EPA Roadmap for Mercury - i 

TABLE OF CONTENTS 

EPA’S ROADMAP FOR MERCURY 

LIST OF TABLES AND FIGURES ii

EXECUTIVE SUMMARY 3

INTRODUCTION 15

I. ADDRESSING MERCURY RELEASES 21

II. ADDRESSING MERCURY USES IN PRODUCTS AND PROCESSES 35

III. MANAGING COMMODITY-GRADE MERCURY SUPPLIES 43

IV. COMMUNICATING TO THE PUBLIC ABOUT MERCURY EXPOSURE RISKS 47

V. ADDRESSING INTERNATIONAL MERCURY SOURCES 53

VI. CONDUCTING MERCURY RESEARCH AND MONITORING 63

APPENDIX 75

ENDNOTES 79
ii - EPA’s Roadmap for Mercury 

LIST OF TABLES AND FIGURES 

FIGURE 1. THE MERCURY CYCLE 16

TABLE 1. NATIONAL AIR EMISSIONS ESTIMATES FOR MERCURY 22

FIGURE 2. AIR EMISSIONS DATA FOR MERCURY 24

FIGURE 3. TOTAL 2001 U.S. MERCURY USE IN PRODUCTS 36

FIGURE 4. U.S. MERCURY PRODUCT AND PROCESS USE TRENDS 37

FIGURE 5. WHERE ARE MAN-MADE MERCURY EMISSIONS ORIGINATING? 53

FIGURE 6. MAN-MADE AIR EMISSIONS OF MERCURY: DISTRIBUTION BY

REGION IN 1990 AND 2000 54

FIGURE 7. GLOBAL MERCURY USE, 2000 55
Executive Summary - 3 

EXECUTIVE

SUMMARY

OVERVIEW 

Mercury is a naturally occurring element. 

It enters the environment as a result of 

natural sources (such as volcanoes) and 

human activities (such as industrial combustion and mining). Mercury is widespread in the U.S. and global environment. Human activities have increased the 

amount of mercury that is available in the 

atmosphere; in soils and sediments; and in 

lakes, streams, and oceans. 

Significant progress has been made to date 

to reduce industrial emissions of mercury 

in the U.S., as well as to reduce or eliminate the amount of mercury used in 

various processes and products. Most of 

the large industrial sources of mercury 

emissions are sites where mercury is 

emitted as a byproduct of combustion 

processes. Other major sources of mercury 

include industrial processes and products 

that use mercury deliberately, such as 

certain chlor-alkali chlorine manufacturing processes, batteries, lamps, and measuring devices such as thermometers. 

Mercury is also released through mining 

practices, sewage discharge, and metal 

refining operations. When mercury is used 

in a product, most releases occur during 

manufacturing or disposal. In the U.S., 

there are over 100 manufacturing processes that use some form of mercury.

1 

While elemental mercury is toxic to 

humans when it is ingested or inhaled, 

EPA is most concerned about methylmercury, as it is a potent form of mercury and 

it is the form to which humans primarily 

are exposed. Methylmercury can be 

formed from other deposited mercury by 

microbial action in sediment and soils. 

Once formed, methylmercury can be 

taken up by aquatic organisms and 

bioaccumulates up the aquatic food web. 

While all forms of mercury can 

bioaccumulate, methylmercury generally 

accumulates to a greater extent than other 

forms of mercury.

2 

Mercury Sources 

The primary sources of mercury releases 

to air, water, soils, and sediments can be 

grouped into four categories: 
4 - EPA’s Roadmap for Mercury 

1. New releases from naturally-occurring 

sources (such as volcanic activity and 

weathering of rocks) 

2. Re-releases of historic mercury previously deposited through natural and 

anthropogenic processes in soils, 

sediments, water bodies, landfills, and 

waste tailings/piles (also called “reemitted sources”) 

3. New releases of mercury impurities 

from combustion of fossil fuels, and 

from smelting of metals such as gold 

and zinc 

4. New releases resulting from uses of 

mercury in products and manufacturing processes such as chlor-alkali 

manufacturing 

Exposure Pathways 

In the United States, humans are exposed 

to methylmercury mainly by consuming 

fish that contain methylmercury. Aquatic 

ecosystems respond to changes in mercury 

deposition in a highly variable manner as a 

function of differences in their chemical, 

biological, and physical properties. Depending on the characteristics of a given 

ecosystem, methylating microbes convert a 

small but variable fraction of the inorganic 

mercury in the sediments and water 

derived from human activities and natural 

sources into methylmercury. Methylmercury is the only form of mercury that 

biomagnifies in the food web. Concentrations of methylmercury in fish are generally on the order of a million times the 

methylmercury concentration in water. In 

addition to mercury deposition, key factors 

affecting methylmercury production and 

accumulation in fish include the amount 

and forms of sulfur and carbon species 

present in a given water body. Thus, two 

adjoining water bodies receiving the same 

deposition can have significantly different 

fish mercury concentrations.3 

While the primary pathway of human 

exposure to mercury is through eating fish 

containing methylmercury, individuals 

may also become exposed to harmful 

levels of elemental mercury vapor found 

indoors in work places and in homes. 

When exposed to air, elemental mercury 

vaporizes and can be inhaled. The number 

of individuals exposed in the U.S. in this 

way is very small. 

Fish Consumption Advice 

Fish and shellfish are an important part of 

a healthy diet, since they contain high 

quality protein and other essential nutrients, are low in saturated fat and contain 

omega-3 fatty acids. A well-balanced diet 

that includes a variety of fish and shellfish 

can contribute to heart health and 

children’s proper growth and development. EPA and the U.S. Food and Drug 

Administration (FDA) have issued fish 

consumption advice to help consumers 

understand the connection between the 

risks of methylmercury and the benefits of 

fish. 

Research shows that most people’s fish 

consumption does not cause a health 

concern. Elevated methylmercury in the 

bloodstream of unborn babies and young 

children may harm the developing nervous system, impairing the child’s ability to 

learn and process information.4 However, 

certain sub-populations are at higher risk 

than the general population because of 

their routinely high consumption of fish 

and shellfish (e.g., tribal and other subsistence fishers and their families who rely 

heavily on locally caught fish for the 

majority of their diet). Mercury concentrations in fish vary widely. While local 

freshwater fish also contain methylmer-
Executive Summary - 5 

cury, the majority of fish species consumed 

in the U.S. are ocean species and the 

methylmercury concentrations in these 

species are primarily influenced by the 

global mercury pool. Fish that are higher 

in the food chain—such as king mackerel, 

swordfish, tilefish, and shark—have much 

higher methylmercury concentrations 

than fish that are lower in the food chain. 

The major tool for reaching and educating affected populations has been through 

fish consumption “advisories” or warnings 

issued by states, tribes, and the FDA. In 

March 2004, EPA and FDA issued a joint 

federal fish advisory for mercury in fish 

and shellfish. The advisory provides advice 

for women who might become pregnant, 

women who are pregnant, nursing mothers, and young children (see Appendix for 

the entire FDA/EPA joint advisory).5 

Additional EPA outreach actions aimed at 

reducing risks from mercury are discussed 

in Chapter IV. 

Continuing Research on Sources of 

Exposure 

U.S. mercury deposition is from domestic 

man-made sources and from global 

sources, including natural, re-emitted, and 

international man-made sources. EPA has 

estimated that over three-quarters (83 

percent) of the mercury deposited in the 

U.S. originates from international sources, 

with the remaining 17 percent coming 

from U.S. and Canadian sources.6 These 

figures include mercury from natural and 

re-emitted sources. This estimate is based 

on an advanced, state-of-the-science 

modeling assessment of atmospheric fate, 

transport, and deposition of mercury. 

EPA’s modeling indicates that a substantial 

variation in mercury deposition occurs 

across the U.S. with domestic sources 

influencing mercury deposition much 

more in the eastern U.S. and global 

sources being a more significant contributor to mercury deposition in the west, 

where relatively few domestic sources exist. 

The scientific community’s understanding 

of mercury atmospheric chemistry is 

evolving and there remain uncertainties 

regarding the simulation of mercury in 

atmospheric chemistry models. EPA 

continues to work to advance the state of 

the science on mercury chemistry and fate 

and transport modeling.7 

EPA has analyzed various scientific questions relating to the primary fish-tohuman exposure route, including key 

scientific questions described in Chapter 

VI. EPA recognizes that there remain 

scientific uncertainties associated with 

some of these questions, and is committed 

to continuing to work to advance the 

science in these areas. 

Reducing Exposure by Addressing 

Mercury Releases and Uses in the 

U.S. and Internationally 

EPA’s long-term goal is to reduce risks 

associated with mercury. EPA recognizes 

that to reduce the risks associated with 

mercury, the Agency must first understand 

what contributes to the risk and what the 

appropriate mechanisms of risk reduction 

might be. EPA will take action to identify 

exposed populations, minimize exposures 

through outreach efforts, and appropriately reduce anthropogenic releases. As 

part of its strategy, EPA will assess mercury 

sources of concern and will: focus on uses 

that would lead to risk, where cost-effective substitutes exist; promote reducing 

mercury in processes and products where 

benefits of such reductions would justify 

costs, even where cost-effective substitutes 

do not exist; and work to identify and 

encourage development of alternatives to 

essential uses of mercury that lead to risk. 

EPA will also work with its federal partners 
6 - EPA’s Roadmap for Mercury 

to address risks associated with management and disposal of excess supplies of 

commodity-grade mercury in the U.S. In 

addition, EPA will support the efforts of 

other countries to take action to address 

risks associated with global mercury 

pollution by developing and implementing 

partnerships with international organizations, non-governmental organizations, 

and the private sector. 

Six Areas of Focus in EPA’s Roadmap 

for Mercury 

EPA’s Roadmap focuses on six key areas, 

with the overarching goal of reducing 

health risks associated with mercury 

exposure. EPA will reduce risk by: 

1. Addressing mercury releases to the 

environment 

2. Addressing mercury uses in products 

and processes 

3. Managing commodity-grade mercury 

supplies 

4. Communicating risks to the public 

5. Addressing international mercury 

sources 

6. Conducting mercury research and 

monitoring 

Success in reducing risks associated with 

mercury exposure and mercury pollution 

in the domestic and global ecosystem will 

depend on pursuing all six of these actions 

simultaneously. The actions described in 

the Roadmap will be implemented over a 

number of years. EPA will periodically 

assess progress and make needed changes 

based on new information, successful 

efforts, and emerging needs. EPA will 

report on its progress, as well as on any 

major changes in direction from the 

current Roadmap. 

ABOUT THIS REPORT 

Over the past decade, addressing mercury 

risks to the environment and human 

health has been a focus for EPA. International, national, and local efforts to reduce 

mercury releases and uses have grown and 

are yielding impressive results. For example, overall U.S. mercury air emissions 

have been reduced by 45 percent since 

1990,8 and mercury use in products and 

processes decreased 83 percent between 

1980 and 1997.

9

 In 1997, U.S. man-made 

emissions contributed to approximately 3 

percent of the global mercury pool.10 

In 1998, EPA issued a draft Mercury Action 

Plan for public comment as part of its 

effort to address priority persistent and 

bioaccumulative toxic pollutants. The 

Agency received extensive comments on 

the 1998 draft and held subsequent 

meetings with states and tribes, municipalities, industry, and environmental 

groups, including a series of “listening 

sessions” in 2003. Stakeholders provided 

very useful input on those aspects of the 

mercury issue on which they believed the 

Agency should focus its efforts. EPA also 

created an agency-wide workgroup to 

develop a new action plan, now called 

EPA’s Roadmap for Mercury (Roadmap). 

Major offices at EPA are continuing to 

work to better understand the sources of 

mercury and how it impacts human 

health and the environment. The 

Roadmap describes the Agency’s most 

important actions to reduce both mercury 

releases and human exposure to mercury. 

Creating the Roadmap has enabled the 

Agency to maximize coordination of its 
Executive Summary - 7 

many diverse efforts, with the goal of 

improving EPA’s mercury program. In 

addition to providing a roadmap for EPA, 

this report provides important information about mercury to other federal 

agencies, to our partners in state, tribal, 

and local governments, and to the public. 

SUMMARY OF THE ROADMAP 

Human Health and Ecological Effects 

Mercury exposure can cause a number of 

adverse effects on human health. These 

effects can vary depending on the form of 

mercury to which a person is exposed and 

the level and length of exposure. The 

primary way humans are exposed to 

methylmercury is through eating fish 

containing methylmercury. Research 

shows that most people’s fish consumption 

does not cause a health concern. Methylmercury exposure can cause neurological 

impairment. The fetus and very young 

children are more sensitive to methylmercury than adults. Methylmercury in the 

mother’s body passes to the fetus and may 

accumulate there. There is evidence in 

adults that the organic form of mercury, 

methylmercury, also affects other systems. 

Specifically, some studies suggest that 

prolonged exposure to methyl-mercury, 

especially at higher levels, can harm the 

heart, kidneys, and immune system. 

However, additional studies are needed to 

better categorize the effect of methylmercury on these health endpoints.11 

In the United States, human populations 

most highly exposed to methylmercury are 

those that eat fish and shellfish containing 

methylmercury in excess of the recommendations contained in the joint U.S. 

FDA and EPA consumer advisory “What 

You Need to Know About Mercury in Fish 

and Shellfish.” Fish and shellfish are an 

important part of a healthy diet because 

they contain protein and other essential 

nutrients. Although nearly all fish and 

shellfish contain traces of mercury, research shows that most people’s fish 

consumption does not cause a health 

concern. However, elevated levels of 

methylmercury in the bloodstream of 

unborn babies and young children may 

harm the developing nervous system, 

impairing the child’s ability to learn and 

process information.12 Fish that are higher 

in the food chain—such as king mackerel, 

swordfish, tilefish, and shark—have higher 

methylmercury concentrations than fish 

that are lower on the food chain. Mercury 

concentrations in commercial fish vary 

widely.

13 The majority of fish species 

consumed in the U.S. are ocean species 

and the methylmercury concentrations in 

these species are primarily influenced by 

the global mercury pool.14 

While the primary pathway of human 

exposure to mercury is through eating fish 

containing methylmercury, individuals 

may also become exposed to harmful levels 

of elemental mercury vapor found indoors 

in workplaces and in homes. When exposed to air, elemental mercury vaporizes 

and can be inhaled. The number of 

individuals exposed in the U.S. in this way 

is very small. 

Fish-eating birds and mammals and their 

predators are at risk for greater exposure 

to mercury than other animals. Methylmercury has been found in eagles, otters, 

and endangered Florida panthers.15 Depending on the level of exposure, effects of 

methylmercury exposure on wildlife can 

include mortality, reduced fertility, slower 

growth, and abnormal behavior that 

affects survival.16 Fish development and 

reproduction may also be altered by the 

levels of methylmercury found in water 

ecosystems. 
8 - EPA’s Roadmap for Mercury 

I. Addressing Mercury Releases 

Air 

Addressing mercury releases to the air is 

important because mercury in the air can 

be deposited to water, converted to methylmercury, and taken up by fish. The U.S. 

has made significant progress in the 

reduction of industrial emissions of mercury to the air. In the last 15 years, EPA 

has focused most of its mercury reduction 

efforts on large point sources of air emissions, such as municipal waste combustors, 

medical waste incinerators, hazardous 

waste combustors, and more recently, 

industrial boilers and chlor-alkali facilities. 

With the March 2005 completion of final 

regulations for coal-fired power plants, the 

Agency now has Clean Air Act (CAA) 

standards in place limiting mercury air 

releases from most major known industrial sources in the U.S. 

In addition to implementing these standards, the Agency, under the CAA Area 

Source program, is in the process of 

addressing certain smaller point sources 

that emit mercury.

17 Under the CAA 

Residual Risk program,18 the Agency is 

evaluating the remaining risks, if any, 

from sources for which EPA has previously 

issued emissions standards under CAA 

§112(d). Mercury is one of several hazardous air pollutants that EPA will be investigating under these programs. 

Water 

The majority of mercury in U.S. waters, 

particularly in the eastern U.S., results 

from air deposition from a variety of 

sources including man-made, natural reemitted legacy mercury, and global deposition.19 States, tribes, and EPA’s air and 

water programs are working together to 

address mercury air deposition issues that 

affect water quality and mercury concentrations in fish. EPA has strengthened its 

modeling tools to better identify sources of 

mercury deposition; relate changes in air 

deposition to mercury concentrations in 

fish; and ultimately determine the best 

mercury reduction strategies. EPA will 

continue to further characterize mercury 

discharges to water and will issue guidance 

on implementation of its methylmercury 

water quality criterion. EPA will work with 

its partners to develop tools and approaches for identifying mercury impairments and developing mercury total 

maximum daily loads (TMDLs) in water 

bodies. 

Mercury can also be released directly to 

water from wastewater treatment plants, 

industrial facilities, and from current and 

historic mining activities (particularly in 

the western U.S.). The Association of 

Metropolitan Sewerage Agencies (AMSA, 

now known as the National Association of 

Clean Water Agencies) estimated that 

about 36 percent of mercury entering 

publicly owned treatment works is discharged from dental offices due to mercury in waste dental amalgam. Mercury 

discharges from dental offices far exceeded 

all other commercial and residential 

sources, each of which was below 10 

percent.20 EPA regions and states are 

working with dental offices to encourage 

collection of dental amalgam before it 

enters the waste stream. In addition, 

wastewater treatment plants are beginning 

to implement best management practices 

for collecting mercury from other industrial sources. EPA is providing guidance to 

wastewater treatment plants on how to 

characterize sources of mercury to the 

collection system and how to develop 

mercury minimization measures where 

appropriate. Mercury in the wastewater 

collection systems may come from the 

medical sector, dental offices, schools, and 

certain industries. EPA and the states also 
Executive Summary - 9 

are modifying surface water discharge 

permits to incorporate more stringent 

requirements in mercury discharges, 

where appropriate. 

Land 

Mining is the largest source of mercury 

releases directly to the land in the U.S.21 

Mining releases occur as a result of existing mining operations for gold, zinc, and 

silver; the smelting of zinc and other 

metals and runoff from waste tailings; and 

from abandoned gold, silver, and mercury 

mines. The Toxics Release Inventory 

(TRI) reporting indicates these types of 

releases to land are large in scope and 

appear to be increasing. Of the 5.14 

million pounds of mercury released to 

land, 1.4 million pounds is placed in 

surface impoundments and 3.7 million 

pounds is placed directly on the land in 

waste piles. Less than 1,000 pounds goes to 

landfills.22 Most of these releases are not 

generally considered as environmentally 

harmful as releases to air, however, because the mercury may be less mobile and 

less likely to reach surface waters and fish. 

However, in certain areas of the western 

U.S., mining runoff/erosion to sediments 

can be the primary source of mercury in 

fish in local waters. The 2004 TRI data 

indicate increases in reported releases 

from mining.23 For more details on the 

TRI, see Section I, Addressing Mercury 

Releases. As a result, EPA is placing a 

higher priority on efforts to understand 

the risk associated with mercury releases 

to land from mining and take appropriate 

action. 

II. Addressing Mercury Uses in Products and Processes 

Addressing uses of mercury in products 

and industrial processes is a component of 

preventing human exposure from mercury releases to air, water, and land. 

Historically, the largest U.S. uses of mercury were in batteries, chlor-alkali manufacturing, and paint.24 Mercury use has 

now been eliminated in most batteries and 

in paint. Today in the U.S. the largest 

industrial use of mercury continues to be 

in chlor-alkali manufacturing, while the 

dominant uses in products are in electrical 

and measuring devices.25 

Many states, tribes, and local governments 

have been leaders in reducing mercury 

use. States have passed legislation calling 

for restrictions, bans, and labeling of 

mercury-containing products, as well as the 

removal and collection of mercury containing devices from the waste stream. 

States and local governments continue to 

initiate their own use reduction and 

collection programs from schools, hospitals, and laboratories to encourage the 

proper disposal and recycling of mercury. 

EPA’s long-term goal is to reduce risks 

associated with mercury. EPA recognizes 

that to reduce the risk associated with 

mercury, the Agency must first understand 

what contributes to the risk and what the 

appropriate mechanisms of risk reduction 

might be. EPA will take action to identify 

exposed populations, minimize exposures 

through outreach efforts, and appropriately reduce anthropogenic releases. As 

part of its strategy, EPA will assess mercury 

sources of concern and will: focus on uses 

that would lead to risk, where cost-effective substitutes exist; promote reducing 

mercury in processes and products where 

benefits of such reductions would justify 

the costs, even where cost-effective substitutes do not exist; and work to identify 

and encourage development of alternatives to essential uses of mercury that lead 

to risk. EPA will also work with its federal 

partners to address risks associated with 
10 - EPA’s Roadmap for Mercury 

management and disposal of excess supplies 

of commodity-grade mercury in the U.S. 

EPA will explore both regulatory and 

voluntary programs looking at substitutes 

for mercury in products. The Agency will 

promote the procurement of non-mercury 

products by federal agencies. EPA is building a national database of information on 

mercury use in products. EPA will continue 

its successful voluntary partnerships, such as 

the Hospitals for a Healthy Environment 

program—its project with the health care 

industry to eliminate the use and purchase 

of mercury-containing medical devices and 

instruments.26 The Agency also will continue to work with the U.S. Chlorine 

Institute to monitor mercury use in the 

remaining mercury-cell chlor-alkali plants 

in the U.S. 

III. Managing Commodity-Grade Mercury Supplies 

Elemental mercury is used in many products and processes, and is sold as a commodity on the global market. In recent years, 

approximately one-half of the current 

world mercury supply has come from 

mercury mines in Spain, Algeria, and 

Kyrgyzstan. (The Spanish mine has recently 

ceased mining operations.) The other half 

comes from the recycling of mercury from 

discarded mercury-containing products and 

other wastes, mercury recovered as a 

byproduct from mining of gold and other 

metals, and mercury supplies from the 

closure of mercury-cell chlor-alkali plants.27 

As industry finds alternatives to uses of 

mercury, and as mercury-cell chlor-alkali 

plants phase out the use of mercury in 

their processes, EPA expects that there will 

be an excess supply of elemental commodity-grade mercury on the global market in 

the near future. As a result, there will be 

an increasing need for safe storage of 

excess mercury supplies. 

Many states and local governments are 

now encouraging public and private 

collection programs for both bulk elemental mercury and discarded mercurycontaining products. The Environmental 

Council of the States (ECOS) has indicated that states do not have the resources or desire to store surplus mercury, 

and are looking to the federal government to address this issue.28 

The issue of whether the federal government, states, or the private sector should 

take responsibility for storing commoditygrade mercury supplies is an important 

and complex policy decision. In 2006, 

EPA will work with other federal agencies 

to initiate a process with technical experts 

and interested parties to discuss options 

for addressing the expected mercury 

surplus. EPA continues to evaluate options for disposal of mercury supplies, 

and published a report in April 2005 on 

the technical and economic feasibility of 

selected land disposal technologies in a 

monofill.29 

IV. Communicating to the Public 

About Mercury Exposure Risks 

The Agency will increase its risk communication and outreach activities to help 

people avoid or reduce their exposure to 

mercury. In the U.S., the greatest mercury exposure to the general population 

is from eating fish and shellfish containing high levels of methylmercury. Fetuses, nursing infants, and young children 

are at greatest risk because of their 

developing nervous systems. The primary 

tool for reaching and educating affected 

populations has been through fish consumption advisories issued by states and 

tribes. In addition, in 2004, EPA and 
Executive Summary - 11 

FDA issued a joint fish consumption 

advisory for mercury that helps consumers 

understand the benefits of fish consumption, the risks of consumption to certain 

sub-populations, and mercury levels in 

certain fish.30 

Many consumers are not aware of potential indoor mercury risks in schools, 

homes, and the workplace. Misuse or 

accidental breakage of some products can 

create indoor air health risks and exposure 

to dangerous levels of mercury. 

The Agency will make it a priority to 

provide consumers with reliable risk 

information about mercury exposure so 

that they can make informed choices 

about the fish they eat and the products 

they use. EPA’s most recent effort has 

been the January 2005 launching of its 

consolidated website on mercury.

