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Environmental and human health effects of compact fluorescent light bulbs

Petition: No. 254

Issue(s): Climate change, human health/environmental health, toxic substances, waste management, and other

Petitioner(s): Magda Havas and Thomas Hutchinson

Date Received: 23 June 2008

Status: Completed

Summary: The petitioners are concerned about a number of environmental and human health issues associated with compact fluorescent light bulbs. The petitioners state that these issues include emissions of ultraviolet (UV) and radio frequency radiation, the generation of electrical pollution, the mercury content in the bulbs, and safe recycling and disposal. The petitioners allege that compact fluorescent light bulbs make some people ill and ask the government to take measures to reduce or eliminate the problems associated with them and to consider alternative technologies.

Federal Departments Responsible for Reply: Environment Canada, Health Canada, Industry Canada, Natural Resources Canada

Petition

 

Environmental Petition submitted to the Auditor General of Canada
June 2008

Environmental and Health Concerns Associated with Compact Fluorescent Lights

Name of Petitioner: Magda Havas, B.Sc., Ph.D. and Tom Hutchinson, B.Sc., Ph.D., FRSC.
Address of Petitioner:

[Information withheld]

 
Telephone Number: [Informaion withheld]  
Email Address: [Information withheld]; thutchinson@trentu.ca.  

Signature:

[Original signed by Magda Havas and Thomas C. Hutchinson]

Magda Havas   Thomas C. Hutchinson

Date:

Document:

15 pages  

 


 

Environmental Petition submitted to the Auditor General of Canada
June 2008

Environmental and Health Concerns
Associated with Compact Fluorescent Lights
Magda Havas, B.Sc., Ph.D. and Tom Hutchinson, B.Sc., Ph.D., FRSC.

[Information withheld] 
[Information withheld]; thutchinson@trentu.ca.

Table of Content

Background Information 3
CFL Bulbs contain Mercury 3
CFL Bulbs emit UV Radiation 6
CFL Bulbs emit Radio Frequency Radiation 6
CFL Bulbs generate Dirty Electricity 7
CFL Bulbs are making People Sick 8
Conclusions 11
Petitions Requests/Questions 11
References 13
Appendix A: What to do if a CFL breaks, EPA 15

Figures and Tables

Figure 1. Waveforms generated by an incandescent light bulb and a compact fluorescent light bulb. Input A: 0.5 meters from bulb. Input B: on wire after passing through a ubiquitous filter that removes the 60-Hz cycle. Readings were taken on a Fluke 196 Scope Meter. 8
Figure 2. Responses to an electronic survey on self-proclaimed electrohypersensitivity and to various types of lighting (n=168). 10
Table 1. Symptoms of Electrohypersensitivity or Radio Wave Sickness 10

 

Environmental Petition submitted to the Auditor General of Canada
June 2008

Environmental and Health Concerns Associated with Compact Fluorescent Lights

Magda Havas and Thomas C. Hutchinson 
[Information withheld] 
[Information withheld], thutchinson@trentu.ca

BACKGROUND INFORMATION

With growing concern about climate change, governments around the world are looking for ways to reduce greenhouse gases and to reduce consumption of fossil fuels. One simple solution that has gained government support is phasing out energy inefficient light bulbs and replacing them with energy efficient ones.   The most popular bulbs that are commercially available and affordable are compact fluorescent lights (CFL). CFL bulbs use approximately 75% less energy than incandescent light bulbs and last longer. At first glance this seems like a good way to conserve energy and to protect our environment. However, there are a number of serious problems associated with CFL bulbs that need to be considered and corrected. These include mercury content, emission of UV radiation, emission of radio frequency radiation, and generation of dirty electricity. There is the additional concern that these lights are making some people ill. This includes those who suffer from migraines, skin problems, epilepsy, and electrical sensitivity (1,2,3,4).

CFL BULBS CONTAIN MERCURY

Mercury is a known neurotoxin and can be dangerous once it is released into the environment. Light bulbs contain approximately 5 milligrams of mercury (although some manufacturers are trying to reduce that amount). The Canadian Water Quality Guideline (CWQG) to protect freshwater life is 26 nanograms of inorganic mercury per litre of water (5). What this means is that one light bulb could contaminate 190,000 liters of water to levels that exceed our water quality guidelines! With thousands of bulbs sold around the country and inadequate disposal facilities we are setting ourselves up for a mercury time bomb.

Mercury is the most volatile of all of the metals and its propensity to volatilize from landfill sites is high. Much of this mercury ends up in the Canadian arctic, where levels are known to be increasing and are of considerable concern (8). Mercury is so ubiquitous that we have advisories in Canada for eating mercury-contaminated fish in lakes (9).

Mercury can be released into the environment if the bulb is accidentally broken in the home, incinerated, or disposed at a landfill site.
Accidental Breakage: The US EPA has information on their website on how to clean up a broken CFL (6). It includes opening windows, wearing rubber gloves, and double-bagging the broken pieces (refer to Appendix A).

Disposal: CFLs need to be deposited at a toxic waste facility. Few Canadians are aware of this. Some information on proper disposal is available at Natural Resources Canada (NRCan) website on consumer questions (7). What is disturbing about information provided by NRCan is that they do not REQUIRE proper disposal of these bulbs. In response to a question about correct disposal of CFL, they state:

"Just like paint, batteries, thermostats and other household chemicals, compact fluorescent bulbs should be disposed of safely. Homeowners are encouraged to take advantage of local disposal programs for CFLs, where available. Governments are working with CFL manufacturers and major Canadian retailers to expand recycling options.

Many municipalities have programs that accept household products that contain mercury. Some have implemented collection programs specifically for mercury-containing switches such as those found in your car, while others collect mercury-containing products as part of their household hazardous waste programs. Contact your municipality to find out about local disposal options.

