Proposed risk management instruments for mercury-containing products

Consultation document

Environment Canada

December 2007

1.0 Introduction

Mercury use and impacts

Mercury is a naturally occurring element that can be released to the atmosphere from natural sources or through human activities. Mercury is a well-known, persistent, bioaccumulative neurotoxin that is still used in some everyday products, such as thermometers, compact fluorescent lights, and batteries. Although the mercury content of these products may not pose a significant risk during normal use, the mercury can escape when products are broken or when products are disposed at the end of their useful life. Mercury from products can enter the environment and become part of the global mercury cycle. Once in the atmosphere mercury can remain airborne for long periods of time and be deposited around the world.

Mercury in the environment can transform, through biological activity, into a highly toxic organic substance called methylmercury. Methylmercury builds up in living organisms through their surrounding environments and is concentrated as it transfers up the food chain. Almost all mercury compounds are toxic and can be harmful at very low levels in both aquatic and terrestrial ecosystems. Human exposure to mercury can cause brain, nerve, kidney, and lung damage and in extreme cases coma or death. Children exposed to mercury while in the womb can experience developmental difficulties.Footnote 1

While instruments are in place or in development to address several sources in Canada, the use of mercury in products continues and has left a legacy of mercury in landfills and homes.

In 2003 approximately 10 tonnes of mercury was used in products imported and manufactured in Canada, while about one quarter of domestic atmospheric mercury emissions were attributable to end-of-life mercury-containing products.

The table below provides an overview of products considered in the development of the Risk Management Strategy (RMS) for Mercury-containing ProductsFootnote 2 as potential candidates for risk management instruments.

Overview of products considered in the development of the Risk Management Strategy (RMS) for mercury-containing products
Product category Product type
Batteries Button batteries (manganese alkaline, silver oxide, zinc air and mercuric oxide), other batteries
Thermometers Mercury thermometers
Measuring Devices Sphygmomanometers, manometers, barometers, psychormeters/ hygrometers, hydrometers, pyrometers
Thermostats Thermostats (not digital)
Dental amalgam Conventional amalgam
Switches/ relays Float switch, tilt switch, temperature switch, displacement/plunger relay, wetted reed relay, flame sensor
Lamps Mercury fluorescent lamps, high intensity discharge, neon signs
Tire balancing products Mercury tire balancing product

Background information and proposed risk management measures for each product are detailed in sections 2.0 and 3.0 respectively.

Canadian Environmental Protection Act, 1999

The Canadian Environmental Protection Act, 1999 (CEPA 1999) is focused on pollution prevention and the protection of the environment and human health in order to contribute to sustainable development. Mercury is on the List of Toxic Substances in Schedule 1 of CEPA 1999 as it is a toxic and persistent metal with significant adverse effects on the environment and human health. The Ministers of Environment and Health have the authority under the Act to control the entry of Schedule 1 substances into the environment throughout their lifecycle.

Risk management process to date

On December 20, 2006 Environment Canada published a Risk Management Strategy (RMS) for Mercury-containing Products as a component of the Government of Canada Chemicals Management Plan. The RMSFootnote 3 considers options for the management of mercury use in a wide range of products. The risk management objective of the Strategy is to reduce mercury releases to the environment from consumer products to the lowest possible level.

The Strategy outlines in general terms the use of mercury in Canada, potential effects of exposure and options available to Environment Canada to prohibit or limit the use of mercury in products. The Strategy identifies a regulation under CEPA 1999 as the best option for managing mercury use in products. Several complementary instruments, such as Pollution Prevention Plans, are also identified as viable options.

Specific actions under the proposed regulation could include prohibiting or limiting mercury use in products, controlling imports or exports where necessary, setting labelling requirements and controls on product disposal.

Stakeholders were advised of the publication and the document was available for public comment until March 31, 2007. Numerous comments were received during the consultation period and taken into consideration during the development of this document. A response to comments is provided in Appendix B of this consultation document.

Mercury-containing products: risk management instruments and exemptions

In developing and evaluating the proposed regulatory approach, Environment Canada has endeavoured to conduct a comprehensive analysis of all lifecycle stages for each product. In weighing the risks and benefits of each product it was concluded that the proposed regulation will prohibit the manufacture, import and sale of all mercury-containing products with the possibility of exemptions for:

  • Products that are prohibited under other regulatory instruments.
  • Products whose benefits significantly outweigh their potential risks to the environment and human health.
  • Products that have critical applications and have no alternative mercury-free replacements.

Current information indicates that mercury-containing lamps and dental amalgam should be exempt from prohibition. The following table provides the rationale for exemption:

Rationale for exemption
Dental amalgam Fluorescent lamps
Dental amalgam is a mixture of metals that does not exhibit the same characteristics as elemental mercury. Compact fluorescent lamps (CFLs) use far less energy than incandescent bulbs, so they reduce greenhouse gas emissions from electrical generating stations powered by fossil fuels. Also, by decreasing the demand for electricity from coal-fired generation plants in certain regions - one of the largest sources of mercury emissions in Canada - CFLs can actually reduce mercury levels in the environment
Current evidence does not indicate that mercury, in the form of amalgam, is a risk to human health in the general population. CFLs last up to 10 times longer than incandescent bulbs, so fewer bulbs and less packaging ends up in landfills.
Mercury amalgams used in dentistry are inexpensive compared to other alternatives such as gold, porcelain and composite (white) restorations. Amalgams are also very durable, relatively fast and easy to place, and can often be repaired. The amount of mercury in CFLs is small - less than one-fifth of the mercury found in some wristwatch batteries.

In addition, significant progress has been made in managing mercury from dental amalgam waste and reducing the amount of mercury in CFLs under the Canada-wide Standards process.

Exemptions to the proposed prohibition regulation may be subject to alternative risk management instruments such as regulated quantity limits, pollution prevention planning notices, labeling, reporting and waste disposal guidelines. Instruments proposed to address the current exemptions include a pollution prevention notice for dental amalgam waste and regulated content limits for fluorescent lamps. These instruments may also incorporate labeling and reporting protocols. All proposed instruments are discussed in detail in Section 3.0.


1.1 Objectives of consultation

Environment Canada is committed to ensuring that all initiatives aimed at developing risk management measures include a process of meaningful and effective consultation with stakeholders. In keeping with this commitment, the Department is planning multi-stakeholder consultation sessions to take place in Toronto and/or Vancouver in early 2008. The purpose of the upcoming consultation sessions and this consultation document is to:

  • invite all stakeholders to provide their comments on the proposed risk management instruments;
  • provide an opportunity for stakeholders to raise awareness of their concerns, to offer suggestions, discuss, and comment on the development of the proposed risk management instruments;
  • provide an opportunity for stakeholders to contribute to the development of recommendations; and,
  • ensure that Environment Canada representatives clearly address any stakeholder questions or concerns on the proposed risk management instruments.


