Risks to Health and the Environment 

Related to the Use of Mercury Products

Final Report 

prepared for 

The European Commission, DG Enterprise 

by 

Risk & Policy Analysts Limited, 

Farthing Green House, 1 Beccles Road, Loddon, Norfolk, NR14 6LT 

Tel: 01508 528465 Fax: 01508 520758 

Email: post@rpaltd.demon.co.uk 

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RPA REPORT - ASSURED QUALITY

Project: Ref/Title J372/Mercury 

Approach: In accordance with the Contract, Scoping Meeting with 

the Commission and associated discussions 

Report Status: Final Report 

Authors: Dr P Floyd & P Zarogiannis, RPA 

Dr M Crane, Crane Consultants 

Prof S Tarkowski, Nofer Institute of Occupational 

Medicine (Poland) 

Prof V Bencko, Charles University of Prague 

Approved for Issue by: Ms M Postle, Director 

Date: 9 August, 2002 

If printed by RPA, this report will be on chlorine free, 100% recycled paper. 

Risk & Policy Analysts 

Page i 

EXECUTIVE SUMMARY

Overview 

Mercury and its compounds are hazardous materials which may pose risks to people and to 

the environment. This report presents an assessment of the risks associated with the use of 

mercury in a range of products. 

The key requirements of the study were: 

• to identify usage of mercury in dental amalgam, batteries, measuring instruments (such 

as thermometers and manometers), lighting, other electrical components and other lesser 

uses; 

• to review data used to evaluate the toxicity of mercury and mercury compounds to 

humans and to the environment; 

• to derive predicted environmental concentrations (PECs) associated with use of the 

products under consideration and compare with those associated with other sources of 

mercury; and 

• to characterise the associated risks. 

Mercury Use in Products under Study

The use of mercury in the main product groups - dental amalgam, batteries, discharge lamps, 

measuring (and control) equipment and electrical control and switching equipment has been 

characterised. Although research and consultation has enabled aspects of the various 

lifecycles to be quantified, comprehensive data were not obtained for all areas with 

particular reference to the last two product groups (measuring (and control) equipment and 

electrical control and switching). 

The mercury used in the products within the EU (and the three accession countries) comes: 

from primary production (in Spain); as a by-product of non-ferrous metal production; from a 

mercury recycling plant; or as an import (usually within the product, as in the case of 

thermometers). Some data on these production routes (and associated emissions) were 

obtained but determining the precise scale and extent of the mercury ‘business’ proved 

difficult. However, it would appear that the recovery of mercury from decommissioned 

chlor-alkali facilities is rapidly become the major source of mercury within the EU. 

 

Overall, there is clear evidence that the use of mercury in batteries and lamps has 

significantly reduced in recent years. There has also been a decline in the use of dental 

amalgam and, as importantly, there has been a significant increase in the use of mercury 

recovery devices (separators) in dental surgeries. Although there has been a reduction in the 

use of mercury thermometers and sphygmomanometers (for measuring blood pressure), it 

has been difficult to estimate the overall use of mercury within this sector. Similarly, whilst 

there has been a move away from the extensive use of mercury tilt switches in domestic 

products (including cars, white goods, etc.), the extent of mercury use in other applications 

within this sector has been difficult to determine. 
Mercury Products - Risks to Health and the Environment 

Page ii 

It is estimated that the current usage of mercury in these product groups is about 120 tonnes 

per year (60% of which is associated with dental amalgam) in the EU with, perhaps, a 

further 50 tonnes per year used in the three accession countries under study (Czech Republic, 

Poland and Slovenia). It is estimated that the emissions to the environment associated with 

the production of mercury used in these products, product manufacture and product use is 

less than 25 tonnes per year. 

Mercury Use in Other Products 

Mercury is used in numerous diverse products and applications, ranging from its use in 

lighthouses (some lights revolve in a bath of mercury) to recoil suppression systems in rifles. 

However, these account for a relatively low consumption with one notable exception. It 

would appear that, perhaps, 50 tonnes per year of mercury is used in the manufacture (within 

the EU) of skin lightening creams and other cosmetic products, most of which are exported 

to, and consumed in, Africa. It should be noted that the marketing of mercury containing 

cosmetic products (with the exception of trace amounts in eye products) is not permitted 

within the EU. 

Other Sources of Mercury 

Large quantities (thousands of tonnes) of mercury are used in chlor-alkali plants throughout 

the world. Most EU countries have such plants (as does the Czech Republic and Poland) and 

current estimates of mercury consumption (within the EU) are of the order of 150 tonnes per 

year. As indicated above, the planned phase-out of mercury usage in chlor-alkali plants will 

lead to a substantial flow of recovered mercury onto the market over the next 20 years 

(perhaps 650 tonnes per year within Europe). The associated emissions (primarily to 

atmosphere) are estimated to be less than 10 tonnes per year although significant amounts of 

mercury are unaccounted for. 