ENERGY STAR qualified CFLs have a warranty. If the bulb fails within the warranty period, return it to your retailer. "

This response is woefully inadequate. Proper disposal of mercury should not be a matter of chance it should be regulated. If the government is going to ban energy inefficient lights then they need also regulate the safe disposal of the toxic alternatives! If toxic waste disposal facilities are not available in a particular community then the retail story selling the product should accept the return of that produce for disposal or recycling.   We do not put lead in paint any more and we should not put mercury in light bulbs. Energy efficient mercury-free bulbs are available but are not yet affordable. Until that day arrives and we can use bulbs without mercury, at the very least we should be safely disposing light bulbs that contain mercury!

The Canadian Council of Ministries of the Environment (CCME) established Canada-wide Standards (CWS) for mercury-containing lamps in 2001. The CWS is aiming for a 70% reduction by 2005 and an 80% reduction by 2010 in the average content of mercury in all mercury-containing lamps sold in Canada, from a 1990 baseline (10).

According to a 2005 Progress Report (11) of the CWS we are not doing well. Below are some examples from this document.

  1. For the period 1999 to 2002 less than 5% of the fluorescent lamps are being recycled in Alberta. And this refers to tube fluorescent lamps, not CFL.
  2. Nova Scotia has been unable to establish a program for recycling due to "relatively small volumes of mercury-containing lamps and a disperse population base." Clearly, the "relatively small volume" no longer applies as incandescent lamps are being phased out.
  3. In Nunavut one method of disposal is "crushing of fluorescent tubes, collecting and shipping the material to disposal facilities." As soon as the tubes are crushed the mercury is released into the environment. Clearly this is not an undesired method of disposal.
  4. Ontario started lamp recycling in several government buildings and, as of 2005, has recycled 30,000 lamps and has captured 1 kg of mercury. Clearly this program needs to be extended beyond government buildings.
  5. Saskatchewan does not have lamp recycling companies and all such materials must be shipped out of province for processing with their related transportation energy costs.
  6. Prince Edward Island has made the most progress. Mercury-containing lamps cannot be placed curbside. They must be taken to one of six Waste Watch Drop-off Centers in the province where they are collected for disposal. Mercury-containing lamps must be removed from buildings prior to demolition. However, it is not clear how the Waste Watch Drop-off Centers dispose of these bulbs and how successful the drop-off program is? In order words, what percentage of the bulbs are left at curbside for dumping.

The CCME clearly recognizes the importance of keeping mercury out of the environment, but their progress in recycling mercury-containing light bulbs has been minimal. Even if the amount of mercury is reduced in light bulbs, the fact that Canadians are required to use these light bulbs means that we are losing the battle of mercury in the environment since a much larger amount of mercury-containing light bulbs are being used now than back in 1990. Unless we have appropriate recycling and proper disposal of all fluorescent lights and other lights that contain mercury (mercury discharge bulbs) we will lose the battle and will introduce more mercury into the environment with serious consequences to the health of wildlife and humans.

Arguments that emission of mercury via light bulbs is much less than the burning of coal is a red herring since in Canada we have other sources of energy including hydroelectric, natural gas, oil, nuclear, wind, and solar. We need to keep mercury levels as low as possible from ALL sources. Clearly mercury is a toxicant that should not be released into the environment.

CFL BULBS EMIT UV RADIATION

Fluorescent light bulbs contain mercury, which emits UV radiation when it is electrically excited. This UV radiation then interacts with the chemicals on the inside of the bulb to generate light. According to Philippe Laroche, Media Relations Officer for Health Canada, compact fluorescent light bulbs, unlike tube fluorescent bulbs, do not have prismatic diffusers to filter UV radiation. "Therefore, there may be skin sensitivity issues, especially in people with certain skin diseases."

Interestingly, the British Dermatological Association has spoken out against CFL bulbs because their patients have adverse reactions to them (3). They are asking the UK government to allow people with skin problems to continue using incandescent light bulbs once the ban for energy inefficient bulbs becomes law.

Not all CFL are the same. GE produces a low-UV bulb called Saf-T-Gard (registered Trade mark) for dark rooms. So the technology to produce safer bulbs is available and should be required for all bulbs. Why do we have bulbs on the market that emit UV when technology preventing this is readily available?

CFL BULBS EMIT RADIO FREQUENCY RADIATION

CFLs emit radio frequency radiation at levels that may interfere with various types of wireless technology. General Electric acknowledges this and puts the following notice on the back of product packaging for all GE electronically ballasted CFLs:

"This product complies with Part 18 of the FCC Rules, but may cause interference to radios, televisions, wireless telephones, and remote controls. Avoid placing this product near these devices. If interference occurs, move the product away from the device or plug either into a different outlet. Do not install this product near maritime safety equipment or other critical navigation or communication equipment operating between 0.45-30MHz. "

Interference with wireless telecommunication technology comes under the jurisdiction of Industry Canada. The type of interference generated by CFL falls into several regulatory categories of "interference" as follows (12):

  1. Electromagnetic Compatibility - The ability of an equipment or system to function satisfactorily in its electromagnetic environment without introducing intolerable electromagnetic disturbances to anything in that environment.
  2. Radio Frequency Interference - Any modification to the reception of sound or picture signals that make them unacceptable (includes Broadcast Interference - BCI, and Television Interference - TVI).
  3. Electromagnetic Disturbance - Any electromagnetic phenomenon (or transmission) which may degrade the performance of a device, equipment or system, or adversely affect living or inert matter.

Despite the potential interference of CFL with wireless technology, there is no mention of or reference to compact fluorescent lighting on the Industry Canada web site. Is industry Canada aware of radio frequency interference and, if they are, how do they propose to minimize it?

CFL BULBS GENERATE DIRTY ELECTRICITY

Poor power quality is commonly referred to as "dirty electricity" and is defined as deviations in the magnitude and frequency of the sinusoidal waveform. According to Hydro One (13).

