Article Archive
Focus on Hazmat - Sept/Oct 2008
Did We Really Mean To Do That?
Volume 23, No. 5

Until the dawn of the twentieth century, Americans and most of the rest of the world for that matter, were pretty much on their own so far as insuring the quality of the food they ate, the medicines they took for their illnesses or the safety of their workplace environments. America was an agrarian society made up of small isolated communities in which everyone knew everyone else and one knew who milked his cow, churned his butter, baked his bread and prepared his medicines; and, he knew how it was done and what went into the final product. He knew that he needed to keep his hand out of the feed mill and also what would happen to him if he did not. Any untoward happening was considered to be his own fault; it was too bad but he should have known better or been more attentive to what he was doing.

As the urban population grew as a result of the great migration from Europe, this idyllic picture of American society changed radically. Foods, drugs and other essential commodities became products, created in inanimate factories by anonymous employees of aggressive and sometimes insensitive entrepreneurs and, as always, there were those who would place profits before quality. In 1906, Upton Sinclair published his muckraking novel The Jungle, which dealt with conditions in the U.S. meat packing industry. The public uproar that followed is credited, at least in part, with the passage of the Pure Food and Drug Act and the Meat Inspection Act in 1906. Thus began the first sustained effort on the part of the government to insure the health and safety of its citizens through regulations and their enforcement.

The trend has continued until the present day, expanding exponentially with the creation of the Centers for Disease Control (CDC), the Occupational Health and Safety Administration (OSHA), the Mine Safety and Health Administration (MSHA), the Department of Transportation (DOT), The Federal Aeronautics Administration (FAA) and the Environmental Protection Agency (EPA) among others, all of which promulgate rules and regulations and have a bearing on legislation passed by Congress.

As a result, the American public has become used, or almost addicted to the idea that the way to protect against any risk or hazard is to legislate against it, or, at least, regulate it, and this is the duty or responsibility of government. John Q. Public wants to be guaranteed a risk free environment; but I've got news for John Q "it ain't gonna happen."

To be sure, most of the protective laws and agencies, especially the earlier ones, were created for laudable reasons to satisfy a real need to protect health or safety of the citizenry or the environment. Certainly no one should be allowed to use formaldehyde to preserve fresh milk or sell cosmetics containing salts of lead, mercury bismuth or other heavy metals.

Other laws have been enacted for the sake of political expediency. After all, what politician wants to be seen as opposed to preserving the environment or providing a safe work environment? Some laws were created in response to the pressure generated by public concern and in some cases actual fears, which were sometimes exacerbated by the media. Whether these concerns or fears are valid does not really matter; they exist, and they can cause a lot of political heat to be generated.

Legislation, and indeed most human endeavor, is subject to the "law of unintended consequences." In an article appearing in The Concise Encyclopedia of Economics, Rob Norton states, "The Law of Unintended Consequences, often cited but rarely defined, is that actions of people--and especially of government--always have effects that are unanticipated or unintended. Economists and other social scientists have heeded its power for centuries; for just as long, politicians and popular opinion have largely ignored it."

In many cases, these "unintended consequences" have actually negated the original purpose of the regulation. Thus we have the Americans with Disabilities Act (ADA), which was intended to increase opportunities for those with disabilities, but, because it increased the cost of hiring employees with disabilities, it has actually decreased their opportunities for employment.

Fire prevention measures within forested areas have actually increased the danger of fire and the damage caused by it through the accumulation of debris. The corn-based ethanol program has increased the demand for corn and resulted in a large increase in food prices, not only in the United States but around the world. The environmental movements has delayed, if not actually prevented, the construction of newer, more efficient oil refining facilities, and this has contributed, at least in part, to the current high price of motor fuel.

In the Desert Southwest, water is a precious commodity. When we find it, we clean it up and use it. When the EPA mandated that all runoff water had to be confined to the site where it originated, the result was the construction of containment ponds to hold this runoff water. The idea seems to have been that any contained water would percolate into the soil (and in the process possibly contaminate the underground aquifers) instead of flowing to the river where it could be caught in reservoirs downstream for later use. The lawmakers failed to reckon with our "adobe" clay soils. These soils hold water like a jug. This is also true of the red clay in Georgia and the "red bed" of west Texas among many others.