1.2 Consultation document

Environment Canada has prepared this consultation document to inform stakeholders of the key elements of its proposed risk management measures. Its purpose is to provide focus and guidance to the consultation process.

In soliciting final input from stakeholders, Environment Canada has posted a copy of this discussion paper on the CEPA Environmental Registry websiteFootnote 4 and distributed it by e-mail and regular mail to all known Canadian stakeholders, including representatives from other federal departments; provincial, territorial, and municipal governments; industry; environmental groups; and public advocacy groups.

Environment Canada will review all written responses received prior to drafting and publishing the proposed instrument provisions in the Canada Gazette, Part I. Environment Canada welcomes the addition of contacts who were not previously involved in the stakeholder consultations, and the distribution of this document to other potential stakeholders.

2.0 Product specific background information

2.1 Batteries

Background:

North American battery manufacturers stopped using mercury in alkaline batteries and discontinued production of mercuric oxide batteries in 1996. Other battery types such as manganese alkaline, silver oxide, zinc oxide, zinc air and zinc carbon cells may contain small amounts of mercury. Button cells can contain between 5 and 25 milligrams of mercury per unit. Currently the only types of batteries for which alternatives are not readily available are button cell batteries that consist of the type found in wrist watches, hearing aids and calculators. However, manufacturers are developing new mercury free button cell batteries which are expected to be widely available in the next 5 years.

At the current time all batteries used in Canada are imported as there are no domestic manufacturing facilities. The total quantity of mercury used in Canada in button cell batteries in 2004 was approximately 500kg and up to 380kg of mercury was imported in mercuric oxide batteries in 2003, 94% of these mercuric oxide battery imports originated in China. The total amount of mercury used in batteries remains unclear as it is not certain if manufacturers of batteries imported from outside of North America have eliminated mercury use in alkaline batteries. The amount of mercury used in batteries also can vary quite significantly; for example, the mercury content of mercuric oxide batteries can range from 30-50% mercury by weight.

Manufacturers have largely stopped designing equipment that requires mercuric oxide batteries. However, the shelf life of mercuric oxide batteries is up to ten years and they may remain in stocks for many years for use in older equipment. Mercuric oxide batteries are generally used in specialized equipment such as medical devices in hospitals and military equipment.

Alternatives:

Commercially viable replacements for alkaline-manganese and zinc-carbon mercury-containing batteries are currently available. However, the few mercury free replacements for button cell and zinc oxide batteries that are commercially available are generally considered to have reduced performance at a significant cost increase. The use of large mercuric oxide batteries is expected to decline rapidly as older hospital and military equipment become obsolete while smaller mercuric oxide batteries can be replaced by alternative battery types.

Existing risk management measures:

Currently there are no measures in place to manage the use of mercury in batteries in Canada. In 1996 the addition of mercury to alkaline batteries was made illegal in the US under federal battery legislationFootnote 5 which resulted in a significant decrease in the amount of mercury used in batteries imported from US manufacturers.

As well as the US, other jurisdictions in the European community have implemented instruments to prohibit mercury contain batteries as well as recover end of life batteries. See Appendix C for specific international risk management measures in place for mercury-containing products.


2.2 Thermometers and other measuring devices

Background:

Mercury is a good conductor of electricity and reacts predictably to temperature and pressure changes; it has therefore been used in a variety of different measuring devices. Mercury-containing measuring and control instruments are diverse and include thermometers, manometers, barometers, sphygmomanometers, psychrometers / hygrometers, hydrometers, flow meters and flame sensors among others. It was estimated that over 350Kg of mercury was used in thermometers and other measuring devices in Canada in 2003.

Alternatives:

All measuring devices mentioned in the above section have viable alternatives that, in many cases, offer cost savings or improved performance.

Alternatives to mecury-containing products
Product category Product type Alternatives
Measuring devices Sphygmomanometers Aneroid sphygmomanometer
Measuring devices Manometers Digital manometer
Measuring devices Manometers Needle bourdon gauge
Measuring devices Barometers Aneroid barometer
Measuring devices Barometers Digital barometer
Measuring devices Psychrometers/ hygrometers Spirit filled psychrometer
Measuring devices Psychrometers/ hygrometers Digital psychrometer
Measuring devices Hydrometers Spirit filled hydrometer
Measuring devices Flame sensors Electric ignition rings
Measuring devices Flow meters Majority of flow meters
Measuring devices Pyrometers Digital pyrometer
Measuring devices Pyrometers Optical pyrometer
Thermometers Mercury thermometers Digital basal thermometer
Thermometers Mercury thermometers Liquid thermometers (e.g., alcohol)

Existing risk management measures:

Currently no domestic legislation exists to address the use of mercury in measuring devices. Jurisdictions in the US and European community have focused on prohibition instruments and labelling to manage use mercury in measuring devices. See Appendix C for specific international risk management measures in place for mercury-containing products.


2.3 Thermostats

Background:

Thermostats are classified as temperature measuring devices, however, the mercury in thermostats is used in a switch that typically contains 3-4g of mercury. A single thermostat may contain more than one switch. Although there is a decreasing trend in the use of mercury-containing thermostats in favour of digital thermostats, significant use of the mercury-containing thermostats continues in Canada. In 2003, an estimated 880kg of mercury was used in thermostats in Canada.

Alternatives:

Mercury-containing thermostats can be viably substituted by digital thermostats. In most cases, a programmable digital thermostat can also encourage energy savings. Presently some manufacturers have programs to take back old mercury-containing thermostats in order to reuse components in new products.

Existing risk management measures:

Currently no domestic legislation exists to address the use of mercury in thermostats. Jurisdictions in the US and European community have focused on prohibition and end of life management instruments. See Appendix C for specific international risk management measures in place for mercury-containing products.


2.4 Dental amalgam

Background:

Dental amalgam is a mixture of metals that has been used for dental restorations for well over a century. The metal mixture in commonly used “silver fillings” can consist of up to 50% mercury by weight. Current evidence does not indicate that mercury, in the form of amalgam, is a risk to human health in the general populationFootnote 6. However, over time mercury from amalgam waste may convert in lakes and waterways to the highly toxic form of methylmercury. Dental amalgam waste should therefore be captured and recovered in order to prevent the release of mercury to the environment.

In September 2001, the Canadian Council of Ministers of the Environment (CCME) endorsed the Canada Wide Standard (CWS) on Mercury for Dental Amalgam waste. The Standard calls for the application of best management practices to achieve a 95% national reduction in mercury releases from dental amalgam waste discharges to the environment, by 2005, from a base year of 2000. Best management practices include the installation, use and maintenance of an ISO certified amalgam separators, or equivalent, by those dental practitioners generating amalgam wastes.

