• Q&A document
  
• position paper on ladders
• draft Occupational Health and Safety (Prevention of Falls) Regulations 2002
• regulatory impact statement
• draft Code of Practice for the Prevention of Falls in General Construction
• draft Code of Practice for the Prevention of Falls in Housing Construction
  (this document has been separated into parts due to its size)
  1. Part 1
  2. Part 2
  3. Part 3
  4. Part 4
  5. Part 5

The Trouble with Mercury II
It's difficult to go a whole day without using a metal halide discharge lamp. Even if you could manage for a single day, or even a week, think about the impact of doing without them altogether. Think very hard.

The majority of ENG, EFP and location equipment is based around that venerable metal halide discharge, the HMI. In the studio, on the stage and in the arena, a wide variety of other metal halide mixtures are present in the lamps used in followspots, robotic luminaires and floodlights. Every variety of metal halide discharge lamp in current use (HMI, MSR, MSD, HTI, HSR, HMP, HSD, etc) contains mercury, in combination with a cocktail of the halide salts of metals. It is with this mercury that the trouble lies.

Long known as a highly toxic and biologically persistent substance, it is now recognized that mercury should only be used if there are no alternative materials and technologies available. If mercury must be used, it should be treated with caution, and extreme care should be taken to prevent its escape into the environment.
Currently there is mercury-related legislation in various stages of enactment, in some twenty US state legislatures, with many more to follow. These bills generally require the labelling of mercury containing products, limit the sale of some goods containing mercury, and mandate that discarded products have their mercury content removed or recovered, before disposal. In most of these states the disposal of mercury bearing products will be implemented through the EPA's Universal Waste Rule. Developed by the EPA in the early nineties, this is a streamlined safe disposal protocol, designed to deal with the huge volume of dangerous waste produced in small amounts in every home and business.

The burden that these bills will impose on the majority of facilities is relatively straight forward. In most cases it will entail setting up a paperwork system to track mercury containing purchases, and the establishment of a single point of disposal for all mercury containing waste. This will encompass fluorescent tubes, some switching gear, and the metal halide discharge lamps used in production, workshops, public spaces, storage facilities, roadway and security lighting. Such a regime should be no more difficult or disruptive to implement than existing in-house programs for secure document destruction or waste paper recycling, and can effectively eliminate the release of mercury into the environment.

However, the Rhode Island Mercury Reduction and Education Act, in addition to the labelling and safe-disposal of mercury containing products, requires the progressive phasing-out of mercury usage in that state. This well-intentioned legislation prevents the sale of any product containing more than 1 gram of mercury after January 1, 2004, an amount that reduces to 100mg from January 1, 2006, and finally comes down to 10mg from the start 2008. This will effectively eliminate the use of metal halide lamps greater than 1kw from the beginning of 2006, and virtually all currently available mercury containing lamps from 2008.

Whilst Rhode Island is a small state, with only .5% of the US population, many in the very active anti-mercury movement, see the elimination of mercury as being preferable to its careful and controlled use, and are looking to use the Rhode Island bill as a model for other states. The impact of the enactment of this type of legislation in just a couple of the more populous states, is potentially devastating to film, television and live production in the US. This in turn will most probably act as a major disincentive for continuing the development of many types of luminaire. If a product is no longer saleable in the US market, then this may deleteriously effect the economics of developing and manufacturing such products.

Although mercury-free xenon arc lamps could possibly be used in some applications, there are presently no low mercury content lamps to replace the majority of metal halides in current use, nor is there any sign of them becoming available in the immediate future. According to some sources, a number of lamp manufacturers have indicated that they have plans to reduce the mercury content of their metal halide lamps. However, ALIA's enquiries of three of the world's largest lamp producers, have as yet, failed to elicit any indications that such work is actually in progress. We will continue to keep you informed of developments on this front.

In the meantime let's consider what our world would be like without the compact, high efficiency lightsources that metal halides provide. The optics of many of today's portable and robotic luminaires are dependent on the availability of a small, high brightness source, while the energy efficiency makes the thermal and mechanical engineering possible. These luminaires simply could not be built using the only alternative technology, incandescent lamps. The filament source area is too large for compact, efficient optics, and the much lower energy efficiency would require roughly four times the input power and four times the cooling.

The 2008 incandescent version of a 2002 robotic (the xxxxx.spot or the MAC 2008), would weigh in at something like 500kg, draw around fifteen kilowatts of power, be the size of a 200 litre drum, and make as much noise as an air conditioner. An 18kW HMI would be replaced by a neat little cluster of around eight incandescent 10K's, complete with CTB gels. An ENG camera light would be replaced by a redhead, powered by a trolley-load of car batteries.

The re-lighting of sports stadiums to broadcast requirements, using tungsten halogen sources will be a nightmare, requiring additional towers and power supplies, and dozens of the new low-efficiency incandescent, Musco Light trucks. General lighting could simply be replaced with four times the number of comparatively low efficiency tungsten halogen luminaires. These would of course require four times as much power, cabling, and support, and up to ten times as much maintenance.

The most ironic aspect to banning, rather than carefully managing mercury-bearing metal halide lamps, is that they will actually be taking the retrograde step towards substantially less energy efficient light sources. Based on the emissions inventory in the EPA's Mercury Study Report to the US Congress in December 1997, the highest emitting source category is coal-burning power stations. This group of sources account for one-third of the man-made emissions to the air in the US. Clearly this absurd outcome is not in anyone's interest, and is almost certainly not the intention of those who care about a sustainable future for humanity.

ESTA, the Entertainment Services and Technology Association, who represent the majority of lamp and luminaire suppliers to the US entertainment industry, are taking this matter very seriously. In addition to promoting the adoption of exemplary waste disposal programs, the association is operating as an entertainment industry focal point for efforts to ensure that whatever legislation is enacted, it will be done with a full understanding of its impact on the industry.
ALIA will continue to keep you informed of the fate of the metal halide lamp in the USA.

Further Reading:
ESTA Mercury page
The Mercury Mess, an article in Lighting Dimensions Magazine
National Electrical Manufacturer's Association on Lamps and Environmental Health And Safety
The Mercury Policy Project
Mercury Product legislation
Northeast Waste Management Officials' Association - Mercury Program

New Falls From Heights Regulations for Victoria
Arising from a report commissioned by the Victorian government, new legislation has been drafted to regulate the prevention of injuries caused by falls from heights. After exhaustive public consultation and comment, the final draft of those regulations is now available, and is expected to be passed into law in the Autumn session of parliament. The document is available as a PDF download.