31 The 

Agency will develop informational materials; support and build upon existing state, 

tribal, and local outreach campaigns; and 

maintain its centralized mercury website 

with helpful information on all aspects of 

mercury. EPA will also conduct public 

awareness evaluations of the effectiveness 

of existing outreach campaigns. 

V. International Mercury Sources 

EPA has estimated that over three-quarters (83 percent) of the mercury deposited 

in the U.S. originates from international 

sources, with the remaining 17 percent 

coming from U.S. and Canadian sources. 

These figures include mercury from 

natural and re-emitted sources. This 

estimate is based on an advanced, state-ofthe-science modeling assessment of atmospheric fate, transport, and deposition of 

mercury. EPA’s air quality modeling 

indicates that a substantial variation in 

mercury deposition occurs across the U.S., 

with domestic sources influencing mercury 

deposition much more in the eastern U.S. 

and global sources being a more significant 

contributor to mercury deposition in the 

west, where relatively few domestic sources 

exist.32 The scientific community’s understanding of mercury atmospheric chemistry is evolving and there remain uncertainties regarding the simulation of mercury in 

atmospheric chemistry models. EPA 

continues to work to advance the state of 

the science on mercury chemistry and fate 

and transport modeling. A number of key 

international emission sources contribute 

to global cycling and deposition of mercury 

via air pathways, including: coal-fired 

combustion sources; mining and metals 

production, such as smelting; mercury-cell 

chlor-alkali manufacturing facilities; and 

combustion or incineration of waste 

products containing mercury.

33 

EPA is currently participating in a wide 

range of bilateral, regional, and international programs and agreements to address 

mercury releases and uses and the resulting 

exposure around the globe. At the twentythird session of the UNEP Governing 

Council, which was held in Nairobi, 

Kenya, February 21–25, 2005, delegates 

agreed to further develop the UNEP 

Mercury Program and to support the 

efforts of countries to take action to 

address global mercury pollution. Governments agreed to develop and implement 

partnerships with international organizations, non-governmental organizations, 

and the private sector to reduce the risks 

that result from the release of mercury to 

the environment. The partnerships 

created will leverage resources, technical 

expertise, technology transfer, and information exchanges to provide immediate, 

effective action that will result in tangible 

reductions of mercury use and emissions.34 
12 - EPA’s Roadmap for Mercury 

EPA is building on existing bilateral, 

multilateral, and international agreements. In addition, EPA will build collaborative partnerships under UNEP with 

industries and environmental groups to 

bring technical expertise and assistance to 

address the global mercury problem. EPA 

plans to work with its international 

partners to reduce risks associated with 

mercury emissions from large point 

sources such as coal-fired power plants, 

chlor-alkali facilities, and artisanal gold 

mining; to reduce mercury use in products 

internationally (including mercury-containing batteries) where there are costeffective opportunities to reduce risk; to 

increase risk communication; to address 

the issue of commodity-grade mercury on 

the international market; and to research 

global fate and transport of mercury. 

VI. Conducting Mercury Research and 

Monitoring 

In 2000, EPA’s Office of Research and 

Development (ORD) published its Mercury Research Strategy,

35 which outlined a 

strategic approach for the Agency’s mercury research program. The purpose of 

the Agency’s mercury research is to 

develop information that will reduce 

scientific uncertainties currently limiting 

the Agency’s ability to assess and manage 

risks posed by mercury and methylmercury. 

Research results support EPA’s air, water, 

waste, and toxics programs in their ongoing regulatory and non-regulatory efforts 

to address mercury. ORD will continue to 

pursue its long-term goals to reduce health 

risks associated with mercury and to better 

understand the transport and fate of 

mercury in the environment. The major 

near-term emphasis of the mercury 

research program will continue to be 

focused on science and technology related 

To access this document 

electronically and to

monitor the status of 

Roadmap activities visit 

www.epa.gov/mercury. 

to the control of coal-fired power plant 

mercury emissions. 

In addition to research, scientifically sound 

mercury monitoring programs are essential for assessing the effectiveness of 

current regulatory and voluntary programs and for tracking health and environmental trends. Much progress has 

been made in recent years by EPA and 

others to establish routine monitoring and 

reporting systems to collect data on 

mercury releases and contamination. EPA 

is continuing to track and report data on 

mercury in four areas: air emissions, 

ambient air, air deposition, and fish tissue. 

The Agency will utilize the Centers for 

Disease Control and Prevention (CDC) 

data on mercury in human blood and hair 

samples. EPA will also continue to work 

with others to monitor other mercury 

releases and ambient concentrations. The 

Agency plans to use various existing 

databases for tracking overall progress in 

reducing mercury exposure. In addition, 

EPA will continue to seek improvement in 

monitoring methods and databases for 

mercury. 
Executive Summary - 13 

ENDNOTES

1. EPA, 1999a. 1999 National Emissions Inventory Documentation and Data—Final Version 3.0. Accessible at: 

www.epa.gov/ttn/chief/net/1999inventory.html. 

2. EPA, 2005c. U.S. Environmental Protection Agency. National Listing of Fish Advisories. Fact Sheet, Sep. 2005. EPA-823-F-05-

004. Accessible at: http://epa.gov/waterscience/fish/advisories/fs2004.pdf. 

3. RIA, Regulatory Impact Analysis, Clean Air Mercury Rule. EPA, 2005. Accessible at: http://epa.gov/ttn/atw/utility/TSC- 112final.pdf. 

4. NRC, 2000. National Research Council. Toxicological Effects of Methylmercury. Committee on The Toxicological Effects of 

Methyl-mercury, Board on Environmental Studies and Toxicology. Accessible at: 

http://books.nap.edu/books/0309071402/html/1.html. 

5. EPA and FDA, 2004. What You Need to Know About Mercury in Fish and Shellfish. EPA-823-F-04-009. Accessible at: www.epa.gov/waterscience/fishadvice/advice.html. 

6. EPA, 2005a. Technical Support Document, Revision of December 2000 Regulatory Finding on the Emissions of Hazardous Air 

Pollutants From Electric Utility Steam Generating Units and the Removal of Coal- and Oil-Fired Electric Utility Steam Generating Units from the §112(c) List: Reconsideration, Oct. 21, 2005. Accessible at: www.epa.gov/ttn/atw/utility/TSC-112finaL.pdf. 

7. A Community Multiscale Air Quality (CMAQ) modeling run was performed to estimate the impact of global sources on U.S. 

deposition estimates. For this analysis, all non-U.S. mercury input species to the model were set to zero. By comparing the results 

of this analysis with the 2001 Clean Air Mercury Rule (CAMR) base case run, which included all U.S. and global mercury species, 

the percent of total mercury deposition attributable to global sources can be estimated. The model estimated that over 80 percent 

of total mercury deposition in the U.S. is attributable to global sources. 

Due to the evolving nature of mercury modeling science, such deposition estimates have associated uncertainties. For example, it 

remains difficult to distinguish between the natural emissions of mercury and the re-emission of previously deposited anthropogenic mercury and there remains uncertainty in the scientific community concerning the atmospheric processes that control the 

oxidation state of atmospheric mercury. Thus, further advances in the current understanding of mercury chemistry could 

potentially lead to changes in the modeling parameters and assumptions governing the mercury chemistry in the models and 

therefore, changes in the estimate of the fraction deposited in the U.S. attributable to global sources. 

8. EPA, 1999a. U.S. Environmental Protection Agency. 1999 National Emissions Inventory Documentation and Data—Final Version 

3.0. Accessible at: www.epa.gov/ttn/chief/net/1999inventory.html. 

9. Jasinski, S.M. 1994. The Materials Flow of Mercury in the United States. U.S. Bureau of Mines, Information Circular 9412. 

Accessible at: http://pubs.usgs.gov/usbmic/ic-9412/. 

10. EPA, 1999a, and UNEP 2002. United Nations Environment Programme. Global Mercury Assessment. Accessible at: 

www.chem.unep.ch/mercury/report/GMA-report-TOC.htm. 

11. CDC, 2005. Centers for Disease Control. Mercury, pp. 45-51 in Third National Report on Human Exposure to Environmental 

Chemicals. Accessible at: www.cdc.gov/exposurereport/3rd/downloads.htm. 

12. NRC, 2000. National Research Council. Toxicological Effects of Methylmercury. Committee on The Toxicological Effects of 

Methyl-mercury, Board on Environmental Studies and Toxicology. Accessible at: 

http://books.nap.edu/books/0309071402/html/1.html. 

EPA, 2001a. Reference Dose for Chronic Oral Exposure (RfD)—Methylmercury, last revised 7/21/01. Integrated Risk Information 

System (IRIS). Accessible at: www.epa.gov/iris/subst/0073.htm#reforal. 

13. FDA. U.S. Food and Drug Administration. Mercury in Fish: FDA Monitoring Program. For information, see: 

www.cfsan.fda.gov/~frf/seamehg2.html. 

14. EPA, 2005a. Technical Support Document, Revision of December 2000 Regulatory Finding on the Emissions of Hazardous Air 

Pollutants From Electric Utility Steam Generating Units and the Removal of Coal- and Oil-Fired Electric Utility Steam Generating Units from the §112(c) List: Reconsideration, Oct. 21, 2005. Accessible at: www.epa.gov/ttn/atw/utility/TSC-112final.pdf. 

15. EPA, 1997. Mercury Study Report to Congress. EPA-452/R-97-003, December 1997. Accessible at: 

www.epa.gov/ttn/oarpg/t3/reports/volume1/pdf. 

16. EPA, 1998. Study of hazardous air pollutant emissions from electric utility steam generating units—Final Report to Congress. EPA453/R-98-004a&b, February 1998. 
14 - EPA’s Roadmap for Mercury 

17. EPA. Area Source Standards. For information, see: www.epa.gov/ttn/atw/urban/arearules.html. 

18. EPA. Residual Risk Program. For information, see: www.epa.gov/ttn/atw/rrisk/residriskpg.html. 

19. EPA, 1997. 

20. LWA, 2002. Larry Walker Associates. Mercury Source Control and Pollution Prevention Evaluation, Final Report, March 2002, 

amended July 2002. Prepared for: Association of Metropolitan Sewerage Agencies. Accessible at: 

www.amsa-cleanwater.org/advocacy/mercgrant/finalreport.pdf. 

21. EPA, 2005b. 2003 Toxics Release Inventory (TRI) Public Data Release eReport, May 2005. Accessible at: www.epa.gov/tri/tridata/tri03/2003eReport.pdf. 

22. EPA, 2005b. 

23. EPA, 2005b. 

24. Jasinski, S.M., 1994. The Materials Flow of Mercury in the United States. U.S. Bureau of Mines, Information Circular 9412. 

Accessible at: http://pubs.usgs.gov/usbmic/ic-9412/. 

25. Lawrence, Bruce, 2001. Bethlehem Apparatus Company, Inc. Personal communication, June 22, 2001. 

26. H2E. Hospitals for a Healthy Environment. For information, see: www.h2e-online.org/. 

27. Maxson, P.A., 2004. Mercury Flows Report: Mercury Flows in Europe and the World, The Impact of Decommissioned Chloralkali Plants. European Commission. Accessible at: 

http://europa.eu.int/comm/environment/chemicals/mercury/pdf/report.pdf. 

28. Quicksilver Caucus, 2003. Mercury Stewardship Storage of Mercury, Review Draft, February, 2003. Accessible at: 

www.sso.org/ecos/Quick%20silver%20documents/RD%20QSC-STOR%20Mar-03.pdf. 

29. EPA, 2005f. Economic and Environmental Analysis of Technologies to Treat Mercury and Dispose in a Waste Containment 

Facility. See: www.epa.gov/ORD/NRMRL/pubs/600r05157/600r05157.pdf. 

30. EPA and FDA, 2004. What You Need to Know About Mercury in Fish and Shellfish. EPA-823-F-04-009. Accessible at: www.epa.gov/waterscience/fishadvice/advice.html. 

31. EPA. Mercury Web site. For information, see: www.epa.gov/mercury/. 

32. EPA, 2005a. 

33. UNEP, 2002. United Nations Environment Programme. Global Mercury Assessment. Accessible at: 

www.chem.unep.ch/mercury/Report/GMA-report-TOC.htm. 

34. UNEP, 2005. Results of the Governing Council’s discussions on chemicals management, including mercury programme, at its 

23rd session in February, 2005. Accessible at: www.chem.unep.ch/mercury/GC23-results.htm. 

35. EPA, 2000. Mercury Research Strategy. EPA-600-R-00-073. Accessible at: http://cfpub.epa.gov/ncea/cfm/recordisplay.cfm?deid=20853. 
Introduction - 15 

EPA’S ROADMAP FOR MERCURY:

Introduction

MMercury is a naturally occurring 

element. It enters the environment as a result of natural 

sources (such as volcanoes) and human 

activities (such as industrial combustion 

and mining). Mercury is widespread in the 

U.S. and global environment. Human 

activities have increased the amount of 

mercury that is available in the atmosphere; in soils and sediments; and in lakes, 

streams, and oceans. 

While elemental mercury is toxic to 

humans when it is ingested or inhaled, 

EPA is most concerned about methylmercury, as it is a potent form of mercury 

and it is the form to which humans 

primarily are exposed. Methylmercury can 

be formed from other deposited mercury 

by microbial action in sediment and soils. 

Once formed, methylmercury can be 

taken up by aquatic organisms and 

bioaccumulates up the aquatic food web. 

While all forms of mercury can 

bioaccumulate, methylmercury generally 

accumulates to a greater extent than other 

forms of mercury. 

Methylmercury accumulates in fish tissue, 

which may then be consumed by people 

and wildlife. Mercury concentrations in 

fish vary widely. Fish that are higher in 

the food chain—such as king mackerel, 

swordfish, tilefish, and shark—have much 

higher methylmercury concentrations 

than fish that are lower on the food chain. 

The majority of fish species consumed in 

the U.S. are ocean species and the methylmercury concentrations in these species 

are primarily influenced by the global 

mercury pool. 

Local freshwater fish also contain methylmercury. States monitor their waters by 

sampling fish tissue for persistent pollutants that bioaccumulate. States issue their 

advisories and guidelines voluntarily and 

have flexibility in what criteria they use 

and how the data are collected. As a result, 

there are significant variations in the 

number of waters tested, the pollutants 

tested for, and the threshold for issuing 

advisories.Based on self-reporting, the 

national trend is for states to monitor 

different waters each year, generally 

without retesting waters monitored in 
16 - EPA’s Roadmap for Mercury 

FIGURE 1. The Mercury Cycle4 

previous years.1 Forty-four states, one 

territory, and two Indian tribes have 

issued fish consumption advisories recommending that some people limit their 

consumption of fish from certain water 

bodies as a result of methylmercury found 

in fish.2 Human-caused mercury emissions 

have dropped 45 percent in this country 

since 1990.3 EPA has not monitored 

natural mercury emissions in this country, 

which may also have changed over the 

same period. 

Mercury Sources 

The primary sources of mercury releases 

to air, water, soils, and sediments can be 

grouped into four categories: 

1. New releases from naturally-occurring 

sources (such as volcanic activity and 

weathering of rocks) 

2. Re-releases of historic mercury previously deposited through natural and 

anthropogenic processes in soils, 

sediments, water bodies, landfills, and 

waste tailings/piles (also called “reemitted sources”) 

3. New releases of mercury impurities 

from combustion of fossil fuels, and 

from smelting of metals such as gold 

and zinc 

4. New releases resulting from uses of 

mercury in products and manufacturing processes such as chlor-alkali 

manufacturing 

Human Health Effects 

Mercury exposure effects can vary depending on the form of mercury to which a 

person is exposed and the level and length 

of exposure. The primary way humans are 

exposed to methylmercury is through 
Introduction - 17 

eating fish containing methylmercury. 

Research shows that most people’s fish 

consumption does not cause a health 

concern. However, elevated methylmercury in the bloodstream of unborn babies 

and young children may harm the developing nervous system, impairing the 

child’s ability to learn and process information. There is some evidence that 

exposures to methylmercury may result in 

genotoxic or immunotoxic effects. Other 

research suggests that reproductive, renal, 

cardiovascular, and hematologic impacts 

may be of concern. However, additional 

studies are needed to better characterize 

the effect of methylmercury on these 

endpoints.5 

While the primary way humans are 

exposed to methylmercury is through 

eating fish containing methylmercury, 

individuals may also become exposed to 

harmful levels of elemental mercury vapor 

in homes and workplaces. When exposed 

to air, elemental mercury vaporizes and 

can be inhaled. Exposures from improper 

handling of mercury in schools, laboratories, and manufacturing plants; from 

accidental mercury spills; or in cultural 

and ritualistic uses can result in severe 

effects. Very small amounts of elemental 

mercury (even a few drops) can raise 

indoor air concentrations of mercury to 

harmful levels. The longer people breathe 

the contaminated air, the greater the risk 

to their health. At high exposures elemental mercury vapors can produce severe 

lung, gastrointestinal, and nervous system 

damage. The number of individuals 

exposed in this way in the U.S. is very 

small. 

Ecological Effects 

Birds and mammals that eat fish and their 

predators are at risk for greater exposure 

to methylmercury than other animals. 

Methylmercury has been found in eagles, 

otters, and endangered Florida panthers. 

The 1997 Mercury Study Report to Congress 

provides some data that suggest some 

highly-exposed wildlife species are affected 

by methylmercury.

6

 Depending on the 

level of exposure, effects of methylmercury 

exposure on wildlife can include mortality, 

reduced fertility, slower growth and 

development, and abnormal behavior that 

affects survival.7 

Reducing mercury releases to the air is 

important because airborne mercury can 

travel short and long distances; be deposited on land and water resources locally, 

nationally, regionally, and globally; and 

lead to elevated methylmercury levels in 

fish. EPA estimates that since the beginning of the industrialized period, total 

global atmospheric mercury burden has 

increased by a factor of between two and 

five.8 Figure 1 illustrates the physical cycle 

of airborne mercury from natural and 

anthropogenic sources as it is deposited to 

land and water and re-released. 

U.S. mercury deposition is from domestic 

man-made sources and from global 

sources, including natural, re-emitted, and 

international man-made sources. EPA has 

estimated that over three-quarters (83 

percent) of the mercury deposited in the 

U.S. originates from international sources, 

with the remaining 17 percent coming 

from U.S. and Canadian sources.9 These 

figures include mercury from natural and 

re-emitted sources. This estimate is based 

on an advanced, state-of-the-science modeling assessment of atmos-pheric fate, 

transport, and deposition of mercury. Air 

emissions of mercury from combustion 

and industrial processes are the largest 

contributor to U.S. emissions. EPA’s air 

quality modeling indicates that a substantial variation in mercury deposition occurs 
18 - EPA’s Roadmap for Mercury 

across the U.S., with domestic sources 

influencing mercury deposition much 

more in the eastern U.S. and global 

sources being a more significant contributor to mercury deposition in the west, 

where relatively few domestic sources exist. 

The scientific community’s understanding 

of mercury atmospheric chemistry is 

evolving and there remain uncertainties 

regarding the simulation of mercury in 

atmospheric chemistry models. EPA 

continues to work to advance the state of 

the science on mercury chemistry and fate 

and transport modeling.10 

Reducing Mercury Exposure 

To further reduce risks associated with 

mercury, EPA’s priority activities focus on 

six key areas: 

1. Addressing mercury releases to the 

environment 

2. Addressing mercury uses in products 

and processes 

3. Managing commodity-grade mercury 

supplies 

4. Communicating risks to the public 

5. Addressing international mercury 

sources 

6. Conducting mercury research and 

monitoring 

EPA will continue to pursue regulatory and 

voluntary actions that will reduce risks 

associated with mercury. EPA’s long-term 

goal is to reduce risks associated with 

mercury. EPA recognizes that to reduce 

the risks associated with mercury, the 

Agency must first understand what contributes to the risk and what the appropriate mechanisms of risk reduction might 

be. EPA will take action to identify exposed populations, minimize exposures 

through outreach efforts, and appropriately reduce anthropogenic releases. As 

part of its strategy, EPA will assess mercury 

sources of concern and will: focus on uses 

that would lead to risk, where cost-effective substitutes exist; promote reducing 

mercury in processes and products where 

benefits of such reductions would justify 

the cost, even where cost-effective substitutes do not exist; and work to identify 

and encourage development of alternatives to essential uses of mercury that lead 

to risk. EPA will also work with its federal 

partners to address risks associated with 

management and disposal of excess 

supplies of commodity-grade mercury in 

the U.S. In addition, EPA will support the 

efforts of other countries to take action to 

address risks associated with global mercury pollution by developing and implementing partnerships with international 

organizations, non-governmental organizations, and the private sector. As we work 

on these short and long-term plans, EPA 

will continue to work with federal partners to continue to educate the public 

about the risks of exposure from dietary 

and non-dietary sources. 

State, Tribal, Local, and International 

Government Collaboration with EPA 

In order to achieve reductions risks from 

mercury exposure, EPA will continue to 

collaborate with its state, tribal, and local 

government partners. As co-regulators 

with EPA, states have been actively engaged in a range of programs and partnerships to reduce mercury uses, releases, and 

exposure and to conduct mercury monitoring activities. In many cases, states and 

local governments have been leaders in 

mercury reduction efforts. EPA will build 

on these efforts and, where appropriate, 
Introduction - 19 

help state and local governments replicate 

successful efforts. 

In May of 2001, a coalition of state government environmental association leaders 

formed the Quick-silver Caucus (QSC) in 

order to provide a forum for states to 

work together, and with EPA, to develop 

collaborative holistic approaches for 

reducing mercury in the environment. In 

addition, the Environmental Council of 

the States (ECOS), an association of state 

environmental agency leaders, has passed 

a number of resolutions over the past 

several years that address mercury issues, 

many of which are also addressed in the 

Roadmap. EPA and states are continuing to 

work together on mercury issues under a 

cooperative agreement with ECOS. 

EPA is also working with tribes to develop 

new activities that will help the Agency 

make progress toward attainment of EPA’s 

long-term goals of “fishable waters” and 

“edible fish.” Tribal community members 

who follow traditional diets and lifestyles 

may face greater risk from locally-caught 

fish than do members of the general 

population due to the prevalence of 

locally-caught fish and shellfish in their 

diets. EPA will work with tribes to improve 

the quality of water and sediments in 

order to improve fish tissue concentrations in tribal waters. 

EPA will also continue to collaborate with 

other federal agencies involved in domestic and international mercury issues, 

including the U.S. Food and Drug Administration; the Centers for Disease Control 

and Prevention; and the Departments of 

Energy, Defense, and State. 

In addition, partnering with the international community is of great importance 

to furthering global mercury reductions. 

The majority of fish species consumed in 

the U.S. are ocean species and the methylmercury concentrations in these species 

are primarily influenced by global mercury 

contributions.11 Also, even domestic 

freshwater and estuarine fish in many 

parts of the U.S. may contain methylmercury as a result of contributions from 

international sources in addition to domestic sources. 
20 - EPA’s Roadmap for Mercury 
I. Addressing Mercury Releases - 21 

I. ADDRESSING

MERCURY RELEASES

OVERVIEW 

Significant progress has been made to date 

to reduce industrial emissions of mercury 

in the U.S., as well as to reduce or eliminate the amount of mercury used in 

various processes and products. Most of 

the large industrial sources of mercury 

emissions are sites where mercury is 

emitted as a byproduct of combustion 

processes. Other major sources of mercury 

include industrial processes and products 

that use mercury deliberately, such as 

certain chlor-alkali chlorine manufacturing processes, batteries, lamps, and measuring devices such as thermometers. 

Mercury is also released through mining 

practices, sewage discharge, and metal 

refining operations. When mercury is 

used in a product, most releases occur 

during manufacturing or disposal. In the 

U.S., there are over 100 manufacturing 

processes that use some form of mercury.

1 

In the last 15 years, EPA focused most of 

its mercury reduction efforts on large 

point sources of air emissions such as 

municipal waste combustors, medical 

waste incinerators, hazardous waste combustors, and more recently, industrial 

boilers and chlor-alkali facilities. With the 

March 2005 completion of EPA final 

regulations for coal-fired power plants, the 

Agency now has standards in place limiting mercury air releases from most major 

known industrial sources in the U.S. 