"It [power quality disturbance] can take many forms, such as: voltage sag, phase unbalance and voltage swells, transient disturbances, momentary interruptions, and long-term steady state waveform distortions."

CFLs produce transients that contribute to poor power quality on electrical wires. According to General Electric (GE) their typical electronically-ballasted CFL operate in the 24-100 kHz frequency range. This range is within the radio frequency band of the electromagnetic spectrum and is classified as Intermediate Frequency (IF) by the World Health Organization. There is concern about electromagnetic interference (EMI) associated with IF and recently studies have shown that IFs are biologically active and can have adverse health effects (14, 15).

Figure 1 provides an example of the dirty electricity generated by a compact fluorescent light bulb in comparison to an incandescent light bulb. Readings were taken through the air (0.5 m from bulb) and on the electrical wire (after passing through a ubiquitous filter that removes the 60-Hz frequency). The waveform through the air is radio frequency radiation that can contribute to electromagnetic interference (EMI), as mentioned above, and the waveform on the wire is dirty electricity.

Not all CFL are the same some generate more dirty electricity than others. In a recent study (16) the values for dirty electricity ranged from 47 to 1450 GS units compared with a background value (with lights off) between 54-58 GS units. Clearly technology exists to produce CFL that do not generate dirty electricity. What is Health Canada doing to require all bulb manufacturers to adhere to the best practices and manufacture light bulbs that do not compromise power quality on electrical wires?

In addition to the effects of poor power quality on sensitive electronic devices, dirty electricity has been shown to adversely affect human health. A recent study of cancer clusters in a school in California associated the increased risk of cancer among teachers to dirty electricity (15). Teachers who taught in classrooms where the dirty electricity was above 2000 GS units had a 5-fold increase risk of cancer (risk ratio 5.1) that was statistically significant.   Teachers who never taught in those classrooms had a risk ratio of 1.8. The CFL bulbs in Figure 1 generated almost 300 GS units of dirty electricity. Clearly a house full of such bulbs could have serious health consequences.

In a Wisconsin school experiencing sick building syndrome, once the power quality was improved with power line filters plugged into electrical outlets student and teacher health improved. Of the 37 students who suffered from asthma and used inhalers on a daily basis only 3 required them and only for exercise-induced asthma once the dirty electricity was eliminated (17).
Studies with diabetics and people who have multiple sclerosis report an improvement in symptoms that coincide with improved power quality in homes (18).

If some CFLs produce dirty electricity and if dirty electricity is associated with ill health, clearly these bulbs need to be redesigned.

Figure 1. Waveforms generated by an incandescent light bulb and a compact fluorescent light bulb. Input A: 0.5 meters from bulb. Input B: on wire after passing through a ubiquitous filter that removes the 60-Hz cycle. Readings taken on a Fluke 196 Scope Meter.

CFL BULBS ARE MAKING PEOPLE SICK

One illness that Natural Resources Canada seems to accept that is exacerbated by CFL is Irien Syndrome. Below is a quote from the NRCan website (19):

"Research has shown that fluorescent lights can intensify the problems associated with Irien Syndrome (also known as Scotopic Sensitivity Syndrome), a perception problem that affects a person's ability to read. Incandescent lamps, on the other hand, have proven to be the most favourable source of artificial light for people with Irien Syndrome. The Government of Canada's proposed phase-out of inefficient lamps will not ban any particular technology but will regulate minimum efficiency levels for lamps. This means that incandescent lamps that meet the minimum requirements -such as a super-efficient incandescent lamp currently under development - will still be available to consumers.

The objective of the Government's regulatory proposal is not to cause hardship for Canadians but to ensure that there are practical and effective replacements for inefficient lamps. Prior to setting minimum efficiency levels, NRCan will consider many issues, including the economic, safety, environmental and health needs of Canadians. Exclusions to the standard will be identified, if necessary."

Clearly, others are also affected by these bulbs as mentioned above for power quality.

A growing population is developing symptoms of electrohypersensitivity (EHS), which the WHO defines as (20):

"... a phenomenon where individuals experience adverse health effects while using or being in the vicinity of devices emanating electric, magnetic, or electromagnetic fields (EMFs). . . . Whatever its cause, EHS is a real and sometimes a debilitating problem for the affected persons . . . Their exposures are generally several orders of magnitude under the limits in internationally accepted standards."

As many as 3% of the population in Sweden has severe symptoms of EHS (21) and another 35% has moderate symptoms of EHS (18) which includes the symptoms in Table. 1.

A survey was conducted on line to determine how self-proclaimed electrically sensitive people respond to different types of lighting.   Participants were asked to identify their degree of electrohypersensitivity and to identify their symptoms when they were exposed to various types of lighting. Figure 3 shows their results for headaches. The highest percentage of headaches was reported for exposure to both tube and compact fluorescent light bulbs among those who classify themselves as either moderate sensitive to extremely sensitive. Results for other symptoms were similar.

Individuals who suffer from extreme sensitivity when exposed to electromagnetic frequencies also complain they develop headaches, eye problems, become irritated, confused, anxious, depressed and experience poor memory, dizziness, nausea, skin problems, heart problems, and poor sleep when they are exposed to either tube fluorescent lighting or CF bulbs (16).

Table 1. Symptoms of Electrohypersensitivity or Radio Wave Sickness (7).