 

Although mercury is a trace constituent of fossil fuels, fossil fuel consumption within the EU 

may release in the order of a further 150 tonnes per year into the environment which is 

comparable to a recent estimate that total anthropogenic emissions from the EU (and the 

three accession countries) are of the order of 160 tonnes per year. 

Apart from anthropogenic sources of mercury, there are ‘natural’ releases from forest fires, 

volcanoes and ‘evaporation’ from the oceans. Within the EU, recent estimates suggest that 

‘natural’ emissions within the EU may amount to 200 tonnes per year. 

Predicting Environmental Concentrations 

The behaviour of mercury in the environment is complex. Most releases are in elemental 

form to atmosphere which is then slowly oxidised to bivalent mercury (inorganic mercury). 

The inorganic mercury enters the terrestrial and aquatic environments through deposition. A 

portion of the inorganic mercury is methylated (particularly within sediments) to produce 

methyl mercury (organic mercury) which enters the water column. There is a general 

consensus that the key concern is organic mercury, which is highly toxic and bio-accumulates 

- particularly in fish. 
Risk & Policy Analysts 

Page iii 

For this study, the EUSES model was used (with some modifications) to predict mercury 

concentrations in the three main environmental compartments (air, terrestrial and aquatic). 

In essence, the model was run twice: 

Run 1: 100% of emissions considered to be as elemental mercury in order to obtain 

predictions for the atmospheric compartment; and 

Run 2: 100% of emissions considered to be as inorganic mercury (mercuric chloride) to 

obtain predictions for the terrestrial and aquatic compartments. 

The key inputs to the EUSES model were emissions (derived from the lifecycle analysis for 

the product groups) and toxicity data for humans and the environment. It was assumed, as a 

worst case, that the organic mercury concentrations would be 10% of the inorganic mercury 

concentrations. 

The PECs (predicted environmental concentrations) for each compartment showed that the 

products’ use, their manufacture and the production of the associated mercury contributed a 

percent to typical existing concentrations at continental level. At a regional level, the 

contribution was higher. 

At a ‘local’ level (i.e. close to production facilities), significant air concentrations (elemental 

mercury) were predicted close to the primary production site in Spain. Otherwise, local 

values were very close to the regional values.

Risks Associated with Products under Study 

Typical intakes of mercury are of the order of 10 μg/day. About 75% is elemental and 

inorganic mercury, most of which is associated with the inhalation of vapours from dental 

amalgam used in fillings. The remaining 25% is organic mercury (primarily methyl mercury 

in fish and fish products). For this study, reference doses of 2.0 and 0.1 μg per kg of 

bodyweight per day have been used as ‘safe’ levels for inorganic (including elemental) and 

organic mercury respectively. 

Risks to humans associated with exposure to mercury in the environment are considered 

against a ‘margin of safety’ (MOS) value which is derived by dividing the reference dose by 

the appropriate predicted environmental concentration (PEC). 

At a regional level, MOS values associated with elemental and inorganic mercury were found 

to be in excess of 100 (i.e. mercury intake is more than 100 times below ‘safe’ levels) whilst 

the MOS value for organic mercury was 18. 

At a local level, MOS values associated with elemental mercury and inorganic mercury were 

generally found to be in excess of 100 although the higher atmospheric emissions close to the 

primary production site in Spain led to an MOS value of 6.5 and that for lamp production 

was found to be 55. For organic mercury, the local MOS values were essentially the same as 

the regional value (18). 

 

In terms of risks to the environment, the criterion of importance is the ratio of the predicted 

environmental concentration (PEC) to the predicted no-effect concentration (PNEC). 

PEC/PNEC ratios of greater than unity are indicators that there may be a risk of concern. 
Mercury Products - Risks to Health and the Environment 

Page iv 

PEC/PNEC ratios were derived for water, sediment, soil and (local) secondary poisoning 

(poisoning through the predatory food chain). The key findings may be summarised as 

follows: 

• for water, the PEC/PNEC ratios for inorganic and organic mercury were significantly 

less than unity; 

• for sediment, the PEC/PNEC ratios were significantly less than unity for inorganic 

mercury whilst those for organic mercury were in the range 0.2 - 0.4; 

• for soil, the PEC/PNEC ratios for inorganic mercury were about 0.2; and 

• for secondary poisoning, the PEC/PNEC ratios were significantly less than unity for the 

terrestrial food chain (inorganic mercury) whilst those for the aquatic food chain 

(organic mercury) approached unity (0.9). 

Recommendations 

Overall, using the TGD/EUSES approach (with modifications), it would appear that there 

are unlikely to be significant risks to the environment associated with the mercury containing 

products under study - with particular reference to dental amalgam, batteries, lamps, 

measuring and electrical equipment. Of the products under study, the key contributor is 

dental amalgam, which accounts for over half of the mercury used. 