In the next 10 years, in addition to implementing the regulatory standards in place, 

the Agency’s efforts to reduce mercury 

pollution will focus on three areas in 

particular: smaller sources and industrial 

uses that collectively contributed over 20 

percent of the nation’s mercury air releases in 1999;2

 understanding and addressing mining releases that in some 

areas of the 

western U.S. are 

the major 

sources of 

mercury pollution to water 

and land; and 

international 

emissions which 

continue to 
22 - EPA’s Roadmap for Mercury 

contribute to the mercury deposited in the address mercury use and emissions abroad 

U.S. EPA’s strategy for addressing these as discussed further in Section V on 

three areas will include, where applicable, international mercury efforts. (Note: The 

a combination of regulatory and voluntary Roadmap generally uses metric tons when 

approaches to reduce mercury releases to discussing global mercury use and emisair, land, and water, coupled with efforts to sions. However, U.S. air emissions are 

address the use of mercury in products and reported in English tons. One English ton 

processes. As the U.S. continues to address is equivalent to 0.9070 metric tons.) 

domestic mercury use and releases, it will 

also promote international efforts to Releases to Air 

Sources. When the 1990 

Clean Air Act Amendments 

TABLE 1. National Air Emissions Estimates for Mercury3 passed, more than half of U.S. 

mercury air emissions came 

Source Category 1990 (tons) 1999 (tons)f % reduction from just three source categories: coal-fired power plants, 

Utility Coal Boilersb 51.1 47.9a 6% municipal solid waste combustors, and medical waste 

Industrial Boilersb 12.0 12.0 0% incinerators. The major air 

emissions source categories 

Medical Waste Incinerators 49.7 1.6 97% are shown in Table 1. 

Municipal Waste Combustion 56.7 4.9 91%	 Progress to date. EPA’s Clean 

Air Rules. Medical waste 

Hazardous Waste Incineratorsb 6.6 6.6 0%	 incinerators and municipal 

Chlorine Production 10.0 6.5 30% 

Electric Arc Furnacesc 6.9 NA NA 

Gold Mining 3.4d 11.5 NA 

Othere 23.5 21.6 6% 

Total 	 219.9 112.6 45% 

a1990 estimate derived using a different methodology. bRegulations for these categories finalized after 1999. 

c

Electric Arc Furnaces data not available for 1999. The 2002 estimate is 

 10 tons per year. dThe 1990 emissions estimate is a preliminary estimate and is based on back 

calculations and assumptions using data from 1999 along with information 

about types of processes, production rates, and ores used in 1990 

compared to 1999. 

eOther includes, but is not limited to such items as, Portland cement production

 –2.36 tons per year (tpy), pulp and paper production–1.69 tpy, and over 219

 miscellaneous industrial processes.

f

1 ton equals 0.9070 metric ton. 

solid waste combustors are 

now subject to stringent 

control standards that require 

facilities to reduce mercury 

emissions by over 90 percent 

from 1990 levels. These 

efforts have contributed to 

reducing overall mercury 

emissions to the air by about 

45 percent (from 220 tons in 

1990 to 113 tons in 1999—see 

Figure 2). 

EPA’s recently promulgated 

Clean Air Mercury Rule 

(CAMR) is part of a suite of 

regulatory actions that will 

dramatically improve 

America’s air quality. CAMR 

directly regulates mercury 

emissions from coal-fired 
power plants. Among other things, 

CAMR requires compliance with a twophase nationwide cap on mercury emissions. The first phase cap (effective in 

2010) is 38 tons per year (“tpy”), and the 

second phase cap (effective in 2018) is 15 

tpy. Once fully implemented, CAMR will 

result in about a 70 percent reduction in 

mercury emissions from domestic coalfired power plants, which is a reduction 

from a 1999 baseline of 48 tons.4 

In addition to CAMR, the Agency recently issued another rule called the Clean 

Air Interstate Rule (CAIR) that addresses 

the transport of pollution across state 

borders in the eastern U.S. CAIR will 

result in the deepest cuts in sulfur dioxide 

and nitrogen oxide emissions in more 

than a decade. Although affected States 

retain flexibility to decide how to achieve 

the sulfur dioxide and nitrogen oxide 

emissions reductions required by CAIR, 

EPA has concluded that obtaining the 

reductions from power plants is highly 

cost-effective. EPA therefore anticipates 

that affected States will meet their emission reduction obligations by controlling 

power plant emissions through the twophase cap-and-trade approach provided in 

the final CAIR, the first phase of which 

occurs in 2010 and the second in 2015. 

EPA also concluded that the technologies 

that most cost-effectively achieve sulfur 

dioxide and nitrogen oxide emission 

reductions for power plants are scrubbers 

for sulfur dioxide and selective catalytic 

reduction for nitrogen oxide. These 

technologies, once implemented, not only 

reduce sulfur dioxide and nitrogen oxide, 

they provide important reductions of 

mercury emissions from coal-fired power 

plants. Thus, CAIR and CAMR work 

together and provide a flexible multipollutant approach for reducing sulfur 

dioxide, nitrogen oxide, and mercury 

I. Addressing Mercury Releases - 23 

What is EPA’s National Emissions Inventory 

(NEI)? 

Section 112 of the 1990 amendments to the 

Clean Air Act (CAA) presents a list of 

Hazardous Air Pollutants (HAPs), also called 

air toxics, which includes mercury and 

mercury compounds. In 1993, EPA began 

developing the National Toxics Inventory (NTI). 

This database has been expanded and is now 

called the National Emissions Inventory (NEI). 

The NEI is a national repository of emissions 

inventory data for HAPs. The emissions data 

and estimates cover major, area, and mobile 

sources, and include estimates of emissions 

at the national, regional, county, and facilityspecific levels. 

The 1999 NEI generally serves as the national 

baseline inventory for this Roadmap because it 

includes HAP emission data supplied by 36 

states in addition to data gathered while 

developing Maximum Achievable Control 

Technology (MACT) standards and Toxics 

Release Inventory (TRI) data. More information 

on the NEI, including summary data and 

documentation, can be obtained at 

http://www.epa.gov/ttn/chief/index.html. 

emissions from power plants. From a 

legislative perspective, the President’s 

proposed Clear Skies legislation, if enacted, would require a mandatory 70 

percent annual cut in power plant pollution (NOx, SOx and mercury) when fully 

implemented.5 

In addition, §112 (f) of the Clean Air Act 

(CAA) required EPA to complete a Report 

to Congress that includes a discussion of 

methods EPA would use to evaluate the 

risk remaining after the application of 

Maximum Achievable Control Technology 

(MACT) standards. These are known as 

residual risks. EPA published the Residual 

Risk Report to Congress in March 1999.6 

The Agency continues to evaluate the 

remaining residual risks, if any, for a 
Tons per 

Year (TPY)

24 - EPA’s Roadmap for Mercury 

FIGURE 2. Air Emissions Data for Mercury 

a

Fifteen tons per year will be acheived when full implementation of the Clean Air Mercury Rule is achieved, 

which may exceed 2020. 

b

Growth in this sector is being offset by regulation. 

c

Electric Arc Furnaces data not available for 1999. The 2002 estimate is 10 tons per year. d

The 1990 emissions estimate is a preliminary estimate and is based on back calculations and

 assumptions using data from 1999 along with information about types of processes, production 

rates, and ores used in 1990 compared to 1999. 

e

These projected emissions do not account for reductions from non-regulatory actions described

 elsewhere in the Roadmap. 

f

1 ton equals 0.9070 metric ton 

Projected by 2020 

1999 

1990 

51.1 

12.0 

49.7 

56.7 

6.6 

10.0 

6.9 

23.5 

47.9 

12.0 

1.6 

4.9 6.6 6.5 

11.5 

21.6 15.0 

12.0 

0.2 2.7 3.8 5.0 

2.4 

26.7 

0 

10 

20 

30 

40 

50 

60 

Utility Coal 

Boilers Industrial 

Boilersb Medical 

Waste 

Incineration 

Municipal 

Waste 

Combustion 

Hazardous 

Waste 

Incineration 

Chlorine 

Production Gold 

Miningd Othere 

3.4 

Electric 

Arc 

Furnacesc 

f 

(except utility coal boilers)a 

number of source categories for which 

EPA has issued MACT standards. In the 

context of that review, EPA will evaluate 

the hazardous air pollutants (HAPs) 

emitted by each source category, including 

mercury. 

Regional initiatives have also resulted in 

substantial reductions in air emissions of 

mercury. For example, EPA’s Region 9 

office and the State of Nevada entered 

into an innovative collaboration with four 

of the largest gold mining companies in 

Nevada to reduce mercury emissions 

associated with gold mining.7 The Voluntary Mercury Emission Reduction Program set a goal to reduce mercury emissions by 50 percent by 2005, and has 

already surpassed this goal. In 2004, the 

program participants reported a 75 
I. Addressing Mercury Releases - 25 

percent reduction from the baseline year. 

This is a reduction of 15,702 pounds of 

mercury from the baseline emissions of 

21,098 pounds.8 

Future focus. The Integrated Urban Air 

Toxics Strategy, which was published in 

the Federal Register in 19999, is an important element in EPA’s national air toxics 

program. The strategy outlines actions to 

reduce emissions of air toxics, as well as 

assessment activities to improve EPA’s 

understanding of the health and environmental risks posed by air toxics in urban 

areas. One major component of the 

Urban Air Toxics Strategy is the Area 

Source Program.10 Area sources are 

smaller sources that can cumulatively emit 

significant amounts of hazardous air 

pollutants. 

The 1999 Strategy identifies 33 hazardous 

air pollutants, including mercury, that 

EPA determined posed the greatest threat 

to public health in the largest number of 

urban areas. The Strategy further identifies 30 of those 33 HAP as being emitted 

by area sources. Finally, the Strategy 

identifies the 70 categories of industry 

sectors (i.e., source categories) that represent 90 percent of the aggregate emissions 

of the 30 identified HAP emitted by area 

sources. To date, EPA has issued standards 

for 16 of the 70 source categories and is 

currently collecting data and information 

for many other source categories. 

Electric Arc Furnaces (EAFs)—one of the 

area source categories that the Agency is 

currently evaluating—emitted about 10 

tons of mercury in 2002.11 In EAFs, 

mercury is emitted through the stack 

when ferrous scrap containing mercury 

switches and other materials contaminated with mercury are melted. Many of 

these mercury-containing switches are 

found in scrap automobiles—over 200 

million of these switches were installed in 

vehicles from 1974 to 2002. Although 

mercury switches were eliminated from 

new vehicles at the end of 2002, mercury 

switches will remain in the steel scrap 

supply for the next 10 to 15 years. The 

steel industry recycles about 12 to 14 

million end-of-life vehicles each year, and 

vehicles retired in 2003 had 8.5 million 

mercury-containing switches.12 The EPA air 

toxics program has identified EAFs as a 

priority sector and currently intends to 

propose emissions standards for that 

source category in 2006. 

Releases to Water 

Sources. The majority of mercury in 

surface waters from human activity in the 

U.S. is the result of air deposition, both 

from international and domestic sources. 

Mercury in surface waters can also occur 

naturally. Mercury can be released directly 

to surface waters from municipal sewage 

treatment plants, also called PubliclyOwned Treatment Works (POTWs), and 

non-municipal facilities (e.g., industrial and 

federal facilities). Point source discharges of 

pollutants to surface waters are required to 

have National Pollutant Discharge Elimination System (NPDES) permits.13 On a 

national basis, these mercury discharges to 

surface waters are significantly smaller 

than nationwide inputs to water from air 

deposition. In some areas, particularly in 

the western states, mercury resulting from 

past mining practices (specifically mercury, 

silver, and gold mining) are significant 

sources of contamination to water bodies.14 

EPA’s Toxics Release Inventory (TRI) 

provides information on mercury releases 

to land, air, and water. (See box on page 

27). Based on the EPA TRI data, total 

quantities of mercury discharged to surface 

waters have declined steadily from 2000 to 
26 - EPA’s Roadmap for Mercury 

2004.15 From 2000 to 2001 the decline was standards) due to mercury contamination 

over 25 percent; from 2001 to 2002 nearly and will require mercury TMDLs,20 and 

32 percent; from 2002 to 2003 4 percent; 44 states, 1 territory, and 2 tribes have 

from 2003 to 2004 nearly 59 percent and fish consumption advisories due to merfrom 2000 to 2004 nearly 38 percent. TRI cury contamination.21 States and EPA 

data for 2004 indicate that surface water have been discussing how to best address 

releases of mercury totaled approximately mercury in their water bodies, since 

694 pounds (0.31 metric tons). An addi- mercury can travel from sources out-oftional 219 pounds (0.10 metric tons) per state and from international sources and 

year of mercury effluent is estimated from be deposited on local waters. Developing 

POTWs.16 TMDLs that identify reductions from local 

sources alone is unlikely to result in 

Clean Water Act requirements. Under attainment of water quality standards in 

the Clean Water Act, states and authorized many water bodies. 

tribes must have water quality standards in 

place that define the designated uses and Progress to date. Because past analytical 

acceptable levels of pollutants for each methods could not detect mercury at the 

water body under their jurisdiction. For level of current water quality standards in 

mercury, EPA has published a national many effluents, there are limited data on 

methylmercury ambient water quality low-level mercury discharges to water from 

criterion for protection of human health. point sources. To address the critical data 

This is a fish tissue concentration of 0.3 gap, EPA recently developed a new more 

parts per million of methylmercury, based sensitive analytical method for use in 

on EPA’s 2001 Reference Dose (RfD) for water discharge permits.22 As NPDES 

methylmercury and consumption rates.17 permits are reissued, they should require 

EPA’s RfD is an estimate, with uncertainty use of this more sensitive method where 

spanning perhaps an order of magnitude, appropriate. Requiring use of this analytiof a daily oral exposure to the human cal method will improve EPA’s underpopulation (including sensitive groups) that standing of the significance of point 

is likely to be without an appreciable risk source mercury contributions to surface 

of deleterious effects during a lifetime.18 waters, and will provide necessary data for 

EPA and states to determine whether 

When pollutant levels exceed water quality surface water discharge permits need to 

standards, state water quality program include mercury effluent limits. 

managers must take action to reduce 

pollutant loadings. An initial step in this As noted earlier, the states, tribes, and 

process is the development of a TMDL for EPA’s air and water programs are working 

a water body. The TMDL is the maximum together on how to address mercury 

daily amount of a pollutant that can enter pollution in TMDLs and water permitting 

a water body and still ensure that the programs, particularly mercury from air 

water meets applicable water quality sources. To date, mercury TMDLs have 

standards. TMDLs also allocate the allow- been developed for over 250 water bodies 

able pollutant loads between the point and in 19 states.23 Many of these TMDLs 

non-point sources of a pollutant.19 Over identify needed reductions in air deposi8,000 individual water bodies are identi- tion of mercury. TMDLs such as those in 

fied as impaired (not meeting water quality Georgia and California also incorporate 
mercury characterization and minimization provisions for water discharge 

(NPDES) permit holders. To assist states in 

developing mercury TMDLs, EPA has 

conducted two pilot projects in cooperation with Florida and Wisconsin to examine approaches that could be used in 

developing TMDLs for water bodies 

impaired by atmospheric mercury. 

Within the Great Lakes basin, the states 

have adopted water quality standards to 

implement the Water Quality Guidance 

for the Great Lakes System, including a 

mercury criterion of 1.3 nanograms per 

liter (ng/l), based on protection of fisheating wildlife.24 Initial results in POTW 

effluent using the low level analytical 

method have averaged around 4 ng/l, and 

it is expected that most POTWs will not 

meet this criterion.25 As a result, EPA 

expects the states in the Great Lakes 

region (EPA Regions 2, 3 and 5) will be 

utilizing statewide or individual variances 

from applicable water quality standards, 

which will involve setting mercury limits 

in NPDES permits based on a lowest 

technically achievable concentration, and 

requiring the POTW to implement a 

Pollutant Minimization Program (PMP) to 

address mercury-contributing sectors 

within its system. Region 5 has developed 

a PMP guidance document to promote a 

consistent approach to PMPs throughout 

its states. 

EPA has provided sophisticated air modeling results to states to better identify the 

mercury contributions to water bodies 

from different air sources and geographic 

areas. The Agency has developed analytical tools that can be used to estimate the 

impact of air emission and deposition 

reductions on freshwater fish tissue concentration. These tools relate changes in 

mercury air emission and deposition rates 

I. Addressing Mercury Releases - 27 

EPA’s Toxics Release Inventory (TRI) 

In 1986, the U.S. Congress enacted the Emergency Planning 

and Community Right-to-Know Act (EPCRA) and in 1990 

passed the Pollution Prevention Act (PPA). Section 313 of 

EPCRA and §6607 of PPA require certain industrial facilities to 

submit reports each year on the amounts of toxic chemicals 

released or otherwise managed as waste. Amounts released 

are reported separately for air, land, water, and offsite disposal. 

The reported information is compiled and presented annually as 

the Toxics Release Inventory (TRI). 

In 1998, several new industry sectors were required to file 

reports for the first time. The new sectors included metal 

mining, electric utilties and hazardous waste treatment 

facilities. These new TRI reports have improved EPA’s 

understanding of releases of mercury and mercury compounds. 

In 2000, the TRI program reduced the use threshold that 

triggers mercury reporting from 10,000 pounds to 10 pounds. 

As a result, small users of mercury and mercury compounds 

are now required to report. TRI information and mapping 

capability can be publicly accessed at www.epa.gov/triexplorer. 

In this document, “TRI releases” refer to quantities of mercuryor mercury compound-bearing wastes that are released into the 

environment or otherwise disposed, and include, but are not 

limited to, releases to air, water and land, and to landfills, 

surface impoundments and underground injection. Even though 

disposals may be subject to regulatory and permitting 

requirements, disposal of mercury in waste to landfills, surface 

impoundments and underground injection is termed a “release” 

under TRI. 

to changes in mercury fish tissue concentrations.26 By using such methods during 

the development of a TMDL, states may 

be able to determine how much of a 

reduction in air deposition is needed in 

order to meet water quality standards, and 

whether other actions in addition to 

anticipated air deposition reductions will 

lead to achievement of the water quality 

standard. 

The Clean Water Act directs EPA to 

develop national technology-based regulations placing limits on the pollutants that 

are discharged by categories of industry to 

surface waters (termed “effluent guide-
28 - EPA’s Roadmap for Mercury 

lines”) or to POTWs (termed “pretreatment standards”). Pretreatment standards 

ensure that pollutants do not pass through 

or interfere with the safe and effective 

operation of these POTWs. CWA §307(b) 

requires that EPA revise or establish 

pretreatment standards from time to time, 

as control technologies, processes, operating methods, or other alternatives 

change.27 As part of its pretreatment 

standards review process, EPA is reviewing 

industrial sources of mercury for potential 

technology-based options for controlling 

mercury discharges to POTWs. In addition, POTWs are beginning to implement 

best management practices for collecting 

mercury from other industrial sources. 

Many states have initiated efforts to reduce 

mercury in wastewater by focusing on the 

dental sector. Mercury in dental wastewater can be removed by relatively inexpensive amalgam separators and/or by using 

other pollution prevention practices. 

Amalgam separators currently on the 

market can capture more than 95 percent 

of the mercury particles in wastewater.

28 In 

addition to outreach and education to 

dentists on safe handling and disposal 

practices for mercury-containing dental 

amalgam, some local efforts are offering 

incentives to encourage the use of amalgam separators. For example, the city of 

San Francisco, California has a goal of 

installing amalgam separators in all 900 

dental offices located in the city and is 

offering assistance and incentives to dental 

offices least able to afford the separators— 

specifically those serving low-income 

communities.29 

Future focus. EPA will continue to work 

with its state and tribal partners to identify 

approaches to TMDLs for water bodies 

impaired by atmospheric mercury in order 

to make progress toward achieving state 

water quality standards. Potential approaches include regional-scale TMDLs 

and approaches which take into account 

comprehensive state mercury reduction 

programs. 

Releases to Land 

Sources. TRI provides the best single 

source of information on releases of 

mercury to land. Based on TRI,30 the total 

amounts of mercury that were released to 

land decreased by about 18 percent between 2002 and 2003 (from 2,554 to 

2,079 metric tons per year). Although 

these amounts are relatively large, based 

on existing information, such releases are 

generally not considered to be as environmentally harmful as releases to air because 

the mercury may be less mobile and less 

likely to reach surface waters and fish. 

Nevertheless, because of the large quantities of mercury in waste being placed on 

the land, it is prudent for EPA to conduct 

further investigations to determine the 

risks associated with these releases. 

The vast majority of U.S. land releases are 

the result of mining activities. Mercury is 

no longer mined domestically in the U.S., 

but is a byproduct of metals mining, 

particularly gold mining. The 2004 TRI 

data indicate that 2079 metric tons of 

mercury were released to the land. Of 

that, 1.461 million pounds were released 

to “other surface impoundments”31 and 

2.620 million pounds were released to 

“other land disposal”.32 Three metal 

mining facilities accunted for over 74 

percent of the total mercury land releases 

in 2004. The majority of TRI land releases 

is due to gold, silver, and zinc mining, and 

may continue to rise over the next few 

years due to increased gold production. 

The Agency is beginning to investigate 

and characterize mercury releases and 
I. Addressing Mercury Releases - 29 

risks from mine tailings and mining 

processes, as well as other land releases. 

EPA plans to use the latest TRI data to 

evaluate trends for how mercury is being 

released to land. 

A small percentage of releases to land 

reported in TRI are not related to mining 

activities. The majority of these releases is 

attributed to the disposal of mercury in 

waste in hazardous or non-hazardous 

regulated landfills or surface impoundments. 

Progress to date. EPA has made substantial progress reducing the volume of 

mercury-containing devices disposed of in 

landfills since 1990. This progress is largely 

due to the Battery Act

33 which places 

limits on mercury used in batteries. The 

promulgation of the Municipal Incinerator Rules34 also helped reduce the amount 

of mercury going into the waste streams 

by limiting mercury emissions from these 

incinerators, which in turn encouraged 

localities to begin collection and recycling 

programs for mercury-containing devices. 

The Universal Waste Rule35 is another 

example of a regulation helping to facilitate proper management of mercurycontaining devices to keep them out of 

incinerators and landfills. In August 2005, 

EPA finalized its proposal to add mercurycontaining devices (e.g., thermometers 

and switches) to the federal Universal 

Waste Rule.36 For these widely-generated 

hazardous wastes, this rule streamlines 

entry into the waste management system, 

encourages recovery and recycling, and 

keeps wastes out of the municipal waste 

stream. States and localities have made 

substantial progress promoting recycling of 

discarded mercury-containing products. 

Many states are also involved in banning 

certain mercury-containing devices and 

actively promoting the use of mercury 

substitutes, where available. 

Future focus. Because there is a steady 

increase in reported land releases, the 

Agency will expand its efforts to better 

characterize and address land releases of 

mercury from the mining sector. The 

Agency intends to evaluate these releases 

to determine whether further action is 

needed. 

Using the latest TRI data, EPA will continue to analyze long-term trends and 

monitor sectors that are not addressing 

their mercury releases to assess appropriate voluntary or regulatory avenues for 

addressing mercury releases. 

EPA will continue to address mercury 

releases at remediation sites with significant mercury contamination consistent 

with the priorities set by the Superfund 

National Priorities List

37 and the RCRA 

Corrective Action baseline for highpriority facilities.38 EPA will continue to 

coordinate with states to assist in cleaning 

up serious spills of mercury in order to 

protect public health. In addition, EPA is 

looking into mercury issues associated with 

abandoned mines relative to downstream 

water quality. 

EPA will continue to work toward reducing risk associated with mercury from the 

nation’s waste streams and from potential 

releases to land by promoting cost-effective 

reductions in mercury use in products and 

processes and by promoting the collection 

and recycling of discarded mercury-containing products. 

State, Tribal, and Local Government 

Release Reduction Efforts 

Many state, tribal, and local governments 

have been leaders in addressing mercury 
30 - EPA’s Roadmap for Mercury 

releases. States have developed innovative 

mercury release and use reduction laws 

and regulations that supplement, and in 

some cases provide a model for, national 

efforts. 