To comply with the EPA directive, property owners have constructed holding ponds on the grounds of their buildings to contain the runoff water and keep it on site. As a result, there are numerous, nicely landscaped ponds all over the community. These are usually filled with large rocks to prevent people or animals from falling in and drowning. These ponds have no outlet and once filled simply sit until the water is removed by pumping or evaporated by the sun. The water stagnates, becomes a source of odor, and, worse, provides, an ideal breeding place for mosquitoes, some of which can, and on occasion do, carry West Nile Virus (WNV). Rains produced by the remnants of Hurricane Dolly have prompted local government to initiate a frantic effort to get all of these ponds sprayed before the WNV-carrying mosquitoes can reproduce. Of course, spraying introduces more pesticide into the environment.

The basic tenants of the promulgations of EPA and OSHA are good and well intentioned, but the "unintended consequences" that have accompanied these regulations have at times created more hazards than they have eliminated.

Another "unintended consequence" of legislation has been the creation of a climate of fear in the mind of the public. As a result, we have seen proposed legislation based on what might happen rather than credible evidence of an existing hazard. No matter how badly society wants it, a risk-free world simply does not and will not exist. Every action carries with it a certain amount of risk. When one steps out to cross the street there is a risk present, even though the light is with the pedestrian. Does the pedestrian want to get to the other side of the street badly enough to justify the inherent risk?

The search of a risk-free society has been a windfall to the personal injury lawyers. Almost nightly we see television advertisements asking, "Have you been hurt by so and so or think you might have been? If so, call this number you may be entitled to compensation." Another television ad actually starts off with the words if you or a loved one has died......" It would be interesting to know just how many inquiries this lawyer has gotten from people who have died. There is risk involved in the use of virtually any medicine, but look at the alternatives; would anyone in his right mind want to have his appendix removed sans anesthetic because of the risk? Would a patient with 98 percent heart blockage forego bypass surgery because the drug Trasylol carries a risk of kidney problems? I think not. The means (relief of surgical pain or bleeding) would justify the risks involved; and besides, you can always sue your doctor later, at least according to some of the personal injury lawyers.

Risks are not restricted to medical issues and as a result we have Material Safety Data Sheets (MSDS) that warn us of the hazard of dropping a steel plate on toes or being hit on the head with it. The coffee cup that one gets at the fast food restaurant now carries the warning that coffee is hot (one would think that the sense of touch would tell him that), as if anyone would want his morning coffee at room temperature.

Mercury (atomic number 80, atomic weight 200.59) is one of the transition ("B" family) elements. Its oxidation states are +2 and +1. Due to its low melting point (-38.58?C), mercury exists as a liquid at room temperature. It is the only metal with this property but gallium (atomic number 31) is closest with a melting point of 29.76 ?Celsius.

Mercury is considered toxic but in reality its toxicity when in the elemental (metallic) state is not nearly as great as it is when combined or when it is encountered in the vapor state. In fact, "elemental mercury is usually quite harmless if touched or swallowed. It is so thick and slippery that it usually falls off your skin or out of your stomach without being absorbed."1 This accounts for its successful use as a weight when introducing some of the early stomach tubes for gastric analysis.

In order to be toxic, a substance must be absorbed into the tissues, and for this reason compounds of mercury which are soluble are far more toxic than the pure metal which is virtually insoluble. Thus the government has banned many mercury-containing medicinals such as red mercurochrome and merthiolate.

While it has not yet been banned, thiomerosal, a common preservative for vaccines and used since the 1930's, has been under scrutiny as a cause of autism and other brain development disorders found in young children. So far mainstream medical opinion is that no convincing scientific evidence supports these claims but the Centers for Disease Control (CDC) and the American Academy of Pediatrics (AAP) under the precautionary principle, which is an assumption that there is no harm in exercising caution even if it later turns out to be unwarranted, have asked vaccine manufacturers to remove thiomerosal from vaccines as quickly as possible. The compound has been rapidly phased out of most U.S. and European vaccines.

