EPA’s Mercurial Hypocrisy

How cynical is the U.S. Environmental Protection Agency about the potential mercury hazard of compact fluorescent light bulbs (CFLs)?

Last week the EPA issued new guidance for the clean-up of mercury-containing CFLs.

Atypically minimizing any potential health risks and arrogantly assuming that people patronize the agency’s web site, the EPA’s media release states,

CFLs contain a small amount of mercury sealed within the glass tubing. When a CFL breaks, some of the mercury is released as vapor and may pose potential health risks. The guidance and brochure will provide simple, user friendly directions to help prevent and reduce exposure to people from mercury pollution. [Emphasis added]

But consider that EPA’s “Mercury and Hazardous Chemicals in Schools: A Manual for Students in Southeast Asia” (April 2008) states that:

Just as there are no safe uses of mercury and mercury-containing equipment in schools, there are no safe uses for these products in homes, either. Tell your parents about the toxic effects of mercury, and encourage them to remove all mercury products from your home.

Also consider that EPA says that eating the mercury from a broken thermometer is safer than inhaling mercury vapor (i.e., how you would be exposed to mercury from a broken CFL):

It is not uncommon for children to break fever thermometers in their mouths. Mercury that is swallowed in such cases poses low risk comparison [sic] to the risk of breathing mercury vapor.

Consider what Brown University researchers had to say in an August 2008 study of CFL breakage published in the journal Environmental Science and Technology:

Some [CFL] lamps are inevitably broken accidentally during shipping, retail sales, consumer use, and recycling and release a portion of their mercury inventory as volatile vapor, which is the dominant mercury form in the early stages of lamp life. Inhalation exposure is a concern because 80% of inhaled [mercury] is physiologically absorbed.

  • The Occupational Safety and Health Administration’s (OSHA) occupational exposure limit (8 h, 5-day week time average) is 100 [micrograms per cubic meter (μg/m3)].
  • The National Institute for Occupational Safety and Health (NIOSH) recommended exposure limit is 50 μg/m3, while American Conference of Governmental and Industrial Hygienists recommends 25 μg/m3 under the same conditions.
  • Because children are more susceptible, the Agency for Toxic Substances and Disease Registry (ATSDR) recommends 0.2 μg/m3 level as a safe continual exposure limit for children.

As an illustration of the effects of CFL breakage, the release of only 1 mg of [mercury] vapor (~20% of the Hg inventory in a single CFL) into a 500 m3 room (10 × 10 × 5m) yields 2.0 μg/m3 or ten times the ATSDR-recommended level of 0.2 μg/m3 in the absence of ventilation. [Footnotes omitted, and bullets and emphasis added]

So how much mercury was released into the air when these researchers fractured CFLs in their study? According to the Brown researchers,

The release is initially rapid producing vapor concentrations from 200−800 μg/m3 during the first hour, which far exceed the OSHA occupational limits.

And if you go to EPA’s IRIS data base, you’ll see that the EPA’s Reference Concentration (RfC or permissible exposure via inhalation) for elemental mercury is 0.3 μg/m3. Note that the reported 200-800 μg/m3 air concentrations upon bulb breakage are somewhat greater  than the EPA’s RfC (by 667 to 2,667 times to be precise).

The EPA promotes the safety of CFLs  in order to advance its jihad against greenhouse gases. The agency would apparently rather have you and/or your children exposed to possibly thousands of times more mercury than the agency itself deems safe than to have you use an incandescent bulb and emit an ounce or so more of CO2 per hour of bulb use.

Were CFLs not useful in the EPA’s cause —  let’s say they were just a funny looking light bulb sold as a novelty item — there can be little doubt that the agency would have long ago taken action to ban them as needlessly unsafe. The agency has stated, after all, “there are no safe uses for mercury-containing products] in homes” and children should tell their parents “to remove” them from homes.

Would you rather be exposed to possibly thousands of more times mercury than the EPA says is safe or....
... or would you rather have your power plant emit an extra ounce or so of carbon dioxide per hour of bulb use?

One common requirement for science, law and government to function as intended is consistency. Exposure to low levels of mercury is either safe or it is not. But the EPA wants it both ways, depending on the purpose being served.

In the realm of federal regulation, this sort of hypocrisy would seem to be proscribed by the Administrative Procedures Act (APA) as “arbitrary and capricious.” When the APA was enacted in 1946, then-Nevada Sen. Pat McCarran called it “a bill of rights for the hundreds of thousands of Americans whose affairs are controlled or regulated in one way or another by agencies of the Federal Government.”

But since there is typically no meaningful way for anyone to enforce that law against the EPA, it is a mere vestige of Congress’ post-New Deal efforts to make the burgeoning federal bureaucracy accountable to the people that pay for, and are impacted by it.

Maybe that accountability is something that the 112th Congress, which begins this week, can begin to reinstate.

11 thoughts on “EPA’s Mercurial Hypocrisy”

  1. Pingback: The Real Polluters
  2. Why the alarm about mercury in CFLs with no mention of the long tube fluorescent bulbs that have been illuminating offices and schools for generations? The average fluorescent tube contains about 40mg of mercury. That’s 8 times the amount in a typical CFL bulb.

    Through all those decades, and even to this day, there’s never been this kind of outcry about mercury in those fluorescent lights.

    The obvious difference is that no one (yet) is compelling private citizens to install the long tube fluorescent fixtures into their homes against their will.

    Whatever one thinks of AGW or mercury toxicity, I think we can all agree that the hubbub is less about science than politics. This article does make that point from an anti-regulation perspective, but when protests selectively target CFLs while overlooking tubes, the same point can be made by the other side.

  3. From Wikipedia: “Mercury poisoning of Chinese factory workers
    In the past decade, hundreds of Chinese factory workers who manufacture CFLs for export to first world countries were being poisoned and hospitalized because of mercury exposure. Examples include workers at the Nanhai Feiyang lighting factory in Foshan where 68 out of 72 were so badly poisoned that they required hospitalization. At another CFL factory in Jinzhou, 121 out of 123 employees were found to have excessive mercury levels with one employee’s mercury level 150 times the accepted standard.”

    Can anyone say, “blood light bulbs”?

    Also, keep in mind that Hg vapor is adsorbed onto organic (carbon containing) media such as carpet and is released during foot traffic. And guess who is closest to floors? Infants get a good snort of Hg adsorbed in carpets. Hg is a persistent bioaccumulative and toxic (PBT) compound otherwise regulated by EPA from steam boilers. Exposure by inhalation is the worst possible route of ingestion, especially by children.

  4. Why should this surprise anybody? Certain guns on the shelves of civilian gun stores are called “assault weapons” and politicians parrot that they are “only good for one thing — to kill the greatest number of people in the shortest time possible.” Yet when police departments order them by the crateload, they are suddenly “tactical rifles,” and nobody asks why a police department is preparing to “kill the greatest number of people in the shortest time possible.”

  5. We should defund the EPA and then abolish it at the first opportunity. It has exactly 0 Constitutional authorization.

  6. Yyes I can see everyopne now just tossing these bulbs along with the mercury into the land fills we have nto even begun to see the damage done n=by our so called over seer’s that claim to know everything about everything. it is comparable to the ban on DDT which saves lives by the country full millions would be alive today if it had not been banned . led’s and incandescent light is the only way to light up your world in your home . the mercury will wind up in our ground water and contaminate our drinking water which may be their goal in the first place . Does it not make one feel warm and fuzzy all over to know we have a person just barely out of puberty slinging the regulations around like a wild person.

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