Neurological: headaches, dizziness, nausea, difficulty concentrating, memory loss, irritability, depression, anxiety, insomnia, fatigue, weakness, tremors, muscle spasms, numbness, tingling, altered reflexes, muscle and joint paint, leg/foot pain, flu-like symptoms, fever. More severe reactions can include seizures, paralysis, psychosis and stroke.
Cardiac: palpitations, arrhythmias, pain or pressure in the chest, low or high blood pressure, slow or fast heart rate, shortness of breath.
Respiratory: sinusitis, bronchitis, pneumonia, and asthma Dermatological: skin rash, itching, burning, and facial flushing.
Ophthalmologic: pain or burning in the eyes, pressure in/behind the eyes, deteriorating vision, floaters, and cataracts.
Others: digestive problems; abdominal pain; enlarged thyroid, testicular/ovarian pain; dryness of lips, tongue, mouth, eyes; great thirst; dehydration; nosebleeds; internal bleeding; altered sugar metabolism; immune abnormalities; redistribution of metals within the body; hair loss; pain in the teeth; deteriorating fillings; impaired sense of smell; ringing in the ears.


Figure 2. Responses to an electronic survey on self-proclaimed electrohypersensitivity and to various types of lighting n=168.

The British Dermatological Association, Migraine Action and Epilepsy Action, have all reported adverse health effects associated with their members who have used CFLs (1,2,3). They are lobbying the UK government to allow their members to continue using incandescent light bulbs after the ban takes effect in 2012.

CONCLUSION

The energy efficient compact fluorescent lights that are commercial available generate radio frequency radiation, ultraviolet radiation, and dirty electricity; they contain mercury-a known neurotoxin; and they are making some people ill including those who suffer from migraines, epilepsy, skin problems and electrical sensitivity. Instead of promoting compact fluorescent light bulbs governments around the world should be insisting that manufactures produces light bulbs that are electromagnetically clean and contain no toxic chemicals.   Some of these are available (CLED) but are not yet affordable. With a growing number of people developing electrohypersensitivity we have a serious emerging and newly identified health risk that is likely to get worse until regulations restricting our exposure to electromagnetic pollutants are enforced. Also, with improper disposal of these bulbs we are creating a mercury-time bomb. Since everyone uses light bulbs and since the energy inefficient incandescent light bulbs are being phased out in many countries by 2010-2014, this is an area that requires immediate attention.

PETITIONS REQUESTS/QUESTIONS:

  1. Has Health Canada evaluated the safety of CFL bulbs, including conducting their own research and obtaining directly relevant information form the industries involved in the manufacture of these light bulbs?
  2. How does Health Canada respond to several reputable organizations (British Dermatological Association, Epilepsy Action, and Migraine Action) that have asked these products to be banned?
  3. In light of all these major health concerns, has Health Canada adequately warned the public? Do they have plans to do so that go beyond information on their website? Has Health Canada considered having manufacturers place health warnings on packaging (similar to warnings on cigarette packages)?
  4. What steps are being taken to inform the public about the potential health and environmental hazards associated with these light bulbs and their safe disposal?
  5. Has Health Canada or Natural Resources Canada worked with industry to set up a scheme of recycling and safe disposal and possibly environmental reuse? How far have they progressed in their discussions?
  6. Will Health Canada now compel manufactures to design bulbs that filter UV radiation? Will they work with manufacturers to ensure that the bulbs sold to the public are ones that have minimum emissions and will they set standards for these environmental emissions so that manufacturers know what they need to produce?
  7. Will Health Canada now compel manufactures to design bulbs that do not contribute to poor power quality? Will they work with manufacturers to ensure that the bulbs sold to the public are ones that have minimum emissions of these high frequency transients and will they set standards for these environmental emissions so that manufacturers know what they need to produce?
  8. Health Canada should ascertain whether the present mercury levels in the light bulbs can be reduced.
  9. Are any incentives being offered for industry to come up with safe and efficient methods of recycling of mercury from spent bulbs?
  10. What is the government doing to regulate the safe disposal or recycling of compact fluorescent light bulbs?
  11. Could they provide updates on their progress with either the manufacturers or such bulbs or the distributors of such bulbs?
  12. Is industry Canada aware of radio frequency interference and, if they are, how do they propose to minimize it?
  13. Why do we have bulbs on the market that emit UV when technology preventing this is readily available?
  14. What is Health Canada doing to ensure that light bulbs do not contribute to poor power quality?
  15. What is Health Canada doing to ensure that compact fluorescent light bulbs do not emit UV radiation?
  16. What is the Canadian government doing to promote the use of alternative technologies, such as CLEDs (clean light emitting diodoes). These bulbs do not contain mercury, do not generate UV, RF, or dirty power and are approximately 5 times more energy efficient than CFL and 20 times more efficient than incandescent light bulbs.

What is needed is that the substantial benefits of energy savings be coupled with reduction and elimination the numerous environmental and health problems. The technology already exists for dealing with most of these.

But serious consideration should also be given to alternative technologies such as light emitting dioxides (LEDs) which are considerably more energy efficient than the CFLs and do not have any of the adverse health and environmental effects of the present generation of CFL bulbs.

REFERENCES:

