Submission Number: 00007
Received: 9/19/2011 3:48:07 AM
Commenter: Steven Lee
Organization: 3E Lighting Inc.
State: Outside the United States
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
‘‘Notice of Proposed Rulemaking on Expanded Bulb Coverage for the Lighting Facts Label (16 CFR part 305) (Project No.P084206)’’
My comments to FTC are:
The CFL lamps must be printed that value of mercury contains such as Hg X.X mg on package and product in a small place on FTC Lighting Facts Label (please re-design it) and on lamp tube or on somewhere of integral CFL. Other lamp source had toxic and hazardous materials shall done the same.
According to Euro Article 5(1)(a) of Directive 2002/95/EC, a maximum concentration value of 0,1 % by weight in homogeneous materials for lead, mercury, hexavalent chromium, polybrominated biphenyls (PBB) and polybrominated biphenyl ethers (PBDE) and of 0,01 % by weight in homogeneous materials for cadmium shall be tolerated.’
Currently the CFL manufactories in China have two ways to meets RoHS required that MUV 0,1 % by weight limitation in homogeneous materials for lead, & mercury and 4 others.
First step make 15 samples for each lamp depend how many wattages manufacturer needs send to SGS Lab Inc for toxic and homogeneous materials tested, They knew that SGS tester engineer does not operated these lamps intended lead, & mercury will a little lower or just met 0.1 % by weight of RoHS required toxic limitation.
Those send for SGS tested CFL lamps Hg intended will be as below:
T3 13W <0.4mg, 18W <0.6mg, 23W <0.8mg,
The weight of T3 23W tube is 75g the Hg is able contain 0.8mg
T4 13W <0.6mg, 18W <0.8mg, 23W <1.0mg,
T5 14W <0.5mg, 21W <0.7mg, 28W <1.0mg,
The T5 28W tube weight is 105g.
Than SGS Lab Inc issued Certification will be RoHS compliant perfect for sure.
Second work to make other 15 samples lamps for each wattages but mercury intended has been different which more than samples was sent to SGS as above which value as below:
T3 13W <1.5mg, 18W <2.0mg, 23W <2.5mg,
T4 13W <1.5mg, 18W <2.0mg, 23W <2.5mg,
T5 14W <2.0mg, 21W <2.5mg, 28W <3.0mg,
Sending samples to Lab do IEC/ ANSI performance test.
The Certification for performance result is perfection. The products contain Hg value will be as same as above for goods export to U.S.A. from China.
Have other way as heard the manufactories select radiations Krypton Gas which used Kr92 but doesn’t know how big value they charged. It will help integral CFL to rated when Hg value has met limit as below:
T3 13W <0.5mg, 18W <0.7mg, 23W <1.0mg,
T4 13W <0.7mg, 18W <1.0mg, 23W <1.5mg,
T5 14W <1.5mg, 21W <1.8mg, 28W <2.0mg,
There is no language on IEC / ANSI 60081 Standard allowed manufacturer to use radiations Krypton Gas put into fluorescent lamps. Please discussion with DOE, DOH, EPA for hard put value limitation and hard to control it by Lighting Facts Label. If FTC will be accept radiation CFL, HID. May be required manufactories should print radiations logo on Lighting Facts Label to note consumers of that.
Please be Label Re-design, Does matter manufactory input more or less of limitation intended that Hg value in the CFLs? HID or other source, the product shall print the toxic and hazardous materials amount information on Lighting Facts Label and show value on product. Once FTC or FCPSC may send-out for check quality and RoHS value contain limit? Than Agency would have rights to issued penalty Ticket.
All LED integral lamps used IEC/ ANSI lamp cap has been selected, the fluorescent G13, G5 and pin-based lamp caps except, shall join Lighting Facts Label program on 2012/1/1, with self-citify that the LM-79 -80, TM-21 test has been sent to XX Lab in processed, promise the result will be done on XX y XX m XX d (shall have a Lab e-mail attached) and agree be submit report to Commission no later than 2015 April 01. After Date any failure and false LED product will be moved-out from the Lighting Facts Label program. And agree that the LED integral lamp only able print L70 on Lighting Facts Label before result have submit approved it.
All lamp source shall all join program once achieved efficiency and performance test. No any lamp able to sale without Lighting Facts Label.
c.c. To Energy Star Lighting Program Manager
3E Lighting Inc.