007-2008 Legislative Session. From this, nine bills were adopted (see examples at the end of this article). NEWMOA, recognized in 1986 by the EPA, represents the six New England states, plus New York and New Jersey.

In 1999, NEWMOA launched the Interstate Mercury Education & Reduction Clearinghouse (IMERC) to provide guidance, fact sheets and reports. It lists corresponding websites for 13 states, those previously mentioned, plus California, Illinois, Minnesota, North Carolina and Washington.

These accelerating regulations concern two aspects: decreasing or minimizing the use of mercury in products, and forcing the recycling of mercury.

IMERC published a fact sheet entitled “Mercury Use in Lighting.” Under its heading of “Neon Lights,” it wrote, “The neon light industry is a cottage industry. Artisans make each lamp individually in small workshops. The vast number of neon-light manufacturers has made it difficult for IMERC to identify and reach out to them. For this reason, IMERC-member states have not yet received Notifications from most of the manufacturers of neon lights.

“Neon lights are estimated to contain approximately 250 to 600 milligrams of mercury per bulb. A new product developed by the manufacturer Eurocom Inc. can reduce the amount of mercury used by 80%.”

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Mercury Recycling (www.mercuryrecycling.co.uk), which states it opened the United Kingdom’s first lamp-recycling facility in 1996, reports the mercury from one fluorescent tube pollutes 30,000 liters of water beyond what the United Kingdom considers a safe drinking level. It further states fluorescent tubes are 2% phosphor powder, and this powder includes the mercury.

Back across the big pond, the Assn. of Lighting and Mercury Recyclers (ALMR) has 19 members (www.almr.org). This Calistoga, CA-based national, nonprofit association represents companies that recycle lamps and mercury. Six members provide national recycling service, while eight others describe themselves as regional. The only international recycler listed, Veolia Environmental Services (www.veoliaes.com), lists nine U.S. locations and ones in France and Norway.

Only one U.S. member, Air Cycle Corp. (Broadview, IL), is listed as making recycling equipment, specifically, lamp-crushing equipment (www.aircycle.com). A Swedish company, MRT System (www.mrtsystem.com), which reports having representatives in 36 countries, makes mercury distillers and equipment that will crush and separate mercury-bearing lamps.

Although 12 ALMR members report handling ballasts, only two (both national) specify transformers: Lighting Resources, Inc. (www.lightingresourcesinc.com) and Luminaire Recyclers Inc. (www.luminairerecyclers.com).

Paul Abernathy, the ALMR executive director, explained that efficient recycling is all about standardization. Recycling fluorescent tubes is relatively easy: Put them in standardized boxes, and ship them.

Neon tubes, however, are irregular and almost always require special arrangements, he continued. And “special” also means more expensive. He couldn’t site a single case history concerning the recycling of neon, and he guessed his members would handle less than 1,000 lbs. a year.

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Jerry Odenwelder, a technical sales manager for Bethelem Apparatus Co. Inc. (Hellertown, PA, www.bethlehemapparatus.com), handles most of the recycling for a prominent, neon-component manufacturer, but he said his company only receives material from sign companies sporadically. Odenwelder estimates receiving less than six requests a year. The company can’t accept any electrical components or transformers.

Although there doesn’t seem to be an industry consensus on this method, Odenwelder said the neon tubes are “crushed into a drum.” To echo Abernathy, he said separating the mercury “is not a cheap process,” and he described the excess as “garbage glass.” Once the mercury is isolated, however, Odenwelder said the subsequent process of “cooking it and distilling it” is easy, and then the mercury can be resold.

Earlier this year, the sign industry erupted with the report that Vermont had banned the sale of neon signs and other mercury-containing tubes. Although essentially correct, some reports neglected to explain available exemptions. The Vermont Dept. of Environmental Conservation imposed the ban January 1, but the exemption applications had been available for nine months (and continue to be) via the aforementioned IMERC webpage. Questions about the ban and the exemptions can be sent to Karen Knaebel at Karen.Knaebel@state.vt.us.

Sign-related mercury bills adopted in 2007 include the following:

• On May 1, Alabama’s Act 452 prohibits anyone from “knowingly” disposing of an “electric lighting device” in a landfill after Jan. 1, 2008, if it contains more than two-tenths of one milligram per liter of “leachable mercury as measured by the Toxicity Characteristic Leaching Procedure as set out in EPA test Method 1311.”

• In Maine, the Chapter 25 law requires “clear warnings on lightbulbs containing mercury.” The adopted House version directs the Dept. of Environmental Protection and the Public Utilities Commission to develop a program that supports fluorescent-lamp recycling.

• In Minnesota, SF 1085, in part, prohibits the sale of mercury-containing products (but not lamps) and regulates the disposal of fluorescent lamps by requiring their delivery to lamp-recycling facilities.

Although mostly unrelated, at press time, the White House said President Bush would veto a bill that would ban childhood flu vaccines that contain thimerosal, a mercury-based preservative.

Overall, the EPA strongly urges the recycling of any mercury-containing item, whether or not it’s mandated. Because of its scattered nature, the sign industry can probably avoid most of its responsibilities. Of course, the more responsible action is to contact a recycler.

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