Special Interest Groups Call on State of Vermont to Ban Sale of Fluorescent Lamps Containing Mercury

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Several environmental and consumer policy groups have worked together to demand new Vermont legislation that would effectively ban the sale of all fluorescent lighting products containing mercury in the state.

In a joint press announcement, the Vermont Public Interest Research Group (VPIRG), the Mercury Policy Project, the Clean Lighting Coalition (CLiC) and the Appliance Standards Awareness project (ASAP) explained their reasons for petitioning the Vermont state legislators through the Vermont Department. of Environmental Conservation (DEC) to modify the current policy.

“Under current Vermont law, fluorescent lamps can only be sold until a mercury-free alternative is available that offers the same performance at equal or less cost,” the advocacy groups explained in the announcement. The groups reported that in October, a letter from VPIRG to DEC argued for the wide availability of LED lamps that meet state criteria as alternatives to fluorescent technology containing mercury.

State seeks industry opinion

In turn, DEC representatives sought industry advice on the comparability of LED lamps and fluorescent lamps in terms of price and performance from the National Electrical Manufacturers Association (NEMA). The association, which represents U.S. manufacturers of electrical and medical imaging equipment, sent a response letter to DEC’s director of waste management and prevention, Matt Chapman, dated November 16, 2021, that NEMA vice president of government relations, Philip A. Squair, identified as “” the collective response of the [NEMA] Light Source Product section to correspondence received on November 1 regarding compliance with 10 VSA §7152 of the 2012 legislation for the collection and disposal of lamps containing mercury.

In the NEMA response letter, Squair outlined the point made by the special interest groups in their initial letter to DEC: There is an energy efficient mercury-free lamp that offers equal or better overall performance at equal or greater cost. the classes of lamps that the manufacturer proposes to sell. “

The parties to NEMA concluded that “the only mercury-added general-purpose lighting product for which a ‘mercury-free, energy-efficient alternative lamp is available that provides equal or better overall performance at equal or greater cost. ‘to that of added mercury. the product is a screw-type compact fluorescent lamp [CFLs]. Mercury-free alternatives for all other general-purpose (as well as specialty) mercury-added lamps are not available, cost significantly more per unit, or have performance issues.

Ultimately, NEMA’s response agreed that while CFLs can be suitably replaced with LED lamps, other retrofit LED lamp offerings do not meet the qualifications that would cause NEMA to identify them as “acceptable replacements” – an extended category of lamps being the Linear Fluorescent Lamp (LFL) alternatives.

Debate on LFL alternatives

Advocacy groups took issue with NEMA’s comments to DEC, summarizing their arguments in the full statement, which is posted in the Company News Feed section of our website. In particular, advocates have challenged cost and price interpretations as they appear to be defined by the NEMA criteria, in addition to the accessibility of LED alternatives to LFLs.

“The price is not the same as the cost from a consumer or small business perspective,” said Ana-Maria Carreño of CLiC. “The cost of a bulb includes both the cost of purchasing the bulb and the cost of operating it in our homes and offices. If the state uses this common sense definition of cost, fluorescent lighting has already lost out across the board.

Additionally, according to ASAP’s Brian Fadie, “[Users] who have instant start fluorescent ballasts can purchase a four-foot LED retrofit bulb for just 72 cents more than a fluorescent bulb “via a Home Depot retailer in Vermont. “Because the LED bulb cuts electricity costs in half, that 72 cents is saved on the utility bill in just one month, and the LED bulb then lasts 9 years,” Fadie said in the ad.

While such cost breakdowns seem solid, the discussion reveals a comparison of apples to oranges. In the NEMA letter, the association cited product and pricing data from professional electrical equipment distributor Grainger – not a big box retailer, which tends to be the domain of the do-it-yourself owner rather. as commercial, industrial and institutional organizations which are the largest consumers of LFL or tube lamps.

In response to a request for comments on lawyers’ points, LED magazine received the following statement from Phil Squair of NEMA:

“Although mercury-free linear LED lamps ARE available as replacements for many linear fluorescent lamps (LFLs), only certain types are ‘plug-and-play’ and thus allow a direct comparison of costs, with LED lamps selling for prices. significantly higher per unit, in the broad sense. Most LFL lighting systems – and virtually all HIDs [high-intensity discharge] lighting systems – will require rewiring or replacement by an electrician to convert to LEDs, which needs to be factored into the cost comparison. Additionally, as the installed base of lighting fixtures is so diverse, there will always be limitations for “plug-and-play” or “drop-in” LED retrofit lamps, which are not universally compatible with all. fluorescent devices. Improper installation can create excess heat which can damage the fixture or ballast and cause the lamp to fail during initial start-up.

“Each situation must be assessed individually by those who manage – and pay for – lighting systems in private and public facilities. The lighting industry has installed fluorescent lighting systems for over 80 years, and manufacturers support and benefit from the continued conversion to mercury-free light sources. It is a TRANSITION, however, based on the fact that mercury-added products remain available as commercial, industrial and institutional companies gradually improve their lighting systems, ”the Squair statement concluded.

VPIRG and partners report that a preliminary decision on this petition is expected to be released by the DEC in early 2022.

More resources

Read the full letter from NEMA to Vermont DEC

Learn more about VPIRG, CLiC, as quickly as possible, and the Draft Mercury Policy

Visit the NEMA website for more details on his mission

Read a recent commentary on eliminating mercury-containing lighting

CARRIE MEADOWS is Associate Editor-in-Chief of LEDs Magazine, with 20 years of business-to-business publishing experience in technology markets including semiconductor technology manufacturing, fiber optic communications, machine vision, lasers and photonics, as well as LEDs and lighting.


Editor’s comment

Other researchers and stakeholders in the lighting industry have admitted that contemporary plug-and-play LED tubes, or TLEDs, are far from an ideal solution to the ubiquitous LFL – but they have improved over it. to previous incarnations. Earlier this year, Michael Siminovitch, director of the California Lighting Technology Center (CLTC), noted that a quality specification for linear LED lamps is a must, after evaluating many options for the latest iteration of California’s Million LED program. Challenge. Still, Siminovitch said in May, “There are places for TLEDs, good quality TLED… Say, if you have a pendant fixture, an expensive indirect fixture. “

It hardly seems like the biggest lighting players are against a phase-out of inefficient general lighting products that contain mercury. After all, in August contributor Mark Halper reported on comments from Signify CEO Eric Rondolat in support of a European climate initiative called Fit for 55. tonnes of CO2 emissions per year, ”Rondolat said.

Some specialized applications such as germicidal ultraviolet (GUV) systems may take longer to achieve massive absorption of LEDs, but semiconductor industry consultant Mike Krames predicts that these products will be widely adopted as the UV-C LED architectures are evolving to provide more UV-C energy than alternatives to mercury lamps.

In any case, policy makers are unlikely to overlook cost / benefit scenarios for LEDs as a natural evolution away from less efficient light sources as loads on power grids become heavier. Now the question remains as to what happens to all the old lamps containing mercury. But that’s a different subject for another day. – CAM


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