Progress reports on the CWS were conducted in 2004 and 2007 based on extensive surveys* of Canadian dentists. Results were as follows:

Progress reports on the CWS
Reporting year 2004 2007
Amount of mercury placed in teeth and left over as scrap. 5352kg 4665kg
Percentage of dentists using ISO certified amalgam separators. 27% 70%

*(Watson et al., 2004 & 2007)


The 2007 progress report also indicates that, of the 2703 kg of amalgams removed from teeth by dentists, only 452kg would enter wastewater as a result of the use of amalgam separators; this could be reduced to 18kg if all dentists used separators.

Alternatives:

There are several alternatives to dental amalgam including cast gold, bonded amalgam, dental ceramics and composite resins. However there are concerns regarding the alternatives including higher costs and lack of suitability for certain procedures. Amalgams are also very durable, relatively fast and easy to place, and can often be repaired.

Existing risk management measures:

Currently there is a Canada Wide Standard (CWS) on Mercury for Dental Amalgam waste which is supported by a Memorandum of Understanding (MOU) between Environment Canada and the Canadian Dental Association. The MOU describes additional best management practices including the use of certified hazardous waste carriers for recycling or disposal of captured amalgam waste. In addition a number of municipalities have instituted sewer use bylaws to limit the amount of mercury discharged to wastewater.

International jurisdictions have developed codes of practice, guidelines and end of life management instruments to manage mercury from dental amalgam waste. A variety of other instruments have also been used and there is no preferred instrument option. See Appendix C for specific international risk management measures in place for mercury-containing products.


2.5 Switches and relays

Background:

The most common type of mercury-containing switch used in products in Canada is the tilt switch. A tilt switch is a mechanical switch that is activated when it changes position. They are commonly used in applications that require activation upon opening such as lights in chest freezers and clothes washers. Float switches and temperature switches may also contain mercury; float switches are commonly used in bilge pumps on pleasure boats.

A mercury-wetted reed relay has a set of contacts “wetted” with mercury contained inside a glass tube. The contacts open or close when an electric current is passed through a coil around the glass tube. There is substantial overlap between the categories of ‘switches' and ‘relays' e.g. the mercury content of many relays is due to the fact that they include one or more mercury-containing switches.

As there is no domestic production, switches and relays are imported as stand alone products and as components in final goods. It is estimated that 740 000 mercury-containing switches and relays containing 772 kg (626 kg Switches, 146 kg Relays) of mercury were imported into Canada in 2003. Mercury-containing switches have a long life span and can remain in circulation for 10-50 years (Jasinski, 1994; Barr Engineering, 2001). It was also estimated, in 2003, that there was 54 tonnes of legacy mercury in switches and relays currently being use in Canada. These estimates do not include switches or relays that were imported as components of larger goods.

Alternatives:

Alternatives for mercury-containing switches and relays vary in relative cost and performance, however viable replacements can be found for most applications. A short list of potential alternatives is provided below.

Mercury-free alternatives
Mercury product Mercury-free alternative
Tilt switch Metallic ball
Tilt switch Electrolytic
Tilt switch potentiometer
Tilt switch Solid-state
Tilt switch solid-state pressure
Temperature switch solid-state temperature switch
Displacement/ plunger relay solid state relay
Displacement/ plunger relay Electro-mechanical relay (mercury free)
Wetted reed relay dry magnetic reed relays

Existing risk management measures:

In winter 2007, Environment Canada will be publishing a “Final Notice Requiring the Preparation and Implementation of Pollution Prevention Plans in Respect of Mercury Releases from Mercury Switches in End-of-life Vehicles Processed by Steel Mills” in Part I of the Canada Gazette. This action requires vehicle manufacturers and steel mills that process end-of-life vehicles to develop and implement pollution prevention plans to address mercury releases from switches found in cars. No other domestic legislation exists to address the use other types of switches or relays.

In general, international jurisdictions have implemented prohibition, reporting and end of life management measure to manage mercury waste from switches and relays. See Appendix C for specific international risk management measures in place for mercury-containing products.


2.6 Lamps

Background:

Lamps use electricity to excite mercury vapour mixtures to produce light. Mercury is contained in a variety of lighting including fluorescent lamps, high intensity discharge (HID) lamps and neon signs. These lamps can vary in size and amount of mercury contained. Mercury in end-of-life lamps tends to be in a solid form as it is absorbed by other lamp materials such as phosphorus and glass. Over 75% of the mercury used in lamps in Canada ends up in landfills.

In the estimates of lamp mercury content below, it was assumed that imported lamps have the same average mercury content as domestically produced lamps. The estimated mercury reservoirFootnote 7 in landfills takes into account the growth in lamp sales along with the dramatic decrease of mercury content in lamps over the past 35 years.

Estimated mecury reservoir in landfills
Lamp type Year Domestic manufacture* Exports* Imports* Total domestic use* Avg. mercury content Total mercury content** Estimated landfill reservoir
Fluorescent lamps 2003 320 272 47 95 11.4 mg 1083 kg 77 tonnes
HID 2003 36 30 5 11 35 mg 385 kg 9 tonnes
Neon signs 2003 - - - - - 453 kg -

* Number in millions.
** Numbers are estimates based on import/export data and average mercury content.


In Canada large numbers of sign manufacturers purchase neon sign kits from suppliers. These kits use elemental mercury or mercury capsules in the production of neon signs. Between 2002 and 2004 neon sign kit suppliers imported about 1153kg of mercury, However imports declined by over 32% over the same time.

Alternatives:

Alternatives for fluorescent and HID lamps are currently not available in the domestic marketplace. In some cases LED lights can be used to replace neon signs; however LED lights are more costly and cannot be used as direct substitutes for all applications.

Existing risk management measures:

The Canada-wide Standard for Mercury-containing Lamps calls for a reduction in the average mercury content of lamps sold in Canada. From a 1990 baseline, the numeric target is a 70% reduction by 2005 and a total reduction of 80% by 2010. This CWS also includes a commitment for jurisdictions to assess the feasibility of recycling/recovery of lamps and to implement initiatives to encourage these types of activities, when appropriate.

According to the 2005 progress report on implementation of the Canada-wide Standards, Electro-Federation Canada reported that the average mercury content of all mercury-containing lamps sold by their members in 2003 was 73.5% lower than the 1990 baseline of 43 mg per lamp, exceeding the 2005 CWS target of 70% reduction. Electro-Federation Canada members include the following lamp manufacturers: GE Lighting; OSRAM Sylvania Ltd.; Panasonic Canada Inc.; and Philips Lighting. However, it is not clear if manufacturers outside of Electro-Federation Canada have adhered to the CWS. Since 2003, lamp sales have increased at a significant rate and as such, it is imperative to ensure that all lamps sold in Canada meet a standard for mercury content.

