CFLs Contain Mercury – Submission to EECA

NZ’s Energy Efficiency and Conservation Authority (EECA) is reviewing the Minimum Energy Performance Standard (MEPS) for Compact Fluorescent Lamps.  They produced a discussion document and invited submissions.  Submissions closed today, 28 Feb 2011.  Here’s what I sent them.

Submission on Proposed MEPS for CFLs

28 February 2011.

My name is Anthony ——–.  I am an electrical engineer and have been involved with electricity network planning, operation and construction for 35 years.

Mercury

It is mentioned in the discussion document that CFLs contain mercury.  But I think the discussion document “brushes off” this issue far too lightly.  Mercury causes serious health effects; mainly nervous system disorders.  This, coupled with CFLs being reasonably fragile, the odds are that some units will break on installation or removal.  Some will be inadvertently knocked or bumped while in service; eg: children playing in a child’s play room.

Then there’s the end of life disposal problem.  At end of life they need to be disposed of properly.  As a country we pride ourselves on being environmentally aware.  It’s a major part of our international brand.

Most home owners (ie: the majority of CFL purchasers) would be unaware of these issues – especially the processes (which may not even be in place yet) – to properly dispose of the units and how to clean up a broken lamp (ie: safely take care of the spilt mercury).

Promoting and distributing mercury tubes throughout all New Zealand homes; while knowing full well its harmful effects is extremely irresponsible.  How could a responsible government entertain such an idea?  Consider what applied to the use of asbestos.  Will the manufacturers of CFLs be ready with their millions of dollars to pay for the health problems they have caused?  Or will that [problem] be handed back to the public through government tax, ACC, increased insurance premiums and/or healthcare costs.

I realise that even in light of the above information you [government] are STILL likely to not only distribute these little bottles of poison, you will even promote and subsidise them, using the extra money you have taken from us in our power accounts.

Given that you’ll likely promote these units anyway – I therefore recommend, as an absolute minimum, that CFL packaging be clearly labelled with information to the effect:

• The CFL contains mercury
• The health effects of mercury
• The fragile nature of the lamp and how to handle it safely
• How to clean up should there be a breakage
• How to properly dispose after the lamp has served its useful life

At least this way you’ll give the public of New Zealand the ability to make an informed choice to protect itself.   Dangerous chemicals and products are only supposed to be sold with an up to date MSDS [Materials Safety Data Sheet].

And don’t forget there is an alternative around the corner.  Efficient, controllable, non- hazardous  LED lighting is fast approaching commercial reality, maybe 3 or 4 years.

Subsidisation

If the benefit /cost ratio was truly as high as the discussion document hypothesises (which I doubt), no (cross) subsidy would be required. The units would sell on their own merit.  Making us all pay more for our power and then transferring it to these lamps, a subsidy which is effectively from consumer to consumer, offers no net benefit.   The action serves is to blinds the purchase decision as to the real cost, an economically inefficient action to take.

If you proceed with the sale of these lamps then I recommend they be sold for their true commercial cost, and they not be (cross) subsidised at all.

Yours faithfully,

Anthony ——–