The modelling results suggest that the risks are primarily associated with organic mercury. 

However, given the complexity of the behaviour of mercury in the environment, the modelling 

has necessitated simplifying assumptions which clearly introduces a degree of uncertainty. 

Furthermore, changes to some critical parameters (such as partition coefficients) can make 

significant changes to the results. 

Nevertheless, in accordance with the TGD, the results suggest a Conclusion (ii) which states 

that there is at present no need for further information and/or testing and no need for risk 

reduction measures beyond those which are being applied already. To this, could be added 

or are already planned, since there are a number of Directives (Water Framework Directive, 

RoHS Directive, ELV Directive, etc.) which will lead to further controls on the usage and 

emissions of mercury. 

However, it is recognised that there is widespread concern over the presence of mercury in 

the environment and a desire to further limit the potential impacts of mercury usage. Of the 

estimated 160 tonnes per year of mercury emitted to the environment from anthropogenic 

sources in the EU and the three accession countries, the products under study account for 

less than 25 tonnes per year. There may, however, be areas where further reductions could 

be achieved in usage and/or associated emissions across the range of products examined 

here. Such reductions should be proportional to the relative emissions within the context of 

the overall anthropogenic use of mercury and the associated emissions. 

 

In relation to the products under study, dental amalgam is the largest use with over 10 tonnes 

per year of mercury being emitted to the environment. The dominant source of emissions is 

releases from crematoria and this may be an area for further investigation. Measuring and 

control equipment would also appear to be a key source with emissions of 8.5 tonnes per year 
Risk & Policy Analysts 

Page v 

- primarily to the atmosphere from landfills. Within this sector, there may be areas where 

usage and/or emissions could be reduced. The other three products areas (batteries, lighting 

and electrical equipment) have significantly lower usage and emissions. 

 

More generally, it is worth noting that the production of skin lightening creams involves the 

consumption of mercury in greater quantities than those used for measuring and control 

equipment - although this may be an area where more enforcement rather than more controls 

is required. 

It is important to stress that any proposed controls would need a further investigation of the 

advantages and drawbacks under the requirements of the Marketing and Use Directive 

(76/769/EEC). 

Finally, it is recommended that consideration should be given to classification and labelling 

under Directive 67/548/EEC based upon the developmental toxicity of methyl mercury and, 

perhaps, of other organic mercury compounds. 
Mercury Products - Risks to Health and the Environment 

Page vi 
Risk & Policy Analysts 

Page vii 

CONTENTS

EXECUTIVE SUMMARY

1. INTRODUCTION

1.1 Overview 

1.2 Background 

1.3 Sources of Information 

1.4 Structure of the Report 

2. GENERAL SUBSTANCE INFORMATION

2.1 Physico-chemical Properties of Mercury and Mercury 

Compounds 

2.2 Environmental Classification and Labelling 

2.3 Human Health Classification and Labelling 

3. GENERAL INFORMATION ON MERCURY USAGE

3.1 Overview of Mercury Production and Usage 

3.2 Dental Amalgam 

3.3 Batteries 

3.4 Lighting 

3.5 Measuring (& Control) Equipment 

3.6 Electrical Control and Switching Equipment 

3.7 Other Products 

3.8 Summary of Product Usage and Emissions 

4. OVERVIEW OF EXPOSURE TO MERCURY

4.1 Background to Discussion 

4.2 Releases of Mercury into the Environment 

4.3 Fate and Behaviour in the Environment 

4.4 Measured Levels in the Environment 

4.5 Human Exposure 

5. CALCULATIONS OF PREDICTED ENVIRONMENTAL 

 CONCENTRATIONS (PECS)

5.1 Introduction 

5.2 Production 

5.3 Formulation and Processing (Product Manufacture) 

5.4 Private Use and Recovery of Mercury in Products 

5.5 Predicted Environmental Concentrations 

Page 

i 

1 

1 

3 

4 

5 

5 

6 

9 

14 

22 

30 

36 

46 

55 

62 

63 

63 

65 

68 

71 

73 

73 

75 

77 

78 
Mercury Products - Risks to Health and the Environment 

Page viii 

CONTENTS (cont.) 