In addition, on April 25th, 2007 the Government of Canada has committed to setting performance standards for all lighting that would phase out the use of inefficient incandescent light bulbs in common applications by 2012, through Regulations under Canada'sEnergy Efficiency Act.

Product bans with exceptions, labelling and end of life management measures are the preferred instruments used in international jurisdiction to address mercury waste from lamps. See Appendix C for specific international risk management measures in place for mercury-containing products.


2.7 Tire balancing products

Background:

Mercury-containing tire balancers are counter-balancing mechanisms composed of mercury filled tubes that are fitted to rotating mechanical parts. Tire balancers allow tires to rotate without causing vibrations. Although mercury-containing counter balancers can be used in a variety of mechanical components including engines, drive shafts and pumps, in Canada, they are used mostly on tires in various types of vehicles including trucks, cars, motorhomes, motorcycles, jetskis, and ultralites.

It is estimated that each mercury-containing balancer contains 99.2g of mercury. From 2000-2004, 744 kg of mercury was used in tire balancers in Canada.

Alternatives:

Traditional tire balancers are made of lead. Although lead is also a toxic substance it remains a preferred alternative as it is not as volatile as mercury and relatively easier to collect and contain.

Existing risk management measures:

Currently there are no risk management measures in place to address the use of mercury in tire balancers or other counter-balancing mechanisms.


2.8 New and other mercury-containing products

To a lesser extent than the products mentioned in sections 2.1-2.7, mercury is used in a variety of other products ranging from LCD display monitors to automobile headlights. Although the amount used in these products is small, the overall accumulated mercury content is a concern.

Historical trends indicate that demand and price for mercury have been decreasing over the past 40 years. However, new mercury-containing products have entered the Canadian market as recently as 2000. The risk of increased future use in new and novelty products is compounded by low prices and potentially greater market availability due to increasing recycling and lowered demand.

There are 32 mercury compounds currently included in the Domestic Substances List (DSL) under the auspices of CEPA 1999. Mercury compounds not on this list are deemed to be new to Canadian commerce and must be notified via the New Substances Notification (NSN) Regulations

3.0 Proposed risk management instruments

3.1 Prohibition of consumer products containing mercury

Environment Canada's proposed regulation will prohibit the import, manufacture and sale of all mercury-containing products with the exception of dental amalgam and lamps. The import, manufacture and sale of products with mercury-containing components, such as white goods (e.g. stove, refrigerator, washing machine), will also be prohibited.

Exemptions will be evaluated on the basis of product purpose (i.e. critical use vs novelty), availability of alternatives and pollution prevention planning. Exempted products will be required to establish labelling, reporting and end-of-life management practices. Labelling requirements may include the identification of mercury content and waste disposal information. See Extended Producer Responsibility section 7.0 for information on end-of-life management and section 8.0 for reporting requirements.

In its current form the proposed regulation will only exempt lamps and dental amalgam from prohibition. These exemptions are due to the lack of viable alternatives and progress made under the Canada-wide Standards initiatives. However these products will be subject to alternative risk management instruments/measures. In its current form the regulation is expected to come into effect by 2012.


3.2 Limits for lamps

Mercury-containing fluorescent lamps are considerably more energy efficient than incandescent bulbs. As there are no mercury free alternatives that provide equivalent energy savings and because considerable progress has been made in reducing the mercury content of fluorescent bulbs, they will not be subject to prohibition. However, mercury-content limits will be established for lamps under the proposed regulation. A content limit for compact fluorescent lamps (CFL) will be established at 5mg/unitFootnote 8. Current estimates for mercury content for various other lamp types are provided as ranges due to varying lamps sizes and configurations:

Mercury content range for fluorescent lamps
Lamp type Mercury content range
Mercury vapor discharge 25 - 225 mg
Sodium vapor discharge 20 - 145 mg
High pressure sodium vapor discharge 20 - 145 mg
Metal halide discharge 25 - 225 mg
Circular fluorescent lamps 3 - 12 mg
Neon lamps Unknown

Limits for these lamps types will be determined following consultations. As with other exempted products, lamps will be subject to labelling, reporting and end of life management requirements. As the lamp limit provision will be a part of the overall regulation it is expected to come into force by 2012.


3.3 Pollution prevention planning notice for dental amalgam waste

In 2001, Canadian Council of Ministers of the Environment (CCME) endorsed the Canada-wide Standard on Mercury for Dental Amalgam Waste (CWS) to address mercury releases from dental facilities in a nationally consistent manner. The CWS calls for the installation of ISO 11143 certified separators and other best management practices in order to reduce releases of mercury from dentistry in Canada. In 2007, it was estimated that 70% of dentists were in compliance with the CWS. Although this number is short of the 95% target set out in the Standard progress is ongoing. Given the advances made under the CWS and that some dentists conclude that there is no viable substitute for dental amalgam in certain applications, Environment Canada will develop a Pollution Prevention Planning Notice to address dental amalgam waste.

The Notice will require dentists who have not established best management practices as outlined in the Canada-wide Standard on Mercury for Dental Amalgam Waste to prepare pollution prevention plans detailing how they will implement them and to provide periodic reports on the status of implementation. Best management practices include but are not limited to:

  • Installing of a International Organization for Standardization (ISO) certified amalgam separator (ISO 11143) or equivalent and maintain it according to the manufacturer's instructions: and,
  • Using a certified hazardous waste carrier to dispose of mercury-containing waste.

The Pollution Prevention Notice for dental amalgam waste is expected to come into effect by 2010. For more information on Pollution Prevention Planning visit Environment Canada's web section on Pollution Prevention.

4.0 Environmental and health impacts

Environmental impacts

The long-term effects of mercury on whole ecosystems are unclear, the survival of some affected populations and overall biodiversity could be at risk. For example, 20 milligrams of mercury, the amount contained in many common products, mixed evenly in a body of freshwater, could contaminate as much as 770 000 litres beyond safe limits for the protection of aquatic life (0.026 micrograms of mercury per litre of water).

Mercury can be converted to methylmercury through biological activity which is a fat-soluble organic compound that can accumulate in living organisms and biomagnifies up the food chain. Piscivorous (fish eating) predators such as loons, merganser ducks, osprey, eagles, herons, and kingfishers are examples of species that can have high concentrations of methylmercury. Wildlife exposed to high levels of methylmercury is at risk of harm. Depending on level of exposure, effects can include slower growth, reproductive failure, the development of abnormal behaviors that can affect survival techniques and mortality.

