States Instituting Mercury Lamp Bans
January 1, 2006--some Happy New Year! You get to spend the day throwing all of your automated lights into the dumpster for the trip to the recycler. While you are cleaning out your inventory, you can pitch in all your blacklight fixtures and all your HMI film fixtures. If you are an owner of a rental shop this scenario may become all too real. If you are based in Rhode Island that is the date that you can no longer purchase any lamp that contains more than 10mg of mercury, which cuts out all but the smallest HID lamps. Other states are lining up to jump on the mercury-ban bandwagon. My extremely unscientific poll of designers and end-users reveals that they know very little about this issue or assume that the lamp manufacturers will come up with mercury-free lamps. This is most definitely an issue that everyone involved in lighting should become more familiar with, and work towards a more reasonable solution.
Okay, mercury is bad for the environment and we could all practice better recycling, but the new law that was signed into effect in Rhode Island and is pending in many states is so far-reaching and reactionary that it will cause irreparable harm to not only the entertainment lighting industry, but also to the architectural lighting industry, and, in the end, the environment as well. The lamp manufacturers could be granted exemptions in two-year increments, so they essentially are limited to developing a product with a two-year life span. ESTA technical standards manager Karl Ruling comments, "No one will buy a $4,000 moving light, for example, with the guarantee that lamps for it will be available for the next two years, or maybe four years, or maybe six, or maybe not at all. The extension provision is a bogus concession; it is hardly better than an outright ban." The manufacturers are also responsible for the disposal of all of the lamps that are sold, something that none of them is equipped to handle, as well as stocking and labeling for each state’s varied legislation.
The Entertainment Services and Technology Association (ESTA) and the National Electrical Manufacturers Association (NEMA) are leading the fight against a series of laws that have been adopted or are on the table in several states designed to restrict the sale and use of mercury-containing products. According to ESTA, most of these laws, intended to help the environment, would effectively ban the use of HMI and other metal-halide lamps without reducing the amount of mercury released into the environment. ESTA has taken several steps to repeal this legislation, while at the same time promoting environmentally responsible lamp product stewardship in an attempt to protect both the lighting industry and the world at large.
Mercury Reduction and Education Act
The first such law to be passed, the Mercury Reduction and Education Act, which went into effect in Rhode Island on January 1 of this year, contains several requirements which apply to metal-halide lamps used in the entertainment industry. Ruling, writing in the winter issue of Protocol, the official magazine of the organization, breaks it down thusly:
(1) A lamp manufacturer or distributor has to notify the Director of the Rhode Island Department of Environmental Management in writing before promoting or offering metal-halide lamps for sale or use in Rhode Island. The notification must include a brief description of the product, the amount of mercury in each unit of the product, an explanation of why the mercury is there, and the total amount of mercury contained in all the products made by the manufacturer.
(2) The amount of mercury allowed in lamps is reduced in steps to less than 10mg over a period of six years. This will have the effect of eliminating most metal-halide lamps of 1kW or larger after January 1, 2006, and most smaller metal-halide lamps after January 1, 2008. UV (blacklight) lamps will also be eliminated. There are exemptions from the mercury reduction requirements for products if such reductions are not possible. However, exemptions are granted for only two years at a time, which is not long enough for a manufacturer to justify developing or maintaining a product line or for a user to be able to buy a metal-halide luminaire with any confidence that it will still be usable in three years.
(3) By January 1, 2003, manufacturers have to provide user-friendly systems for the collection of their spent mercury-containing lamps. The system has to be documented and proof has to be available that every party in the system is ready and able to make it work. The system has to have the approval of the Director of the Rhode Island Department of Environmental Management.
As Ruling notes, "Mercury is an essential part of all metal-halide lamps used in entertainment lighting. It is a starting aid and voltage-control mechanism, and also contributes to the visible light produced. While mercury-free metal-halide lamps are under development, the experimental ones generally have poor color rendering and require very high starting voltages and special ballasts. Mercury-free substitutes for today’s high-CRI, high-output metal-halide lamps are unlikely to be realized anytime soon, if at all."
Ruling also believes that the power generation issue is being overlooked by the legislatures. "The gross inefficacy of incandescent lamps makes metal-halide lamps the environmentally better choice by far. Power generation has environmental consequences. Pumping three to 10 times more particulates and greenhouse gases into the air, building more nuclear power plants, and damming more rivers to power incandescent lamps is not environmentally responsible behavior.
"If legislation leads people to turn away from metal-halide lamps toward incandescent, the amount of mercury in the environment may increase--a very perverse outcome for environmental legislation," says Ruling. "Coal, America’s most abundant fuel, contains mercury. When it is burned, mercury goes up the smokestack into the air and then rains down on the countryside. If smokestack scrubbers are used to capture the mercury, the amount of mercury that must be handled as hazardous waste is increased. More than 2mg of mercury are released for every thousand lumens produced per hour using incandescent lamp technology. Less than 0.5mg are released with metal-halide technology--even if one assumes that spent lamps are simply tossed into a landfill.
"Metal-halide lamps are vital to the entertainment industry," says Ruling. "They are the sources for most automated luminaires and for many studio luminaires and some stage lighting instruments. Metal-halide lamps are used in automated luminaires because of their high output per watt consumed and their small light source size. They are used in stage and studio luminaires because of their high output and daylight-like color. No other source comes even close to metal-halide for producing lots of lumens with a few watts."
Call to Action
ESTA firmly believes that the Rhode Island Mercury Reduction and Education Act needs to be repealed. "Companies and people in the entertainment lighting industry need to use and dispose of metal-halide lamps in an environmentally responsible manner so that goals of the Universal Waste Rule may be achieved," states Ruling. "Keeping waste mercury out of the environment, energy efficiency, and good lighting are goals that can be realized together."
Laws aimed at eliminating mercury-containing lamps are a threat to the entertainment lighting industry. ESTA is leading the efforts in our industry to block or repeal this legislation and to promote environmentally responsible product stewardship, and is coordinating these efforts with those of the National Electrical Manufacturers Association. Those who want to learn more about this issue and what can be done to help should go to the ESTA website at www.esta.org, where the full text of Ruling’s article is available, plus a position paper on mercury legislation and entertainment lighting, lamp product stewardship program materials, the list of states in which anti-mercury legislation is being proposed, as well as sample letters to send to local legislators in affected states.
Write to Your Legislator
Letter-writing works. On January 31 the New Hampshire House of Representatives voted 207 to 147 against adopting HB 675, an anti-mercury bill. The bill was then referred to interim study by a vote of 285 to 70, which will keep this legislation from coming up again in the House for the rest of the year. These votes may simply show the good sense of the New Hampshire legislators, but the votes may also be the result of the letter that ESTA’s Lori Rubinstein, executive director, and Ruling sent to each of the 400 members of New Hampshire’s House of Representatives, along with the numerous other letters and testimony offered against the bill by other associations and individuals.
Lighting Dimensions will continue to follow ESTA’s efforts on this issue, which will affect us all. We need to act before it is too late. As Ruling says: "Mercury is toxic. It is definitely something we want to keep out of our landfills, streams, and air. High doses can cause tremors, convulsions, and death. Mercury should be kept out of the environment, but legislating its elimination from lamps isn’t a good way to do this. Eliminating mercury from lamps will have a severe effect on entertainment lighting and will have a net negative effect on the environment."
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