6. EFFECTS OF MERCURY 

6.1 Overview 

6.2 Environmental Toxicity 

6.3 Human Toxicity 

7. RISK CHARACTERISATION

7.1 Overview 

7.2 Risks to the Environment 

7.3 Risks to Humans 

7.4 Discussion 

 

8. OVERALL FINDINGS

8.1 Mercury Use in Products under Study 

8.2 Mercury Use in Other Products 

8.3 Other Sources of Mercury 

8.4 Predicting Environmental Concentrations 

8.5 Risks Associated with Products under Study 

8.6 Recommendations 

9. REFERENCES

 

ANNEX 1: TECHNICAL SPECIFICATION FOR STUDY

ANNEX 2: LIST OF CONSULTEES 

ANNEX 3: LIST OF MERCURY CONTAINING PRODUCTS

ANNEX 4: ANALYSIS OF AQUIRE DATA FOR CONSISTENCY

Page 

85 

85 

95 

101 

101 

104 

105 

107 

107 

108 

108 

109 

110 

113 

 
Risk & Policy Analysts

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1. INTRODUCTION

1.1 Overview 

Mercury and its compounds are hazardous materials which may pose risks to people 

and to the environment. This report presents an assessment of the risks associated 

with the use of mercury in a range of products. 

Specifically, the key elements of the study were specified in the Technical 

Specifications (reproduced in Annex 1) as follows: 

• to identify the usage of mercury in dental amalgam, batteries, measuring 

instruments (such as thermometers and manometers), lighting, other electrical 

equipment and other lesser uses; 

• to review data used to evaluate the toxicity of mercury and mercury compounds to 

humans and to the environment; 

• to derive predicted environmental concentrations (PECs) associated with the use 

of the products under consideration; 

• to characterise the associated risks; and 

• to compare these with the risks associated with other sources of mercury. 

 

1.2 Background 

European legislation has significantly reduced the use of mercury in a range of 

products in recent years. In addition, there is a number of EU Directives which 

regulate mercury in relation to health and safety, water quality, pesticides, foodstuffs, 

atmospheric emissions and waste disposal. Directives of interest include: 

• Council Directive 82/176/EEC which laid down emission limits values and 

quality objectives for mercury discharges by the chlor-alkali electrolysis industry; 

• Council Directive 84/156/EEC which laid down limit values and quality 

objectives for mercury discharges by sectors other than the chlor-alkali industry; 

• Council Directive 89/677/EEC which restricted the use of mercury in preservative 

paints used for anti-fouling and for wood, textiles and yarn; 

• Council Directive 91/157/EEC which introduced requirements for the safe 

collection/disposal of spent batteries and accumulators; 

• Council Directive 91/188/EEC which prohibited the marketing and use of mercury 

compounds in plant protection products; 

• Commission Directive 98/101/EC which prohibits marketing of batteries with 

more than 0.0005% mercury by weight (more than 2% for button cells); 

• Council Directive 2000/53/EC which prohibits use of mercury in new road 

vehicles from 2003; 
Mercury Products - Risks to Health and the Environment 

Page 2

• Directive 2000/60/EC of the European Parliament and Council which established 

the framework for, inter alia, regulating discharges to water (the Water 

Framework Directive); and 

• Proposed Directive COM (2000) 347 which, if adopted, will impose restrictions 

on the use of certain hazardous substances (including mercury) in electrical and 

electronic equipment (the RoHS Directive). 

It should be noted that under the Water Framework Directive, mercury and its 

compounds have been designated1 as ‘priority hazardous substances’ (based, in part, 

upon the recommendations of international fora - as outlined below). As such, this 

designation requires, in principle, the “cessation or phasing out of discharges, 

emissions and losses within 20 years”. However, as mercury is naturally occurring, 

this requirement is modified as follows: 

“... cessation of discharges, emissions and losses into water of those 

priority hazardous substances which derive from human activities.” 

(Decision 2455/2001/EC, para 4) 

In addition, some member countries have moved to implement a more comprehensive 

phase-out of mercury use. Examples of relevant national legislation include: 

• Denmark: Prohibition of Sale and Export of Mercury and MercuryContaining Products (Statutory Order 692 dated September 1998), which 

provides for a gradual phase-out of products containing more than 50 ppm 

mercury (i.e. 0.005% by wt); 

• Sweden: A Chemical Strategy for a Non-Toxic Environment (Bill 2000/01:65), 

which is seeking a complete phase-out of mercury in new products by 2003; and 

• Netherlands: Decree on Products Containing Mercury (dated 9 September 

1998) which is also seeking a ban on mercury-containing equipment by 2003 - 

although there are exemptions for a range of specified products. 

 

One of the aims of this study is to inform discussions on further possible restrictions 

on mercury through the provision of up to date and relevant information from across 

the EU (as well as from three accession countries - Poland, Czech Republic and 

Slovenia). 

Mercury and its compounds are also the subject of other international initiatives 

which will need to be taken into account. These include: 

• the 1998 Aarhus Protocol on Heavy Metals2 relating to cadmium, lead and 

mercury. This UN Economic Commission for Europe (UNECE) Protocol has 

been signed up to by 36 countries (including all EU states and the three accession 

countries of interest to this study). Each party which has signed the protocol is 

 

 1 Decision 2455/2001/EC of the European Parliament and Council dated 20 November 2001. 

 2

 Full text and associated information available from www.unece.org/env. 
Risk & Policy Analysts

Page 3

required to reduce their total annual mercury emissions to below 1990 levels with 

the use of best available techniques and the setting of limit values for emissions. 