For example, the state of Maine passed a 

law requiring removal of mercury convenience lighting switches from automobiles 

prior to crushing the automobiles for scrap 

metal.39 The purpose of the legislation is 

to reduce mercury releases from Electric 

Arc Furnaces (EAFs) used to melt scrap 

metal for steel production. The source of 

mercury from EAFs has been determined 

to be mercury components contained in 

the scrap metal melted by such furnaces. 

Scrap automobiles are the largest mercurycontaining feedstock for these furnaces.40 

Several other states are pursuing their own 

auto switch removal programs, including 

Pennsylvania, New York, New Jersey, 

Illinois, Colorado, Washington, Oregon, 

and Idaho. As a result of this state leadership, auto manufacturers no longer install 

mercury switches for convenience lighting 

and are actively investigating ways to keep 

mercury out of vehicles. In addition, EPA 

is engaging in discussions with various 

stakeholders, including auto dismantlers, 

shredders, steel makers, auto manufacturers, environmental groups, and states, with 

the aim of developing a collaborative 

national approach to removing mercury 

switches from the large inventory of autos 

in use today prior to their disposal, crushing, and smelting. 

States, tribes, and local governments have 

played a key role in outreach to the business community and to the general public 

about the importance of properly disposing of mercury-containing products and 

about alternatives to such products. Many 

states and local governments have sponsored mercury collection programs for 

businesses and households. For example, 

cities such as San Francisco, California, 

and states, such as Florida and New 

Hampshire, are conducting outreach to 

dentists on the proper handling and 

disposal of mercury-containing dental 

amalgam, including efforts to promote 

increased use of dental amalgam separators that reduce the amount of mercury 

discharged into the POTWs from dental 

wastewater. 

Priority Activities for Addressing 

Mercury Releases 

• Standard for Coal-Fired Power Plants 

– On March 15, 2005, EPA finalized 

the Clean Air Mercury Rule which 

establishes standards of performance 

for electric power plants based on a 

market-based cap-and-trade methodology. This rule will build on EPA’s 

Clean Air Interstate Rule (CAIR) to 

significantly reduce emissions from 

coal-fired power plants. The standards 

address mercury air emissions from 

new and existing coal-fired electric 

utility steam generating units. When 

fully implemented, these rules will 

reduce power plant emissions of 

mercury from 48 tons per year to 15 

tons per year, a reduction of nearly 70 

percent.41 Timeline: CAMR will reduce 

emissions from 48 tons to 31 tons beginning 

2010 and declining thereafter until emissions 

are reduced to 15 tons when the program is 

fully implemented 

• MACT Standard for Industrial 

Boilers – EPA promulgated a MACT 

standard for mercury air emissions 

from industrial boilers in September 

2004. This effort should result in a 17 

percent reduction in mercury emissions from this sector since 1990. 

Timeline: Implementation by 2007 
I. Addressing Mercury Releases - 31 

• MACT Standard for Hazardous iron and steel and pour the resulting 

Waste Combustors – In October molten metal into molds to produce 

2005, EPA published emission stan- shaped products. The rule includes 

dards for mercury and other hazard- emission limits for manufacturing 

ous air pollutants for incinerators, processes and pollution preventioncement kilns, lightweight aggregate based requirements to reduce air toxics 

kilns, industrial/commercial/institu- from furnace materials and coating/ 

tional boilers and process heaters, and binder formulations. Implementation 

hydrochloric acid production furnaces of the rule is expected to reduce 

that burn hazardous waste. An interim mercury emissions by 1.4 tons—an 80 

standard that took effect in 2003 has 

already reduced mercury emissions 

percent reduction from current levels.44 Timeline: Implementation by 2007 

from levels in 2000 for incinerators, 

cement kilns, and lightweight aggre- • Area Source Program – Under the 

gate kilns. The final MACT standard Urban Air Toxics Strategy, EPA is 

is estimated to further reduce mercury developing standards to control emisair emissions from all hazardous waste sions of toxic air pollutants (hazardous 

combustors by an additional 39 per- air pollutants or HAP) from area 

cent (from 2.4 tons/year to 1.5 tons/ 

year).42 Timeline: Implementation by 2008 

sources. Area sources are those sources 

that emit less than 10 tons annually of 

a single HAP or less than 25 tons 

• MACT Standard for Chlor-Alkali annually of a combination of HAP. 

Sector – In December 2003, EPA 

promulgated a rule to regulate emis- The Clean Air Act (CAA) requires 

sions of mercury from mercury-cell 

chlor-alkali plants.43 Mercury-cell 

EPA to identify a list of at least 30 

HAP that pose the greatest potential 

chlor-alkali plants produce chlorine health threat in urban areas, and in 

and caustic soda (used to neutralize the 1999 strategy, EPA identified 33 

acidic compounds) using mercury cells. such pollutants. Of those 33 identified 

The rule will also require rigorous pollutants, EPA determined that 30 

work practice standards that will stem from area source emissions. 

reduce mercury emissions from fugi- Through three separate listings (includtive sources. Although EPA is not able ing a list in the Urban Air Toxics 

to accurately quantify the reductions Strategy), EPA has identified a total of 

associated with these work practice 70 area source categories which represtandards, the requirements will sent 90 percent of the aggregate 

reduce mercury air emissions industry- emissions of the 30 listed area source 

wide. Timeline: Implementation by Decem- HAP. Of these 70 area source categober 2006 ries, 16 have been regulated, and EPA 

is currently collecting data and infor-

• MACT Standard for Iron and Steel mation for many other source categoFoundries – In 2004 EPA issued a ries. Timeline: Ongoing 

final rule to reduce toxic air emissions, 

including mercury, from iron and steel • Rule on Electric Arc Furnaces (EAFs) 

foundries. Iron and steel foundries – In 2006, EPA plans to propose a 

melt scrap, ingot, and other forms of comprehensive rule for steel mills that 
32 - EPA’s Roadmap for Mercury 

use EAFs to address emissions of 

mercury, lead, and other metals and 

organic hazardous air pollutants. EPA 

will also pursue voluntary programs in 

parallel with the development of 

regulations to ensure mercury emissions reductions. These actions collectively should greatly reduce mercury air 

emissions from EAFs and other scrap 

consumers over the course of the next 

10 years. Timeline: Propose rule in 2006 

• Mercury Automobile Switches – 

Many pre-2003 domestic passenger 

vehicles have mercury-containing 

switches in convenience light assemblies and anti-lock braking systems 

(ABS). Building on and coordinating 

with successful state and local automotive switch removal efforts, EPA hopes 

to develop a partnership with automobile dismantlers, scrap shredders, 

steelmakers, and the automotive 

industry to remove mercury switches 

from scrapped autos in the U.S. prior 

to disassembly, shredding, and melting 

in steelmaking furnaces. Timeline: 2006 

• Characterize Mining Releases – EPA is 

examining the issue of mercurybearing materials being placed on land 

at active gold mines and any subsequent releases which are not covered 

by TRI (air, surface, water, or ground 

water) associated with that placement. 

An effort is underway to assess the 

releases and their potential impact to 

determine if further action is warranted. Timeline: 2006 

• Characterize Mercury Discharges to 

Surface Water – As mentioned in the 

progress to date section, EPA recently 

developed a new analytical method for 

use in water discharge permitting 

programs that will improve EPA’s 

understanding of point source mercury contributions to surface waters. 

Based on that information, EPA is 

providing guidance to Publicly Owned 

Treatment Works (POTWs) on how to 

characterize sources of mercury to the 

collection system and how to develop 

mercury minimization measures where 

appropriate. Mercury in POTW 

collection systems may come from the 

medical sector, dental offices, schools, 

and certain industries. EPA is continuing to explore opportunities for 

pollution prevention in the dental 

sector and other sources. Timeline: 

Ongoing 

• Issue Mercury Water Quality Criterion Implementation Guidance – EPA 

currently intends to issue implementation guidance to states and tribes for 

the fish-tissue-based mercury water 

quality criterion and how to incorporate it into permits and TMDLs. Once 

states and tribes adopt the water 

quality criterion into their water 

quality standards, officials can incorporate appropriate controls where 

necessary into TMDLs and watershed 

management decisions. State environmental officials can incorporate 

appropriate controls where necessary 

into permits and enforce these requirements. Timeline: 2007 

• Improve Tools for Tracking Mercury 

in Fish Tissue – EPA continues to 

improve its models for tracking 

methylmercury in fish tissue and air 

deposition trends.45 EPA will also 

begin to estimate the expected effectiveness of proposed Hg source reduction activities in terms of reduced fish 

tissue methylmercury concentrations. 

This effort may involve the continued 

evolution of the Mercury Maps model-
I. Addressing Mercury Releases - 33 

ing framework, and its integration amalgam is sent to responsible recywith sophisticated air deposition clers who can adequately minimize 

model outputs (e.g., CMAQ [Commu- mercury releases by keeping the 

nity Multiscale Air Quality]). In addi- amalgam waste out of the wastewater 

tion, EPA will continue to refine its air stream and out of municipal and 

emission inventories to provide an medical incinerators. Timeline: In 2006 

assessment of emission reductions 

gained through implementation of its • Fluorescent Lamp Recycling – EPA is 

regulatory programs. Timeline: To be administering a grant program to 

determined increase the recycling rate of mercury-

• Develop Alternative Approaches and 

Tools for Identifying Mercury Impairments and Developing Mercury 

TMDLs – EPA will work with states, 

containing lamps. Grants are used to 

create lamp recycling outreach programs targeting commercial and 

industrial users of mercury-containing 

lamps. State environmental agencies, 

tribes, and stakeholders to determine tribes, non-profit organizations, lamp 

how best to use TMDLs to provide a manufacturers, and recyclers are all 

basis for reducing mercury releases to partners in implementing this prowater, including those from air deposi- gram. EPA is currently providing 

tion, to meet state water quality national coordination of these efforts 

standards and Clean Water Act goals. as well as technical expertise on regulaEPA will provide updated mercury tory issues. EPA will build upon the 

deposition modeling results to states results of this grant program to infor use in TMDLs, including the crease the national rate of bulb recymajor sources of mercury deposition cling. EPA is also working with Reto each state. EPA will also evaluate gions and states to develop guidance 

approaches for identifying mercury on the conditions under which drum 

impairments and developing mercury top crushing of waste lamps can be 

TMDLs, such as regional-scale TMDLs permitted without unacceptable 

and approaches that acknowledge mercury releases or danger to personstrong state mercury reduction pro- nel who operate the crushers. Timeline: 

grams, in order to make progress In 2006 

• 

toward attaining state water quality 

standards. Timeline: Ongoing 

Promote The Proper Collection and 

Recycling of Dental Office Amalgam 

Waste – EPA is currently developing a 

• Analyze Sectors and Trends for 

Mercury Releases in the TRI/NEI 

Databases – EPA will continue to 

evaluate the “other” smaller sources, as 

appropriate, that cumulatively release 

dental office amalgam recycling significant amounts of mercury to the 

program called its “gray bag” program. environment. EPA will monitor 

This program will assist dentists in existing data on how mercury is 

properly collecting and managing managed onsite and/or off-site and 

dental amalgam wastes generated in will examine potential sectors for 

their offices to minimize mercury expanding voluntary mercury reducreleases to air, land, and water. This tion programs. Timeline: Ongoing 

program also will ensure that dental 
34 - EPA’s Roadmap for Mercury 
II. Addressing Mercury Uses in Products and Processes - 35 

II. ADDRESSING MERCURY USES IN

PRODUCTS AND PROCESSES

OVERVIEW 

Addressing uses of mercury in products 

and processes is a component of preventing mercury releases to air, water, or land. 

These releases may occur during manufacturing and industrial processes, or during 

the disposal or recycling of mercurycontaining products and wastes. Addressing mercury use in products also reduces 

the demand for mercury by product 

manufacturers, thereby reducing demand 

for new mercury mining. Mercury mining 

still occurs in other countries and causes 

further releases to the global environment. Addressing demand for and use of 

mercury is critical to breaking the cycle of 

Uses Can Contribute to Releases 

Mercury use in products can lead to 

mercury releases through: 

• Manufacturing of product 

• Spills/breakage 

• Recycling/collection 

• Disposal 

mercury being transferred 

from one environmental 

medium to another. 

EPA’s long-term goal is to 

reduce risks associated with 

mercury. EPA recognizes 

that to reduce risks associated with mercury, the 

Agency must first understand what contributes to 

the risk and what the 

appropriate mechanisms of 

risk reduction might be. 

EPA will take action to 

identify exposed populations, minimize exposures through outreach efforts, and appropriately address 

anthropogenic releases. As part of its 

strategy, EPA will assess mercury sources of 

concern and will: focus on uses that would 

lead to risk, where cost-effective substitutes 

exist; promote reducing mercury in processes and products where benefits of such 

reduction would justify the cost, even 

where cost-effective substitutes do not 

exist; and work to identify and encourage 
36 - EPA’s Roadmap for Mercury 

FIGURE 3. Total 2001 U.S. Mercury Use in Products2 

Total: 245 metric tons 

34 metric tons 

14% 

17 metric tons 

7% 103 metric tons 

42% 

21 metric tons 

9% 

69 metric tons 

28% 

development of alternatives to essential 

uses of mercury that lead to risk. 

Sources. In 1980, the three largest U.S. 

industrial uses of mercury were in batteries 

(1,052 metric tons), the chlor-alkali manufacturing process (358 metric tons), and 

paint (326 metric tons).1 Mercury use in 

products accounted for an estimated 245 

metric tons in 2001. As Figure 3 illustrates, 

the dominant use of mercury in products 

in 2001 was in switches and wiring devices 

at 42 percent (103 metric tons), followed 

by measuring and control devices at 28 

percent (69 metric tons), dental amalgam 

at 14 percent (34 metric tons), and electrical lighting at 9 percent (21 metric tons). 

Mercury is also found in laboratories, 

including school science labs. Breakage or 

spillage of mercury supplies and mercurycontaining lab equipment creates the 

potential for inhalation exposure to 

airborne mercury indoors. Mercury in 

schools can pose a significant exposure 

concern for children and adults. 

In 2001, the largest use of mercury in 

manufacturing processes was by the chloralkali industry (producers of chlorine and 

caustic soda), estimated at 38 metric tons, 

or 12 percent of overall 

mercury use by U.S. industry.

3 

Progress to date. Over the 

past two decades there has 

been a dramatic drop in 

mercury use by industries in 

the United States, decreasing 

83 percent between 1980 and 

1997, from 2,225 metric tons 

to 381 metric tons (see Figure 

4).4 This reduction in use was 

due in large part to state and 

congressional limits placed on 

mercury use in batteries, EPA’s regulatory 

ban on mercury in paint, closure of some 

mercury-cell chlor-alkali manufacturing 

plants, and progress made under the U.S./ 

Canada Great Lakes Binational Toxics 

Strategy, a voluntary agreement which set 

forth a goal of 50 percent reduction in the 

deliberate use of mercury nationwide by 

2006.5 

The lamp industry has made significant 

progress in reducing use of mercury. The 

National Electrical Manufacturers Association (NEMA) reported that its members 

have significantly reduced use of mercury 

in lamps while increasing their production 

of lamps. In 1990, NEMA estimates that 

its lamp members used 23.6 tons of 

mercury in slightly fewer than 500 million 

mercury-containing lamps. After a concerted effort to reduce mercury use, this 

mercury usage declined to 7 tons by 2003. 

In the same timeframe, sales by NEMA 

lamp members have increased to 650 

million mercury-containing lamps. The 

Association of Mercury and Lamp Recyclers reports that lamp recycling has 

increased from fewer than 10 million 

lamps in 1990 to 156 million lamps in 

2003.6 
II. Addressing Mercury Uses in Products and Processes - 37 

As a result of a voluntary commitment to 

mercury reduction made by the U.S. 

Chlorine Institute under the Great Lakes 

Binational Toxics Strategy, the chlor-alkali 

industry has made significant progress in 

reducing its mercury use since 1995. The 

U.S. Chlorine Institute’s Ninth Annual 

Report to EPA showed a 91 percent 

reduction between 1995 and 2005 in 

mercury used in the U.S. production of 

chlorine and caustic soda, after adjusting 

for shut down facilities.7 

EPA’s Hospitals for a Healthy Environment (H2E) program is a partnership 

among EPA, the American Hospital 

Association (AHA), the American Nurses 

Association, and Health Care Without 

Harm to encourage hospitals to eliminate 

the use and purchase of mercury-containing products such as measurement and 

control devices.8 Under H2E, these health 

care facilities have pledged to eliminate 

mercury use and waste whenever possible 

by 2005 and to reduce all types of waste by 

2010. 

State, Tribal, and Local Government 

Use Reduction Efforts 

Many state, tribal, and local governments 

have been leaders in reducing mercury 

use. States have developed innovative 

mercury use and release reduction laws 

and regulations that supplement, and in 

some cases provide a model for, national 

efforts. For example, all of the New 

England states have adopted legislation to 

reduce mercury use in products.9 

States, tribes, and local governments have 

played a key role in outreach to the business community and to the general public 

about the importance of properly disposing of mercury-containing products and 

FIGURE 4. U.S. Mercury Product and Process Use Trends 
38 - EPA’s Roadmap for Mercury 

about alternatives to such products. Many 

states and local governments have sponsored mercury collection/replacement 

programs for businesses and households 

for products such as mercury thermometers. They have also made special efforts 

to educate and encourage hospitals and 

schools to eliminate the use of mercury 

and mercury-containing products. For 

example, over the past few years, the 

northeast states, in conjunction with the 

eastern Canadian provinces, have collected 

over 2,000 pounds of mercury from 

cleanout efforts at over 200 schools.10 

These efforts have been key to the 

progress made to date on reducing mercury use in school science laboratories. 

Likewise, several states such as Maine, 

Texas, and localities such as Alameda 

County, California have built green 

purchasing requirements that specify the 

use of non-mercury alternatives into their 

state procurement systems. 

Future focus. During the next ten years, 

EPA will focus on uses that would lead to 

risk, where cost-effective substitutes exist; 

promote reducing mercury in processes 

and products where benefits of such 

reductions would justify the costs, even 

where cost-effective substitutes do not 

exist; and work to identify and encourage 

development of alternatives to essential 

uses of mercury that lead to risk by working with state and tribal partners, industry, 

and non-governmental organizations. The 

Agency’s use reduction activities will be 

conducted in the context of the global 

market for commodity-grade elemental 

mercury and the need for global use 

reductions. (See Section III for further 

discussion of the mercury commodity 

market.) EPA will continue to support and 

build on successful state and local efforts by 

funding selected mercury projects, providing information about mercury sources 

and reduction opportunities, and coordinating joint efforts to further progress on 

addressing mercury use. EPA will also 

continue to work with other countries and 

international organizations to address 

global demand for and use of mercury as 

discussed further in Section V on international mercury sources. 

Need for a National Mercury Use 

Database 

Reliable and publicly available data on 

mercury use is a prerequisite to gauging 

the success of EPA initiatives to reduce the 

use of mercury. In 1998 the U.S. Geological Survey discontinued its annual reporting of mercury use, due to low voluntary 

response from mercury-using manufacturers. More recently, other limited sources 

of mercury use information have 

emerged: (1) the U.S. Chlorine Institute’s 

annual report to EPA on mercury usage by 

the chlor-alkali industry;11 and (2) the 

Northeast Waste Management Officials’ 

Association’s (NEWMOA) database on 

mercury-containing products, housed in 

NEWMOA’s Interstate Mercury Education and Reduction Clearinghouse 

(IMERC).12 The IMERC database contains 

annual data (beginning with 2001) required from manufacturers by the states of 

Connecticut, Maine, New Hampshire, and 

Rhode Island on national sales of specific 

mercury-containing products that are sold 

in these four states. The IMERC database 

is updated every three years. The base year 

for data is 2001; companies are required 

to report on 2004 data in 2005. EPA is 

evaluating how best to build upon this 

information as it is developing its database 

for mercury use in products and processes 

nationwide. A national use database will 

enable EPA and its partners to evaluate 

the effectiveness of its outreach activities. 
II. Addressing Mercury Uses in Products and Processes - 39 

Priority Activities for Reducing Mercury Uses 

To further progress in reducing risks 

associated with mercury use, EPA will 

continue to pursue a number of priority 

activities. These activities are based on 

considerations of the quantity of mercury 

used by specific industry categories; opportunities to provide national leadership; 

and opportunities to work in partnership 

with industries, other federal agencies, 

state, tribal and local governments, other 

institutions, and public interest groups. 

Industrial Processes 

• Track Reductions by Mercury-Cell 

Chlor-Alkali Facilities – EPA will 

continue to monitor the use of mercury by the chlor-alkali industry 

through the EPA/U.S. Chlorine 

Institute voluntary agreement on use 

reporting for the remaining U.S. 

mercury-cell chlor-alkali plants. 

Timeline: Ongoing through 2006 

Mercury-Containing Products 

• Further Reduce Risks Associated with 

Mercury Use Using TSCA Authorities and Voluntary Mechanisms – EPA 

will focus its new reduction efforts on 

switches, relays, and measuring devices 

because these sectors represent the 

majority of mercury use in products, 

and cost-effective alternatives are 

available for many uses in these 

categories. EPA will conduct a preliminary market analysis of mercury 

switches, relays, and measurement 

devices to identify candidate product 

manufacturers to partner with the 

Agency to reduce mercury use. Building upon successful state regulatory 

programs, EPA will pursue further use 

reductions in this product area using 

TSCA and voluntary mechanisms. 

Timeline: Proposed auto switch significant 

new use rule in 2006 

• Develop Database to Track Reductions in Mercury Use by Key Sectors 

– EPA is compiling and assessing 

information on mercury use and 

substitutes from existing data sources. 

The Agency will explore using various 

mechanisms to improve the comprehensiveness and reliability of its national database on mercury use, supply, 

and substitutes. This information also 

will allow EPA to evaluate the effectiveness of its outreach activities on mercury-containing products. Timeline: Data 

collection is ongoing; database in 2007 

• Promote Procurement of NonMercury Products by Federal Agencies – EPA is compiling a list of alternative non-mercury products with a 

special emphasis on those that contain 

non-mercury switches, relays, and 

measuring devices. EPA will compile 

and convey information—such as 

federal, state, and local bid specifications—to federal purchasers using its 

Environmentally Preferable Products 

(EPP) Database.13 The intent is to 

harness the large federal buying power 

to increase demand for non-mercury 

products. EPA will also make such 

information available to other interested purchasers, including state, 

tribal, and local governments; large 

industrial purchasers currently using 

mercury switches and relays (such as 

manufacturers of cars, airplanes, and 

appliances); institutional purchasers 

such as hospitals and schools; and 

individual consumers. Timeline: Ongoing 

• Partner with Automobile Manufacturers to Eliminate Mercury – EPA will 

work with the auto manufacturers on 
40 - EPA’s Roadmap for Mercury 

additional mercury use reduction and 

elimination of mercury from products, 

such as high-intensity discharge (HID) 

headlights. EPA will provide auto 

manufacturers with information on 

non-mercury alternatives to auto 

components through its Green Suppliers Network, an EPA partnership 

effort with manufacturers and their 

supply chains.14 Timeline: Enhance partnership efforts on auto products in 2006 

• Reduce Mercury in Health Care 

Facilities – EPA will continue partnerships with the American Hospital 

Association (AHA), the American 

Nurses Association, and Health Care 

Without Harm to encourage hospitals 

to eliminate the purchase of mercurycontaining products such as measurement and control devices, and properly 

dispose of mercury-containing products 

currently in health care facilities. EPA 

will expand these efforts by recruiting 

additional facilities. Timeline: Recruit 

2,000 new facilities by 2007 

• Promote Mercury Reduction in 

Schools – Building upon the successful 

work of the mercury-in-schools projects 

throughout the country by states and 

EPA regions, EPA will continue to 

work with school administrators and 

policy makers to promote the substitution of mercury with environmentally 

preferable chemicals through procurement policy guidelines and the use of 

green chemistry; the removal of 

elemental mercury, mercury reagents, 

and mercury waste products from 

school laboratories; the replacement of 

mercury-containing devices with safer 

non-mercury-containing devices in all 

school facilities; and the use of software to educate school maintenance 

workers and decisionmakers about 

potential environmental hazards in 

schools and ways to reduce them. EPA 

is developing a handbook, “Chemical 

Management for Schools: Recommended Actions for Administrators,” 

which will help schools safely manage 

chemicals, including mercury. This 

guidance will help school officials 

ensure the health and safety of the 

students and school employees. 

