Thermostat Safety Compliance
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Training The Next Generation of Technicians about Mercury Thermostats.
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Thermostat Safety Compliance
- 1. Thermostat Safety & Compliance: Training The Next Generation Technicians About Mercury Thermostats March 28th, 2018 Ryan L Kiscaden - Executive Director Warren Lupson – Consultant
- 2. TRC is giving away an ACOPOWER Portable Generator Multipurpose: This power generator with 2 AC outlet, 2 USB port, 3 DC port and an extra cigarette lighter socket, is capable of meeting different kinds of electricity demands and can be used almost everywhere, eg. outdoor usage for picnics, camping and car travel. HIGH CAPACITY: With 40,800 mAh high battery capacity. This power generator is powerful enough to charge smartphones, lamp, laptops, tablet, TVs, mini-refrigerator or other. Easy to RECHARGE & USE: 3 ways to recharge your power station by your home AC, car cigarette socket and solar panels, and only 7~8 hours to full charge it. It can charge USB/5V, DC/9~12.6V and AC appliance anywhere.
- 3. What is this session about? This experiential learning session is designed to enhance the HVAC training professional’s knowledge of environmental compliance and personal safety when de- installing mercury thermostats. Even though these devices haven’t been made since 2007, they still remain in many HVAC applications and regulations require proper disposal of them. While mercury thermostats are less frequently seen in commercial and residential buildings, many are still in circulation, and the new HVAC workforce needs the tools and knowledge of what is required of them when needed.
- 4. Overview Background on Program Legislative and Regulatory Environment Frameworks Break Identification, De-Installation and Safety Best Practices Break Future of the Collection Program
- 6. Industries that charge for end of life product recycling or have stewardship programs PaintCare (Paint): A manufacturer-funded non-profit that operates the mandatory paint stewardship program for CA, CO, CT, ME, MN, OR, RI, and VT. Call2Recycle (Batteries): A non-profit organization that collects and recycles batteries at no cost for municipalities, businesses, and consumers. National program. Mattress Recycling Council (Mattresses): a non-profit organization formed by the industry to operate the Bye Bye Mattress recycling programs in states that have enacted mattress recycling laws. Connecticut and California programs began in 2015. Rhode Island's program will begin on May 1, 2016. Other: Save money by familiarizing yourself and your community with other local business-funded take-back programs for products like CFLs (Lowe’s, Ace Hardware, IKEA, Home Depot), medical sharps (doctors offices, hospitals, pharmacies, etc.), and tires (Bridgestone)
- 7. What is the Thermostat Recycling Corporation? Industry stewardship program for end-of-life mercury thermostats Non-profit founded 20 years ago by Honeywell, White-Rodgers, and General Electric; 31 manufacturers now participate Mission is to promote and facilitate the proper management of end-of-use mercury containing thermostats through reverse distribution
- 8. Mercury History Bio Toxin Nickname – Quicksilver Element 80 on periodic table First Discovered in 1500 BC Egyptian tombs; thought to prolong life, heal fractures, and maintain good health Element found deep in the Earth’s crust Was first used to extract silver from mines in Peru and Spain Mines in the United States, Mexico, and Italy have been mined out, shut down due to low price, contamination and low demand for Mercury Nevada’s mine – McDermitt Mine closed in 1992, last of its kind European Union directive made mining for Mercury available in China for CFL bulbs – 2005 opened up old mercury mines.
