A Troubling Trend

There is a growing trend in the promoting and consumption of energy efficient compact fluorescent and cold cathode bulbs to replace older less efficient ones. This is a short sighted and poorly conceived plan to reduce consumption without any regard to the long lasting effects on the environment or its’ inhabitants. Certainly, the reduction of demand is an effective rapid response strategy to energy production shortcomings and environmental impacts, thereof. However, without a plan to recycle, manage or even educate the public on the potential hazards associated with this technology; we will certainly see a backlash of public outcry in the coming years unless measures to remedy this are taken.

Disposal Regulation
Measures are currently being taken by state and federal organizations to educate high volume consumers on the dangers of using fluorescent and cold cathode technology. But it must be pointed out that the largest portion of the general public are still being under educated with regard to the long term effects of improper disposal and safe handling procedures. In the United States, most consumers are not regulated on proper disposal of compact fluorescent bulbs. There is no federal requirement for users disposing of less than 220 pounds of hazardous waste each month. States are increasingly becoming aware of the issue and are tightening regulations. Some states, including Maine, allow no exemptions for disposal. These regulations are a clear indication that government officials are aware of the hazards that improper disposal of mercury lamps poses to the environment.

Other Risks
Beyond the previously mentioned long term accumulation of mercury in solid waste landfills across America, what other risks does the use of these bulbs pose to the health of the general public? The most important and hazardous issue is the factor of broken bulbs. The largest percentage of the mercury in these lamps is in the form of a vapor that is released when the glass enclosure is compromised either through breakage or cracking. In the case of state regulations, crushing for disposal is almost across the board not allowed as a method of disposal. (Association of Lighting and Mercury Recyclers 2004) Crushers and compactors at lamp recycling centers are sealed, filtered and heavily monitored to keep mercury vapor levels below OSHA (Occupational Safety and Health Administration) levels (Labor, Occupational Safety and Health Administration - U.S. Department of n.d.). According to a recent study by the State of Maine, indicates “mercury concentration in the study room air often exceeds the Maine Ambient Air Guideline (MAAG) of 300 nanograms per cubic meter (ng/m3) for some period of time, with short excursions over 25,000 ng/m3, sometimes over 50,000 ng/m3, and possibly over 100,000 ng/m3 from the breakage of a single compact fluorescent lamp.” (Maine Bureau of Remediation and Waste Management 2008) The cleanup procedures outlined by the State of Maine has been found by the Environmental Protection Agency (EPA) to be sound and has caused the EPA to adopt these methods as the preferred process to minimize airborne hazardous vapors caused by the breakage of fluorescent lamps. Remaining residual mercury is managed based on space flooring materials and space usage (see recommendations).

Impacts
With all of these known environmental hazards and impacts, the most disturbing trend is the increasing use of compact fluorescents across the country in a wide variety of spaces with a broad range of spatial considerations. Commercial and industrial applications are less disconcerting than residential usage, as in most states commercial users are regulated to ensure compliant disposal and OSHA inspectors help to manage air quality in the workplace. Residential management, however, falls on the consumer and/or property owner and is not monitored or inspected to any level of general air quality on a regular basis. There is an additional category of space that does not quite fit into either of these conditions and that is the agricultural sector. A typical farm is either subcontracted to grow or raise products for a particular company or is independently owned and sold directly to the customer. Because the majority of these farmers live on or in close proximity to the farm and usually own the land, these facilities fall under the category of residential usage and is not managed by OSHA. Food and Drug Administration (FDA) inspectors concentrate efforts on processing, packaging, storage, delivery and preparation facilities. At the same time, consumer protection exists to monitor and test feed supplies and vaccination for contaminants and environmental impacts. Further pending legislation is being discussed to extend the inspection process onto the production facilities to prevent food contamination and food borne illnesses that have surfaced in the news over the last several years. Regardless of the outcome of this legislation, inspectors will have specific quality control measures to be monitored and reported. Very little attention will be given to air quality, in terms outside of the airborne pathogens and/or bacterium. The inhalation of mercury vapors is the quickest and surest method of elemental neurotoxin contamination. (Department of Health and Human Services 1999) This type of contamination is far more detrimental than feed contaminants and cannot be overlooked during the inspection process.


Farm Efficiency Strategy
At this point, it is important to understand that farms, whether independently owned or under contract, are inherently responsible for electrical consumption on the property. Narrowing margins, rising electricity rates, fuel increases and higher interest rates have taxed the agriculture community beyond its fiscal limitations and have caused them to look for ways to reduce demand to keep production costs low. That being said, increased use of energy efficient lighting has taken a front seat in the struggle to remain financially sound. The promotion of CFLs through cooperative networks, public service announcements, government programs, commercial promotions, and the like have led many farms to begin converting from incandescent bulbs to compact fluorescent lamps. Saving advantages of this conversion is prevalent enough to even be recommended by the contractor or integrator. For many locations on a farm this is a very viable approach and will lead to significant savings. There are locations on the farm where converting to CFLs or cold cathode would be a concern unless measures are taken to prevent exposure to elemental mercury and mercury vapor.