Timeline: Finalize Chemicals Management 

Document in 2006 

• Schools Chemical Cleanout Campaign (SC3) – Existing stocks of outdated, unknown, excessive or unnecessarily hazardous chemicals—are present 

in schools across the country. These 

chemicals can pose safety and health 

risks to students and staff, and a 

number of widely reported incidents 

involving such chemicals have resulted 

in school closures and costly clean-ups. 

To reduce the number of these incidents, the Agency has initiated the 

Schools Chemical Cleanout Campaign 

(SC3)15 which promotes removal of 

existing stocks of hazardous chemicals 

from secondary schools; safe chemical 

management; and national awareness. 

The ultimate goal of the SC3 is to 

create a chemically safer school environment in which chemicals are 

purchased wisely, stored safely, 

handled by trained personnel, used 

responsibly, and disposed of properly. 

In the summer of 2004, EPA launched 

ten SC3 pilots, one in each EPA 

region. EPA provided funding for an 

additional eight pilots in 2005. Outreach materials are now available on 

the website at www.epa.gov/sc3. 

Timeline: Ongoing 

• Promote Mercury Product Use 

Reduction Partnerships – Many 
II. Addressing Mercury Uses in Products and Processes - 41 

current mercury uses in products have 

cost-effective, mercury-free alternatives. EPA is currently inviting companies to voluntarily commit to mercury 

product use reduction and phaseout 

goals and to become partners in EPA’s 

National Partnership for Environmental Priorities (NPEP) Program. As a 

component of these partnerships, EPA 

is promoting mercury-containing 

product take-back/recycling programs 

and providing technical assistance to 

industry in achieving their NPEP 

goals. Timeline: Ongoing 

• Promote the Mercury Challenge – 

EPA is currently inviting companies to 

commit to establish inventories of 

mercury; remove mercury and mercury-containing equipment from their 

plants; and institute purchasing policies to reduce mercury use. This 

mercury challenge is a component of 

the NPEP program.16 
42 - EPA’s Roadmap for Mercury 
III. Managing Commodity-Grade Mercury Supplies - 43

 III. MANAGING COMMODITYGRADE MERCURY SUPPLIES

OVERVIEW 

The Agency expects that an excess supply 

of elemental, commodity-grade mercury 

will emerge on the market over the 

coming years as various secondary sources 

of mercury—especially the expected phaseout of mercury-cell chlor-alkali plants— 

overtake a shrinking demand for mercurycontaining products and industrial use of 

mercury. As a result, there will be an 

increasing need to safely manage mercury 

supplies for the long term. Ultimately, it 

will be important to look at ways to permanently “retire” most supplies of mercury 

that will eventually have little or no 

economic value. EPA estimates that 

current world demand for mercury is 

approximately 2,000 metric tons per year 

(mt/yr). Although highly variable from 

one year to the next, the amount of 

mercury available in commerce globally is 

also estimated at 2,000 mt/yr.

1

 Other 

estimates prepared for the European 

Union (EU) indicate that the global 

mercury supply may be over 3,300 metric 

tons.2 It is important to note that supply 

and demand numbers for countries 

outside the U.S. and Europe are very 

rough estimates. In the absence of efforts 

to retire mercury supplies, there is a 

danger that supplied mercury will find uses 

that have already been banned or eliminated in some countries, particularly in 

the developing world, possibly leading to 

unnecessary releases. 

Sources. In recent years, approximately 

one-half of the world mercury supply has 

come from mercury mines in Spain, 

Algeria, and Kyrgyzstan 

(although Spain is no 

longer mining mercury). 

China has also mined 

mercury to meet its domestic demand.3

 There have 

been no active mercury 

mines in the U.S. since 

1990. The remaining half 

of the world’s mercury 

supply comes from secondary sources, such as industrial wastes and scrap 

products, as byproduct 

from gold mines in the 

U.S. and abroad, and from 
44 - EPA’s Roadmap for Mercury 

closing mercury-cell chlor-alkali plants. (DNSC) published its final Mercury 

The secondary mercury produced from Management Environmental Impact 

these other sources is price-insensitive Statement regarding the disposition of its 

because the mercury results from environ- mercury.

5

 The DNSC decided to store its 

mental regulations and polices that require mercury at one location for at least a 40-

or encourage recovery (e.g., RCRA land year period. In addition, the Department 

disposal restrictions), and from industrial of Energy has a known supply of 1,306 

process conversions to non-mercury tons of mercury. 

processes. Environmental regulations and 

polices that require mercury recovery can State and local governments have prooverride the market’s natural tendency moted public and private collection 

over the long term to match supply with programs for both bulk elemental merdemand. Whereas the long-term trend for cury and discarded mercury-containing 

mercury mining has been one of decline, products. Some businesses are also collectsecondary production has remained ing unwanted mercury or mercury-conrelatively constant. It may even increase as taining products (e.g., thermostats). The 

mercury continues to be recycled/recov- total amount of mercury collected 

ered and more mercury-cell chlor-alkali through these programs is unclear. Most 

plants close, thereby making more mer- of this mercury is sent to retorters, and it 

cury available to the secondary market. is likely that the supply of mercury will 

increase due to successful collection 

The most significant factor driving the programs and efforts to eliminate mercury 

timing of a global mercury surplus is the from schools, laboratories, and businesses. 

rate at which remaining U.S. and international mercury-cell chlor-alkali plants close The Environmental Council of the States 

and liquidate their stocks of some 22,000 (ECOS) and the Quicksilver Caucus 

metric tons. Of these stocks, mercury-cell (QSC), a coalition of state associations 

chlor-alkali plants in the U.S. account for concerned with mercury pollution, have 

about 2,600 metric tons of mercury indicated that states do not have the 

stocks.4 Mercury-cell chlor-alkali plants are resources or desire to manage surplus 

being closed at the end of their useful life mercury for the long term and are lookin the U.S. and abroad due to the ing to the federal government to address 

industry’s conversion to non-mercury this issue.6 Environmental groups and the 

technologies, a shrinking customer base, U.S. Chlorine Institute are also looking to 

and high energy costs. the federal government to address or 

assume responsibility for all private sector 

Progress to date. The Department of commodity-grade mercury that exceeds 

Defense (DoD) has mercury stocks that are U.S. demand. 

being stored. The DoD has 4,436 metric 

tons of mercury in its strategic stockpile. In addition, EPA’s Office of Research and 

DoD has sold some of its mercury stocks in Development conducted research and 

the past, but since 1994 DoD has been published a report in 2005 on the technistoring its mercury in response to requests cal and economic feasibility of selected 

from EPA, states, and non-governmental land disposal technologies in a monofill 

organizations (NGOs). On April 30, 2004, context, as compared to above-ground 

the Defense National Stockpile Center storage for elemental mercury.

7 
III. Managing Commodity-Grade Mercury Supplies - 45 

Future focus. The issue of whether the 

federal government, states, or the private 

sector should take responsibility for 

managing commodity-grade mercury 

supplies from state and private sources is 

an important policy decision. Decisions 

regarding the disposition of commoditygrade mercury should be made in light of 

the global mercury market; data and 

research needs; public policy, statutory, 

and economic considerations; and the 

views of Congress, states, tribes, and nongovernmental organizations. 

Ultimately, it will be important to look at 

ways to permanently “retire” non-federally 

owned or managed commodity-grade 

mercury that will eventually have little or 

even negative economic value. Disposal of 

commodity-grade mercury would require 

regulatory changes, as current regulations 

under the Resource Conservation and 

Recovery Act (RCRA) require high concentration mercury wastes to be retorted 

for mercury recovery and reuse.8 

Additional information on mercury 

supplies and flows would allow for more 

informed policy choices and decisions on 

this issue, and to better estimate when the 

global mercury surplus may occur. EPA, 

states, tribes, and the private sector must 

continue efforts, domestically and internationally, to address exposure, potential 

reduction strategies, and the quantity of 

mercury that will ultimately need to be 

stored or land disposed permanently. 

Priority Activities for Addressing 

Mercury Supplies 

Address Data Gaps on Mercury Supplies 

• Publish Initial Report and Assemble 

Existing Data on Domestic and Global 

Commodity Mercury Production and 

Use – EPA will explore with industry 

and other federal agencies ways to fill 

information gaps on annual production and use of commodity mercury. 

Timeline: 2006 

Safe Storage Practices for Disposal of 

Mercury 

• Establish a Process to Address Mercury Surplus Issues – In 2006, EPA 

will work with other agencies to 

initiate a process with technical experts 

and interested parties to discuss options for addressing the expected 

mercury surplus over the next 10–30 

years, and how to encourage the phaseout of mercury mining abroad. 

Timeline: Initiate discussion in 2006 
46 - EPA’s Roadmap for Mercury 
 IV. Communicating to the Public about Mercury Exposure Risks - 47 

IV. COMMUNICATING

TO THE PUBLIC ABOUT

MERCURY EXPOSURE RISKS

OVERVIEW 

While the Agency is pursuing regulatory 

and voluntary activities aimed at industrial 

reduction of mercury releases and uses, 

EPA will also increase its risk communication and outreach activities to help people 

avoid or reduce their exposure to mercury 

in the near term. The most common way 

people in the U.S. are exposed to mercury 

is by eating fish containing methylmercury 

(an organic mercury compound). Consumption of fish with higher methylmercury levels can lead to elevated levels of 

methylmercury in the bloodstream of 

unborn babies and young children and 

may harm their developing nervous 

system.1 The primary tool for reaching 

and educating affected populations has 

been through fish consumption advisories 

issued by states, tribes, and FDA. For 

example, in March 2004, EPA and FDA 

issued a joint federal fish consumption 

advisory for mercury in fish and shellfish 

that helps consumers understand the 

benefits of fish consumption, the risks of 

consumption to certain sub-populations 

(e.g., groups with routinely high consumption), and mercury levels in certain fish. 

Fish and shellfish are an important part of 

a healthy diet, since they contain high 

quality protein and other essential nutrients, are low in saturated fat, and contain 

omega-3 fatty acids. A well-balanced diet 

that includes a variety of fish and shellfish 

can contribute to heart health and 

children’s proper growth and development. Research shows that most people’s 

fish consumption does not cause a health 

concern. 

EPA and FDA have issued fish consumption advice to help consumers understand 

the connection between the benefits of 

fish and possible risks of methylmercury 
48 - EPA’s Roadmap for Mercury 

What You Need to Know About

Mercury in Fish and Shellfish

U.S. Food and Drug Administration and

U.S. Environmental Protection Agency

Advice for

Women Who Might Become Pregnant, Women Who Are

Pregnant, Nursing Mothers, and Young Children

1. Do not eat: 

• Shark 

• Swordfish 

• King Mackerel 

• Tilefish 

They contain high levels of mercury. 

2. Eat up to 12 ounces (2 average meals) a week of a variety 

of fish and shellfish that are lower in mercury. 

• Five of the most commonly eaten fish that are low in 

mercury are shrimp, canned light tuna, salmon, pollock, 

and catfish. 

• Another commonly eaten fish, albacore (“white”) tuna has 

more mercury than canned light tuna. So, when choosing 

your two meals of fish and shellfish, you may eat up to 6 

ounces (one average meal) of albacore tuna per week. 

3. Check local advisories about the safety of fish caught by 

family and friends in your local lakes, rivers and coastal 

areas. 

If no advice is available, eat up to 6 ounces (one average 

meal) per week of fish you catch from local waters, but 

don’t consume any other fish during that week. Follow 

these same recommendations when feeding fish and 

shellfish to your young child, but serve smaller portions. 

For more information, please visit:

www.epa.gov/waterscience/fishadvice/advice.html

(See full text of Joint Fish Advisory in Appendix A)

exposure. Elevated methylmercury in the 

blood stream of unborn babies and young 

children may harm the nervous system, 

impairing the child’s ability to learn and 

process information. Certain sub-populations may be at higher risk than the 

general population because of their routinely high consumption of fish and 

shellfish (e.g., tribal and other subsistence 

fishers and their families who rely heavily 

on locally caught fish for the majority of 

their diet). 

Although people are exposed to methylmercury via the dietary route, there are 

also some non-dietary sources of mercury 

exposure. Many consumers are not aware 

that mercury has been used for years in 

common household products such as 

thermostats. Releases from the manufacture of mercury-containing products and 

inappropriate disposal of these products 

have contributed to mercury entering the 

environment and ultimately the food 

chain. Misuse of or accidental breakage of 

some products can create indoor air 

health risks and expose consumers to 

dangerous levels of mercury. In addition, 

certain cultural or religious uses of mercury may also result in harmful mercury 

exposure. The number of individuals 

exposed in the U.S. in this way is very 

small. 

The Agency will make it a priority to 

provide consumers with reliable risk 

information about mercury exposure so 

that they can make informed choices 

about the fish they eat and the products 

they use. 

Progress to date. EPA has directed most of 

its mercury risk communication activities 

toward raising awareness about dietary 

practices. The FDA-EPA national advisory, 

What You Need to Know About Mercury in 

Fish and Shellfish, provides advice for 

women who might become pregnant; 

women who are pregnant; nursing mothers; and young children.2

 This advisory 

represents the first time FDA and EPA 

have combined their advice into a single 

uniform advisory. During the summer 

and fall of 2004, the two agencies distrib-
 IV. Communicating to the Public about Mercury Exposure Risks - 49 

uted brochures about the advisory to 

approximately 200,000 medical providers 

in the U.S. 

In September 2005, EPA sponsored the 

Eighth Annual National Forum on 

Contaminants in Fish (“Fish Forum”). The 

forum provided an opportunity for people 

who have an interest in the subject of 

advisories, from both the public and 

private sectors, to discuss scientific and 

policy issues, risks and benefits, and 

communication strategies associated with 

exposure to chemical contaminants in 

sport- and subsistence-caught fish and 

shellfish. In September 2005, the 13th 

straight year, EPA released its National 

Listing of Fish Advisories, a summary of 

information on locally-issued fish advisories and safe-eating guidelines.3

 This 

information is provided to EPA annually 

by states, territories, and tribes. 

States and tribes issue fish consumption 

advisories if elevated concentrations of 

chemicals such as mercury are found in 

local fish. States monitor their waters by 

sampling fish tissue for persistent pollutants that bioaccumulate. States issue their 

advisories and guidelines voluntarily and 

have flexibility in what criteria they use 

and how the data are collected. As a 

result, there are significant variations in 

the number of waters tested, the pollutants tested for, and the threshold for 

issuing advisories. Based on self-reporting, 

the national trend is for states to monitor 

different waters each year, generally 

without retesting waters monitored in 

previous years.4 As new waters are tested 

and results are added to previous years’ 

findings, the number of fish advisories 

continues to rise. EPA makes information 

on the fish advisories, as well as Fish 

Forum proceedings, easily accessible to the 

public on its website. 

Although most of EPA’s risk communication efforts have been directed to increasing awareness of mercury in the food 

chain, the Agency has also investigated 

non-dietary sources of mercury exposure 

about which the public should be aware. 

Risk communication has been conducted 

in conjunction with mercury reduction 

activities, such as school clean-outs or 

thermometer collection programs. In 

many cases, critical mercury outreach to 

schools and communities would not 

otherwise occur without EPA assistance. 

For example, EPA’s Region 6 has identified a particular need for such support in 

communities on the U.S./Mexico border. 

EPA’s national efforts on mercury risk 

communication have been aimed at 

making information widely available to 

the public and at co-sponsoring national 

conferences that bring together people 

from across the country to share information on mercury risk communication. A 

unique exposure concern is raised by 

ritualistic use of mercury in certain cultural communities. For this reason, in 

January 1999, EPA and the U.S. Agency 

for Toxic Substances and Disease Registry 
50 - EPA’s Roadmap for Mercury 

(ATSDR) convened the Task Force on 

Ritualistic Uses of Mercury to recommend 

an appropriate course of action regarding 

the use of elemental mercury as part of 

certain folk practices and religious traditions. The Task Force prepared a report in 

2002 which recommended approaches 

that rely primarily on community outreach 

and education activities to inform mercury 

suppliers and the public about mercury’s 

risks, and encourage the use of safer 

alternatives.5 

In January 2005, EPA launched its consolidated website on mercury, www.epa.gov/ 

mercury.

6

 This new website, organized by 

subject matter and geographic region, 

provides one location to find information 

about mercury in a useful format for the 

American public. Because the most effective mercury risk communication activities 

will be carried out at the state and local 

level, another important contribution to 

mercury risk communication is the provision of grants, cooperative agreements, 

and other types of funding for state, tribal, 

and local mercury risk communication 

activities. 

States, tribes, and local governments have 

also conducted outreach activities in 

conjunction with most of the mercury 

collection programs mentioned in Sections 

I and II on addressing mercury releases 

and uses in processes and products. In 

order to get a high rate of participation in 

these voluntary programs, it is important 

to educate the public on the risks of 

mercury exposure, the need for proper 

disposal of mercury-containing products, 

and the availability of safe, non-mercury 

alternatives. For example, in an innovative 

project, the state of Minnesota trained a 

dog to locate mercury in buildings by sense 

of smell. Minnesota’s Mercury-Free Zone 

Program is modeled after a Swedish 

program that uses dogs to detect mercury 

in schools.7

 Schools that take the mercuryfree pledge are eligible to receive a visit 

from Clancy the mercury dog. Clancy has 

received media coverage which has raised 

general awareness of the dangers of 

mercury and the need to dispose of 

mercury responsibly. States, tribes, and 

local governments are in the best position 

to develop material tailored to local 

populations. For example, the state of 

Washington is using an EPA grant to 

conduct a survey of fish consumption 

among Asian/Pacific Islander populations 

in the Puget Sound region. As part of this 

project, the state will identify community 

groups to educate these populations in a 

culturally sensitive manner by tailoring 

messages and translating documents. 

Future focus. As long as mercury is 

present in the environment and in food 

and consumer products, consumers will 

need reliable risk information about 

mercury exposure; about making informed choices regarding the benefits of 

fish consumption, the risks of consumption for certain groups, and mercury levels 

in certain fish; and about the purchase, 

use, and disposal of mercury-containing 

products and mercury-free alternatives. 

EPA will continue to provide support for 

national and local outreach and education 

programs on the effects of mercury and 

consumer choices. EPA will also support 

risk communication and outreach efforts 

about mercury through its international 

activities and programs. 

Priority Activities for Mercury Risk 

Communication 

• Continue Assistance in Implementing 

Fish Advisories – EPA will continue to 

work closely with FDA to implement 

the 2004 joint EPA-FDA national fish 

advisory for methylmercury across the 
 IV. Communicating to the Public about Mercury Exposure Risks - 51 

U.S. EPA will also work with FDA to the Home – Building upon the inforcontinue targeted outreach efforts to mation already available from states 

the U.S. medical community to pro- and other groups about consumer 

vide information on dietary risks of products that contain mercury, EPA 

methylmercury exposure, and ways will develop an inventory of mercurythat medical professionals can help containing products and mercury-free 

patients and their families reduce substitutes. EPA will also identify 

exposure to mercury while maintain- information gaps. EPA will make the 

ing a healthy diet. EPA will continue information available on its website. 

to assist the states and tribes with Timeline: 2006 

development and communication of 

their fish advisories through the 

National Forum on Contaminants in 

• Outreach to Health Professionals and 

Health Care Associations – Health 

Fish (held every 15–18 months), professionals are an important partner 

updating of risk communication in the dissemination of mercury risk 

guidance documents, and updating the information. EPA is working to eduNational Listing of Advisories. cate health professionals about a 

Timeline: Ongoing; Biennial Fish Forums variety of children’s environmental 

• Maintain Centralized Mercury Portal 

Website – EPA will provide up-to-date 

health issues, including mercury. For 

example, EPA is coordinating an 

interagency effort to work with the 

information on all aspects of the risk Pediatric Environmental Health 

of mercury exposure through food Speciality Units to provide pediatric 

consumption and product use by consultative services covering mercury 

maintaining its electronic Mercury and other key concerns for children’s 

Portal Website, which will be EPA’s environmental health. EPA will also 

primary mechanism for communicat- partner with health care associations 

ing with the public about mercury. and universities to disseminate merTimeline: Ongoing cury risk information and increase 

• Assist State, Tribal, and Local Government Mercury Outreach Activities – 

proper mercury disposal in health care 

facilities. Through the Hospitals for a 

Healthy Environment (H2E) program, 

EPA will continue to assist and support EPA and its regions will continue to 

state, tribal, and local government work with universities to educate 

efforts to conduct mercury risk com- future health professionals in proper 

munication and outreach, research disposal of chemicals in hospitals. 

and mitigation activities addressing Timeline: Ongoing 

important routes of mercury exposure, 

and actions that can be taken by 

individual consumers to reduce mer-

• Outreach to Schools on the Need to 

Remove Mercury – As part of its 

cury exposure and pollution. Timeline: national project to work with science 

Ongoing teachers, curriculum developers, 

• Outreach Activities to Consumers on 

Mercury-containing Products and 

Mercury-free Substitutes for Use in 

facilities managers, and pollution 

prevention professionals to promote 

mercury reduction in schools, EPA will 

work to make school officials and staff 
52 - EPA’s Roadmap for Mercury 

aware of the risks of exposure to 

mercury and the availability of mercury-free alternatives. This includes the 

use of software to educate school 

decisionmakers about potential environmental hazards in schools and ways 

to reduce them. Timeline: Ongoing 

• Conduct Public Awareness Evaluation 

for Dietary Issues – To better educate 

the U.S. public on how to make 

informed dietary choices, FDA, with 

assistance from EPA, is conducting 

surveys to evaluate how well the U.S. 

public understands the effects of 

methylmercury exposure from eating 

certain fish and shellfish. Timeline: 

Surveys conducted and completed during 

2006/2007 
V. Addressing International Mercury Sources - 53 

V. ADDRESSING INTERNATIONAL

MERCURY SOURCES

OVERVIEW 

EPA is actively engaged and collaborating 

with international organizations and 

partners to address risks associated with 

mercury uses, releases, and exposure. As 

previously discussed, the greatest mercury 

exposure to the 

based on an advanced, state-of-the-science 

modeling assessment of atmospheric fate, 

transport, and deposition of mercury. 

EPA’s modeling indicates that a substantial 

variation in mercury deposition occurs 

general population is 

from eating fish 

containing methylmercury, including 

marine fish. EPA has 

estimated that over 

three quarters (83 

percent) of the 

mercury deposited 

in the U.S. originates from international sources (with 

the remaining 17 

percent coming 

from U.S. and 

Canadian sources). 

These figures include mercury from 

natural and reemitted sources. 

This estimate is 

FIGURE 5. Where are Man-Made Mercury Emissions Originating?1 

1995, metric tons per year. 
54 - EPA’s Roadmap for Mercury 

FIGURE 6. Man-Made Air Emissions of Mercury: Distribution by Region in 1990 and 20003 

1990 

Total: 1,181 metric tons 

Africa 

178 tons 

9% South America 

62 tons

 3% 

Asia


705 tons
 North America 38% 261 tons 

14% 

Europe


Australia 627 tons


48 tons 33%


3%


across the U.S., with domestic sources 

influencing mercury deposition much 

more in the eastern U.S. and global 

sources being a more significant contributor to mercury deposition in the west, 

where relatively few domestic sources exist. 

The scientific community’s understanding 

of mercury atmospheric chemistry is 

evolving, and there remain uncertainties 

regarding simulation of mercury in atmospheric chemistry models. EPA continues 

to work to advance the state of the science 

on mercury chemistry and fate and transport modeling.2

 International collaboration is critical to refining our understanding of global mercury sources, 

international transport pathways, and 

environmental impacts, and most importantly, for addressing the adverse impacts 

of mercury on human health and the 

environment globally. 