- 9. How the Program Works 1. Mercury thermostats are removed from wall 2. Thermostats are taken to closest collection point or stored in TRC’s container at job site 3. When bin is filled or one year’s time of accumulation, it is sent to TRC’s processing facility in Port Washington, Wisconsin 4. After processing, the empty bin is returned to start the collection process again
- 10. TRC Collection Partners HVAC Wholesalers (67%) Sold mercury thermostats Collection location convenient for generators; HVAC Contractors HVAC Contractors (17%) Installed mercury thermostats Hands-on collectors of end-of-life mercury thermostats HHW Facilities (9%) Deal with household hazardous waste, which includes mercury thermostats Thermostats collected from residents per each location’s rules and ordinances Retailers (5%) Schools (<1%)
- 11. Just A Few Wholesale Distributor Partners… Johnstone Supply RE Michel Ferguson United Refrigeration Lennox Parts Plus Johnson Supply CC Dickson Goodman Gustave Larson APR Supply Baker Distributing
- 12. Collection Product Offerings Large recycling container Holds roughly (100) T87F Round™ Thermostats Locations offered merchandising display $25 for each large container. NEW - Small 1-gallon pails Holds up to (6) T87F Round™ Thermostats $10 for each pail order. One time use only
- 13. Collected over 2.1 million thermostats Diverted more than 10 tons of mercury from the ecosystem 48 contiguous states Distributed over 9,400 recycling bins 4,498 Mandatory 4,904 Non-mandatory How the Program Works
- 14. TRC MILESTONES 1998: Voluntary take-back program began in Arlington, VA 2004-2007: Production of mercury thermostats stops 2006: First mandatory extended producer responsibility (EPR) law 2010: Collections exceed 200,000 units 2017: TRC headquarters move to Ft. Washington, PA 2014: Annual collections peak with 203,346 units
- 15. LEGISLATIVE and REGULATORY ENVIRONMENT FRAMEWORKS
- 16. Universal Waste Handling / Rules
- 17. TRC Listed On EPA Website
- 18. Legislative Requirements on Mercury Thermostat Recycling RCRA (Resource Conservation Recovery Act) Federal law regulates hazardous waste disposal Includes mercury containing equipment such as mercury switch thermostats Must be recycled if they come out of commercial buildings; any state Certain states are more restrictive and require thermostats removed from any structure to be recycled. Disposal bans (if removed, can not go in solid waste) California, Connecticut, Iowa, Illinois, Florida, Maine, Maryland, Massachusetts, Minnesota, New York, New Hampshire, Oregon, Rhode Island, Pennsylvania, Vermont, Washington HVAC contractor provision requires recycling California, Connecticut, Iowa, Illinois, Maine, Massachusetts, Minnesota, New York, New Hampshire, Oregon, Rhode Island, Pennsylvania, Vermont Mandatory Recycling for DSM State/Rate Payer Funded projects
- 19. Legislative Requirements on Mercury Thermostat Recycling MEBA (Mercury Export Ban Act) Became law in 2008 under “Mercury Export Ban Act of 2008” Aims to reduce the use of mercury mining for commercial purposes globally Ban on export took effect January 1st, 2013 Requires DOE to designate and operate a facility for long term management of storage of elemental mercury generated in the U.S. Largest holders of elemental mercury are: Department of Defense Department of Energy DOE must submit to congress by July 1st, 2014 results of study of long- term storage of elemental mercury on mercury recycling DOE facility by permit application by January 1st, 2015 (Status Unknown)
- 20. 3 Legged Stool of Responsibility - State Laws PROFIT MANUFACTURER WHOLESALER CONTRACTOR
- 21. Mercury Added Thermostat State Legislation
- 22. Contractor – No Leave Behind on Premises (Ex. - NY Law)
- 23. Mandatory Recycling For State Funded DSM Projects (Ex. NY Law)
- 24. Fines and Fees of State Law (Example - New York) Improper Disposal (ie. Throwing mercury thermostats in the trash): First offense is warning and education Second through fourth offense is $50, $75, $100 respectively $500 fine after fourth offense Failure for HVAC wholesalers to act as collection point and continue to sell thermostats: $1,000 per day per violation Enforceable through Department of Conservation (branch of the state EPA)
- 26. IDENTIFICATION, DE-INSTALLATION and SAFETY BEST PRACTICES
- 27. How To Identify A Mercury Thermostat
- 28. Explanation of How a Mercury Thermostat Works Acts as an electrical switch Makes and breaks the circuit depending on mode Very reliable – average warranty life was 38 years Harmless in operation