With regard to mercury products in particular, the Protocol requires that the 

contracting parties should apply control measures on the content of Hg in alkalinemanganese batteries (0.05% for batteries used in extreme conditions and 0.025% 

for all other alkaline-manganese cells) and should also consider applying product 

management measures including substitution of products, reduction or substitution 

of mercury in products, appropriate labelling for safe use and disposal of products 

and use of economic instruments and voluntary agreements. Precautionary 

measures should be considered for mercury-containing measuring and electrical 

control equipment, fluorescent lamps, dental amalgam, pesticides, paints, and 

batteries; 

• HELCOM3 (the Helsinki Commission or, more formally, the Baltic Marine 

Environment Protection Commission) has an active interest in limiting mercury 

emissions to the Baltic Sea; 

• similarly, OSPAR4 (the OSPAR Commission for the Protection of the Marine 

Environment of the North-East Atlantic) has an active interest in limiting mercury 

emissions to the Atlantic Ocean; and 

• UNEP (the United Nations Environment Programme) is currently undertaking a 

Global Mercury Assessment (as discussed further below). 

1.3 Sources of Information 

The starting point for the study was two earlier studies undertaken for the 

Commission: 

• WS Atkins (1998): Assessment of the Risk to Health and to the Environment 

of Mercury Contained in Certain Products, Final Report dated August 1998. 

This report focuses on the risks associated with electrical equipment, measuring 

instruments and lighting - but not batteries nor dental amalgam; and 

• ERM (1998): Analysis of the Advantages and Drawbacks of Restricting the 

Marketing and Use of Mercury in Certain Products, Final Report dated 

December 1998. This report focuses on the potential for substitution of mercury 

in dental amalgam, electrical equipment, measuring instruments and lighting - but 

not batteries. 

In order to extend and refine the data presented in these reports, there has been an 

extensive review of literature and other sources of information as well as consultation 

with a range of interested parties. Particular attention has been given to recent 

submissions to the Global Mercury Assessment being co-ordinated by UNEP. 

Submissions from EU Governments and others can be inspected (and downloaded) 

 

 3 The contracting parties are Denmark, Estonia, European Commission, Finland, Germany, Latvia, 

Lithuania, Poland, Russia and Sweden. Further information is available from www.helcom.fi. 

 4

 The contracting parties are Belgium, Denmark, European Commission, Finland, France, Germany, 

Iceland, Ireland, Luxembourg, the Netherlands, Norway, Portugal, Spain, Sweden, Switzerland and the 

UK. Further information is available from www.ospar.org 
Mercury Products - Risks to Health and the Environment 

Page 4

from www.chem.unep.ch/mercury. This website is a valuable resource containing 

current information from a wide range of countries and organisations, as well as a 

large collection of relevant reports and other documents. UNEP has prepared an 

initial draft report on the submissions received (UNEP, 2002). 

Further information on the changing usage of mercury-containing products has been 

sought from the Europroms database5

. The focus of this data-base is on trade (i.e. 

imports and exports) with EU members states, both ‘intra EU’ and ‘extra EU’. 

However, these data do not provide a direct route to reliably estimate usage by 

individual member states (nor, indeed, by the EU-15 as a whole). Against this 

background, the Europroms data have been used to illustrate trends in usage rather 

than as a primary source of usage data. 

1.4 Structure of the Report 

An overview of the properties of mercury and its compounds is presented in Section 2 

with a detailed review of mercury usage in products presented in Section 3. 

The complex behaviour of mercury in the environment together with an overview of 

typical concentrations in the EU environment are presented in Section 4. 

The predicted environmental concentrations (PECs) associated with the usage of 

mercury in products are presented in Section 5. Section 6 provides a review of the 

toxicity of mercury and its compounds to people and to the environment. 

Combining the results from Sections 5 and 6 enables an estimate to be made as to 

whether there are significant risks associated with the products under consideration 

and this is presented in Section 7. Section 8 summarises the overall findings. 

 

 

 

 5 Eurostat (2001): Europroms - European Production and Market Statistics, data-base available 

from the European Commission which includes comprehensive data on products on a quarterly and 

annual basis up until 1999. 
Risk & Policy Analysts

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2. GENERAL SUBSTANCE INFORMATION 

2.1 Physico-chemical Properties of Mercury and Mercury Compounds 

Physico-chemical properties and classification numbers of mercury and mercury 

compounds of relevance are summarised in Table 2.1. 

Table 2.1: Main Physico-chemical Properties and Chemical Registration Numbers of 

Mercury and Mercury Compounds 

Substance Formula CAS No. 

(EC No.) 