Sources. A number of key international 

emission sources contribute to global 

cycling and deposition of mercury via air 

pathways, including: coal-fired combustion 

sources; mining and metals production, 

such as smelting; mercury-cell chlor-alkali 

2000 

Total: 2,269 metric tons 

Africa 

407 tons 

18% 

South America 

92 tons 

Asia 4% 

1204 tons 

52% North America 

202 tons 

9% 

Europe 

239 tons 

11% 

Australia 

125 tons 

6% 

manufacturing facilities; and combustion 

or incineration of waste products containing mercury. The United Nations Environment Program (UNEP) estimates that 

the total global emissions of mercury 

(anthropogenic and natural to the atmosphere) range from 4,400 to 7,500 metric 

tons per year.

4

 EPA estimates that 50–70 

percent of current global anthropogenic 

atmospheric emissions come from fuel 

combustion, and much of this is from 

China, India, and other Asian countries.5 

Coal consumption in Asia is expected to 

grow significantly over the next 20 years. 

This source of mercury emissions may 

grow substantially if left unaddressed.6 

Small-scale “artisanal” gold and silver 

mining is an important mercury emissions 

source in numerous Asian, South American, and African countries. Atmospheric 

mercury emissions from artisanal gold 

mining have been estimated by UNEP to 

be about 300 metric tons per year,

7

 but 

some experts estimate that total mercury 

releases from artisanal gold mining are 

between 650 and 1,000 metric tons per 

year on a global basis.8 An estimated 13 

million people in 55 countries work and 
V. Addressing International Mercury Sources - 55 

are affected by occupational exposures in and international programs and agreeartisanal mining.9 ments to address mercury uses, releases, 

and the resulting exposure around the 

Using data presented in the 2002 United globe. These include: 

Nations Environment Program Global 

Mercury Assessment, EPA has calculated • U.S./Canada Great Lakes Binational 

that mercury-cell chlor-alkali factories are Toxics Strategy, which provides a 

the third largest source of atmospheric framework for actions to reduce or 

mercury releases to the global environ- eliminate mercury and other persisment. While the number of mercury-cell tent toxic substances. The Strategy sets 

chlor-alkali facilities has been greatly forth challenge goals to reduce merreduced in the United States and Europe cury use by 50 percent and to reduce 

over the last two decades, the process is releases by 50 percent by 2006 (from 

prevalent in many parts of the world the 1990 baseline). The use goal has 

including Russia, several South American been met. The releases goal has almost 

countries, and India, which is estimated to been met. Mercury releases have 

have the most plants of any developing decreased by 47 percent. By 2006, 

country.

10 EPA estimates that there may additional regulations and voluntary 

be 135–170 mercury-cell plants globally, activities are expected to reduce merwith half located in developing countries.11 cury emissions by at least 50 percent, 

meeting the release goal as well.14 

Global estimates for mercury use in 

processes and products range from 2,000– • New England Governors/Eastern 

3,400 metric tons per year.

12 Mercury-cell Canadian Premiers Regional Mercury 

chlor-alkali facilities are among the 

principal users of mercury in the FIGURE 7. Global Mercury Use, 2000 world. In addition to industrial 

uses, mercury has been used in Total: 3,386 metric tons 

numerous products, including Dental amalgam 

household appliances, electronics, 272 tons 

Measuring and Control 8% 

batteries, automobile switches, 166 tons 

5% Batteries dental amalgam, and thermom- Lighting 1081 tons 

eters. While mercury use in pesti- 91 tons 32% 

3% cides, fungicides, paints, and most Other uses 

batteries has been banned or 175 tons 

phased-out in the U.S. and other 5% 

Electrical control & swtiching developed countries, these uses are 154 tons 

continuing in developing coun- 4% 

tries. For example, battery production accounts for an estimated one 

third of global mercury use in 

products (see Figure 7).13 Small-scale gold & silver 

mining (artisanal) 

650 tons 

Progress to date. EPA is currently 19% 

engaged in the implementation of Chlor-alkali 

797 tons 

a wide range of bilateral, regional, 24% 
56 - EPA’s Roadmap for Mercury 

Action Plan, which establishes long- protocol also requires mandatory 

term and short-term regional mercury mercury concentration limits for 

reduction goals. The plan addresses certain types of batteries, and encourmercury emission reductions; source ages parties to consider various manreduction and safe waste management; agement measures to address use of 

outreach and education; and research, mercury in other products. The U.S. 

analysis and strategic monitoring. Due 

to successfully reaching the goal of 50 

meets the provisions of the Heavy 

Metals Protocol.17 

percent reduction of emissions by 

2003, the Governors and Premiers are • UNEP Mercury Program, which was 

now working on meeting a 75 percent 

reduction goal for emissions by 2010.

15 

created at the February 2003 meeting 

of the United Nations Environment 

Program (UNEP) Governing Council. 

• Commission for Environmental The United States government was 

Cooperation (CEC) North American instrumental in providing much of the 

Regional Action Plan for Mercury, initial funding and leadership for the 

which aims to reduce man-made creation of the UNEP Mercury Promercury releases to the North Ameri- gram. This program is based on the 

can environment through appropriate key finding of the 2002 UNEP Global 

international and national initiatives Mercury Assessment that there is 

to amounts that are attributable to sufficient evidence of significant global 

naturally-occurring levels and fluxes. adverse impacts from mercury and its 

The U.S. has made considerable compounds to warrant international 

progress in implementing the provi- action to reduce the risks to human 

sions of the plan regarding mercury air health and the environment. Supemissions; processes, operations, and ported by the 130 nations attending 

products; and waste management; as the Governing Council meeting, the 

well as research, monitoring, model- UNEP Mercury Program endorses 

ing, and inventories; and communication activities.16 immediate actions to reduce mercury 

uses and releases, assist developing 

countries to create mercury emissions 

• United Nations Economic Commis- inventories, raise awareness, and 

sion for Europe (UNECE) Convention provide technical assistance. The U.S. 

on Long-range Transboundary Air government has been involved in all 

Pollution Protocol on Heavy Metals is of these efforts, and has funded the 

a legally-binding agreement that majority of the UNEP Mercury Protargets emissions of cadmium, lead, gram to date. EPA funded technical 

and mercury. The U.S. is a party to the staff to work in the UNEP Mercury 

Heavy Metals Protocol, which went Program for two years, provided 

into effect in December 2003. The technical review of UNEP draft 

protocol aims to cut emissions from mercury guidance, and sent experts to 

industrial sources, combustion processes, and waste incineration through conduct training at the UNEP regional 

mercury workshops.18 

application of best available technologies and emission limit values for new At the twenty-third session of the 

and existing stationary sources. The UNEP Governing Council, which was 
V. Addressing International Mercury Sources - 57 

held in Nairobi, Kenya, February 21– Council Action Plan (ACAP) and the 

25, 2005, delegates agreed to further Arctic Monitoring and Assessment 

develop the UNEP Mercury Program Program (AMAP). EPA has worked to 

and to support the efforts of countries strengthen capacity building and 

to take action to reduce mercury technical cooperation programs 

exposure, releases, and uses. The among the Arctic countries, particuGoverning Council urged govern- larly to assist Russia in the developments, intergovernmental and nongovernmental organizations, and the 

ment of Russia’s mercury action 

plan.22 In 2005, two ACAP mercury 

private sector to develop and imple- reports were issued. The first, an 

ment partnerships in a clear, transpar- “Arctic Mercury Releases Inventory,” 

ent, and accountable manner to summarizes current releases, usage, 

reduce the risks of mercury to human 

health and the environment.19 

and disposal of mercury within all 

eight Arctic countries. The second, an 

“Assessment of Mercury Releases from 

The U.S. initiated five mercury part- the Russian Federation,” represents 

nerships for: (1) artisanal and small- the first comprehensive assessment of 

scale gold mining; (2) chlor-alkali mercury releases at the national level 

manufacturing; (3) products; (4) coal by that country. With the cooperation 

combustion; and (5) fate and transport of the Russian authorities, a limited 

research. EPA held consultative meet- number of point sources in the Rusings with other countries and domestic sian Federation are being evaluated in 

and international stakeholders on the terms of their potential as sites for 

first three partnerships in 2005. The mercury demonstration projects. The 

partnerships created will leverage Agency is coordinating U.S. federal 

resources, technical expertise, technol- government involvement, which 

ogy transfer, and information ex- includes the U.S. Geological Survey, 

changes to provide immediate, effec- Department of Energy, Department of 

tive action that will result in tangible State, and National Oceanic and 

reductions of mercury use and emissions.20 Atmospheric Administration. 

Future focus. EPA will continue to work 

• United Nations Industrial Develop- with the U.S. Department of State and 

ment Organization (UNIDO) Global other federal agencies to provide internaMercury Project, which provides tional leadership in addressing mercury in 

training on best management practices international fora, including the CEC, 

to reduce occupational exposures, to UNECE, Arctic Council, and UNEP. 

reduce emissions, and to reduce the Consistent with the 2005 UNEP Governamount of mercury used in small-scale ing Council Decision on mercury, the goal 

“artisanal” gold and silver mining of the U.S. government is to reduce 

operations around the world. EPA has human and ecosystem risks associated with 

provided funding and technical expertise to assist in this effort.

21 

the use and emissions of mercury from 

international sources. Global mercury 

reductions can be accomplished by address-

• Arctic Mercury Project, which was ing all major aspects of the global mercury 

developed in the context of the Arctic problem and collaborating on the develop-
58 - EPA’s Roadmap for Mercury 

ment of partnerships and specific resultsoriented projects to reduce mercury uses 

and emissions nationally, regionally, and 

globally. It is critical to more fully engage 

developed and developing countries, 

industry, environmental groups, international organizations, and funding institutions to bring needed technical expertise 

and financial resources to address the 

global mercury problem. 

Priority Activities to Reduce Global 

Mercury Sources and Releases 

The following is a list of important components to an international approach to 

facilitate global reductions in mercury use, 

releases, and exposure, followed by brief 

descriptions, and EPA’s priority actions in 

each area. These activities build upon and 

complement existing actions under UNEP, 

UNECE, Arctic Council, UNIDO, and 

multi-lateral and bilateral agreements, and 

may include the development of or participation in specific partnerships and projects 

in the following areas: 

• Increase international awareness of 

mercury risks and risk communication approaches 

• Improve global understanding of 

international emissions sources, 

releases and transport mechanisms 

• Address mercury emissions from 

point sources 

• Address mercury use in products 

and processes where there is an 

opportunity to reduce risk 

• Address mercury supply issues 

• Improve management of mercurycontaining wastes and surplus 

mercury 

• Increase International Awareness of 

Mercury Risks and Risk Communication Approaches – There is a need to 

enhance international awareness and 

understanding of mercury sources 

(national, regional, and global) and 

risks to the general public. It is important to develop and share key health 

messages and methods regarding 

exposure from dietary sources (e.g., 

fish consumption advisories, testing 

methods, and protocols for determining the level of mercury in fish) and 

non-dietary sources (e.g., consumer 

products) and the need to use mercury 

alternatives. 

EPA will work with its federal, state, nongovernmental, and international partners 

to: 

• Share sampling and analysis 

protocols that have been developed to determine the level of 

mercury in fish. Timeline: Ongoing 

• Support international outreach 

efforts to communicate risk. 

Timeline: Ongoing 

• Improve International Understanding of Global Emissions Sources, 

Releases, and Transport Mechanisms 

– International cooperation has 

helped shape understanding of mercury cycling on local, regional, and 

global scales, and determine the effects 

of mercury exposure on human 

health. Working with international 

partners is critical to improving 

understanding of mercury’s global 

impacts. Areas of collaboration will 

include transport and fate research; 

development of production, use, 

source, and emissions data. 
V. Addressing International Mercury Sources - 59 

EPA will work with its federal, state, nongovernmental, and international partners 

to: 

• Coordinate monitoring research 

and measurement work in Asia 

and elsewhere. Timeline: Ongoing 

• Continue to conduct high altitude 

research in the U.S. to continue to 

transect with ongoing long-range 

transport monitoring in other 

parts of the world by the U.S. and 

other countries. Timeline: Ongoing 

• Develop and implement 

workplans with UNEP, United 

Nations Institute for Training and 

Research (UNITAR) and other 

countries for assessment/inventory 

of mercury emissions and use. 

Timeline: 2006 

• Support the development of a 

global partnership on mercury fate 

and transport research. Timeline: 

Initiate in 2006 

• Address Mercury Emissions from 

Point Sources – Mercury is emitted to 

the air from combustion of fossil fuels, 

metal production, mining, mercurycell chlor-alkali plants, waste incinerators, zinc smelters, and other point 

sources. International efforts to build 

on a number of existing techniques to 

reduce mercury emissions from these 

point sources by sharing information 

and expertise on air control technologies and multi-pollutant approaches 

will be key. 

EPA will work with other federal agencies 

and departments to: 

• Build on bilateral agreements to 

improve inventories and introduce 

control technologies in China, 

India, and Russia. Timeline: Ongoing 

• Achieve reductions of global 

mercury emissions from the coalfired power sector through voluntary partnerships. Timeline: Initiate 

in 2006 

• Raise awareness and knowledge of 

the applicability, effectiveness and 

cost of newly emerging mercury 

and multi-pollutant control technologies. Timeline: Ongoing 

• Coordinate with the Chinese 

government, the private sector, 

Japan, and Canada to follow up on 

the workshop conducted in 

Beijing, China in November 2005 

to provide information on coalfired power plant multi-pollutant 

strategies and mercury control 

techniques, and to establish mechanisms to ensure continued information exchange with China and 

other countries. Timeline: Ongoing 

• Review data on emissions from 

international large-scale metals 

mining operations in areas with 

high mercury content ore and 

explore options for transfer of EPA 

Region 9’s Mining Voluntary 

Partnership Program. Timeline: 

2006/2007 

• Address Mercury Use in Products 

and Processes – Mercury is used 

globally in a variety of products and 

industrial processes. For most products 

and processes, there are cost-effective 
60 - EPA’s Roadmap for Mercury 

alternatives available that could replace 

mercury, which would reduce demand 

and emissions. There is a need for 

several sector-oriented approaches, 

including: (1) developing an industry 

partnership on chlor-alkali best management practices to reduce mercury 

use and emissions in countries or 

regions that use or emit the largest 

amounts of mercury; (2) reducing 

global demand for commodity-grade 

mercury through the use of inventories and partnering with national and 

international stakeholders to share 

information and approaches for 

mercury reductions and substitutes, 

particularly for measuring devices, 

batteries, and products used in the 

health care sector; and (3) promoting 

artisanal mining techniques that are 

safer and that eliminate or reduce the 

input of mercury. 

EPA will work with its federal, state, nongovernmental, industry, and international 

partners to: 

• Develop a multi-stakeholder global 

partnership on mercury-cell chloralkali sector. The partnership 

would include pilot projects; 

information exchange on best 

management practices and conversion to non-mercury processes; and 

use reporting, to reduce mercury 

releases from facilities that use or 

emit the largest amounts of mercury, including facilities in Mexico, 

India and Russia. Timeline: Initiated 

in 2005 

• Develop a multi-stakeholder global 

partnership for reducing or eliminating mercury use in products 

where there are cost-effective 

substitutes through pilot projects 

and activities, such as: 

• Sharing information and approaches for mercury reductions 

and substitutes (e.g., batteries and 

other products). 

• Conducting a mercury product 

workshop to build capacity in 

Mexico and other countries in the 

Caribbean, Central and South 

America through the CEC Mercury Task Force (U.S., Canada, and 

Mexico) in Merida, Yucatan, 

Mexico in 2006. 

• Developing country-specific use 

inventories, e.g. the Americas, 

Africa. 

• Transferring successful reduction 

programs, such as EPA’s successful 

Hospitals for a Healthy Environment program and the U.S. Green 

Suppliers Network to other countries, e.g., China. Timeline: Initiate in 

2006 

• Expand upon the UNIDO work 

on best management practices for 

artisanal mining to develop a 

multi-stakeholder global partnership on artisanal and small-scale 

gold mining to address use, exposure, and releases from this sector. 

Activities include the development 

of pilot projects, training, and 

monitoring, among others. 

Timeline: Initiated in 2005 

• Address Mercury Supply Issues – 

Given declining demand in many 

developed countries, ongoing primary 
V. Addressing International Mercury Sources - 61 

mercury mining, and growing global the waste stream. In addition, the 

supplies from secondary sources, prices global supply of commodity-grade 

for mercury are expected to decline. A mercury will increase as various secglobal mercury market surplus is ondary sources of mercury overtake 

expected by 2020 (but may occur the shrinking demand. There will be 

earlier), keeping the price of mercury an increasing need to safely manage 

low and potentially discouraging its mercury supplies for the long term. 

safe storage and management, the Actions may include: (1) sharing 

implementation of best management information on successful approaches 

practices, substitution, and phase-out. and best management practices for 

The 2005 Governing Council Deci- storage of commodity-grade mercury 

sion 23/9 requests that the UNEP and safe treatment, retorting, and 

prepare a report on mercury supply, disposal of waste, including discarded 

trade, and demand information for mercury-containing products; (2) 

consideration of possible further coordinating waste management 

action. The Decision also requests activities with the Basel Convention’s 

governments, the private sector, and capacity-building program for waste 

international organizations to take 

actions to reduce risks posed on a 

management to avoid duplication and 

to leverage resources;23 and (3) as 

global scale by mercury in products technologies come on-line, building 

and processes, such as considering capacity to create waste disposal/ 

curbing primary mercury production recycling programs for mercury-

(mining) and introduction of mercury containing batteries, lamps, scrap 

into commerce. metal, etc. 

EPA will work with the U.S. Department EPA will work with its federal and state 

of State, other federal agencies, and partners, non-governmental organizations, 

international partners to: and international partners to: 

• Share U.S. data on mercury • Share U.S. best management 

imports and exports with UNEP. practices for automobile switch 

Timeline: 2006 removal, collection, and recycling 

programs. Timeline: 2006 

• Explore mechanisms for facilitating the phase-out of primary • As previously discussed in the 

mercury mining. Timeline: Initiate in Commodity section of the 

2007 Roadmap, EPA will establish a 

• Improve Management of MercuryContaining Wastes and Surplus 

stakeholder process to address the 

mercury surplus issue. Timeline: 

Initiate in 2006 

Mercury – Mercury-containing wastes 

present significant challenges, where 

municipal, hazardous, and medical 

waste management systems are illequipped to separate mercury from 
62 - EPA’s Roadmap for Mercury 
 VI. Conducting Mercury Research and Monitoring - 63 

VI. CONDUCTING MERCURY

RESEARCH AND MONITORING

MERCURY RESEARCH OVERVIEW 

There is much mercury research underway to investigate the occurrence and 

impact of mercury in the environment. 

EPA is actively engaged in a variety of 

research activities. In 2000, EPA’s Office 

of Research and Development (ORD) 

published its Mercury Research Strategy,

1 

which provides broad strategic directions 

for EPA’s mercury research program. 

The overarching goal of the research 

strategy is to provide information and 

data that reduce scientific uncertainties 

limiting the Agency’s ability to assess and 

manage mercury and methylmercury 

risks. The strategy provides a rationale 

and framework for setting future mercury 

research priorities, which are reflected in 

EPA’s Mercury Research Multi-Year Plan 

(MYP) covering the period 2002–2010.

2 

This implementation plan contains longterm goals to: (1) reduce and prevent 

release of mercury into the environment; 

and (2) understand the transport and fate 

of mercury from release to the receptor 

and its effects on the receptor. 

In conducting its mercury research program, ORD’s in-house efforts are coupled 

with those of its Science to Achieve Results 

(STAR) Grants Program,3 which sponsors 

extramural research on many topics by 

academic institutions and other not-forprofit entities. In addition, some of EPA’s 

research is undertaken in cooperation with 

other organizations such as the U.S. 

Department of Energy (DOE) and the 

U.S. Geological Survey (USGS). Important 

coordination occurs among federal agencies and state, tribal, and local governments, through science forums such as the 

EPA/USGS Mercury Roundtable.4 It is 

also important to note that additional 
64 - EPA’s Roadmap for Mercury 

mercury research activities are conducted 

by EPA headquarters and regional offices 

that are not described in ORD’s Mercury 

Multi-Year Plan. 

The primary exposure route addressed in 

the ORD Mercury Research Strategy 

involves fish consumption where deposited 

mercury is converted to methylmercury in 

water bodies, consumed by fish, and then 

accumulated in mammals, including 

humans that eat fish. Within the context 

of this primary exposure route, EPA has 

analyzed various scientific questions, 

including the following. 

Key Scientific Questions 

• How much methylmercury in fish 

consumed by the U.S. population is 

contributed by U.S. emissions relative 

to other sources of mercury (such as 

natural sources, emissions from sources 

in other countries, and re-emissions 

from the global pool)? How much, and 

over what time period, will levels of 

methylmercury in fish in the U.S. 

decrease due to reductions in environmental releases from U.S. sources? 

• How much can mercury emissions 

from coal-fired power plant boilers and 

other combustion systems be reduced 

with innovative mercury-specific and 

multi-pollutant control technologies? 

What is the relative performance and 

cost of these approaches compared to 

currently available technologies?5 

• What is the magnitude of contributions of mercury releases from noncombustion sources? How can the most 

significant releases be minimized?6 

• What critical changes in human health 

are associated with exposure to environmental sources of methylmercury 

in the most susceptible human populations? How much methylmercury are 

humans exposed to, particularly 

women of child-bearing age and 

children among highly-exposed population groups? What is the magnitude of 

uncertainty and variability of mercury 

and methylmercury toxicokinetics in 

children?7 

• What are the most effective means for 

informing susceptible populations of 

the health risks posed by mercury and 

methylmercury contamination of fish 

and seafood?8 

EPA based the proposed and final §112(n) 

Revision Rule and the Clean Air Mercury 

Rule on the current state of the science.9 

In the context of these rules, EPA, among 

other things, identified the pertinent 

health endpoints associated with methylmercury contamination, considered the 

primary exposure pathways for ingestion 

of methylmercury, analyzed mercury 

control technologies, and considered the 

effectiveness and costs associated with 

reducing mercury emissions from coalfired power plants. EPA recognizes that 

there remain scientific uncertainties 

associated with some of the above-noted 

questions and is committed to continuing 

to work to advance the science in these 

areas. 

Progress to date. Research results provide 

important information to support EPA’s 

air, water, waste, and toxics programs in 

their ongoing efforts to address mercury. 

In recent years the major emphasis of 

research activities has been to support 

EPA’s regulatory efforts to control mercury from coal-fired power plants, and to 

increase the Agency’s understanding of 
 VI. Conducting Mercury Research and Monitoring - 65 

mercury fate and transport. The following 

are major research results from the period 

2001–2004. 

EPA researchers have developed the 

methodology and instrumentation to 

make semi-continuous ambient measurements that distinguish among mercury 

forms—elemental gaseous mercury, divalent mercury (also referred to as reactive 

gaseous mercury [RGM]), and particulate 

phase mercury. The resulting speciated 

data have improved the understanding of 

atmospheric transport and fate and 

enhanced the ability to attribute the 

relative contributions of local, regional, 

and global sources of mercury to domestic 

and global deposition.10 

EPA has produced a state-of-the-science 

atmospheric simulation model which 

incorporates the current understanding of 

chemical and physical processes involving 

mercury, including complex interactions 

with other atmospheric pollutants. This 

model uses highly efficient formulations 

and numerical methods, and has recently 

been used to simulate a full year of atmospheric mercury transport and fate over 

most of North America. Notwithstanding 

these recent advances in modeling atmospheric fate, transport, and deposition of 

mercury, there remain difficult scientific 

challenges to resolve. The Agency is 

currently working with international 

groups to better quantify atmospheric 

chemistry kinetics in Community 

Multiscale Air Quality (CMAQ) and to 

readily assess the impacts of these model 

adjustments to the fate, transport, and 

deposition of mercury.

11 

EPA has developed and tested mass balance models that use speciated atmospheric mercury deposition fluxes to 

calculate expected watershed mercury 

loadings, water body concentrations, and 

concentrations in fish. EPA’s STAR grant 

research program, in addition to its 

research in other areas, has furthered the 

understanding of the reduction-oxidation 

balance between aquatic mercury and 

atmospheric mercury, and the effect of 

this cycling on the total mercury presence 

in freshwater and marine systems. 