Health impacts

In most chemical forms, mercury is a neurotoxin which can cause damage to the brain, central nervous system, kidneys and lungs. The severity of mercury's toxic effects depends on the form and concentration of mercury and the route of exposure.

Methylmercury, one of the most toxic mercury compounds, readily enters the brain. In adults high levels of exposure to methylmercury can lead to health effects such as personality changes, tremors, changes in vision, deafness, loss of muscle coordination and sensation, memory loss, intellectual impairment, and in extreme cases even death.

Unborn children may receive some of the maternal mercury body burden as mercury can cross the placental barrier. Children can suffer neurodevelopmental problems due to exposure while in the womb. Affected children may exhibit reduced coordination and growth, lower intelligence, and seizures. A recent studyFootnote 9 indicates that as many as 60,000 babies born in the United States each year could be at risk of neurodevelopmental delays due to in-utero exposure to methylmercury.

5.0 Economic considerations

Cost to consumers as well as economic impact on manufacturers and importers were taken into consideration during the development of potential instrument provisions.

It was found that many mercury-free alternatives are currently available in the marketplace and have small or no significant cost implications for the consumer. In addition many mercury containing products have functionally equivalent alternatives so product performance is not sacrificed. Product types that fall into this category include thermostats, switches and relays, measuring devices and thermometers. Mercury-containing products, such as dental amalgam and lamps, do not yet have sufficiently developed, widely available and cost competitive mercury-free alternatives.

There is limited manufacturing of mercury-containing products in Canada. Where domestic manufacturers would be impacted by this potential regulation, it was found that the cost of replacing elemental mercury as a process input was small to negligible relative to total end-product sales.

6.0 International actions

Canada continues to play a leadership role in the development and implementation of international mercury management initiatives including the Aarhus (Heavy Metals) Protocol under the United Nations Economic Commission for Europe Convention on Long-range Transboundary Air Pollution, the Arctic Council, the Great Lakes Binational Toxics Strategy, the North American Regional Action Plan on Mercury and various national and bilateral monitoring programs.

Canada is an active member of the United Nations Environment Programme's (UNEP) Mercury Programme. The 24th Session of the UNEP Governing Council, held in February 2007, reviewed global progress towards reducing or eliminating releases of mercury and its compounds into the environment. The Governing Council, as a result of this review, recognized that current global efforts to reduce the risks from mercury are not sufficient to address the global challenges posed by mercury and concluded that further long-term international action is required to reduce risks to human health and the environment. The Governing Council also cited the following action items to support further long-term international action: information gathering, continued voluntary partnership activities and the establishment of an ad hoc open-ended working group to review and assess the options for enhanced voluntary measures and new or existing international legal instruments. Furthermore, the following priorities were established by the Governing Council to guide international action, and more specifically the work of the ad hoc open-ended working group:

  • Reduce atmospheric mercury emissions from human sources;
  • Find environmentally sound solutions for the management of waste containing mercury and mercury compounds;
  • Reduce the global mercury demand related to use in products and production processes;
  • Reduce global mercury supply, including consideration curbing primary mining and taking into account a hierarchy of sources;
  • Find environmentally sound storage solutions for mercury;
  • Address the remediation of existing contaminated sites affecting public and environmental health; and,
  • Increase knowledge on areas such as inventories, human and environmental exposure, environmental monitoring and socio-economic impacts.

Further information on the 24th Session of the UNEP Governing Council, including the terms of reference of the ad hoc open-ended working group, is available on the UNEP Chemicals and Waste website.

7.0 Waste issues

The management of hazardous waste and hazardous recyclable material within Canada is a shared responsibility. All orders of government have a role to play to ensure that wastes and recyclables are managed in an environmentally sound manner. Environment Canada is consulting with provincial/territorial partners and all stakeholders in examining best management options for end-of-life mercury.

Many municipalities have programs that accept household waste products that contain mercury. Some have implemented collection programs specifically for mercury-containing products such as lamps, while others collect mercury-containing products as part of their household hazardous waste programs. Several retailers of fluorescent lamps, such as Ikea and Home Depot, have also implemented take-back programs for used lamps.

Currently Environment Canada recommends the recycling of mercury recovered from end-of-life products. Recycling discourages the mining of new mercury whereby decreasing overall global potential for environmental releases. However, Environment Canada recognizes the need for long term solutions for the safe end-of-life management of recovered mercury and is currently evaluating options such as long-term storage.

8.0 End of life management

End of life management is aimed at keeping material and products from being released to the environment by ensuring that manufacturers and distributors play a role in effective waste management beyond the point of sale or warranty. The essence of an end of life management program is "the polluter pays" principle and its capacity to influence the design of new products and product systems that avoid waste and enable effective and efficient recovery, reuse or recycling of discarded product.

Potential end of life management programs will include requirements for importers and manufacturers of mercury-containing products to participate in the development and implementation of programs to recover and safely dispose of end of life products.

9.0 Reporting

Manufacturers or importers of mercury-containing products subject to the proposed instruments, as outlined in section 3, will be required to submit information on their activities such as:

  • Their name, civic and postal addresses of principal place of business, e-mail address, if any, telephone number and fax number, if any.
  • The name, title, civic and postal addresses, e-mail address, if any, telephone number and fax number, if any, of the person authorized to act on behalf of the manufacturer or importer, if any.
  • The name of the mixture or the product containing the mercury, if applicable.
  • The calendar year.
  • The total quantity manufactured, and the unit of measurement.
  • The total quantity imported, and the unit of measurement.
  • The quantity sold in Canada, and the unit of measurement.
  • The identification of each proposed use of the mercury and the mixture or product containing the toxic substance, if applicable.
  • The annual average concentration, if applicable.
  • The analytical method used to determine the concentration of the toxic substance in the mixture or product, if applicable.
  • The analytical method detection limit used to determine the concentration of the toxic substance in the mixture or product, if applicable.

10.0 Next steps

Stakeholders are invited to provide written comments on this consultation document by January 31st, 2008. Environment Canada will publish a summary and response to comments which will be followed by consultation sessions in early 2008. Environment Canada will consider all input received from stakeholders in the drafting of proposed instrument provisions. The draft provisions will then be published for public comment in the Canada Gazette, Part I.