- 29. Applications Still In Use with Mercury Thermostats Residential (single/multi-family and attached/detached, or semi-attached): Boilers Air conditioners Heat Pumps Light Commercial (hotels, restaurants, banks, retail outlets): Unit Heaters PTAC’s Rooftop units Education buildings (schools, colleges, libraries) Unit Heaters PTAC’s Rooftop units
- 30. Replacement Work Targeting the Removal of Mercury Thermostats Residential: HVAC Contractor retrofit/replacement Utility programs focused on HVAC energy efficiency BYOT – Bring your own thermostat Direct Install Incentives for programmable or smart thermostats Trade ally networks Light Commercial: HVAC Contractor retrofit/replacement Utility programs focused on HVAC energy efficiency BYOT – Bring your own thermostat Direct Install Incentives for programmable or smart thermostats Trade ally networks
- 31. THE ‘GOLDILOCKS ZONE’ Climate Zone Cold/Very-Cold regions produce double the next climate zone Presence of a boiler system Region Midwest produces most - 36% of all thermostats collected Not attributed directly to population Propensity for residential retrofit and replacement Presence of R.E. Michel's or Johnstone Supply Represents 1/3 of all U.S. based collections since 2012 Presence of a disposal ban
- 32. Safety Best Practices Identify if the thermostat has mercury by looking for dials or levers or the mercury ampoule Turn power off to the equipment prior to removal of thermostat Take the cover off of thermostat (save) Loosen the contact screws that hold thermostat to the sub-base Remove the thermostat from the sub-base Put the cover back over the thermostat to protect the mercury bulb Remove the sub-base or the back plate Return the thermostat to the recycling bin (either wholesaler or at contractor’s shop or at your school).
- 34. THE FUTURE OF THE COLLECTION PROGRAM
- 35. REDUCED MERCURY EMISSIONS (In Pounds),Trend Report For Facilities in All Industries Mercury Emissions toAir Toxics Release Inventory, U.S. EPA
- 36. DECLINING STATE COLLECTIONS 0 2000 4000 6000 8000 10000 12000 14000 16000 18000 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 Illinois Collections by Year 0 5000 10000 15000 20000 25000 30000 35000 40000 45000 50000 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 Maryland Collections by Year 0 500 1000 1500 2000 2500 3000 3500 4000 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 Vermont Collections by Year 0 2000 4000 6000 8000 10000 12000 14000 16000 18000 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 Michigan Collections by Year
- 37. Support Materials YouTube videos Flash drives Presentation Marketing materials List of legislated states
- 38. CONTACT INFORMATION Ryan L Kiscaden Executive Director Thermostat Recycling Corporation E. ryan.kiscaden@thermostat-recycle.org P: 267-513-1727 F. 703.852.7202 T. @tstat_recycle www.thermostat-recycle.org
Editor's Notes
- Speak over the cover slide. Show actual mercury thermostat – ask a questions of the audience and pause long enough for them to answer: Has anyone seen this before? Has anyone seen one working in a home or building recently? No? That’s because these devices have not been manufactured since 2007. You are more likely to see one in a museum instead of in the population; actually if you go to the Smithsonian Washington DC, you will see them there. Yes? Finally, someone who has spotted one! Where? They are becoming more difficult and more expensive to find!
- Many common products that we use in our daily lives contain potentially hazardous components and require special care when disposed of. It is illegal to dispose of hazardous waste in the garbage, down storm drains, or onto the ground. Chemicals in illegally disposed hazardous waste can be released into the environment and contaminate our air, water, and possibly the food we eat. And by throwing hazardous waste in the garbage, you can cause additional hazards to your garbage handler. These items are banned due to their classification. Even without a law degree, most US citizens are aware they can’t dispose of these items in your trash. Universal Waste
- Minamata Convention Highly toxic if spilled, leaked Pollutes: Air – through incineration in a facility without proper stack “scrubbers” Land & Water - through landfills Health Effects: Most humans are exposed to methylmercury through fish and shellfish consumption Shark, Swordfish, Albacore (white tuna) Women who are pregnant or nursing impacts: cognitive thinking, memory, attention, language, and fine motor skills. Adult exposure may exhibit symptoms: Impairment of peripheral vision, lack of coordination, impairment of speech, muscle weakness. Exposure symptoms depend on: Chemical form of mercury, dose, age, duration of exposure, route of exposure (inhalation, digestion, dermal contact), health of person.