Molecular

Weight 

Melting 

point o

C 

Boiling 

point oC 

Solubility 

in water 

Mercury Hg 7439-97-6 

(231-106-7) 201 -39 357 0.06 mgl-1

Mercuric 

chloride HgCl2

7487-94-7 

(231-299-8) 271 276 302 69,000 mgl-1

Mercuric 

sulphide HgS 1344-48-5 (215-696-3) 233 sublimes at 400 n/a insoluble 

Mercuric 

oxide HgO 21908-53-2 (244-654-7) 217 500 n/a 50 mgl-1

Methyl 

mercury * CH3Hg+

 22967-92-6 216 

Methyl 

mercuric 

chloride 

CH3Hg Cl 115-09-3 

(204-064-2) 251 170 n/a near insoluble 

Dimethyl 

mercury 

C2H6Hg 593-74-8 

(209-805-3) 231 -43 92 9,000 mgl-1

Sources: Croner (1999): Substances Hazardous to the Environment, London, Croner 

Publications; ChemFinder Internet site, www.chemfinder.com; and Sigma-Aldrich Material Safety 

Data Sheets. 

* Note that methyl mercury is an ion rather than a chemical compound and, as such, does not exist 

in a ‘free’ state. 

2.2 Environmental Classification and Labelling 

Commission Directive 98/98/EC of December 1998 (which adapted Council 

Directive 67/548/EEC on the Classification, Packaging and Labelling of 

Dangerous Substances to technical progress for the 25th time) introduced 

environmental classification and labelling for mercury and its compounds as shown in 

Table 2.2. 

 

Table 2.2: Classification of Mercury Compounds for Environmental Effects 

Substance Classification Risk Phrases 

Mercury 

Inorganic mercury compounds in 

general (except mercuric 

sulphide) 

Organic mercury compounds in 

general 

N: Dangerous to the 

environment 

R 50/53: Very toxic to aquatic 

organisms, may cause longterm adverse effects in the 

aquatic environment 
Mercury Products - Risks to Health and the Environment 

Page 6

2.3 Human Health Classification and Labelling 

Mercury and mercury compounds of interest for this study have also been given 

classifications under Directive 67/548/EEC for human health and safety. These are 

summarised in Table 2.3. 

Table 2.3: Classification of Mercury Compounds for Human Health and Safety

Substance Classification Risk Phrases Safety Phrases 

Mercury Toxic (T) R 23 

R 33 

S (1/2); S 7; S 45; 

S 60; S 61 

Mercuric chloride Very Toxic (T+) 

Corrosive (C) 

Toxic (T) 

R 28 

R 34 

R 48/24/25 

S (1/2); S 36/37/39; 

S 45; S 60; S 61 

Mercuric oxide (and inorganic 

mercury compounds in general 

- but with some exceptions) 

Very Toxic (T+) R 26/27/28 

R 33 

S (1/2); S 13; S 28; 

S 45; S 60; S 61 

Organic mercury compounds in 

general 

Very Toxic (T+) R 26/27/28 

R 33 

S (1/2); S 13; S 28; 

S 36; S 45; S 60; S61 

Sources: The National Chemical Emergency Centre UK Internet site, www.the-ncec.com 

 International Labour Organisation, International Chemical Safety Cards 

Note: Classifications confirmed on www.kemi.se/nclass which maintains data on classification 

on behalf of the European Chemical Bureau (ecb.jrc.it/classification_labelling). Latest 

classification for mercury and its compounds is based on 25th ATP (Directive 98/98/EC). 

Risk Phrases:

 R 23 Toxic by inhalation; 

R 26/27/28 Very toxic by inhalation, in contact with skin and if swallowed; 

R 28 Very toxic if swallowed; 

R 33 Danger of cumulative effects; 

R 34 Causes burns; and 

R 48/24/25 Toxic: danger of serious damage to health by prolonged exposure in 

contact with skin and if swallowed. 

Safety Phrases:

S 1/2 Keep locked up and out of reach of children; 

S 7 Keep container tightly closed; 

S 13 Keep away from food, drink and animal feeding stuffs; 

S 28 After contact with skin, wash immediately with plenty of water; 

S 36 Wear suitable protective clothing; 

S 36/37/39 Wear suitable protective clothing, eye/face protection and gloves; 

S 45 In case of accident or if you feel unwell, seek medical advice 

immediately (show label where possible); 

S 60 This material and its container must be disposed of as hazardous waste; 

and 

S 61 Avoid release to the environment. Refer to special instructions/safety 

data sheet. 
Risk & Policy Analysts

Page 7

It should be noted that risk phrases associated with substances toxic to reproduction 

are not currently applied to mercury and its compounds. Such phrases include: 

R 60 May impair fertility; 

R 61 May cause harm to the unborn child; 

R 62 Possible risk of impaired fertility; and 

R 63 Possible risk of harm to the unborn child. 

