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energy lamps label mercury
In its NPRM, the Commission proposed a mercury disclosure for CFLs on the Lighting Facts label to warn consumers of possible hazards from broken bulbs.
That disclosure stated:
Contains Mercury Hg [encircled]:
Manage in accordance with local, state, and federal disposal laws. For information: epa.gov/bulbrecycling or 1-800-XXX-XXXX.
The proposed language is similar to CFL disclosures currently required by the ENERGY STAR program and to those recommended by NEMA.
The Commission intended the proposed amendments to work in conjunction with state mercury disclosure requirements, to the extent possible.
Therefore, the Commission sought comment on the impact of the proposed disclosures on existing state requirements, including whether, how, and why the Commission should address any inconsistencies between its proposed disclosure and state requirements.
Comments: Commenters agreed that the final amendments should require a mercury disclosure on the Lighting Facts label. Several, however, proposed revising the disclosure. CEE recommended adding the term recycle to remind consumers of the environmental benefits of recycling CFLs. NEMA, GE, and EPA recommended referencing clean-up procedures.
NEMA and GE suggested:
For Clean-Up and Disposal see:
(lamprecycle.org) or 1-800-XXXXXXX.
NEMA and GE favored giving manufacturers the option of including the industry website along with, or in lieu of, the EPA website proposed by the Commission because the industry website, (lamprecycle.org), has existed for ten years, is well known, and was redesigned recently to make it more consumer friendly. Similarly, NEMA and GE recommended that manufacturers have the option to include their toll-free numbers with, or in lieu of, EPAs toll-free number.
EPA suggested revisions to encompass the entire lifecycle of the lamp and breakage. Specifically, EPA proposed, Contains Mercury: For proper handling, disposal, or clean-up, see epa.gov/cfl. Additionally, it supported inclusion of an EPA website, but recommended the soon to be developed epa.gov/cfl. It also cautioned against including any toll-free telephone number because funding for public and private hotlines is uncertain.
Commenters disagreed about the inclusion of the Hg symbol. EPA and state regulators objected to using the symbol, explaining that they have received feedback indicating that consumers ha[ve] no idea what the Hg symbol means. NEMA and GE supported the symbol because NEMA members already provide it on CFL packages and because it is recognized internationally.
In addition, IMERC, QSC, and MPCA recommended increasing the type size of the disclosure.95 Based on its members regulatory experience, IMERC stated that any font size less than 8 to 10 point font is not legible to the average consumer. Therefore, all three commenters recommended ten-point type for the entire disclosure, as generally required by state laws.
The commenters expressed opposing views on state preemption.
Commenters representing states--MPCA, QSC, and IMERCí¬asserted that the proposed amendments would not preempt state disclosure laws. On the other hand, NEMA expected that to the extent the Commissions amendments differed from state labeling requirements, it would preempt them.
Discussion: In response to the comments, the final amendments revise the mercury disclosure on the Lighting Facts label to read: Contains Mercury For more on clean up and safe disposal, visitepa.gov/cfl.
In doing so, the Commission made a number of changes suggested by commenters, declined to make others, and attempted to minimize potential conflicts with state requirements, as discussed below.
The Commission agrees with commenters CEE, NEMA, and GE that the mercury disclosure should alert consumers to follow certain steps when cleaning up and disposing of CFLs because improper clean up or disposal can release mercury vapor, which EPA describes as harmful to human and ecological health.
The final disclosure requirement specifically addresses clean up and safe disposal to alert consumers to this risk.99
The revised disclosure omits any reference to a toll-free number and contains a link to a new EPA website.
The Commission agrees with EPAs comment that, due to the uncertainty of future funding, a toll-free number should not be included in the disclosure. Moreover, the final disclosure directs consumers to the EPA website, which the EPA has determined is most appropriate. The disclosure does not include an industry website, as proposed by NEMA and GE, because EPAs expertise on environmental issues, as well as safe clean up and disposal, puts it in the best position to provide consumers with this important information.
Additionally, the final amendments do not include CEEs suggestion that the disclosure instruct consumers to recycle CFLs. The Commission is concerned that the term recycle could lead consumers to dispose of CFLs in home recycling bins, a practice that may pose an environmental hazard from potential bulb breakage.101 Similarly, the final amendments do not use the term handle in addition to clean up and disposal as suggested by EPA.
In the Commissions experience, vague terms such as handle do not add to consumer understanding
The disclosure no longer requires the Hg symbol in light of the states and EPAs comments that consumers do not understand the symbol.
However, manufacturers may voluntarily include the symbol in the disclosure after the term Contains Mercury. This flexibility will allow manufacturers to comply with state and ENERGY STAR requirements.
The final amendments also increase the disclosures minimum size to a uniform ten-point type.
This minimum type size harmonizes the disclosure with several states requirements.104 As discussed above, the final amendments attempt to minimize conflicts with state requirements while providing disclosure requirements that are practical and benefit consumers.
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