- This is a prepaid program which comes with a FedEx label, liner, and sturdy recycling container What facilitates thermostats being removed from the wall? (ranked in most likely to occur) HVAC contractor (system replacement, retrofit/remodel, new wi-fi/programmable, or smart thermostat marketing) Utility Energy Efficiency projects (BYOT, incentives/rebates, direct install) Homeowner/building owner or facility manager decides to upgrade Many variables are factored in when considering removal but by far the largest driver of removal is HVAC systems in which the thermostat controls such as boilers, air conditioners and furnaces. When these need to be replaced is much more likely to generate removal of the mercury thermostat. And HVAC systems are largely driven by region’s climate zone and proximity to different fuel sources Our efforts under the TRC are not unlike the efforts of the National Vehicle Mercury Switch Recovery Program (NVMSRP) and its End-of-life Vehicle Solutions (ELVS) program. They are similar in that the mercury is encased in a product that is used in a vehicle or a home. Both also deal with a product that is no longer manufactured with mercury Both deal with end-of-life issues and collection rates are expected to decrease over time as old products are removed ELVS collections are tracking down as expected TRC collections have plateaued but we should expect they too will track down as a result of our continuing efforts to find them and dispose of them properly. Automakers removed mercury switches in 2002 Thermostat manufacturers removed mercury from thermostats in 2006 Moved many years prior to programmable Several product life cycles from mercury thermostats HVAC channel – quick note; although mercury thermostats are mostly located in residential dwellings, it is not commonly disposed of from homeowners. The reason is simple, what facilities a replacement of a thermostat in majority of cases has to do with HVAC repair or replacement, not thermostat switch out by itself Happen to be in homes; not like batteries & paint & other household hazardous wastes
- Represents almost 95% of market share in the HVAC wholesale business. Well over $2-5 billion in annual sales
- Costs of container
- Our members branded and sold mercury thermostats in the U.S., or produced devices that may replace mercury-containing thermostats. They internalize costs to operate program through TRC. They do not use Point of Purchase fees. Once mercury has been used in a product, and is collected and recycled, there is limited commercial value for it. Additionally, no more mercury thermostats are being made. Once they are removed from the population there will never be one of its kind to replace it, ever. To help you understand the enormity of these numbers we’ve drawn a couple of comparisons. BINS DISTRIBUTED: 9400 bins is the mathematical equivalent of a 933 stories of a building TRC has distributed enough bins to build 9 Trade Centers THERMOSTATS COLLECTED: We’ve collected 2.1 million mercury thermostats If we placed one of these thermostats on every seat in the NFL Cowboys At&T stadium, we could fill the seats of 21 AT&T Stadiums HVAC Wholesalers (67%) Sold mercury thermostats Collection location for recyclers convenient for generators; HVAC Contractors HVAC Contractors (17%) Installed mercury thermostats Hands-on collectors of end-of-life mercury thermostats HHW Facilities (9%) Deal with household hazardous waste, which includes mercury thermostats Collect mercury thermostats from residents per each location’s own rules and ordinances Retailers (5%)
- Archive photos of mercury thermostat production – production numbers how many were made Founded in 1998, the Thermostat Recycling Corporation (TRC) began as a voluntary, industry-funded take back program. program started in designated states, then went nationwide in 2001 after remaining states adopted UW Rule Between 2004 and 2007, manufacturers permanently stopped producing mercury thermostats Eight years after TRC’s inception, in 2006, the first extended producer responsibility (EPR) law for thermostats was passed in Maine but years prior in 90’s MN leads with mercury product management regulations Soon after, 12 more states followed and mandated the collection and recycling of mercury thermostats through EPR plans In 2010, TRC’s collections exceeded 200,000 units and peaked in 2014 Now, just 25 miles outside of Philadelphia, and in closer proximity to some of our manufacturer-members, we are very excited about marking TRC’s 20th anniversary in 2018
- Manufacturers Makers of mercury bearing thermostats Provides funding for TRC Wholesaler Distributors of mercury bearing thermostats Acts as a collection point (either voluntary or mandatory depending on state regulation) Educates contractors about their responsibility Contractor Installs mercury bearing thermostats Returns mercury thermostats to wholesale distributor