The next opportunity for stakeholders to comment on the proposed risk management measures will be following the publication of the provisions in the Canada Gazette, Part I. Please send your comments on this consultation document in writing, by March 7th, 2008, to either of the following addresses:

Regular mail:
Mercury
Waste Reduction and Management
Environment Canada
70 Crémazie St., 6th Floor
Gatineau QC  K1A 0H3
E-mail:
ec.mercureqc-mercuryqc.ec@canada.ca
Please type “Consultation on risk management measures for mercury products” in the subject line of your message

Appendix A - risk management strategy for mercury-containing products

On December 20, 2006, Environment Canada published a Risk Management Strategy for Mercury-containing Products. The Strategy provides a general overview of mercury uses and emission sources in Canada as well as the potential harmful effects of exposure on human health and the environment.

The Risk Management Strategy proposes the development of a mix of risk management instruments to reduce mercury releases to the environment from products to the lowest possible levels. Although the Strategy applies to mercury-containing products in general, it specifically addresses the use of mercury in dental amalgam, thermostats, switches/relays, lamps, batteries, measuring devices, thermometers and tire balancing products.

The Strategy considers prohibition or limits for existing products and new products, labelling requirements, waste management and extended producer responsibility. The tool deemed most appropriate for managing mercury releases from mercury-containing products, to a level consistent with the risk management objective, is a regulation under section 93 of CEPA 1999.

Appendix B - Response to comments

The Risk Management Strategy for Mercury-containing Products was posted on the CEPA Registry website from December 20th/06 - March 31st/07 for public comment. Identified stakeholders were advised of the comment period via regular mail. Fourteen sets of comments were received from industry, industry associations, and environmental groups, including:

  • Canadian Vehicle Manufacturers Association
  • Health Canada
  • International Academy of Oral Medicine and Toxicology
  • Fisher Scientific Company - Thermo Fisher Scientific
  • Metropolitan Council Environmental Services Industrial Waste & Pollution Prevention Section
  • Sign Association Of Canada
  • gGE Consumer & Industrial
  • Pollution Probe
  • EcoSuperior Environmental Programs
  • Clean Air Foundation
  • IVEY Foundation
  • The Canadian Dental Association
  • Dental Industry Association of Canada

In general, stakeholders acknowledged the negative impacts of mercury releases on the environment and recognized the need to minimize them. Comments contained differing views on the best tools to manage releases and the product life-cycle stages to which they should be applied. Several stakeholders submitted technical data on their use of mercury. Comments were considered in the development of this discussion document. Several specific stakeholder comments have been addressed below.

Comments and responses on mercury-containing products
Subject Comment Response
Dental amalgam Estimates of mercury used in dental amalgam are too high. The amount should be closer to 1500kg than 5000kg. A 2007 study based on an extensive survey of dentists indicates that:
- 2051 kg of mercury are used in new and replacement restorations
- 2614 kg of mercury are generated as scrap amalgam
- 2703 kg of mercury were removed in amalgam restorations
- 70% of dentists use ISO separators
Dental amalgam According to sales data about 1500kgs/yr of mercury, under 100gms/yr/dentist is sold yearly. That is less than 0.5gms per day. If 10% is wasted, that would amount to less than 0.05gms of mercury per dentist per day entering the water system from amalgam insertions. This assumes that all dentists have separators and does not include amalgam removed from restorations. It also assumes that the 1500kg sales data is the total amalgam used. These assumptions may not accurately reflect the amount of mercury entering the waste stream from dental facilities.
Dental amalgam EC should provide guidance on appropriate amalgam separators. EC does not endorse specific models but can provide guidance on the ISO standard for dental amalgam separators.
Dental amalgam Dental amalgam should be prohibited without exemptions. Environment Canada's risk management objective is to reduce mercury releases to the environment from consumer products to the lowest possible level. As viable alternatives do not currently exist for all applications of dental amalgam it is not possible to prohibit its use, end-of-life management has been determined to be the preferred option to manage amalgam releases to the environment.
CFLs The amounts of mercury used in fluorescent lamps are so low, they are no longer considered to be a hazardous waste at disposal. Designation as hazardous waste depends on the quantity being disposed.
CFLs Lower energy usage also results in less mercury emissions from power plants. Environment Canada recognizes the energy efficiency of CFLs. However, CFLs only reduce atmospheric mercury emissions where energy is produced from coal fired power plants.
CFLs Suggested use of IMERC US sales data to estimate Canadian usage. Product import data was gathered from Canadian Border Services Agency, including elemental mercury imports by domestic manufacturers. Environment Canada researchers also gathered information on domestic manufacturing from Electro-Federation Canada.
General Stakeholder recommends overall mercury strategy which includes international initiatives in addition to risk management strategy. Environment Canada is considering the development of an overall mercury strategy.
General Stakeholder would like to clarify that mercury used in dental amalgam is inorganic mercury and not methylmercury.  
General The way section 3.1 is written it appears that any level of exposure to mercury could be harmful. The first paragraph of this section states that "the severity of mercury's toxic effects depends on the form and concentration of mercury and the route of exposure."
General - lamps Stakeholder would like to note that mercury use in automotive headlights is low and should not be used as an example in Table 2 of the Risk Management Strategy . Table 2 is intended to provide a sample of how mercury-containing products can be used as components of larger products. This list is not comprehensive or indicative of the quantity of mercury in products.


Appendix C - general overview of international risk management actions on mercury-containing products

C-1 Batteries
Jurisdiction: country/region Background legislation 1 Background legislation 2 Tool Type of product(s) controlled
Sweden Swedish Government Ordinance (1998:944)   Environmental Tax batteries
USA Maine Legislature Bill LD 1061 Act to regulate the use of batteries containing mercury EPR batteries
USA Maine Legislature Bill LD 1060 Act to regulate the use of batteries containing mercury incineration ban batteries
USA Maine Legislature Bill LD 1058 Act to regulate the use of batteries containing mercury labeling batteries
  Maine Legislature Bill LD 1059 Act to regulate the use of batteries containing mercury landfill ban batteries
USA Connecticut Legislature Bill HB 5446   product ban batteries
USA Maine Legislature Bill LD 1058 Act to regulate the use of batteries containing mercury product ban batteries
European Community (Germany, Greece, Ireland, Italy, Luxembourg, Spain, UK, Norway, Sweden), Switzerland, USA EC Directive, Ordinance related to environmentally hazardous substances (amended 1998), Mercury-containing and re-chargeable battery management Act 1996 98/101/EC product ban with exemptions batteries
European Community (Germany, Greece, Ireland, Italy, Luxembourg, Spain, UK, Sweden), Denmark, Finland, France EC Directive, Statutory Order, Council of State Decision 17/1999; HELCOM Recommendation 14/5, Decree 12.5.1999, modified 29.12.1999, Municipal waste collection bylaws 91/157/EEC; 98/101/EC, EC Battery Directive Required collection of end of life product batteries
Switzerland Ordinance related to environmentally hazardous substances (amended 1998) Annex 4.10 Required collection of end of life product; producer pays fee batteries
Canada Voluntary Agreement US Battery Act Voluntary agreement batteries

