Despite that fact, the two sectors are regulated differently. Processors of lighting are regulated as “destination facilities” and are subjected to myriad Resource Conservation and Recovery Act (RCRA) compliance requirements for storage, testing and monitoring, worker health evaluations, inspections, downstream product uses and more. Electronics processors are generally not subject to the same levels of stringency and are not defined as hazardous waste processors.
Mercury is what makes energy-efficient lighting toxic and, therefore, regulated under RCRA and the Universal Waste Rule. Lighting is considered “characteristically hazardous” because levels of mercury found in lights typically fail the toxicity characteristic leaching procedure (TCLP) test, a common method of determining through chemical analysis whether a material is hazardous.
But electronics may not fail this test, even if the entire device could be ground up into beakers and tubes and subjected to the leaching reagents — something very impractical, if even possible. That means e-scrap processors may be unwittingly exposing their facilities to mercury and should test accordingly.
Mercury in devices
For several years, I went to e-scrap conferences and would often ask vendors and processors about mercury. Mostly I got blank stares or denials that any mercury was present in the materials they were disassembling or shredding.
Many people don’t realize that any device with a screen, backlighting or any type of visual display contain small amounts of mercury (it makes them light up). CRTs, cell phones, LCD and other flat panels, laptops, certain printers and medical imaging equipment all contain mercury, as do some batteries, switches, thermostats, instruments and so on.
When these devices are breached by physical or mechanical separation, typically from hammer mills, shredders, magnetic separators or even eddy current sorting, they break and the mercury contained inside is released into the workplace. Although the mercury from one device is minute, collectively enough mercury can be released to be detected on equipment, walls and floors, in HVAC ducting and elsewhere. The emitted mercury vapor is almost impossible to find unless you look for it.
This phenomenon could present a risk to workers that would go unnoticed unless they are sent to toxicologists for urine and blood testing. Additionally, mercury vapor, which is invisible, odorless, colorless and tasteless, can be detected by government inspectors or industrial hygienists.
Simple steps to know where you stand
Aaron Blum, co-founder and chief operating officer at ERI, one of the e-scrap industry leaders, describes the steps ERI takes to ensure mercury does not become a problem in the workplace. ERI handles mercury-containing devices such as LCD televisions/monitors, as well as all-in-one scanners and copiers.
“We do in-depth training on the proper way to hand-dismantle these items in order to prevent breakage of the mercury tubes,” Blum said. “We also have procedures around the cleanliness of our facilities on a daily basis. The mercury tubes are very fragile and our team expertly handles the devices to properly remove and safely package the tubes. We ensure proper handling procedures that prevent breakage and mercury releases into the environment. ERI also has a third-party Certified Industrial Hygienist come in at least once a year to do a full Industrial Hygiene monitoring on all positions. ERI prides itself on the ongoing safety of its employees and its facilities.”
All members of the Association of Lighting and Mercury Recyclers (ALMR) routinely test for mercury. Checking to see if mercury is present is easy and inexpensive. There are several brands of handheld mercury vapor analyzers that can be used by anyone with minimal training. They can even be rented by the day. Manufacturers include Jerome (Arizona Instruments), Ohio Lumex, Mercury Instruments, Nippon Instruments, Genesis Laboratory Systems and Bacharach. While I have not used all these brands, the ones I am familiar with are easy to learn and very easy to use. They provide instant quantification of mercury vapor in the workplace air or worker breathing zone.
We think testing for mercury is a necessary activity in your workplace to ensure you are not being impacted. We recommend periodic checks anywhere electronics are processed, and any industrial hygienist can provide guidance.
Knowing where you stand is good for your business. It could also put your mind at ease.
Paul Abernathy is the executive director of the Association of Lighting and Mercury Recyclers, which represents leading lamp recyclers in the U.S. Its membership also includes electronic recyclers and recycling equipment manufacturers.
This In My Opinion is a follow-up to a recent E-Scrap News piece exploring the importance of testing for lead in e-scrap processing facilities.
The views and opinions expressed are those of the author and do not imply endorsement by Resource Recycling, Inc. If you have a subject you wish to cover in an op-ed, please send a short proposal to news@resource-recycling.com for consideration.
