Submission Number: 00004
Received: 8/2/2011 4:20:42 PM
Commenter: James Moore
Organization: Government Management Associates
Agency: Federal Trade Commission
Initiative: 16 CFR Part 305: Appliance Labeling Rule; Proposed Rule to Expand Coverage of the Lighting Facts Label; FTC Project No. P084206
Attachments: No Attachments
The proposed FTC Appliance Labeling Rule will increase human sickness and death by emphasizing and promoting the benefits of CFL's while ignoring the dangers of having breakable containers containing mercury in the home.
Such policy is inconsistant other FTC policies regarding labeling requirements of less harmful substances often kept in more stable containers under the sink, such as drain cleaners and certain household cleaning supplies.
Whereas the EPA may place a higher value on the health of the environment than human life, it is the responsibility of the FTC to first and formost protect human life.
Under the proposed rules, it is probable that many young children will needlessly be exposed to mercury in excess of of OSHA legal limits and NIOSH not-to-exceed limits, 1) through intentional action of investigatory learning and experimentation and, 2) unintentionally through accidental breakage in enclosed spaces such a bathrooms.
Without clear indication of the presence of hazardous material, consumers will assume that CFL's are equally safe to incandescent bulbs and have not, nor will not, take appropriate action to safeguard their families. This is clearly indicated by consumers currently only recycling 2% of CFL's.
CFL's should, therefore, be labeled with standard skull-and-crossbones or another identifiable multi-lingual warning symbol.
In addition, the FTC should warn the public that the EPA is not responsible for safeguarding human life when in conflict with the health of the environment. Specifically, the FTC falsely represents CFL's as containing "about" four milligrams of mercury when major manufacturer's, such as General Electric, clearly state that an average of five milligrams is present.