 

C-2 Measuring and medical devices
Jurisdiction: country/region Background legislation 1 Background legislation 2 Tool Type of product(s) controlled
48 US States Voluntary Extended Producer Responsibility (EPR) Program, Maine Legislature Bill LD 1792 Act to Protect Maine Families and the Environment by Improving the Collection and Recycling of Mercury Thermostats EPR thermostats
USA Louisiana Legislature Bill SB 615   labeling dairy manometers, gas manometers, thermometers
USA State (Washington, Vermont) Washington Legislature BILL SB 6090, Vermont Legislature H 0876 Management of Exposure to Mercury Act Mercury Action Plan hospital equipment, thermostats
USA State (Massachusetts, New York, New Jersey, Maryland), Sweden, France, Norway Massachusetts Legislature Bill H5112 (previously known as H4670), New York Legislature Bill A 05543, New Jersey Legislature Bill A3377, Maryland Legislature Bill SB 772, Swedish Government Ordinances 1991:1290 and 1998:947, Decree 24.12.1998, Legislative Order 26 March 1998 Act Relevant to Mercury Management, Regulations 98:8, Hazardous Products Act product ban barometers, bougie tubes, esophageal dilator, flow meter, gastrointestinal tube, hydrometer, hygrometer, manometer, Measuring instruments, psychrometer, pyrometer, sphygmomanometers, thermometers, thermostats
USA State (California, Louisiana, Rhode Island, Maine, IMERC), Denmark California Assembly Bill 1415, Louisiana Legislature Bill SB 615, Rhode Island Legislature Bill S0611, Statutory Order, Interstate Mercury Education and Reduction Clearinghouse (IMERC) Chapter 578, Statutes of 2005, Mercury Reduction and Education Act 2001, IMERC is a program established by the Northeast Waste Management Official's Association (NEWMOA) product ban with exemptions barometers, blood pressure cuffs, dairy manometers, dairy manometers, flame sensors (mercury diostats), flow meters, gas manometers, gastrointestinal tubes, hydrometers, manometers, measuring devices, medical devices, pyrometers, thermometers
USA Interstate Mercury Education and Reduction Clearinghouse (IMERC). IMERC is a program established by the Northeast Waste Management Official's Association (NEWMOA). product disposal regulations thermostats
USA Maine Legislature Bill LD 1792 Act to Protect Maine Families and the Environment by Improving the Collection and Recycling of Mercury Thermostats Reporting requirement thermostats

 

C-3 Dental amalgam
Jurisdiction: country/region Background legislation 1 Background legislation 2 Tool Type of product(s) controlled
USA Rhode Island Legislature Bill H7812/H7812Aaa   BMP dental amalgam
UK Pollution Prevention and Control Regulations 2000 (PPC) Regulation 37 burden sharing dental amalgam
Norway , Sweden, New Zealand Voluntary Agreement, New Zealand Dental Association Guideline # 2916, Agreement between dental associations and Swedish EPA, 'Practice Guideline - controlling dental amalgam waste and wastewater discharges' Code of Practice dental amalgam
USA Maine Legislature Bill LD 1338 Act to Limit Human Exposure to Mercury Dental Plan Coverage Requirements dental amalgam
USA Maine Legislature Bill LD 1338 Act to Limit Human Exposure to Mercury Education / Outreach programs dental amalgam
UK Pollution Prevention and Control Regulations 2000 (PPC) Regulation 37 emission controls dental amalgam
Norway Emission Regulations   Emission limit dental amalgam
France , Sweden Decision by Agence Francaise de Securite Sanitaire et des Produits de Sante (AFSSAPS), Guidelines and Sector specific guidance document (crematoria)   Guidelines dental amalgam
USA Maine Legislature Bill LD 1338 Act to Limit Human Exposure to Mercury liability dental amalgam
USA Maine Legislature Bill LD 1338 Act to Limit Human Exposure to Mercury product ban dental amalgam
Denmark Statutory Order   product ban with exemptions dental amalgam
USA Federal Food, Drug, ands Cosmetics Act (FFDCA) Medical device regulations Regulations dental amalgam
France , Sweden Regulations 30.3.1998, Municipal waste collection bylaws   Required collection of end of life product dental amalgam
USA New Mexico Legislature - House Memorial 13   Study dental amalgam
Canada CCME Guidelines CWS for dental amalgam Voluntary agreement dental amalgam - emissions to sewers only
Sweden Public Dental Care Association Policy Compensation policy Withdrawal of public health coverage dental amalgam

 

C-4 Switches and relays
Jurisdiction: country/region Background legislation 1 Background legislation 2 Tool Type of product(s) controlled
USA State (Maine, New Jersey, Rhode Island, South Carolina, Texas, Utah, Vermont) Maine Legislature Bill LD 185, Maine Legislature Bill LD 692, New Jersey Legislature Bill A2482, Rhode Island Legislature Bill H8220, South Carolina Legislature H3922, Texas Legislature HB 2793, Utah Legislature House Bill 138, Vermont Legislature H 0876 Act to Amend the Law on Mercury-Added Products, Act to Require that Hazardous Waste be Removed from Junked Vehicles, Mercury Switch Removal Act, Management of Exposure to Mercury Act EPR switches
USA State (Massachusetts, North Carolina, Rhode Island) Massachusetts Legislature Bill H5112 (previously known as H4670), North Carolina Legislature Bill 1136, Rhode Island Legislature Bill H5911/H5911Aaa Act Relevant to Mercury Management EPR / P2P switches
USA State (Massachusetts, North Carolina, Rhode Island) Massachusetts Legislature Bill H5112 (previously known as H4670), North Carolina Legislature Bill 1136, Rhode Island Legislature Bill H8220 Act Relevant to Mercury Management financial incentives switches
USA State (Washington) Washington Legislature BILL SB 6090   Mercury Action Plan switches
Canada CEPA Part 4. Pollution Prevention Pollution Prevention Plan switches
Sweden Swedish Government Ordinances 1991:1290 and 1998:945   product ban level switches, pressure switches, relays
USA State (Massachusetts, New York) Massachusetts Legislature Bill H5112 (previously known as H4670), New York Legislature Bill A 05543, New York Legislature Bill A 05543, New York Legislature Bill S 07961 Act Relevant to Mercury Management product ban relays, switches
USA State (California) California Assembly Bill 1415 Chapter 578, Statutes of 2005 product ban with exemptions relays, switches
USA Interstate Mercury Education and Reduction Clearinghouse (IMERC), Proposed EPA Rule IMERC is a program established by the Northeast Waste Management Official's Association (NEWMOA). product ban with exemptions switches
USA State (Massachusetts, North Carolina) Massachusetts Legislature Bill H5112 (previously known as H4670), North Carolina Legislature Bill 1136 Act Relevant to Mercury Management Reporting requirement switches
Norway , Sweden Regulation, Municipal waste collection bylaws   Required collection of end of life product switches, components from vehicles
USA National Vehicle Mercury Switch Recovery Program 2006   voluntary agreement switches