  1. The Daily Mail, June 24, 2007. Mayne, E. "Energy-saving light bulbs "are threat to epileptics." http://www.dailymail.co.uk/pages/live/articles/health/healthmain.html?in_ article id=463 911&in page id=1774, also Epilepsy Action Research Possible effects of low energy light bulbs - survey findings. http://www.epilepsy.org.uk/research/researchprojects.html.
  2. The Telegraph, January 3, 2008. Clout, L. "Energy-saving light bulbs blamed for migraines." Interview with Migraine Action Association.
    http://www.migraine.org.uk/index.aspx.
  3. BBC News, January 4, 2008. Low-energy bulbs "worsen rashes." Interview with the British Association of Dermatologists. http://news.bbc.co.uk/go/pr/fr/-/2/hi/health/7170246.stm.
  4. Havas, M. and D. Stetzer. 2004. Dirty electricity and electrical hypersensitivity: Five case studies. World Health Organization Workshop on Electricity Hypersensitivity, WHO, Prague, Czech Republic, 25-26 October, 2004.
  5. Environment Canada, 2005. Canadian Water Quality Guidelines, Inorganic Mercury and Methylmercury, National Guidelines and Standards Office, Environment Canada, Ottawa, ON, February 2005. website: www.ec.gc.ca/ceqg-rcqe/
  6. US EPA. 2008. Mercury. Spills, Disposal and Site Cleanup. http://www.epa.gov/mercury/spills/index.htm#flourescent, updated June 11, 2008.
  7. Natural Resources Canada Questions and Answers on CFLs, Date Modified: 2007-12-06, http://www.oee.nrcan.gc.ca/energystar/english/consumers/questions-
    answers.cfm#phase-out.
  8. Outridge, P.M., R.W. Macdonald, F. Wang, G.A. Stern, and A. P. Dastoor. 2008. A mass balance inventory of mercury in the Arctic Ocean. Environmental Chemistry 5(2):89-111.
  9. Environment Canada. 2004. Mercury and the Environment, Fish Consumption. Environment Canada, http://www.ec.gc.ca/MERCURY/EN/fc.cfm#ON last updated 2004-02-04.
  10. CCME. 2008. Mercury-containing lamps. Canadian Council of Ministries of the Environment. http://www.ccme.ca/ourwork/pollution.html?category id=120, last updated: June 12 2008.
  11. CCME. 2005. Canada-wide standards for mercury: mercury emissions, mercury-containing lamps, and mercury for dental amalgam waste. A report on progress. June 2005. 40 pp. Canadian Council of Ministries of the Environment.
  12. RAC. 2004. Interference, Canada's National Amateur Radio Society, http://www.rac.ca/regulatory/interfer.htm, last updated 2004-07-12.
  13. Hydro One. 2004. Power Quality-What it means to you.
    http://www.hydroonenetworks.com/en/customers/transmission/operations/power quality, asp.
  14. Havas, M. and D. Stetzer. 2004. Dirty electricity and electrical hypersensitivity: Five case studies. World Health Organization Workshop on Electricity Hypersensitivity, WHO, Prague, Czech Republic, 25-26 October, 2004.
  15. Milham, S. and L.L. Morgan. 2008. A New Electromagnetic Exposure Metric: High Frequency Voltage Transients Associated With Increased Cancer Incidence in Teachers in a California School. American Journal of Industrial Medicine. 8 pp.
  16. Havas, M., D. Stetzer, L. Kelley, R. Frederick, and S. Symington. in prep. Compact Fluorescent Lights and Power Quality and Health.
  17. Havas, M. 2006. Dirty Electricity: An invisible pollutant in schools. OSSTF/FEESO Education Forum Vol 32, Issue 3, Fall 2006, 4 pp.
  18. Havas, M. 2006. Electromagnetic Hypersensitivity: Biological effects of dirty electricity with emphasis on diabetes and multiple sclerosis. Electromagnetic Biology and Medicine, 25: 259-268.
  19. Natural Resources Canada Questions and Answers on CFLs, Date Modified: 2007-12-06, http://www.oee.nrcan.gc.ca/energystar/english/consumers/questions-answers.cfm#phase-out.
  20. WHO. 2004. Workshop on Electricity Hypersensitivity, World Health Organization, Prague, Czech Republic, 25-26 October, 2004.
  21. Johansson, O. 2006. Electrohypersensitivity: State-of-the-Art of a Functional Impairment. Electromagnetic Biology and Medicine, 25: 245-258, 2006
  22. 22.  Firstenberg, A. (Editor). 2001. "No Place To Hide" vol. 3, no. 1, April 2001, "Special Issue on Russian and Ukrainian Research", The Cellular Phone Taskforce.

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Minister's Response: Environment Canada

9 December 2008

Dr. Magda Havas
Dr. Thomas C. Hutchinson

[information withheld]

Dear Dr. Havas and Dr. Hutchinson:

I am pleased to provide Environment Canada’s response to your Environmental Petition No. 254, to the Commissioner of the Environment and Sustainable Development, regarding environmental and health concerns associated with compact fluorescent lamps. Your petition was received in the Department on July 7, 2008.

Enclosed is Environment Canada’s detailed response to those questions that fall within the Department’s mandate. I understand that the ministers of Industry, Health and Natural Resources will be responding separately to the questions that fall under the mandate of their departments.

I appreciate the opportunity to respond to your petition, and trust that you will find this information helpful.

Sincerely,

[Original signed by Jim Prentice, Minister of the Environment]

The Honourable Jim Prentice, P.C., Q.C., M.P.

Enclosure

c.c.: The Honourable Leona Aglukkaq, P.C., M.P.
The Honourable Tony Clement, P.C., M.P.
The Honourable Lisa Raitt, P.C., M.P.
Mr. Scott Vaughan, Commissioner of the Environment and Sustainable Development


Environment Canada’s response to Environmental Petition No. 254,
pursuant to section 22 of the Auditor General Act,
regarding environmental and health concerns associated with
compact fluorescent lamps

Question 4: What steps are being taken to inform the public about the potential health and environmental hazards associated with these light bulbs and their safe disposal?

Response: Environment Canada recognizes that public information is a crucial element of waste-collection programs. Therefore, information on the risks posed by mercury, disposal of compact fluorescent lamps, and what to do when a fluorescent lamp breaks can be found on Environment Canada’s “Mercury and the Environment” website, http://www.ec.gc.ca/MERCURY/EN/index.cfm.

In addition, with amendments to the Government of Canada’s Energy Efficiency Regulations that will phase out inefficient incandescent lamps by 2012, the use of their replacements—fluorescent lamps—will increase, as will the quantity of end-of-life lamps generated that must be managed. In 2004, only 7 percent of end-of-life fluorescent lamps were recycled. Efforts are required to increase the recycling rate of these lamps.