EPA’s research program has provided 

extensive support to Agency program 

offices and the Administrator on mercury 

control technologies, including: 

• Several comprehensive reports that 

document the development, cost and 

effectiveness of various mercuryspecific control technology options 

(including sorbent injection), and 

evaluate co-control reductions that can 

be achieved using existing technologies 

including sulfur dioxide (SO2) scrubbers and selective catalytic reduction 

(SCR)-based nitrogen oxide (NOx) 

emissions control systems;12 

• A White Paper, placed in EPA’s coalfired power plant rulemaking regulatory docket, summarizes the status of 

control technology options and outlines what can be achieved in the 

future using various alternative mercury removal technologies. This White 

Paper was updated to support EPA’s 

Office of Air and Radiation and 

enable stakeholders to identify optimal 

management approaches.13 In particular, these research results provide state 

agencies, industry, and others with the 

most current technology performance 

and cost information to inform their 

implementation decisions. 
66 - EPA’s Roadmap for Mercury 

EPA has developed a report describing the foundation for subsequent products 

impact of selected mercury control tech- including a literature review of the sources 

nologies on the characteristics of coal and remediation of mercury-contaminated 

combustion residues and how selected sediments and a model for evaluating the 

utilization/disposal practices impact the effects of remedial actions on mercury 

fate of mercury residues. As part of this speciation and transport.16 This work 

effort, ORD has generated a standard demonstrated how the introduction or 

protocol that will be used to establish the exclusion of oxygen via risk management 

leaching and thermal stability for the strategies impacted the fate and transport 

range of environmental conditions that of mercury in sediments. 

coal combustion residues are exposed to 

during storage, land disposal, and use in EPA has evaluated the effectiveness of 

commercial applications.14 several risk management strategies to 

address mercury-contaminated sediments, 

EPA has evaluated the performance of including dredging, capping, and monicontinuous emission monitors (CEMs) for tored natural recovery. Work has focused 

coal-fired power plant boilers as one on the Lavaca Bay, Texas Super-fund site. 

possible tool for measuring total and 

speciated forms of mercury emitted from EPA, as part of its effort to develop treatplants under different operating condi- ment alternatives for waste from sites 

tions.15 Based on that evaluation, the contaminated with mercury mining 

Agency has concluded that CEMs are wastes, has completed a study describing 

suitable regulatory tools. EPA’s evaluation leaching profiles of mercury-containing 

entailed a series of pilot-scale combustion waste rock and roaster tailings from a 

experiments, representing realistic coal- Superfund site in California.17 These 

fired power plant boiler measurement results were used to predict the fate and 

environments, that allowed controlled stability of mercury present, and will be 

investigation of specific measurement used to assess the suitability of any appliissues associated with mercury CEM cable remediation treatment. 

operation. Measurement results were 

obtained rapidly so that timely feedback To support EPA’s efforts to address issues 

could be provided to the monitor manu- associated with the long-term storage of 

facturers in order to optimize their instru- mercury, the Agency has: (1) completed a 

ments. The improvements accomplished report that describes a systematic method 

during the pilot-plant tests resulted in for comparing options for the long-term 

these same mercury CEMs participating in management of surplus elemental merthree full-scale utility boiler field evalua- cury in the U.S.,18 and (2) collected infortions that demonstrated their perfor- mation on state-of-the-art practices for 

mance and capabilities. These results also macro-encapsulation and micro-encapsulaapply to hazardous waste incinerators. tion of mercury-contaminated hazardous 

wastes. 

EPA has conducted a literature review to 

assess mercury methylation processes in EPA has evaluated the effectiveness of 

aquatic sediments to inform selection and some existing and future risk communicaimplementation of risk management tion tools in a variety of formats, using 18 

strategies. This provided the technical focus groups. Results show clear age, 
 VI. Conducting Mercury Research and Monitoring - 67 

gender, and risk-related trends, which 

indicate that different risk communication 

tools will be required for each of these 

audiences, and that no one tool will be 

optimally effective across the board. The 

results of this work will be published in 

2006/2007, and will add to the body of 

work outlining risk communication as an 

important tool for reducing environmental risk and protecting human health. 

EPA is working with states to conduct 

research on fish tissue. For example, 

Region 8 has collected over 500 fish 

samples over the last three years from the 

Cheyenne River Sioux Tribal lands in 

stock ponds and in the Cheyenne, 

Moreau, and Missouri Rivers. Data from 

Region 8 showed that fish from small 

ponds have high levels of methylmercury. 

This may be a function of a 

biogeochemically favorable environment 

for methylmercury production (i.e., 

methylation of elemental mercury) in 

these environments, although further 

research is needed to confirm this hypothesis. 

Region 8 has also used the data to determine Exposure Point Concentrations 

(EPC) for several species.19 The regional 

office is working with the tribe to make 

recommendations on fish stocking in 

stock dams, and also on recommendations 

about how many meals per month should 

be eaten for each species according to the 

mercury EPC for that species. 

Future focus and priority activities. EPA 

will continue to support the long-term 

goals described in the Mercury Multi-Year 

Plan and this Roadmap. The major emphasis of the mercury research program will 

continue to be the control of utility 

emissions, because utilities represent the 

most significant source of mercury release 

to the atmosphere in the United States. 

• Toxic Metals Fate Report – EPA will 

develop a report on the fate of toxic 

metals from land disposal and commercial use of coal combustion residues from plants equipped with multipollutant control technologies. 

Timeline: 2008 

• Sources of Mercury Emissions – EPA 

will develop information on sources of 

mercury emissions including the 

regional/global atmospheric fate and 

transport of such emissions. Timeline: 

2008 

How EPA Will Track

Progress and Key Trends

1. Air Emissions 

• National Emissions Inventory (EPA) 

• EPA’s primary source for air 

emissions data 

• Toxics Release Inventory (EPA) 

2. Ambient Air and Air Deposition 

• Mercury Deposition Network (MDN) 

(joint federal/state program) 

• New England Mercury Monitoring 

Network (joint EPA/state program) 

• Long Range Transport Monitoring 

(joint EPA/NOAA activity) 

3. Water Quality/Fish Tissue 

• National Fish Tissue Study (baseline 

study) (EPA) 

• National Listing of Fish Advisories 

(EPA) 

• National Coastal Assessment 

ecological monitoring (EPA) 

• Commercial fish monitoring (FDA) 

4. Human Biomonitoring 

• National Health & Nutrition

Examination Survey (CDC)
68 - EPA’s Roadmap for Mercury 

• Integrated Multimedia Modeling – 

EPA will develop an integrated multimedia modeling framework for the 

scientific understanding of mercury. 

Timeline: 2010 

MERCURY MONITORING OVERVIEW 

There are many ongoing monitoring 

projects and programs that measure 

mercury in various media. These projects 

and programs are conducted by other 

federal agencies, states and tribal governments, and in academia. Access to routine, 

ongoing monitoring information is 

needed to track environmental and health 

trends and to measure program effectiveness. 

A basic strategy for routine mercury 

monitoring is to focus on the most efficient points to monitor along the major 

transport and exposure path of air-towater-to-fish-to-humans, in order to determine trends in environmental and health 

levels and whether they are responding to 

control and reduction measures. Based on 

this mercury transport and exposure path, 

the four most important media of concern 

are: (1) air emissions, (2) ambient air and 

air deposition, (3) fish tissue, and (4) 

human tissue. The Centers for Disease 

Control and Prevention (CDC) collects 

data on human tissue, which includes 

blood, hair, and urine. Data on emissions 

and deposition allow EPA to detect 

changes quickly that reflect program 

activities with great relevance to long-term 

health and the environment. Data on fish 

and human tissue allow EPA to measure 

longer-term changes that are slower to 

respond to control measures but are better 

indicators of environmental quality and 

human health. EPA will continue to work 

with other federal agencies, states, and 

tribal governments to coordinate and 

enhance data collection for these four key 

indicators of long-term trends and program results for mercury. 

Progress to date. Much progress has been 

made by EPA and others to establish 

monitoring and reporting systems to 

collect data on mercury releases and 

contamination. During the last five years, 

in particular, EPA has encouraged and 

supported increased national monitoring 

of mercury in both fish tissue and human 

blood and hair samples, which is discussed 

in more detail below. The following 

discussion provides information on current monitoring programs conducted or 

supported by EPA, and on recent EPA 

reports that highlight significant new data 

from various mercury monitoring activities. 

Air Emissions Monitoring 

Atmospheric transport is the primary 

focus for mercury monitoring and modeling, as it is the dominant means for 

cycling mercury from anthropogenic 

sources, such as coal-fired power plant 

combustion sources, into other media. 

Emissions inventories provide information 

about the sources of mercury, and the 

relative contributions of those sources to 

total releases. Routine air emissions 

monitoring is needed to track long-term 

trends of mercury emissions over time and 

geographic space in the U.S. Such information is essential to evaluating the 

success of EPA’s programs for reducing 

mercury air emissions from specific 

sources. 

Two key EPA reporting efforts for air 

emissions are the National Emissions 

Inventory (NEI) and the Toxics Release 

Inventory (TRI). These databases have been 

modified and improved over time so that 

the Agency has the latest information 

necessary to measure program effective-
 VI. Conducting Mercury Research and Monitoring - 69 

ness and track environmental trends. (For 

further information, see Section I.) 

Ambient Air and Air Deposition Monitoring 

Both ambient air monitoring and air 

deposition networks provide information 

on mercury once it has been emitted. This 

monitoring information is needed to track 

long-term mercury contamination in 

ambient air, and to provide input to 

ongoing research and modeling activities 

to improve scientific understanding of 

mercury transport and fate in the environment; stationary and mobile sources of 

mercury; and the relative contributions of 

those sources to total mercury releases to 

the environment. 

Major routine monitoring activities for 

mercury in ambient air and air deposition 

include the following: 

• Mercury Deposition Network 

(MDN)20 – Formed in 1995, the MDN 

is part of the National Atmospheric 

Deposition Program/National Trends 

Network (NADP/NTN), a nationwide 

network of over 70 precipitation 

monitoring sites that collect weekly 

data on the chemistry of precipitation 

for monitoring of long-term geographical and temporal trends. The 

network is a cooperative effort among 

state agricultural experiment stations, 

the U.S. Geological Survey, U.S. 

Department of Agriculture, EPA, and 

numerous other governmental and 

private entities. Information from the 

MDN is being used to develop a 

national database of weekly concentrations of total mercury in precipitation 

and the seasonal and annual flux of 

total mercury in wet deposition. 

However, there are some gaps in the 

current geographic coverage of MDN 

which may limit the analysis. Also, the 

MDN does not collect data on dry 

deposition for either elemental or 

divalent mercury. At present, no 

adequate field routine measurement 

method exists. EPA and others recognize that dry deposition data are 

important—in some areas such data are 

as important as wet deposition in 

understanding total deposition. For 

these reasons, EPA announced in 

December 2005 a request for proposals to stimulate development of such 

methods. 

• New England Mercury Monitoring 

Network – EPA and the New England 

states have established a mercury 

monitoring network. A number of 

monitoring field studies have been 

initiated in New England to measure 

mercury deposition and ambient 

concentration of atmospheric mercury. These studies provide baseline 

information on mercury deposition to 

support regional efforts to control 

mercury contamination and to evaluate the ecological effects of mercury 

contamination. 

• Long Range Transport Monitoring – 

EPA, in collaboration with the U.S. 

National Oceanic and Atmospheric 

Administration (NOAA), is working 

with other countries on characterization, modeling, and speciation of 

ambient and source level mercury 

related to mercury emissions transport 

and deposition on local, regional, and 

global scales. As part of this effort, 

high and low altitude monitoring is 

being conducted at various sites, 

including Mauna Loa, Hawaii. (For 

further information, see Section V.) 
70 - EPA’s Roadmap for Mercury 

Fish Tissue Monitoring results to develop the first national 

Monitoring of fish tissue provides essential estimates of the mean concentrations 

information about the levels of mercury of mercury and 267 other chemicals in 

consumed by the human population. lake fish, to define a national fish 

Routine monitoring of marine and fresh- contamination baseline to track 

water fish consumed in the U.S. diet is progress of pollution control activities, 

needed to track trends in the level of likely and to identify areas where contamimercury exposure by the U.S. population, nant levels are high enough to waras well as trends in mercury concentrations rant further investigation. Sampling 

in fish in U.S. water bodies over time and has been conducted for four years at a 

geographic space. Information on mercury total of 500 locations, or about 125 

concentrations in fish tissue from U.S. sites annually. EPA has worked with 47 

water bodies is essential to evaluating the states, three tribes and two other 

success of EPA’s programs for addressing federal agencies to collect fish for the 

mercury releases from air, water, and land study. While planning for the study 

sources. EPA has recently developed a new began in 1998, fish sampling began in 

water quality criterion for mercury that is 2000 and ended in November 2003. 

based on the amount of mercury found in EPA has released all 4 years of raw 

fish tissue rather than the amount in data to the public. Agency analysis of 

water bodies. Fish tissue data are also the cumulative 4-year data set will be 

needed as input to research and modeling completed, and the final report will be 

activities to improve scientific understand- completed in December 2006. 

ing of mercury transport and fate in the 

environment; sources of mercury in water • EPA’s National Listing of Fish Advisobodies; and the relative contributions of ries23 – This database contains all fish 

those sources to total mercury releases to advisory information provided to EPA 

the environment. by the states, tribes, and Canada. It 

also contains information on mercury 

Many governmental organizations provide in fish tissue that states and tribes 

important monitoring data on fish, such as collect as part of their fish advisory 

FDA’s commercial fish monitoring pro- programs. States monitor their waters 

gram.21 EPA’s major monitoring activities by sampling fish tissue for persistent 

include the following: pollutants that bioaccumulate. States 

issue their guidelines voluntarily and 

• EPA’s National Lake Fish Tissue have flexibility in what criteria they 

Study22 – The National Study of use and how the data are collected. As 

Chemical Residues in Lake Fish Tissue a result, there are significant variations 

(or National Lake Fish Tissue Study) is in the number of waters tested, the 

being conducted by EPA’s Office of pollutants tested for and the threshold 

Water (OW). It is a one-time screening- for issuing advisories. Based on selflevel study to sample contaminants in reporting, the national trend is for 

fish tissue in freshwater lakes and states to monitor different waters each 

reservoirs in the contiguous U.S., year, generally without retesting waters 

including mercury as well as other monitored in previous years. States 

chemicals. EPA will use the study issue fish consumption advisories to 
 VI. Conducting Mercury Research and Monitoring - 71 

the public if elevated concentrations of 

chemicals such as mercury are found 

in local fish. EPA makes information 

about fish advisories easily accessible to 

the public on its website. 

• EPA’s Ecological Monitoring to 

Characterize the Condition of U.S. 

Estuarine Resources – As part of its 

National Coastal Assessment, EPA’s 

Office of Research and Development 

seeks to characterize the ecological 

condition of U.S. estuarine resources 

through the collection and analysis of 

fish tissue for mercury (and various 

other contaminants) from estuaries 

throughout the U.S., at about 35–100 

sites per year for each of twenty-three 

coastal states and Puerto Rico. The 

National Coastal Assessment data is a 

relatively new program in the Office 

of Research and Development, which 

is beginning to provide information 

on fish tissue toxics concentrations 

from selected U.S. estuaries. ORD is 

currently reviewing these data to 

determine their usefulness for integration with existing EPA approaches for 

assessing fish tissue mercury concentrations and their changes over time due 

to both emissions and deposition 

changes. 

States are also actively engaged in monitoring fish levels of methylmercury in 

their waters. For example, the Alaska 

Department of Environmental Conservation has been conducting a multi-year 

study of safety of fish and seafood resources in Alaska waters with respect to 

contaminants. EPA Region 10 secured 

funding for Alaska to perform additional 

PBT organic analyses, including methylmercury, and a final report is pending. 

This monitoring project is ongoing. 

Human Biomonitoring 

Routine monitoring of human tissue 

samples is needed to track long-term 

trends in the levels of mercury exposure of 

people in the U.S. over time and geographic space. CDC collects data on 

human tissue, including blood, hair, and 

urine. Such human biomonitoring may be 

the most meaningful long-term indicator 

of the effectiveness of programs for 

reducing risks associated with mercury 

releases and exposure. It is also useful in 

setting priorities for future research and 

for risk communication strategies and 

activities to reduce mercury exposure in 

the short-term. 

The level of methylmercury in blood is the 

best available indicator of human exposure 

to methylmercury through fish consumption. Mercury blood levels in women of 

childbearing age is an especially useful 

indicator of mercury exposure, since this 

measure indicates both the actual exposure 

of adult women and the potential for 

exposure of fetuses through the transfer of 

maternal blood through the placenta. 

Other types of human tissue have been 

sampled for mercury such as hair, but so 

far they have been found less useful than 

blood levels. At the present time there is 

insufficient understanding of the relationship of mercury in blood and hair to 

mercury levels found in these other 

tissues.24 

The only source of nationwide information on methylmercury in humans is the 

National Health and Nutrition Examination 

Survey (NHANES), which is conducted by 

the U.S. Centers for Disease Control and 

Prevention (CDC) with financial support 

from EPA and other agencies. NHANES is 

a continuous survey of the health and 

nutritional status of the civilian, non-
72 - EPA’s Roadmap for Mercury 

institutionalized U.S. population, and data 

are released and reported in 2-year cycles.25 

In 1999 NHANES began measuring 

mercury levels in blood, hair, and urine 

for the first time in a national sample of 

childbearing-aged women and in children 

aged 1–5 years in the U.S. The CDC’s 

report, published in 2003, provided the 

first nationally representative estimates of 

U.S. women’s and children’s exposures to 

mercury based on biologic measures.26 

In November 2004, the CDC published 

an updated summary of NHANES data for 

the four-year period 1999 to 2002.27 These 

updated findings confirm that blood 

mercury levels in women of childbearing 

age are usually below levels of concern, but 

that approximately six percent of childbearing-aged women had levels at or above 

EPA’s Reference Dose (RfD). 

CDC plans to continue this NHANES 

mercury monitoring in future years. 

NHANES 2005–2006 will include measurements of mercury species (methyl, 

ethyl, and inorganic) in blood in order to 

define more precisely the exposure to 

various sources of mercury. Blood mercury 

levels will be measured in persons (male 

and female) one-year and older, while 

urinary mercury will be measured in 

persons six years of age and older.

28 

Recent EPA Reports Utilizing Mercury 

Monitoring Data 

• America’s Children and the Environment: Measures of Contaminants, 

Body Burden, and Illness29 – Published in February 2003, this is EPA’s 

second report on trends in environmental factors related to the health 

and well-being of children in the U.S. 

The report brings together, in one 

place, quantitative information from a 

variety of sources to show trends in 

levels of environmental contaminants 

in air, water, food, and soil; concentrations of contaminants measured in the 

bodies of children and women; and 

childhood illnesses that may be influenced by exposure to environmental 

contaminants. This second report 

provides mercury information for the 

first time. The section on body burdens includes a new measure of 

mercury in the blood of women of 

child-bearing age, using NHANES 

data. A new section on emerging issues 

presents information about important 

aspects of children’s environmental 

health for which data had recently 

become available, including mercury 

in fish as an important source of 

mercury exposure for people in the 

U.S. 

• EPA’s Draft Report on the Environment 200330 – Published in June 2003, 

the report presents EPA’s first national 

picture of the U.S. environment, 

including mercury contamination. 

This report was the first step in the 

Agency’s Environmental Indicators 

Initiative, launched in November 

2001, which seeks to identify better 

indicators that EPA can use to measure 

and track the state of the environment and support improved environmental decisionmaking. 

Future focus and priority activities. EPA 

will continue to need reliable sources of 

routine mercury monitoring data. Since 

monitoring activities are resource intensive, EPA will continue its current strategy 

of focusing primarily on monitoring for a 

small number of key environmental and 

health indicators, and to leverage resources by looking for opportunities to 

collaborate with other governmental and 
 VI. Conducting Mercury Research and Monitoring - 73 

non-governmental entities where appropriate. In addition, the Agency plans to 

publish the following documents: 

• Final Results of EPA’s National Lake 

Fish Tissue Study – The final report 

will be published in 2006. EPA will use 

the study results to develop the first 

national estimate of mean concentrations for mercury and 267 other 

chemicals in fish, to provide a baseline 

to track progress of pollution control 

activities, and to identify areas where 

contaminant levels are high enough to 

warrant further investigation. 

• EPA’s Report on the Environment 

2007 – Under EPA’s Environmental 

Indicators Initiative, the Agency will 

continue working to identify better 

indicators that EPA can use to measure 

and track the state of the environment and support improved environmental decisionmaking. The next 

report to present a national picture of 

the U.S. environment, planned for 

publication in 2007, will be providing 

additional emphasis on mercury 

indicators and information. 
74 - EPA’s Roadmap for Mercury 
Appendix - 75

APPENDIX
76 - EPA’s Roadmap for Mercury 
Appendix - 77
78 - EPA’s Roadmap for Mercury 
Endnotes - 79 

ENDNOTES 

Introduction 

1. “EPA Releases 12th Annual National Listing of Fish Advisories.” Press release. August 24, 2004. 

2. EPA, 2005c. U.S. Environmental Protection Agency. National Listing of Fish Advisories. Fact Sheet, Sep. 2005. EPA-823-F-05-

004. Accessible at: http://epa.gov/waterscience/fish/advisories/fs2004.pdf. 

3. Table 1: National Air Emissions Inventory for Mercury. Source: EPA, 1999a. 

4. Figure 1: The Mercury Cycle. Adapted from EPA, 1997. Mercury Study Report to Congress. EPA-452/R-97-003, December 1997. Accessible at: www.epa.gov/ttn/oarpg/t3/reports/volume1.pdf. 

5. EPA, 2001a. 

NRC, 2000. National Research Council. Toxicological Effects of Methylmercury. Committee on The Toxicological Effects of 

Methylmercury, Board on Environmental Studies and Toxicology. Accessible at: 

http://books.nap.edu/books/0309071402/html/1.html. 

6. EPA, 1997. Mercury Study Reprot to Congress. EPA-452/R-97-003, December 1997. Accessible at: 

www.epa.gov/ttn/oarpg/t3/reports/volume1.pdf. 

7. EPA, 1997. 

8. EPA, 1997. 

9. EPA, 2005a. Technical Support Document, Revision of December 2000 Regulatory Finding on the Emissions of Hazardous Air 

Pollutants From Electric Utility Steam Generating Units and the Removal of Coal- and Oil-Fired Electric Utility Steam Generating Units from the §112(c) List: Reconsideration, Oct. 21, 2005. Accessible at: www.epa.gov/ttn/atw/utility/TSC-112finaL.pdf. 

10. A Community Multiscale Air Quality (CMAQ) modeling run was performed to estimate the impact of global sources on U.S. 

deposition estimates. For this analysis, all non-U.S. mercury input species to the model were set to zero. By comparing the results 

of this analysis with the 2001 Clean Air Mercury Rule (CAMR) base case run, which included all U.S. and global mercury 

species, the percent of total mercury deposition attributable to global sources can be estimated. The model estimated that over 80 

percent of total mercury deposition in the U.S. is attributable to global sources. 

Due to the evolving nature of mercury modeling science, such deposition estimates have associated uncertainties. For example, it 

remains difficult to distinguish between the natural emissions of mercury and the re-emission of previously deposited anthropogenic mercury and there remains uncertainty in the scientific community concerning the atmospheric processes that control the 

oxidation state of atmospheric mercury. Thus, further advances in the current understanding of mercury chemistry could 

potentially lead to changes in the modeling parameters and assumptions governing the mercury chemistry in the models and 

therefore, changes in the estimate of the fraction deposited in the U.S. attributable to global sources. 

11. EPA, 2005a. 

I. Addressing Mercury Releases 

1. EPA, 1999a. 1999 National Emissions Inventory Documentation and Data—Final Version 3.0. Accessible at: www.epa.gov/ttn/chief/net/1999inventory.html. 