Mercury vapors are also toxic and the inhalation of these vapors emanating from spilled mercury can have serious consequences. This is the rationale for the current efforts to reduce the amount of metallic mercury in the environment. Mercury that has been absorbed into the body tends to remain in the body.

While the average citizen is not aware of it, there is a great deal of elemental mercury in the ordinary environment. It is present in thermostats, electrical switches and dental fillings. It is also used to fill various gauging instruments (thermometers and barometers) and manometers (the doctor's sphygmomanometer for example).

Mercury is also a component of batteries and, with the proliferation of small efficient electronic devices such as in-ear hearing aids, cell phones, pocket radios and digital cameras, the number of these being used and later discarded into the environment is growing exponentially, becoming a matter of concern to environmentalists.

Because metallic mercury was formerly used in various oil field gauging instruments, the petroleum industry has now been required to spend great sums of money to clean up the sites of numerous pipeline gauging stations and refineries.

In the nineteenth and early twentieth centuries, large amounts of mercury were used as a component of the amalgam process to extract precious metals from their ores. In this process, up to 300 pounds of mercury are combined with a ton of metallic ore, thus an amalgamation of the mercury and other metallic minerals is formed. This method, for example, extracted some 50-85 percent of the precious metals from the Comstock Lode ores it was used to treat. In the process, however, one to three pounds of metallic mercury were usually lost to the environment in a typical operation. In the case of the Comstock Lode, several million pounds (up to 14 million pounds by some estimates) of elemental mercury now exists in the Carson River down stream from the mills. This mercury will eventually be converted to soluble compounds and slowly find its way into the food chain as methylmercury or other compounds which can be assimilated by the human body.

While the amalgam process has been superseded by the cyanide process in the United States, mercury is still used in many Third World countries to treat precious metal ores and continues to be a source of environmental contamination. Cyanide on the other hand will rapidly degrade into carbon and nitrogen in sunlight or in contact with the atmosphere. Cyanide can also be rapidly neutralized by hydrogen peroxide and other chemicals. Even though cyanide is highly poisonous, the fact that it will deteriorate in the environment makes it more desirable than the amalgam process.

Another source of mercury is the exhaust from coal burning power plants. Now there is, of course, nothing unique about power plants. Any coal fired factory will emit mercury, but the generation of power accounts for the largest amount of coal consumption in the U.S.

In recent years, the rising cost of energy has caused the general population to focus on efficiency in the home and in the work place. One of the biggest, if not the biggest, energy wasters is the incandescent light bulb. This device has been around for almost a hundred years and it was truly one of the great inventions of the twentieth century; but it is very inefficient with 95 percent of the energy consumed being given off as heat rather than as light. This is not a bad thing when you are brooding baby chicks with a couple of 150 watt light bulbs but it does become a problem when these same lights raise the temperature of an already stifling living room in the summer.

The problem becomes more acute with the advent of air conditioning. Now we find ourselves paying to create the heat as a by product of light and then paying again to pump it out of the house. The same thing, by the way, applies to the domestic refrigerator. The heat extracted from the food compartment is discharged into the room through the condenser, thus increasing the load on the air conditioning system and causing us to spend more money to remove it.

In 1992 the EPA initiated the Energy Star program to promote efficiency. Part of this program encourages the phase out of tungsten lamps in favor of more efficient types. In reality this means Compact Fluorescent Lamps (CFLs). These lamps are 75 percent more efficient than conventional tungsten lamps. For instance, a standard 150 watt tungsten lamp will consume, you guessed it, 150 watts of energy and produce 2,600 lumens, the equivalent CFL emitting the same light (2,600 lumens) will consume on the average 41 watts of power to produce the same 2,600 lumens; a saving of about 75 percent. The energy saved translates into less required generation of power and less carbon emissions, or a smaller "carbon footprint."