In February 2008, Environment Canada consulted on a document, Proposed Risk Management Instruments for Mercury-containing Products, under its Risk Management Strategy for Mercury-containing Products. One of the proposed instruments is a regulation that will prohibit the manufacture, import and sale of all mercury-containing products except for dental amalgam and lamps. Mercury content limits will be set for these lamps. With regard to end-of-life management, it is not addressed by the proposed regulation; and as waste management is a shared responsibility, Environment Canada wishes to develop a national approach to the recycling of end-of-life fluorescent lamps that will mitigate the environmental and health risks arising from the disposal of these lamps. To this end, Environment Canada has created the National Fluorescent Lamp Recycling Technical Working Group, which brings together specialists (from the federal and provincial/territorial governments, manufacturers, recyclers, retailers and environmental organizations) to address the issue. Natural Resources Canada and Health Canada are both participating in the Working Group.

The aim of the Working Group will be to provide recommendations on a recycling framework for end-of-life fluorescent lamps. The recommendations will then be considered for implementation by the Working Group members’ organizations.

Public education mechanisms will also be evaluated by the Working Group during the development of these recommendations, to ensure that disposal information is readily available, such as through the labelling of lamps and through the “Mercury and the Environment” website.

The Working Group, which was created during summer 2008, will complete its work within approximately six months.

Question 5: Has Health Canada or Natural Resources Canada worked with industry to set up a scheme of recycling and safe disposal and possibly environmental reuse? How far have they progressed in their discussions?

Response: Please refer to the answer to Question 4.

Question 8: Health Canada should ascertain whether the present mercury levels in the light bulbs can be reduced.

Response: The Canada-wide Standards for Mercury-Containing Lamps set a target of an 80 percent reduction, from a 1990 baseline level, in the average content of mercury in mercury-containing lamps sold in Canada by 2010. This initiative has been successful. The target was surpassed in 2006, four years ahead of the deadline. According to the 2008 Progress Report on the implementation of the Canada-wide Standards, Electro-Federation Canada—a national not-for-profit industry association that represents companies that manufacture, distribute and service electrical, electronic and telecommunications products—reported that the mercury content in lamps sold by their members in 2006 had dropped to 7.9 mg, which represents an 81.6 percent decrease from the baseline level of 43 mg.

However, more can be done. As mentioned in the answer to Question 4, in early 2008 Environment Canada consulted on a document entitled Proposed Risk Management Instruments for Mercury-containing Products. The proposed regulation described in the document will prohibit the import, manufacture and sale of all mercury-containing products with the exception of dental amalgam and lamps, because no comparable alternatives for these products exist at this time. Nevertheless, the proposed regulation will restrict the mercury content in exempt lamps to the lowest possible level. The content limits will be established after consultation with manufacturers and distributors and also after examining what is being done in other countries. These limits will be reviewed periodically with a view to lowering the limits or to removing the exemption on lamps should comparable alternatives become available.

The regulations are expected to come into effect by 2012. More details regarding the proposed regulations and the outcomes of the consultation process are available on Environment Canada’s “Mercury and the Environment” website.

Question 9: Are any incentives being offered for industry to come up with safe and efficient methods of recycling of mercury from spent bulbs?

Response: At the present time there are no such incentive programs at the federal level. Industry has agreed to work with Environment Canada as part of the Working Group mentioned in the response to Question 4. This is the forum where issues such as safe and efficient methods of recycling mercury from end-of-life lamps will be addressed.

The recycling of fluorescent lamps is already occurring in Canada, and recycling facilities must comply with provincial and territorial licensing and permitting requirements, which include occupational health and safety requirements. As recycling rates in Canada increase, recycling infrastructure will need to be developed to meet the demand. Appropriate recycling technologies will be considered in the development of the Working Group’s recommendations on a national framework for the management of end-of-life fluorescent lamps.

Question 10: What is the government doing to regulate the safe disposal or recycling of compact fluorescent light bulbs?

Response: As mentioned in the answer to Question 4, waste management is a shared responsibility. Provinces and territories are responsible for the licensing and permitting of authorized facilities undertaking recycling operations. If the Working Group cannot agree on acceptable and viable options for all members, Environment Canada could decide to develop an Extended Producer Responsibility (EPR) approach. For more information on EPR, please consult Environment Canada’s “Extended Producer Responsibility” website at www.ec.gc.ca/epr/default.asp?lang=En&n=052F5879-1.

Question 11: Could they provide updates on their progress with either the manufacturers of such bulbs or the distributors of such bulbs?

Response: As mentioned in the answer to Question 4, as a member of the National Fluorescent Lamp Recycling Technical Working Group, Environment Canada is working closely with all stakeholders involved in the recycling of fluorescent lamps, including manufacturers and retailers. Also, in the context of the development of the proposed prohibition regulation on mercury-containing products, Environment Canada is consulting with the principal manufacturers and distributors of lamps, as well as with Electro-Federation Canada.

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Minister's Response: Health Canada

29 October 2008

Dr. Magda Havas and Dr. Thomas C. Hutchinson

[information withheld]

Dear Drs. Havas and Hutchison:

This is in response to your environmental petition No. 254 of July 7, 2008, addressed to the Commissioner of the Environment and Sustainable Development (CESD).

In your petition, you expressed concerns with the health and environmental impacts of compact fluorescent light bulbs.

I am pleased to provide you with the enclosed Health Canada response to your petition. I understand that the Ministers of Industry, Natural Resources and the Environment will be responding separately to questions which come under the purview of their respective departments.

I appreciate your interest in this important matter, and I hope that you will find this information useful.

Yours sincerely,

[Original signed by Tony Clement, Minister of Health and the Minister for the Federal Economic Development Initiative for Northern Ontario]

Tony Clement

Enclosure

c.c.: Mr. Scott Vaughan, CESD
The Honourable Jim Prentice, P.C., M.P.
The Honourable John Baird, P.C., M.P.
The Honourable Gary Lunn, P.C., M.P.