 

C-5 Lamps and electronic/electrical devices
Jurisdiction: country/region Background legislation 1 Background legislation 2 Tool Type of product(s) controlled
USA Illinois Legislature Bill HB 1149   Establishes commission to review computer recycling computer equipment
Norway , Washington State Guidelines, Washington Legislature BILL SB 2662/6428   Extended Producer Responsibility (EPR) Program E & E products
USA Louisiana Legislature Bill SCR 20   Requires Senate Committee to review computer and other E&E recycling E&E
USA State (New Mexico, Rhode Island) New Mexico Legislature - Senate Joint Memorial 9, Rhode Island Legislature Bill H7789/H7789A   Study E&E
USA Rhode Island Legislature Bill H7789/H7789A   disposal ban E&E
European Community, Denmark, Germany, Greece, Ireland, Italy, Luxembourg, Spain, UK, Norway, Sweden Statutory Order, EC Directive WEEE and/or RoHS 2002/95/EC product ban with exemptions electrical equipment
Sweden Swedish Government Ordinances 1991:1290 and 1998:946 Regulations 98:8 product ban electrical equipment
Sweden Municipal waste collection bylaws   Required collection of end of life product electronics, fluorescent lamps
USA State (Maine, Minnesota) Maine Legislature Bill LD 185, Minnesota Legislature Bill 3712 Act to Amend the Law on Mercury-Added Products, Companion to Bill SF3398 labeling lamps
Washington State Washington Legislature BILL SB 6090   Mercury Action Plan lamps
Canada CCME Guidelines CWS for lamps Voluntary agreement lamps

 

C-6 Other
Jurisdiction: country/region Background legislation 1 Background legislation 2 Tool Type of product(s) controlled
USA Massachusetts Legislature Bill H5112 (previously known as H4670) Act Relevant to Mercury Management Education programs all
USA US EPA Regulation, US EPA New Source Performance Standards (NSPSs) and Emission Guidelines   emission regulation all
USA State (Massachusetts, Rhode Island) Massachusetts Legislature Bill H5112 (previously known as H4670), Rhode Island Legislature Bill S0611 Act Relevant to Mercury Management, Mercury Reduction and Education Act 2001 EPR all
Denmark Statutory Order 692 export ban all
USA State (Louisiana Massachusetts, Rhode Island, IMERC), European Community, Sweden Louisiana Legislature Bill SB 615, Massachusetts Legislature Bill H5112 (previously known as H4670), Rhode Island Legislature Bill S0611, Interstate Mercury Education and Reduction Clearinghouse (IMERC), EC Directive Act Relevant to Mercury Management, Mercury Reduction and Education Act 2001, IMERC is a program established by the Northeast Waste Management Official's Association (NEWMOA), 67/548/EC, 2001/59/EC labeling all, mercury products for schools, novelty items
USA State (Louisiana, New Mexico, Washington) Louisiana Legislature House Concurrent Resolution HCR 51, New Mexico Legislature - House Memorial 5, Washington Legislature BILL SB 6090   Mercury Action Plan all
Sweden Action Program Swedish EPA Mercury Collection Action Program all
Norway General requirement   National Guidelines all
USA State (Massachusetts, Rhode Island, IMERC) Massachusetts Legislature Bill H5112 (previously known as H4670), Rhode Island Legislature Bill S0611, Interstate Mercury Education and Reduction Clearinghouse (IMERC). Act Relevant to Mercury Management, Mercury Reduction and Education Act 2001, IMERC is a program established by the Northeast Waste Management Official's Association (NEWMOA) notification all
Sweden National Ban must be approved by European Commission - decision expected 2007 Product ban all
Canada Hazardous Products Act Prohibited uses of Mercury Product ban Coatings for use on childrens toys, equipment
USA State (Maine, Rhode Island) Maine Legislature Bill LD 1058, Rhode Island Legislature Bill S0611 Act to regulate the use of batteries containing mercury, Mercury Reduction and Education Act 2001 product ban novelty items
European Community (Germany, Greece, Ireland, Italy, Luxembourg, Spain, UK), Norway, Sweden EC Directive 2000/53/EC product ban vehicles
USA Pollution Prevention Act 1990 Prohibition on mercury use in paints product ban paints
USA State (Louisiana, Rhode Island) Louisiana Legislature Bill SB 615, Rhode Island Legislature Bill S0611 Mercury Reduction and Education Act 2001 product ban with exemptions all
Denmark , Netherlands, Switzerland Statutory Order, Decree on products containing mercury (# 553), 1998, Regulation on mercury-containing products (1986) 692, Environmentally Hazardous Substances Act product ban with exemptions all
USA Interstate Mercury Education and Reduction Clearinghouse (IMERC). IMERC is a program established by the Northeast Waste Management Official's Association (NEWMOA). product ban with exemptions mercury
USA Louisiana Legislature Bill SB 615   product ban with exemptions mercury products for schools
USA State (Louisiana, IMER) Louisiana Legislature Bill SB 615, Interstate Mercury Education and Reduction Clearinghouse (IMERC). IMERC is a program established by the Northeast Waste Management Official's Association (NEWMOA). product ban with exemptions novelty items
USA State (California) California Assembly Bill 1415 Chapter 578, Statutes of 2005 product ban with exemptions ovens / gas ranges
USA Resource Conservation and Recovery Act (RCRA) Universal waste rule (1995) product disposal regulations all
USA State (Indiana) Indiana Legislature Bill HB 1102   Public education programs all
USA State (Massachusetts) Massachusetts Legislature Bill H5112 (previously known as H4670) Act Relevant to Mercury Management Regulation: disposal restrictions all
USA State (Maryland) Maryland Legislature Bill SB 772   Reporting requirement all
USA Pollution Prevention Act 1990 Toxics Release Inventory (TRI) Regulations Reporting requirement all
Germany , Greece, Ireland, Italy, Luxembourg, Spain, UK, Norway EC Directive 2000/53/EC Required collection of end of life product vehicles
Sweden Swedish Government Bill (1990:91/90), Swedish Government Bill (1993:94/163), Swedish Government Bill (2000:01/65) Overarching goal-setting legislation set of legislative and voluntary tools all
USA Voluntary 35/50 Program   voluntary agreement all
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