Bulb Eater® 3 Air Emissions Report
Bureau Veritas North America, Inc. (Bureau Veritas / BVNA) conducted an industrial hygiene assessment on the Bulb Eater® 3. The report states "Operator and operator assistant are not exposed to excessive mercury concentrations in air as the personal air sampling results in this assessment did not exceed the OSHA or ACGIH exposure limits at any time during the actual crushing operations or when averaged over an 8-hour work period. All air sample results collected during this assessment were below the limits of analytical detection."
Bulb Eater® Emission Testing Summary
Air Cycle Corporation has performed extensive testing and evaluation of mercury emission from the Bulb Eater as we continually seek to improve our product. In addition, Air Cycle Corporation has participated in various 3rd-party evaluations and studies, which are detailed in this summary and listed below.
Geocenter, Testing For US Navy (2003)
Mercury emissions were detected at several points during this extensive study; however, the 8-hr TLV was determined to be less than 0.00005 mg/l or less than the “mercury analytical detection limit,” despite crushing two full drums of lamps and performing filter and drum change-outs (0.00005 mg/m3 is 2000 times less than the OSHA 0.1 mg/m3 limit).
MN Lamp Crushing Report (2003)
An older model Bulb Eater was demonstrated for the MN Pollution Control Agency for 8 minutes and mercury emissions were tested. It is claimed in the report that “the measured mercury concentrations in breathing space approached the Minnesota OSHA TWA (8 hour) limit of 50,000ng/m3.” That is not accurate. While the instant readings approached the time-weighted average standard, those readings were at the point of exhaust and not the operator’s breathing zone.
Furthermore, comparing instant readings to time-weighted average (TWA) standards is misleading to readers who may not understand the rather significant difference. As the report then correctly notes, the established standards are time-weighted values, and thus exposure levels would not exceed the Federal OSHA standard of 100,000 ng/m3 or the Minnesota OSHA limit of 50,000 ng/m3.
Industrial Hygiene Survey—Osceola, FL (2004)
Mercury emissions were non-detectable or less than the laboratory detection limit of 0.0034 mg/m3.
Industrial Hygiene Survey—Polk County, FL (2004)
Mercury emissions testing was conducted on top of the drum and on the operator. Emissions were recorded at 0.0234 mg/m3 on the machine. The operator reading was 0.0068 mg/m3. Both readings were 8-hour time weighted averages. *An older, "Standard" model Bulb Eater with was tested in the study, whereas all other studies tested the "Premium" model Bulb Eater, which has more sophisticated filtration.
EPA Region 3 Study (2006)
This study included extensive testing of the Bulb Eater® and three other devices; mercury emissions were detected at several points during this study. However, the 8-hr TWA never approached 0.1 mg/m3, which is the OSHA limit, despite crushing two full drums of lamps in a plastic containment room with limited ventilation and with background levels of mercury due to testing being performed at lamp recycling facilities. Only four readings were slightly higher than the ACGIH TLV of 0.025 mg/m3 recommended level. *Air Cycle is "Manufacturer C" in the study
Maryland OSHA Study(2010-Present)
The Maryland OSHA conducted emissions testing and assessments at six facilities that operate the Bulb Eater. The summary report has not been completed, but six individual reports are included which document the findings. Most of the readings are “non-detectable” and the ACGIH TLV of 0.025 mg/m3) was not exceeded in any of the tests.
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