Health Canada Response to Environmental Petition
No.
254 filed by Dr. Magda Havas and
Dr. Thomas C. Hutchinson
under Section 22 of the Auditor General Act
Received July 7, 2008

Environmental and
 Health Concerns Associated with Compact Fluorescent Lights

November 4, 2008

Minister of Health and the Minister for the Federal Economic
Development Initiative for Northern Ontario

1. Has Health Canada evaluated the safety of CFL bulbs, including conducting their own research and obtaining directly relevant information form the industries involved in the manufacture of these light bulbs?

With respect to human exposure to electric and magnetic fields from Compact Fluorescent Light bulbs (CFL), Health Canada has undertaken a review of electric and magnetic field emissions from CFLs, including in-house emission measurements as well as surveillance of the applicable literature. No information is required from the manufacturer to carry out these measurements, nor has any manufacturer been involved in any manner of the testing. Health Canada does not consider exposure to electric and magnetic fields from CFLs to be a health risk.

With respect to ultraviolet (UV) radiation, Health Canada has been and will continue to review the scientific literature on this aspect of fluorescent light sources. Health Canada scientists are aware that regular fluorescent light bulbs, including CFLs, produce UV radiation, but not at hazardous levels. Most light sources, in addition to fluorescent bulbs, emit a very small amount of UV, an amount far less than that produced by the sun. If future in-house testing to confirm the UV emission component of CFL identifies hazardous levels of UV, then appropriate actions will be taken as mandated under the Radiation Emitting Devices Act.

At the request of and in collaboration with Natural Resources Canada, Health Canada will be testing CFLs to study electromagnetic field (EMF) and UV emissions. These studies will be funded exclusively through Governmental resources.

2. How does Health Canada respond to several reputable organizations (British Dermatological Association, Epilepsy Action, Migraine Action) that have asked these products to be banned?

Health Canada takes its responsibility to protect the health and safety of Canadians seriously. Health Canada values the input of stakeholders and is aware of the concerns expressed by some non-governmental organizations such as the ones mentioned above.

In assessing potential health risks, Health Canada considers all credible, peer-reviewed scientific studies and scientific evidence using a weight-of-evidence approach. This takes into account both the quantity of studies on a particular endpoint (whether adverse or not), but also the quality of those studies. Poorly conducted studies (e.g. incomplete dosimetry or inadequate control samples) receive relatively little weight while properly conducted studies (e.g. all controls included, appropriate statistics, complete dosimetry) will receive more weight.

3. In light of all these major health concerns, has Health Canada adequately warned the public? Do they have plans to do so that go beyond information on their website? Has Health Canada considered having manufacturers place health warnings on packaging (similar to warnings on cigarette packages)?

6. Will Health Canada now compel manufacturers to design bulbs that filter UV radiation? Will they work with manufacturers to ensure that the bulbs sold to the public are ones that have minimum emissions and will set standards for these environmental emissions so that manufacturers know what they need to produce?

Answer to Questions 3 & 6:

Health Canada does not consider exposure to electric and magnetic fields from CFLs to be a health risk. This is based on a continuous, on-going review of the scientific literature and the results of the in-house measurement of emissions. Health Canada scientific staff are aware of the studies and references provided with the petition relevant to EMF exposure. Health Canada considers all credible, peer-reviewed scientific studies and scientific evidence using a weight-of-evidence approach for assessing the possible health risks of radiofrequency fields. This takes into account both the quantity of studies on a particular endpoint (whether adverse or not), but also the quality of those studies. Poorly conducted studies (e.g. incomplete dosimetry or inadequate control samples) receive relatively little weight while properly conducted studies (e.g. all controls included, appropriate statistics, complete dosimetry) will receive more weight.

The small amount of UV radiation from fluorescent lamps, including CFLs, falls below the level of general concern. If any in-house testing identifies hazardous levels of UV or EMF, then appropriate actions will be taken as mandated under the Radiation Emitting Devices Act.

7. Will Health Canada now compel manufactures to design bulbs that do not contribute to poor power quality? Will they work with manufacturers to ensure that the bulbs sold to the public are ones that have minimum emissions of these high frequency transients and will they set standards for these environmental emissions so that manufacturers know what they need to produce?

14. What is Health Canada doing to ensure that light bulbs do not contribute to poor power quality?

Answer to Questions 7 & 14:

The term "power quality" describes the quality of the voltage on the wires of a power system. High quality implies that the voltage waveform is nearly perfectly sinusoidal at a fundamental frequency of 60 cycles per second or 60 Hz. The fidelity of the voltage waveform is normally a concern of the system operator and its customers since it primarily affects system reliability and the performance of equipment attached to the network.

Power systems and their operation are regulated by provincial/territorial authorities. Health Canada has no involvement in the operation of power systems and therefore cannot respond further to this question.

Electric fields in the band 3 kHz - 500 kHz, produce exposures below the general public guidelines published in Safety Code 6. Magnetic fields in the 3 kHz - 500 kHz frequency band are very low when compared to the general public guidelines in Safety Code 6. At the power frequency (60 Hz) and its harmonics, electric and magnetic field emissions are below major international guidelines for short-term, acute (excitable tissue) effects.

On the basis of the understanding and analysis of electric and magnetic field emissions performed so far, Health Canada sees no reason to intervene in the design or manufacturing of CFLs.

13. Why do we have bulbs on the market that emit UV when technology preventing this is readily available?

The small amount of UV radiation from fluorescent lamps, including CFLs, falls below the level of general concern. If any in-house testing identifies hazardous levels of UV, then appropriate actions will be taken as mandated under the Radiation Emitting Devices Act.

15. What is Health Canada doing to ensure that compact fluorescent light bulbs do not emit UV radiation?

The small amount of UV radiation from fluorescent lamps, including CFLs, falls below the level of general concern. If any in-house testing identifies hazardous levels of UV, then appropriate actions will be taken as mandated under the Radiation Emitting Devices Act.