2. EPA, 1999a. 

3. Table 1: National Air Emissions Inventory for Mercury. Source: EPA, 1999a. 

4. President’s Clear Skies Legislation of 2003. For information, see: www.epa.gov/air/clearskies/. 

5. EPA. Clean Air Act rules on mercury emissions. For information on EPA’s activities to control power plant emissions, see: 

www.epa.gov/mercury/control_emissions/index.htm. 

6. EPA, 1999b. Residual Risk Report to Congress. EPA 453/R-99-001, March 1999. Accessible at: www.epa.gov/ttn/oarpg/t3/reports/risk_rep.pdf. 

For information about EPA’s Residual Risk Program, see: www.epa.gov/ttn/atw/rrisk/residriskpg.html. 

7. EPA. Nevada Mining Partnership Program. For information, see: www.epa.gov/Region9/cross_pr/innovations/mining.html. 
80 - EPA’s Roadmap for Mercury 

8. EPA, 2004a. 2003 Report on Success of Voluntary Mercury Reduction Program (VMRP) with Nevada Gold Mines, October, 

2004. Accessible at: www.epa.gov/region9/toxic/mercury/goldmine.pdf. 

9. 64 Federal Register 38705, 7/19/99. 

10. EPA. Area Source Standards. For information, see: ww.epa.gov/ttn/atw/urban/arearules.html. 

11. Ecology Center, 2001. Ecology Center, Great Lakes United, and University of Tennessee Center for Clean Products and Clean 

Technologies. Toxics in Vehicles: Mercury. Accessible at: www.cleancarcampaign.org/pdfs/toxicsinvehicles_mercury.pdf. 

12. The estimate is based on data gathered from industry by EPA during the initial phase of EAF area source rulemaking which is still 

under development. 

13. EPA. National Pollutant Discharge Elimination System (NPDES) Permits. For information about this program, see: 

http://cfpub.epa.gov/npdes/. 

14. Alpers, C.N. and M.P. Hunerlach, 2000. Mercury contamination from historic gold mining in California. USGS Fact Sheet FS061-00. Accessible at: http://ca.water.usgs.gov/mercury/fs06100.html. 

15. EPA, 2005b. 2003 Toxics Release Inventory (TRI) Public Data Release eReport, May, 2005. Accessible at: 

www.epa.gov/tri/tridata/tri03/2003eReport.pdf. 

16. EPA, 2005b. 

17. EPA, 2001b. Water Quality Criterion for the Protection of Human Health: Methylmercury. EPA-823-R01-001. Accessible at: 

www.epa.gov/waterscience/criteria/methylmercury/. 

18. EPA, 2001a. 

19. 40 Code of Federal Regulations 130.7. 

20. These statistics were compiled from data received by EPA and available on its Total Maximum Daily Loads (TMDL) webpage 

accessible at: http://oaspub.epa.gov/waters/national_rept.control. 

21. EPA, 2005c. 

22. EPA, 2001b. 

23. These statistics were compiled from data received by EPA and available on its TMDL webpage accessible at: 

http://oaspub.epa.gov/waters/national_rept.control. 

24. 40 Code of Federal Regulations 132 Table 4. 

25. The average was developed by EPA based on effluent data reported by the EPA Region 5 states: Illinois, Indiana, Ohio, Michigan, 

Minnesota and Wisconsin. States discuss effluent data in reports on their web sites. For example: 

Michigan: www.michigan.gov/deq/0,1607,7-135-3313_3686_3728-11384—,00.html. 

Wisconsin: http://dnr.wi.gov/org/caer/cea/mercury/potw.htm. 

Minnesota: www.pca.state.mn.us/water/tmdl/tmdl-mercuryplan.html. 

26. Cocca, P. 2001. Mercury Maps: National Report on Human Exposure to Environmental Chemicals. Publication No. 01-0379. 

27. Clean Water Act (Federal Water Pollution Control Act, as amended) §307(b); 33 United States Code §1317. 

28. LWA, 2002. Larry Walker Associates. Mercury Source Control and Pollution Prevention Evaluation, Final Report, March 2002, 

amended July 2002. Prepared for: Association of Metropolitan Sewerage Agencies. Accessible at: 

www.amsa-cleanwater.org/advocacy/mercgrant/finalreport.pdf. 

29. San Francisco Public Utilities Commission. For information about the San Francisco Dental Mercury Reduction Program, see: 

http://sfwater.org/main.cfm/MC_ID/4/MSC_ID/85. 

30. EPA, 2005b. 

31. Surface impoundments include natural topographic depressions, man-made excavations and diked areas that primarily are made 

of earthen materials and which hold liquid wastes. These uncovered areas are commonly used to volatilize and/or settle materials. 

Other surface impoundments are surface impoundments other than those which are authorized under the Resource 

Conservation and Recovery Act (RCRA) to accept hazardous waste for disposal. 
Endnotes - 81 

32. Other land disposal is the disposal of the toxic chemical to land at the facility that does not fall into one of the other on-site 

land release categories found in Section 5.5.1 through 5.5.3 of the TRI Form R. Other disposal includes such activities as 

placement in waste piles and spills or leaks. Data from Section 5.5.4 on the TRI Form R. 

33. Mercury -Containing and Rechargeable Battery Act, 42 United States Code 14301, and EPA Universal Waste Rule. For information, see: www.epa.gov/epaoswer/hazwaste/id/univwast/regs.htm. 

34. EPA. Municipal Incinerator Rules. For information about Large Municipal Waste Combustors, see: 

www.epa.gov/ttn/atw/129/mwc/rimwc.html. 

For information about Small Municipal Waste Combustors, see: www.epa.gov/ttn/atw/129/mwc/rimwc2.html. 

35. EPA. Universal Waste Regulations. For information, see: www.epa.gov/epaoswer/hazwaste/id/univwast/regs.htm. 

36. 70 Federal Register 45508, 8/5/05. 

37. EPA. Superfund National Priorities List. For information on NPL Site Listing Process, see: 

www.epa.gov/superfund/sites/npl/npl_hrs.htm. 

38. EPA. RCRA Corrective Action Program. For information on the program, see: 

www.epa.gov/epaoswer/hazwaste/ca/backgnd.htm#5. 

39. Maine. An Act to Prevent Mercury Emissions When Recycling and Disposing of Motor Vehicles. Provision to remove mercury 

switches found at Sec. 3.38 Me.Rev.Stat.Ann.tit. §1665-A.3. Accessible at: 

http://janus.state.me.us/legis/ros/lom/LOM120th/5Pub651-700/Pub651-700-05.htm. 

40. Ecology Center, 2001. 

41. EPA, 2005d. Clean Air Mercury Rule (CAMR) and Clean Air Interstate Rule (CAIR). For information, see: 

www.epa.gov/air/mercuryrule/. 

42. 69 Federal Register 21198, 4/20/04. 

43. 68 Federal Register 70903, 12/19/03. 

44. 69 Federal Register 21906, 4/22/04. 

45. Cocca, P. 2001. 

64 Federal Register 38705, 7/19/99. 

II. Addressing Mercury Uses in Products and Processes 

1. Jasinski, S.M., 1994. The Materials Flow of Mercury in the United States. U.S. Bureau of Mines, Information Circular 9412. Accessible at: http://pubs.usgs.gov/usbmic/ic-9412/. 

2. Figure 3: Total 2001 U.S. Mercury Use in Products. Source: Lawrence, Bruce, 2001. Bethlehem Apparatus Company, Inc. 

Personal communication, June 22, 2001. 

3. Lawrence, 2001 and The Chlorine Institute, Inc., 2-006. 

4. Figure 4: U.S. Mercury Product and Process Use Trends. Sources: For 1980 through 1997: USGS. U.S. Geological Survey. Minerals Yearbook: Mercury, 1994–2001. Accessible at: http://minerals.usgs.gov/minerals/pubs/commodity/mercury/. For 2001: Lawrence, 2001 and The Chlorine Institute, Inc., 2006. 

5. Environment Canada and EPA, 1997. The Great Lakes Binational Toxics Strategy. Accessible at: 

www.epa.gov/glnpo/p2/bns.html. 

6. Environment Canada and EPA, 2004. Great Lakes Binational Toxics Strategy 2004 Annual Progress Report. Accessible at: 

http://binational.net/bns/2004/index.html. 

7. The Chlorine Institute, Inc., 2006. Ninth Annual Report to EPA for the Year 2005, May 15, 2006. Accessible at: www.epa.gov/region5/air/mercury/9thcl2report.pdf. 

8. H2E. Hospitals for a Healthy Environment. For information, see: www.h2e-online.org/. 

9. For information about legislation to reduce mercury in the New England states, see: IMERC. Interstate Mercury Education and 

Reduction Clearinghouse at: www.newmoa.org/newmoa/ntdocs/prevention/mercury/imerc.cfm. 
82 - EPA’s Roadmap for Mercury 

10. Conference of New England Governors and Eastern Canadian Premiers, 2002. Summary of School Mercury Programs in New 

England and Eastern Canada. August 2002. Accessible at: www.cap-cpma.ca/images/pdf/eng/10-mtf_school_survey_e.pdf. 

11. The Chlorine Institute, Inc., 2006. 

12. IMERC. For information, see: www.newmoa.org/Newmoa/htdocs/prevention/mercury/imerc.cfm. 

13. EPA. Environmentally Preferable Purchasing, Database of Environmental Information for Products and Services. For information, see: http://yosemite1.epa.gov/oppt/eppstand2.nsf/Pages/Homepage.html?Open. 

14. EPA. Green Suppliers Network. For information, see: www.epa.gov/p2/programs/gsn.htm. 

15. EPA. Schools Chemical Cleanout Campaign (SC3). For information, see:

www.epa.gov/epaoswer/osw/conserve/clusters/schools/index.htm.

16. EPA. National Partnership for Environmental Priorities (NPEP) Program, The Mercury Challenge. For information, see: 

www.epa.gov/epaoswer/hazwaste/minimize/mercchall.htm. 

III. Managing Commodity-Grade Mercury Supplies 

1. Lawrence, Bruce, 2002. Bethlehem Apparatus Company, Inc. World Mercury Market(s) From the Supply Side. Presentation at 

conference: Breaking the Mercury Cycle, Boston, MA, May 1–3, 2002. Accessible at: 

www.newmoa.org/Newmoa/htdocs/prevention/mercury/breakingcycle/toc.cfm. 

2. Maxson, P.A., 2004 Mercury Flows Report: Mercury Flows in Europe and the World, The Impact of Decommissioned Chloralkali Plants. European Commission. Accessible at: 

http://europa.eu.int/comm/environment/chemicals/mercury/pdf/report.pdf. 

3. Maxson, 2004. 

4. The Chlorine Institute, Inc., 2006. 

5. 69 Federal Register 23733, 4/30/04. 

6. Quicksilver Caucus, 2003. Mercury Stewardship Storage of Mercury, October 2003. Accessible at:

www.ecos.org/files/721_file_QSC_STOR_Oct_03.pdf

7. EPA, 2005f. Economic and Environmental Analysis of Technologies to Treat Mercury and Dispose in a Waste Containment 

Facility. See: www.epa.gov/ORD/NRMRL/pubs/600r05157/600r05157.pdf. 

8. EPA. Mercury Laws and Regulations. For information on how mercury is regulated under RCRA, see:

www.epa.gov/epaoswer/hazwaste/mercury/reg_stand.htm.

IV. Communicating to the Public About Mercury Exposure Risks 

1. Figure 1: The Mercury Cycle. Adapted from EPA, 1997. Mercury Study Report to Congress. EPA-452/R-97-003, December 1997. 

Accessible at: www.epa.gov/ttn/oarpg/t3/reports/volume1.pdf. 

2. EPA and FDA, 2004. What You Need to Know About Mercury in Fish and Shellfish. EPA-823-F-04-009. Accessible at: 

www.epa.gov/waterscience/fishadvice/advice.html. 

3. EPA, 2005c. 

4. “EPA Releases 12th Annual National Listing of Fish Advisories.” Press release. August 24, 2004. 

5. EPA, 2002a. Task Force on Ritualistic Uses of Mercury Report, Dec. 2002. EPA-540-R-01-005. Accessible at:

www.epa.gov/superfund/action/community/mercury.pdf.

6. EPA. Mercury Web site. For information, see: www.epa.gov/mercury/. 

7. Minnesota Pollution Control Agency. Mercury-Free Zone Program. For information, see:

www.pca.state.mn.us/programs/mercury-free/.

V. Addressing International Mercury Sources 

1. Figure 5: Where are Man-Made Mercury Emissions Originating? Source of figure: Pacyna, J., S. Wilson, F. Steenhuisen and E. 

Pacyna. 2005. Spatially Distributed Inventories of Global Anthropogenic Emissions of Mercury to the Atmosphere. Accessible at: 

(www.amap.no/Resources/HgEmissions/). Original figure presented courtesy of AMAP, Arctic Monitoring and Assessment 

Programme, Oslo, Norway. 
Endnotes - 83 

2. EPA, 2005a. 

3. Figure 6: Man-Made Air Emissions of Mercury: Distribution by Region in 1990 and 2000. Source: Pacyna, J. and J. Munthe, 

2004. Summary of research projects on mercury conducted by researchers in Norway and Sweden. Presentation at Workshop on 

Mercury, Brussels, March 29–30, 2004. Accessible at: www.ivl.se/nytt/konferenser/mercury/pacyna.pdf. 

4. UNEP, 2002. United Nations Environment Programme. Global Mercury Assessment. Accessible at: 

www.chem.unep.ch/mercury/Report/GMA-report-TOC.htm. 

5. EPA estimate based on UNEP 2002. 

6. EIA, 2004. Energy Information Administration. International Energy Outlook 2004 (annual report). Report #DOE/EIA0484(2004), April, 2004. Accessible at: www.eia.doe.gov/oiaf/ieo/. 

7. UNEP, 2002. 

8. Veiga, M. and R. Baker, 2004. Protocols for Environmental and Health Assessment of Mercury Released by Artisanal and Smallscale Gold Miners, Report to the Global Mercury Project: Removal to Barriers of Introduction to Cleaner Artisanal Gold Mining 

and Extraction Technologies, GEF/UNDP/UNIDO, Vienna, Austria, 170. Accessible at: 

www.unites.uqam.ca/gmf/intranet/gmp/files/doc/gmp/Protocols_for_Environmental%20_Assessment_2005_08_11.pdf. 

9. Veiga, M.M. and J.J. Hinton, 2002. Abandoned Artisanal Gold Mines in the Brazilian Amazon: A Legacy of Mercury Pollution. 

Natural Resources Forum, February, 2002. 

10. UNEP, 2002. 

11. This estimate is based on communication with The Chlorine Institute and review of the following two pamphlets: The Chlorine 

Institute, Inc., 2004b. Pamphlet 10, North American Chlor-Alkali Industry Plants and Production Data Report 2003, Updated 

June, 2004. The Chlorine Institute, Inc., 2004c. Pamphlet 16, Chlor-Alkali Plants Outside North America, Updated October 

2004. 

12. Source of 2,000 estimate is Lawrence, 2002. Source of 3,400 estimate is Maxson, 2004. 

13. Figure 7: Global Mercury Consumption, 2000. Source: Maxson, 2004. 

14. Environment Canada and EPA, 2005. Great Lakes Binational Toxics Strategy: Assessment of Level 1 Substances, Summary 

Report. Accessible at: http://binational.net/bns/2005/iindex.html. 

15. Conference of New England Governors/Eastern Canadian Premiers, 2003. Report to the New England Governors and Eastern 

Canadian Premiers on Mercury Projects, August 2003. Accessible at: 

http://cap-cpma.ca/images/pdf/eng/2003reportmercury.pdf. 

16. CEC. Commission for Environmental Cooperation. North American Regional Action Plan on Mercury. Accessible at: 

www.cec.org/programs_projects/pollutants_health/smoc/merc134.cfm?varlan=english. 

17. UNECE, 1998. United Nations Economic Commission for Europe. Convention on Long-Range Transboundary Air Pollution. 

Protocol on Heavy Metals. Accessible at: www.unece.org/env/lrtap/hm_h1.htm. 

18. UNEP Mercury Programme. For information, see: www.chem.unep.ch/mercury/default.htm. 

19. UNEP, 2005. Results of the Governing Council’s discussions on chemicals management, including mercury programme, at its 

23rd session in February, 2005. Accessible at: www.chem.unep.ch/mercury/GC23-results.htm. 

20. UNEP Mercury Programme Partnerships. For information, see: www.chem.unep.ch/mercury/partnerships/default.htm. 

21. UNIDO. United Nations Industrial Development Organization. Global Mercury Project. For information, see: 

www.unido.org/en/doc/4571. 

22. AMAP. Arctic Monitoring and Assessment Programme. For information, see: www.amap.no/. 

23. UNEP. Basel Convention. For information, see: www.basel.int/index.html. 

VI. Conducting Mercury Research and Monitoring 

1. EPA, 2000. Mercury Research Strategy. EPA-600-R-00-073. Accessible at: 

http://cfpub.epa.gov/ncea/cfm/recordisplay.cfm?deid=20853. 

2. EPA, 2003a. Mercury Research Multi-Year Plan. Accessible at: www.epa.gov/osp/myp/mercury.pdf. 
84 - EPA’s Roadmap for Mercury 

3. EPA. Science To Achieve Results (STAR) Program. For information, see: 

http://cfpub.epa.gov/ncer_abstracts/index.cfm/fuseaction/recipients.display/rfa_id/109. 

http://cfpub.epa.gov/ncer_abstracts/index.cfm/fuseaction/research.display/rpt/abs/rfa_id/2. 

4. USGS. The Mercury Roundtable. For information, see: http://minerals.usgs.gov/mercury/roundtable.html. 

5. EPA, 2003d. Performance and Cost of Mercury and Multipollutant Emission Control Technology Applications on Electric 

Utility Boilers; EPA/600/R-03/110; October, 2003. 

Srivastava, R.K., J.E. Staudt, and W. Jozewicz, 2004. Preliminary Estimates of Performance and Cost of Mercury Emission 

Control Technology Applications on Electric Utility Boilers: An Update. Prepared for presentation at The Combined Power 

Plant Air Pollutant Control Mega Symposium, Washington, DC, August 30–September 2, 2004. 

6. EPA, 2005a. 

7. EPA, 2005a. 

8. www.epa.gov/mercury. 

9. Revision of December 2000 Regulatory Finding on the Emissions of Hazardous Air Pollutants From Electric Utility Steam 

Generating Units and the Removal of Coal- and Oil-Fired Electric Utility Steam Generating Units from the Section 112(c) List” 

(The Section 112(n) Revision Rule) (70 FR 15994 (Mar. 29, 2005) and “Standards of Performance for New and Existing Stationary Sources: Electric Utility Steam Generating Units” (“The Clean Air Mercury Rule” or “CAMR”) (70 FR 28606 (May 18, 2005). 

10. Landis, M.S., R.K. Stevens, F. Shaedlich, and E.M. Presbo, 2002. Development and Characterization of an Annular Denuder 

Methodology for the Measurement of Divalent Inorganic Reactive Mercury in Ambient Air. Environmental Science Technology 

26: 3000–3009. 

11. Bullock, R. and Brehme, K. 2002. “Atmospheric Mercury Simulation Using the CMAQ Model: Formulation, Description, and 

Analysis of Wet Deposition Results”, Atmos. Envi., 36, pg. 2135-2146. 

12. EPA, 2003d. 

Srivastava, R.K., J.E. Staudt, and W. Jozewicz, 2004. 

13. EPA, 2005e. Control of Mercury Emissions from Coal-Fired Electric Utility Boilers: an Update, 02/18/05. Accessible at: 

www.epa.gov/ttn/atw/utility/ord_whtpaper_hgcontroltech_oar-2002-0056-6141.pdf. 

14. Kosson, D.S., H.A. van der Sloot, F. Sanchez, F. and A.C. Garrabrants, 2002. An Integrated Framework for Evaluating Leaching 

in Waste Management and Utilization of Secondary Materials. Environmental Engineering Science 19(3):159–204. 

Thorneloe, S., 2003. Presentation to EPA Science Advisory Board, Environmental Engineering Committee, Washington, D.C., 

June 17, 2003. 

Potential for Cross-media Transfers from Management of Mercury-enriched Coal Combustion Residues. Feb. 18, 2005. Available 

through www.regulations.gov at EPA-HQ-OAR-2002-0056/6139. 

15. EPA. Mercury Continuous Emission Monitors. For information, see: www.epa.gov/etv/verifications/vcenter1-11.html. 

16. Wang, Q., D. Kim, D. Dionysiou, G. Sorial and D. Timberlake, 2004. “Sources and Remediation for Mercury Contamination in 

Aquatic Sediments—A Literature Review,” Environmental Pollution 131 (2004) 323–336. 

Kim, D., Q. Wang, G. Sorial, D. Dionysiou and D. Timberlake, 2004. “A Model Approach for Evaluating Effects of Remedial 

Actions on Mercury Speciation and Transport in a Lake System,” Science of the Total Environment 327 (2004) 1–15. 

17. Randall, P.M., Chattopadhyay, S., and Ickes, J.A, 2004. Influence of pH and Oxidation-Reduction (Eh) Potential on the 

Dissolution of Mercury-Containing Mine Wastes from the Sulfur Bank Mercury Mine, Minerals & Metallurgical Processing 

Journal 21:93–98, May 2004. 

18. Randall, P.M, L. Brown, L. Deschaine, J. Dimarzio, G. Kaiser, and J. Vierow, 2004. Application of the Analytic Hierarchy 

Process to Compare Alternatives for the Long-Term Management of Surplus Mercury, Journal of Environmental Management 

71(1):35–43. Accessible at: http://dx.doi.org/10.1016/j.jenvman.2004.01.004. 

Porter, S., et al., 2004. Toxic Metals in the Environment: Thermodynamic Considerations for Possible Immobilization Strategies 

for Pb, Cd, As, and Hg, Critical Reviews in Environmental Science and Technology, 34:395–604. 

EPA, 2002b. Preliminary Analysis of Alternatives for the Long Term Management of Excess Mercury. EPA/600/R-03/048. 

Accessible at: www.epa.gov/ORD/NRMRL/Pubs/600R03048/600R03048.html. 
Endnotes - 85 

19. Discussions of the fish sample data gathered by Region 8 will be included in the Human Health and Ecological Risk Assessment 

for the Cheyenne River Basin Site. 

20. MDN. Mercury Deposition Monitoring Network. NADP. National Air Deposition Monitoring Program. For information see: 

http://nadp.sws.uiuc.edu/mdn/. 

21. FDA. U.S. Food and Drug Administration. Mercury in Fish: FDA Monitoring Program. For information, see: 

www.cfsan.fda.gov/~frf/seamehg2.html. 

22. EPA. National Fish Tissue Study. For information, see: www.epa.gov/waterscience/fishstudy/. 

23. EPA, 2005c. 

24. Mahaffey, K.R., 2005. Exposures to Mercury in the Americas. In: Pirrone, N. and K.R. Mahaffey, Dynamics of Mercury Pollution 

on Regional and Global Scales. Springer-Verlag, New York. 

25. CDC. National Health and Nutrition Examination Survey, (NHANES). For information, see: 

www.cdc.gov/nchs/about/major/nhanes/growthcharts/charts.htm. 

26. CDC, 2003. Mercury, PP. 17-19 in Second National Report on Human Exposure to Environmental Chemicals, January 2003. 

Accessible at: www.cdc.gov/exposurereport/2nd/. 

27. CDC, 2004. Blood Mercury Levels in Young Children and Childbearing–Aged Women—United States, 1999–2002. Morbidity 

and Mortality Weekly Report, November 5, 2004/53(43):1018–1020. Accessible at: 

www.cdc.gov/mmwr/preview/mmwrhtml/mm5343a5.htm. 

28. NHANES 2005-2006 Ethics Review Board Protocol. CDC, National Center for Health Statistics, Division of Health and 

Nutrition Examination Survey. 

29. EPA, 2003b. America’s Children and the Environment: Measures of Contaminants, Body Burden, and Illness. EPA 240-R-03-

001, February 2003. Accessible at: www.epa.gov/envirohealth/children/. 

30. EPA, 2003c. Draft Report on the Environment. Accessible at: www.epa.gov/indicators/roe/html/roeTOC.htm.