Farm production is a harsh environment for equipment and durability is a very important factor. Dusty and muddy environments can lead to residue accumulation on lamps and can cause overheating of lamps, ballasts and glass which will lead to premature failure. In the case of animal production areas, most animal housing is on backup generators. These generators must be tested regularly and power surges can cause damage to ballasts. One of the principle reasons for conversion is, not only the low consumption, but the higher cost is promoted to be offset by the longer life expectancies. Suffice it to say that the combination of harsh environment and systemic configurations can cause lamp life to fail to meet expectations.
The failure and breakage of lamps in animal housing is a potential hazard and is a much overlooked risk for food safety and will be very difficult to manage. Shatter protection is difficult for CFLs as enclosing the lamps in housings will cause overheating and premature failures. Based on the EPA clean up requirements, evacuation and removal of all porous substances will be a monumental task in animal housing, which typically includes some type of bedding material. Without a complete change out of bedding, the animals themselves will continually reactivate and recirculate settled mercury vapors. The indoor air quality (IAQ) will not be monitored and will eventually make its way into the neurological system of the animals housed there. The difficulty of cleanup is further exacerbated by the requirement of housing evacuation. Most animal housing can have in excess of 20,000 animals in a single facility. Many farm management teams would forgo such procedures, without regulation, due to the logistical complications associated with removal and temporary housing of large quantities of animals. Other complications in this process is the growing trend of recycling and reuse of bedding materials in states which highly regulate and/or ban the disposal of used litter. The process of reuse of such litter includes the rotation of the bedding, further activating settled vapor particulates. This process is done in unpopulated houses. However, the farm workers performing the procedure will surely be exposed to toxic levels of mercury vapor as levels accumulate through ongoing breakage and litter recycling.
To determine the impact on production, reports from the USDAs National Agriculture Statistics Survey in 2007 indicate over 300,000 farms in the United States dedicated to some level of animal housing, whether it is dairy, swine or poultry production (United States Department of Agriculture 2009). Even with conservative figures of 2 houses per farm with a density of 50 lights per house, produce figures of 30 million bulbs in use today. Harsh environments of animal housing can shorten longevity by as much as 75 percent of life expectancies. Longer usage hours on farms put typical CFL life expectancies at 6 months to a year. Even halving the number replaced annually, indicates that a total market conversion can produce somewhere around 15 million bulbs replaced annually. With each farm replacing less than 220 lbs of hazardous materials per month, they are completely unregulated. But as a whole, the impact is staggering.

Conclusion
The principle concern here is the unregulated use of mercury-based consumable lighting products in animal housing for the food sector. Without education and recycling infrastructure, the use of these products will without question eventually be of such a scale that mercury contamination in land based animal production will rival if not exceed the previous contamination seen in aquaculture in the 1990s. The potential for mercury vapor neurotoxins should undoubtedly be a principle concern for any animal agriculture or consumer of those products. Conversion for the sake of energy efficiency is understandable but must be managed in such a way that either eliminates the hazard or is monitored to prevent hazardous contaminants from entering the food chain through a loophole in the inspection process. Energy efficiency, while important in economic vitality, is not worth the hazards associated with currently promoted technologies. New strategies are essential to continued success without sacrifice.


Bibliography
Association of Lighting and Mercury Recyclers. "State-by-State Stringency Comparison Table." Laws and Regulations. June 2004. http://www.almr.org/stringency3.html (accessed July 27, 2009).

Department of Health and Human Services. "Agency for Toxic Substances & Disease Registry." Public Health Statement for Mercury. March 1999. http://www.atsdr.cdc.gov/toxprofiles/phs46.html (accessed July 27, 2009).

Labor, Occupational Safety and Health Administration - U.S. Department of. "OCCUPATIONAL SAFETY AND HEALTH GUIDELINE FOR MERCURY VAPOR." Health Guidelines. http://www.osha.gov/SLTC/healthguidelines/mercuryvapor/recognition.html (accessed 08 02, 2009).

Maine Bureau of Remediation and Waste Management. "Maine Compact Fluorescent Lamp Breakage Study Report ." Maine.gov. February 2008. http://www.maine.gov/dep/rwm/homeowner/cflreport.htm (accessed 08 02, 09).

United States Department of Agriculture. "National Agriculture Statistics Service." The Census of Agriculture - 2007. February 2009. http://www.agcensus.usda.gov/Publications/2007/Full_Report/index.asp (accessed July 27, 2009).