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Minister's Response: Industry Canada

15 December 2008

Dr. Magda Havas
Dr. Thomas C. Hutchinson

[information withheld]

Dear Drs. Havas and Hutchinson:

I am writing to provide you with Industry Canada’s response to Environmental Petition No. 254, dated June 19, 2008, regarding radio frequency interference as a result of compact fluorescent lights. This petition was forwarded to the Minister of Health and the Minister of Industry by the Commissioner of the Environment and Sustainable Development. I am pleased to respond to your question that falls within Industry Canada’s area of responsibility.

Question 12: Is Industry Canada aware of radio frequency interference and, if they are, how do they propose to minimize it?

Industry Canada is aware that fluorescent bulbs can create radio frequency interference to radiocommunication services and devices. For this reason, the department has technical regulations in place for these types of devices. The technical requirements are set out in the Interference‑Causing Equipment Standard (ICES)-005, entitled Radio Frequency Lighting Devices (RFLDs).

I appreciate this opportunity to respond to your petition, and trust that this information is of assistance.

Yours sincerely,

[Original signed by Tony Clement, Minister of Industry]

Tony Clement

c.c. Mr. Scott Vaughan
Commissioner of the Environment and Sustainable Development

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Minister's Response: Natural Resources Canada

Dr. Magda Havas and Dr. Thomas C. Hutchinson

[information withheld]

Dear Dr. Havas and Dr. Hutchinson:

I am pleased to provide Natural Resources Canada’s response to your Environmental Petition no. 254, to the Interim Commissioner of the Environment and Sustainable Development, regarding your concerns in the use of compact fluorescent light bulbs (CFL) and their potential effects on health and the environment in Canada. The department received your petition on July 7, 2008.

Our response focuses on our involvement in promoting energy efficient alternative lighting technologies in Canada. I understand that the ministers of Environment Canada, Health Canada and Industry Canada, will be responding separately to questions that fall under their mandates.

On April 25, 2007, I announced our intention to implement a minimum energy performance standard for general service lighting in Canada. I can report that the development of that standard is going well and was pre-published in the Canada Gazette on March 29, 2008. At present, we are finalizing the regulation in advance of submitting it to Cabinet for approval for publication. While we expect that, in many instances, a CFL will be the replacement bulb of choice, it is important to note that we have designed the standard to ensure that there will be alternatives to satisfy consumer preferences.

I trust that you will find the information provided by this response useful.

Yours sincerely,

[Original signed by Gary Lunn, Minister of Natural Resources]

The Honourable Gary Lunn, P.C., M.P.

Enclosure: (1)

c.c.: Mr. Scott Vaughan Commissioner of the Environment and Sustainable Development
The Office of the Minister of the Environment
The Office of the Minister of Industry
The Office of the Minister of Health

 


 

Question #16

What is the Canadian Government doing to promote the use of alternative technologies, such as CLEDS (clean light emitting diodes)? These bulbs do not contain mercury, do not generate UV, RF, of dirty power and are approximately 5 times more energy efficient than CFL and 20 times more efficient than incandescent light bulbs.

Natural Resources Canada is very much engaged in researching, testing, and developing standards of more efficient lighting technologies, such as LED (Light Emitting Diodes). Our efforts are predicated on the view that although the technology is very promising and potential efficiencies are very high, there are quality assurance and performance issues that need to be resolved before its widespread suitability for general illumination service. We have sought to address these through our participation and financial support of committees responsible for developing LED standards at the Canadian Standards Association (CSA), and committees developing specifications for LEDs for use by the ENERGY STAR program.

LED is widely used and very effective in many specific applications and NRCan has been very active in promoting its use. LED Exit Signs and Traffic Signals started as qualifying levels for the ENERGY STAR mark in Canada and the U.S. and due to the success of the program the market for these products was transformed. The mandatory standard for Exit Signs is now at the LED level and a similar performance level for Traffic Signals has been pre-published in the Canada Gazette, Part I on March 29, 2008.

NRCan has also led the development of ENERGY STAR® criteria for Decorative Light Strings that use LED technology. NRCan is also currently supporting a pilot study called LightSavers in the Greater Toronto Area that will be testing LED outdoor lights in the area that will contribute to the development of standards for that application.

However, as mentioned there are some outstanding issues to address before this technology can be used for general illumination. First, although manufacturers promote very high efficiency levels such as 150 lumens/watts which is approximately 3 times better than a CFL, it is important to remember that this is currently achieved in laboratory conditions only.

When using an LED module within a fixture intended for a specific application, issues such as heat dissipation have to be addressed. Also one must consider not only the LED module efficiency, but the entire fixture design which is critical to the true efficiency of this specific technology. Specific standards have just recently been developed for these applications and designs, to adapt their products to them.

Secondly, LEDs that are available today are very expensive. Consumers will want a quality product that will last its rated lifetime. Newly developed standards introduced to measure LED lamps’ life can now be used to build consumer confidence in the product. A premature introduction of poor quality LED could have an adverse effect on the use of high energy efficient LEDs in the future.

The ENERGY STAR specifications for solid state lightings are to be released soon. These specifications will initially focus on qualifying products that require mostly task specific applications such as under cabinetry lighting, desk lighting, and outdoor pathway or wall fixtures. Most of these products are available on the market today in Canada. The specification will also apply to qualify lamps used for general illumination as they become available for use by consumers.

In brief, our strategy has been to work on an application by application basis to promote the technology where it is effective but under-utilized, regulate it where it is well established and cost effective and support the quality assurance infrastructure for its introduction to applications for which it holds promise. As a result of this, together with the research efforts of the industry and other governments in North America, we anticipate that LED will become and effective and efficient replacement technology for general illumination application in the near future, thus contributing greatly to energy savings and the reduction of GHG emissions in Canada.