As explored in more detail in Section 6.3, developmental toxicity effects are 

considered to occur with exposure to low levels of methyl mercury. On this basis, 

and with reference to the guidance provided by the 28th ATP6, it would appear that 

methyl mercury (at least) could be designated a Category 1 substance (due to 

observed developmental toxicity in humans) and require the risk phrase R61. For 

other organic mercury compounds, it may be the case that a Category 3 designation 

(‘substances which cause concern for humans owing to possible developmental toxic 

effects’) and an associated R63 risk phrase is more appropriate. 

 

 6 Commission Directive 2001/59/EC of August 2001 (which adapted Council Directive 67/548/EEC on 

the Classification, Packaging and Labelling of Dangerous Substances to technical progress for the 

28th time). 
Mercury Products - Risks to Health and the Environment 

Page 8
Risk & Policy Analysts

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3. GENERAL INFORMATION ON MERCURY USAGE 

3.1 Overview of Mercury Production and Usage 

3.1.1 Introduction 

There are three sources of mercury for use in the products of interest: 

• extraction of mercury from mercury ore; 

• production of mercury as a by-product of non-ferrous metals processing; and 

• recovered mercury from waste streams and other sources. 

The general picture has changed dramatically in the last few years with the 

commitment of the chlor-alkali industry to phase-out the use of mercury cells in 

European chlorine production. This will lead to the recovery and potential re-use of 

perhaps 15,000t of mercury over the next 20 years (ERM, 2000). 

 

3.1.2 Mined (Primary) Production 

Mercury is a naturally occurring metallic element, found in rocks, soils and 

sediments, which comprises part of the earth’s crust at levels of approximately 0.5 

ppm. It is commonly found as the red sulphide ore, cinnabar (HgS), which provides 

the main source of mined mercury. 

The worldwide primary production of mercury peaked in the early 1970s at about 

10,000 tonnes per annum. Since then, there has been a steady decline to perhaps 

1,650 tonnes in 2000 (USGS, 2001) as presented in Table 3.1. Estimated world 

resources are about 600,000 tonnes - mainly in Kyrgyzstan, Russia, Slovenia, Spain 

and Ukraine. World reserves (i.e. currently accessible) are estimated to be 240,000 

tonnes (see Table 3.1). The decline in production has been accompanied by a 

dramatic decline in price from around €1,000 per flask7 in the late 1960s to less than 

€100 per flask in 1991, compared with a current price of about €180 per flask (i.e. 

about €5 per kg). 

Within the EU, Minas de Almadén y Arrayanes SA (MAYASA) of Spain is the main 

producer (accounting, historically, for more than 30% of the world’s mined 

production) with smaller amounts being produced in Finland (as a by-product of zinc 

mining at Kokkola - see below) and, formerly, at the Idrija mine in Slovenia as set out 

in Table 3.2. Also, the cinnabar mines of Mount Amiata in Italy were a major source 

of mercury for many centuries but were finally closed in 1976. Of note is that nearly 

75% of Spain’s current sales is exported to Asia with only 15% (about 150 t/year) 

being used within the EU (consultation). Of the three accession countries of interest, 

only Slovenia is associated with the primary production of mercury. 

 

 7 Quantities of mercury are often expressed in flasks. One flask is about 2.5 litres and weighs 34.5 kg. 
Mercury Products - Risks to Health and the Environment 

Page 10

Table 3.1: Mercury World Mine Production 1996-2000 (metric tonnes) 

Country 1996 1998 2000* Reserves 

Algeria 368 224 240 3,000 

China 510 230 200 

Finland 88 54 45 

Italy 0 0 0 69,000 

Kyrgyzstan 584 620 550 13,000 

Mexico 15 15 25 

Russia 50 50 50 

Slovakia 0 20 0 

Slovenia 5 5 0 

Spain 862 675 500 90,000 

Tajikistan 45 35 40 

Ukraine 30 20 ? 

USA ? ? ? 

Other 0 0 0 61,000 

World Total 

(rounded) 2,560 1,950 1,640 240,000 

* estimates (by US Geological Survey - USGS) 

Source: USGS, 2001

 

Table 3.2: Mercury Primary Production in EU and the 3ACs1 (1996-2000) (metric tonnes)

Country 1996 1997 1998 1999 2000 

Spain2 1053 863 675 1352 (sales) 1095 (sales) 

236 (mined) 

Slovenia 5 5 5 closed closed 

Sources: USGS (2001) and consultation. 

Notes: 

1) 3ACs = Czech Republic, Poland and Slovenia 

2) The figures for Spain are derived from direct consultation with MAYASA and that ‘sales’ now 

include mined production, recovered mercury from the chlor-alkali industry and sales from stock. It 

will be noted that in 2000, the actual mined production was 236 tonnes, much lower than the 500 

tonnes estimated by USGS (as presented in Table 3.1). 