The Energy Independence and Security Act of 2007 (the "Energy Bill"), signed by the President on December 18, 2007 requires all light bulbs use 30 percent less energy than today's incandescent bulbs by 2012 to 2014. The phase-out will start with 100-watt bulbs in January 2012 and end with 40-watt bulbs in January 2014. By 2020, a Tier 2 would become effective, which requires all bulbs to be at least 70 percent more efficient (effectively equal to today's CFLs). While this legislation does not specifically mandate the use of compact fluorescent lamps, they are about the only viable alternative to the tungsten lamp currently available. On the surface, this legislation has a laudable purpose, but that "Law of Unintended Consequences" does come into play.

All of the high efficiency lamps now available contain mercury. This is true whether they are the mercury vapor lamps or the high pressure sodium vapor lamps that light streets, factories and plant areas or the common fluorescent tubes that light supermarkets, offices and classrooms. All contain some mercury. Each CFL or fluorescent tube contains about four or five mg of the metal. The exception is the low pressure sodium (LPS/SOX) lamps which usually do not contain mercury but these are not suitable for general illumination where the ability to distinguish colors is essential. This mercury is a source of environmental contamination in the event of breakage or when the lamp is discarded at the end of its useful life.

Presently most mercury-containing lamps (particularly those types containing the most mercury) are contained in fixtures that are inaccessible to the general public such as signs, street lights, large manufacturing facilities and athletic fields, gymnasiums or auditoriums. Lamps in such installations are normally fairly well protected from breakage by their housings and their inaccessible locations and are usually maintained by professionals who see to it that the replaced lamps were disposed of in a safe manner. There are relatively few vapor discharge lamps in the average home, and those that are present are the familiar fluorescent tubes. These are usually located in mounted fixtures and are out of reach of children or pets.

With the advent of the CFL this is changing. CFLs are now found in desk lamps, in mechanic's drop lights and in other portable lighting applications throughout the home, office, plant or factory where they have simply been installed in existing fixtures to replace the heat generating and power hungry tungsten lamps previously utilized. CFLs in these applications are far more susceptible to breakage than are those housed in inaccessible mounted fixtures. Because of this possibility of accidental breakage, many jurisdictions now require secondary containment of the traditional fluorescent tubes when used in hazardous locations and sometimes in public buildings. This usually takes shape in the form of a flexible clear plastic tube fitted with sealing end caps that slips over the lamp at the time of installation and contains the fragments and the metallic mercury in the event of breakage. We have found no indication of this requirement for fluorescent tubes installed in private homes. Neither is there any record of any secondary containment requirement for CFLs.

To be sure, each vapor discharge lamp contains only a small amount of elemental mercury (four to five mg) but look at a modern city, operating refinery or other similar industrial installation at night to get an idea of the number of mercury-containing lamps in operation. In aggregate, this represents a significant quantity of mercury and this amount will increase as CFLs become more common.

One retailer has announced a sales goal of one million CFLs for 2008. This goal is llikely to be met and possibly even exceeded. The main reason is that conversion of an existing light fixture to use CFLs is usually easy. Unlike the traditional fluorescent tubes or other vapor discharge lamps, CFLs do not require a special fixture containing a ballast transformer and/or a starter. All of these components are contained in the base of the lamp. All that is necessary for conversion is to unscrew the old tungsten bulb, screw in the new CFL and turn on the switch; nothing else is required. It is also true that as CFLs are discarded, more valuable materials, mainly metals, are lost and may revert to the environment unless a vigorous effort is initiated and pursued.

The current OSHA standard for mercury in air is 0.1mg/m3; therefore the 5 mg in an average CFL could contaminate 50 cubic meters of atmosphere. An average ten by twelve foot room with an eight foot ceiling contains 27.19 m3, thus a spill of the mercury contained in one CFL could significantly contaminate two rooms. Parameters like whether or not the lamp was operating at the time or if the mercury contained in it would be warm and therefore more likely to be released in the vapor state as opposed to the emanation from a cold, or non operating, lamp which might release some metallic mercury which is less dangerous. A catastrophic event such as a fire, explosion or violent weather, impacting a large industrial installation or city could cause the breakage of a significant number of mercury-containing lamps and concurrently the release of a dangerously large amount of mercury.

