Perhaps Lewis Carroll was referring to the twinkle of mercury used for hat production in the 1800s, which led to the Hatter’s ultimate madness. Mercury use dates back to 4,500 BC when Egyptians and Chinese used it as a pigment to paint their tombs and preserve their dead. Since then humans have used this unique form of liquid metal for a variety of applications, including warding off evil spirits, healing, processing precious metals, and more recently, conducting electricity.
The toxic effects of mercury also date back to its early applications when workers in mercury mines were almost guaranteed death or insanity. More recent cases of direct mercury poisoning have occurred in Minamata, Japan (1956), Iraq (1971), and northwestern Ontario (1969). The first two incidents led to thousands of deaths and highly elevated mercury levels in survivors.
High-level mercury exposure can lead to birth defects, brain, kidney or liver damage, and central nervous system disorders. More recently, medical researchers have concluded that chronic exposure to low-levels of mercury by children and fetuses increases the risk of neurological damage, behavioral problems and learning disabilities. So serious are the toxicological effects of mercury exposure that a leading medical researcher, Dr. Philippe Grandjean, commented on governments inaction on mercury, warning, “Given the existence of many other neurotoxins about which we know much less, a regulatory stalemate on mercury is bad news for the protection of the brains of future generations”.
For the last decade, monitoring mercury releases to air and land has focused on large generators in the mining, electricity and pulp and paper sectors. For the most part, significant (~50 per cent) reductions in mercury emissions in this country can be attributed to upgrades to modern industrial processing technology. Today, these three sectors account for about 7.1 tonnes of mercury emissions and disposal. Under the Canadian Environmental Protection Act (CEPA) industry is required to report onsite and transferred mercury waste each year. But the tracking system — the National Pollutant Release Inventory (NPRI) — does not track mercury in products. This is a serious problem because under CEPA, Canada’s strategy for preventing mercury pollution is through so-called life-cycle management. Yet because of poor consumer education, no product labelling, and an immature household hazardous waste collection infrastructure, most mercury products end up in the municipal waste stream destined for landfills or incinerators. There is no lifecycle management infrastructure nor is there enough information to make informed decisions.
Recent analysis confirms that municipal solid waste may indeed be the greatest source of mercury pollution in Canada today (op.cit.).
Thousands of grams of mercury are put into consumer products sold in Canada every year. These include fluorescent lamps, thermostats, automobiles, appliances, electrical switches and gauges, thermometers, hospital equipment, dental amalgam, contact-lens solution, and even nasal spray. While cost-effective alternatives to mercury use in these products do exist (except for fluorescent lamps), there are no restrictions in Canada on putting mercury into consumer products (outside of children’s toys). U.S. consumption data tells us that about 70 per cent less mercury is used in products today than ten years ago. This may explain Canada’s laissez-faire attitude toward mercury policy. The trouble is that many of the products sold ten years ago are still in use, or are being stored, and will be disposed over the next decade.
In their recent study, Canadian Mercury Inventories: The Missing Pieces, authors L. Hagreen and B. Lourie attempt to quantify the amount of mercury contained in products in Canada, and calculate the annual release to air and land from disposal. The results show about 327 tonnes of mercury in products in Canada, from which approximately 20 tonnes are released into the environment through sewage, landfill and incinerators every year. These findings demand immediate action. A single gram of mercury can contaminate a 20-acre lake.
The role of product stewardship
A decade of federal policy paralysis on mercury in products compels us to look to other organizations and other levels of government for solutions. The last five years has seen significant movement on provincial stewardship initiatives for end-of-life product management. Every province has the necessary legislative framework to require a program which, if designed wisely, can be effective in tackling the problem of mercury in products.
The program elements needed are as follows: phase out mercury in products; require manufacturers or brand owners to disclose (via labeling) that their products contain mercury; and, oblige manufacturers or brand owners to establish and finance consumer education, product take-back facilities and end-of-life management.
Provincial governments can designate programs specifically dedicated to one product or a group of products. For example, Ontario’s new Waste Diversion Act enables the environment minister to regulate stewardship programs for a specific product, or group of products. When the Act was promulgated in 2002, the ministry indicated that it intends to designate electronics equipment (which can include electrical switches, appliances, relays and thermostats), fluorescent lamps, automobiles and batteries.
Provincial governments also have legislative authority to set targets, require a minimum collection infrastructure, set parameters for end-of-life management guidelines, identify minimum education and awareness activities as well as product phase-outs and bans and/or product procurement requirements.
End the madness!
When we consider the toxic effects of mercury and that product alternatives exist for nearly every application today, we must ask our leaders, “where is the policy to protect the public?” While a number of voluntary guidelines have been established under the Canada-wide standards process, these are primarily focused on end of life emissions and do not address pollution prevention and product use. CEPA provides the Federal government with the means to address mercury use and pollution, however after years of indecision and inaction under CEPA, provincial product stewardship maybe the answer. Comprehensive, consultative provincial product stewardship, combined with product phase-outs and consumer education, can offer the long-awaited relief to this mercury madness.
Clarissa Morawski is principal of CM Consulting in Toronto, Ontario. Bruce Lourie is a former mercury policy consultant, and now executive director of the Richard Ivey Foundation in Toronto, Ontario.