16 CFR Part 305: Final Amendments to the Appliance Labeling Rule That Require Changes to the Existing Labeling Requirements for Lamp Products (Light Bulbs) #549189-00011 

Submission Number:
549189-00011 
Commenter:
Jane Grosslight
Organization:
Durwood Publishers LLC
State:
Florida
Initiative Name:
16 CFR Part 305: Final Amendments to the Appliance Labeling Rule That Require Changes to the Existing Labeling Requirements for Lamp Products (Light Bulbs)

Please reconsider rewording the information about mercury in lamps, especially compact fluorescent lamps. As the wording stands now, THE LABEL WILL BE A "KILL SWITCH" for the general public considering purchasing a compact fluorescent lamp. It will derail the use of compact fluorescent lamps to reduce electricity consumption, minimize global warming, and less the strain on nonrenewable energy resources. At the store, the public would not purchase anything indicating mercury--even though the amount is little and they are unlikely to breathe it in or ingest it. These facts are unknown to them. DON'T DO IT! I have lots of experience teaching lighting to architects, interior designers, and the general public. I know how they think. I understand their "knee-jerk" reactions. I understand their lack of technical information about light bulbs. They will buy and hoard as many incandescent A lamps that they can get their hands on. Do you want that? I don't. Educate them in a usable way! The label could read: A small amount of mercury is present. If the bulb breaks, pick up the pieces with sticky tape and seal in double plastic bags. Mercury is harmful only if breathed or swallowed. Recycle all broken or burned out bulbs and do not incinerate! In addition, what are the provisions for labeling "amalgam technology" compact bulbs that hold the mercury if cold? Surely they should be credited for a better technology. I recommend them always. I have developed a 4-fold brochure on how to choice CFLs, where to use them, and what to do with them if broken or burned out. Unfortunately, the home improvement stores do not buy from small providers, like me, who are trying to sell intellectual property. If you know of a government grant to help disseminate the 4-fold brochure as a free handout, please let me know. The general public often makes poor decisions about CFLs, often dislike them, and frequently avoid buying them. We've got to turn this around. I have been publishing books on lighting since 1984. Look at www.durwoodpublishers.com for my educational publications and look at www.aBulbandaSocket.com for my general public publication, an IESNA award-winning Progress selection for unique and significant advancement to the art and science of lighting for 2010. Jane Grosslight, LC FL