Firefighters responding to an incident in even a moderate sized mercantile or industrial establishment should bear in mind the large number of mercury containing lamps in these locations and always use appropriate respiratory protection. This admonition should also be heeded by clean up crews removing debris after the initial event.

Government guidelines for handling a broken CFL or regular fluorescent lamps include:

  • Evacuation of the room and preclusion of the use of a vacuum cleaner, which would spread the contamination.
  • Ventilation of the area for 15 minutes before attempting clean up and the continuation of ventilation for several hours afterward. This may lower the concentration of mercury in the room but it will spread it over a larger area. Air conditioning may well circulate the contamination throughout the entire system.
  • Pat the area of the spill with the sticky side of duct tape, packing tape or masking tape to pick up fine particles. Wipe the area with a wet wipe or damp paper towel to pick up even finer particles. This is good practice so far as picking up shards and small particles of glass, but just how much mercury will be picked up is questionable since the metal does not readily adhere to such surfaces.
  • Devices for picking up spilled mercury in the laboratory have been around for years. These devices take advantage of the fact mercury will adhere to a clean copper surface. They usually take form in the shape of a scoop and some sort of sweeper, often a series of copper washers, mounted on an axle, which will pick up the spilled mercury. These fairly inexpensive devices are much more effective than masking tape. A small wad of copper wool (sometimes sold under the name of "Chore Girl") used for scrubbing pots in the kitchen can also be found to effectively retrieve spilled mercury.
  • Governmental guidelines also suggest that removal of carpeting may be necessary since cleaning this material is extremely difficult at best and often is a practical impossibility.

Practical questions such as central air conditioning and the ability to adequately ventilate interior rooms should be considered. In short, how many building occupants will actually go to the trouble of following all these guidelines? Commercial establishments subject to OSHA regulations may be required to do so but will the average homeowner or tenant follow suit?

Now this is not to make light of the recommendations for handling breakages involving mercury-containing lamps. In fact, a cleanup carried out following these guidelines would very likely protect persons working or living in the vicinity from another hazard, namely the phosphors used to coat the inside of the lamps. Some of these are thought to be toxic or carcinogenic.

So, in an effort to conserve energy, bring operational costs down and reduce mercury emissions from coal-fired power plants, we have, due to the inexorable operation of the "law of unintended consequences," induced another potential hazard, increased mercury content, into the homes and workplaces of America. Is the risk justified by the benefits? Is the energy saving and the concomitant reduction of the carbon footprint worth the increased risk of mercury contamination? Have we really achieved the projected benefits or have we merely moved the source of contamination from the smokestack to the light socket? Do we need to re-evaluate the risks from mercury exposure and take into consideration the toxic properties of compounds of mercury as opposed to those of the metallic element?

Should we, perhaps, defer the phase-out of the tungsten lamp to await the advent of non-mercury sources of illumination such as the light emitting diode (LED), which will very likely reach a state of practical viability for use in general illumination in the fairly near future? If so, should we not place greater emphasis on the development of this technology?

Once introduced into the environment, and worse into the body, mercury is tenacious and remains for years, even centuries. The mercury contamination caused by the use of the amalgam process at the site of the Comstock Lode in Nevada during the nineteenth and early twentieth centuries is proof enough of that. The metal per se may do little or no harm, but as it is gradually incorporated into the environment, it is absorbed by living organisms, such as fish and other marine life, and converted into methylmercury (any of the compounds containing the CH3Hg complex) and other toxic compounds or vapors. There is already a lot of mercury out there to convert. In light of the problems associated with inadvertent mercury exposure from compounds like thiomerosal, do we want to add more?

As mercury-containing lamps reach the end of their useful lives, they must be disposed of. Will their disposal in community landfills create a new source of mercury contamination near each center of population or will recycling be made "consumer friendly" and economically feasible enough that people will actually use it? These questions and others should give us pause to re-think our initial question with regard to increasing the number of mercury-containing lamps. Did we really mean to do that?

1 See: National Library of Medicine, Medline Plus entry "mercury" (


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