- Title 29 – Mercury Thermostat Collection Act Section 27 – 2909 Article 3.1 The language in all states aforementioned from previous slide, have similar language And leaving it at the premise is a violation of NY conservation law and is subject up to a $500 per violation Check your states laws regarding this. Each state is different but most that have a disposal ban have a provision in the law requiring this for contractor
- Example of NY law again Lists of states with a similar provision Rhode Island Connecticut Massachusetts
- Presence of a law assists collections but states in the goldilocks zone produce more. Goldilocks zone as defined by a planets to have life resides in the perfect conditions Overlaid TRC Data with Climate Zone Statistics from Energy Star’s website: Cold-Very Cold represents over 50% of all thermostat collections Next climate zone is Mixed-Humid at 26% Average age of replacement of HVAC such as heat pump, air conditioner, or furnace is 12-15 years. Boilers last 18 – 22 years and more likely to be present in a region which is cold and has access to cheap energy such as natural gas/oil Population centers not a better predictor. If true, coastal regions would produce most thermostats yet the Midwest does Mercury thermostats closely tie to HVAC equipment replacement such as boilers, air conditioners, heat pumps, and furnaces. Northeast is responsible for more than half the boiler sales in the U.S. and ¾ths of the U.S. markets for furnaces with an AFUE rating 82-94% Presence of law helps in collections but that by itself is not greater than self-interest or personal choice of the generator of the waste. Presence of law increases collections initially. We do witness a clearing out effect of mercury thermostats stored in shops are recycled in the program Discuss Michigan as the golden standard – Michigan has most of this criteria in place and is number four in collections HVAC Industry Behavior of HVAC techs, HVAC contracting company owners, and generators of waste Replacement rate of thermostats HVAC equipment shipments Support of site visits from the state agency to enforce on generators does have a positive effect
- The United States has made considerable progress on the largest emission sources. The Toxic Release Inventory shows steady decline of mercury emissions to the air from all sources. 2010 snapshot to capture the relative contributions to estimated emissions to air from man-made sources. Mercury containing products were a relatively small source of mercury. and mercury thermostats would be a sliver of a sliver Gold mining operations and combustion sources dominate. And of note, right here in Boston, a recent Boston Globe article from David Abel cites, “2014 study found that mercury pollution in MA had dropped by 90 percent since 1990’s.” this can be credited directly to TRC’s program along with the MSP plans that the WTE has in place diverted tons of mercury. Also, WTE have put into place mercury capture devices by injecting carbon prior to emissions NON-ANTHROPOGENIC SOURCES of mercury in the environment are HUGE. Best examples are volcanoes and forest fires. One volcano eruption probably throws more mercury into the atmosphere than anything man could do in ten years. Reference quickly the consumption loosening of EPA guideline for fish consumption A problem averted by good public and private policy
- But the reality is that mercury thermostats are an exhaustible resource. For every thermostat collected, it is one less to collect. The cost of recovering the next unit is going to higher than prior unit Softening in collections; down 16% in 2016; peaked in 2014 KPI’s such as average thermostat in bin compared (goes down 1 – 2 units every month) while the count of bins processed (goes up). A sign of weakening program. We do more to collect less. Budget is growing exponentially from an ROI perspective; we are now spending 3x as much to collect compared to 2015. Example: IA it is averaging $1.44 per click (CPC or cost per click) and $25 or so cost per conversion. Not only the TRC program has seen diminishing returns; but other publicly available pathways of the disposal of mercury thermostats including Veolia’s RecyclePak program, California’s 303 collection data on HHW, and Canada’s thermostat recovery program all show a decline in collections. Similarly situated mercury product collection program, ELVS shows a decline in collections trends. For those who advocated for a mercury collection program through state legislation, I congratulate you all. The plans worked…