3.1.3 Production from Non-Ferrous Metals Processing 

Many ores contain traces of mercury and their processing (usually involving heat) 

generates mercury vapour which is recovered from the gas cleaning stream. Due to 

the large quantities of ores, even low concentrations of mercury can generate 

significant quantities (for example - 200,000 t/year of ore containing 0.01% mercury 

will produce 20 t/year). Within the EU, the overall mercury production rate is 

estimated to be about 350 t/year (EC, 2001), primarily associated with zinc and lead 

smelting/refining. Within the EU, there are 10 zinc smelters with capacities of greater 

than 100,000 t/year and 7 primary lead smelters/refiners with capacities of greater 
Risk & Policy Analysts

Page 11

than 40,000 t/year located in Belgium, France, Germany, Italy, the Netherlands, Spain 

and the UK. There is also extensive lead/zinc mining and processing in Poland 

(especially in the Tarnowskie Góry area). It is worth noting that although Ireland 

mines the most zinc ore in Europe, the associated processing is carried out in Finland. 

Of the associated mercury recovery operations, those in Finland have been regularly 

recorded as primary mercury production as shown in Table 3.3. However, 

consultation with some of the other large zinc smelters indicates much lower 

quantities of mercury being produced which, in some cases, is sent directly to landfill 

in the form of mercurous chloride (calomel). 

Table 3.3: Mercury Production in Finland (1996-2000) (metric tonnes)

Country 1996 1997 1998 1999 2000 

Finland 88 63 54 55 77 

Sources: Finnish Ministry of Trade and Industry (www.gsf.fi/explor/finmipr9800.htm) and USGS 

(2001). 

3.1.4 Reclaimed Mercury (Secondary Production) 

Factors including moves to minimise releases of mercury to the environment have led 

to an increase in the recovery of mercury from waste products. By way of example, 

Finland has one plant recovering mercury from dental amalgam. Similarly, a mercury 

recycling facility in Manchester, UK8 recovers mercury from lights, dental amalgam, 

button cells and thermometers and the mercury is reused in lights, barometers and 

other uses. 

Although the overall quantity of secondary (reclaimed) mercury production (within 

the EU and the three accession countries) is difficult to estimate, it was, until recently, 

perhaps of the order of 50 t/year. However, the situation has now changed 

dramatically as the mercury from decommissioned chlor-alkali plants begins to enter 

the market. By way of example, MAYASA reports that 400t of mercury from 

decommissioned chlor-alkali plants were processed for re-sale in 2000. In the coming 

years, the chlor-alkali industry would be expected to generate about 650 t/year (i.e. 

15,000 tonnes over the period 1998-2020). 

 

3.1.5 Trade in Mercury 

Recent data from Europroms indicate that the EU is a net exporter of mercury, as 

shown in Table 3.4. 

Table 3.4: EU Trade in Elemental Mercury (i.e. not in products) 

Year Imports into EU Exports from EU Exports from Spain 

1997 250t 810t 510t 

1998 120t 670t 300t 

1999 430t 910t 510t 

Source: Europroms data 

 

 8 See www.mercuryrecycling.co.uk 
Mercury Products - Risks to Health and the Environment 

Page 12

As indicated in Section 1.3, caution must be exercised in relying on data such as those 

presented in Table 3.4. Nevertheless, as would be expected, the export figures are 

dominated by those from Spain (MAYASA) although the Europroms values are 

slightly lower than those provided by MAYASA. In relation to the products under 

study, there are imports (into the EU) of products containing mercury (such as 

thermometers and batteries). However the imported quantities of liquid mercury as a 

‘raw’ material for these products is likely to be limited9

. In other words, the imported 

quantities of mercury required for the products under consideration are likely to be 

well below the quoted figure of 400 t/year. Possible explanations include: 

• imported figures include figures for material that is re-exported (for example, in 

transit through the Port of Rotterdam in the Netherlands); 

• some imports may be destined for mercury recovery plants; and 

• some imports may be destined for use in chlor-alkali plants. 

Indeed, the ‘real’ situation may be more complex. By way of example, the 1999 

imports include over 60t destined for Spain, which according to MAYASA, were reexported with minimal processing. Although efforts have been made to clarify other 

key national figures for recent imports and exports with the relevant national 

authorities, these have not produced any useful data. 

3.1.6 Overview of Mercury Uses 

Mercury is found in a wide range of products including dental amalgam, 

pharmaceuticals, thermometers, manometers, batteries, fungicides/pesticides, 

fluorescent tubes, high-pressure lights, neon lighting, thermostats (and other switch 

sensors) on heating/ventilation systems, industrial plant controls, electrical equipment 

(relays, etc.), mercury cells used in chlorine production, etc. 

This study is focused on the use of mercury in certain products and excludes mercury 

usage in chlorine production, for pharmaceuticals and for agrochemical purposes. 

The main use ‘types’ have therefore been defined as follows: 

• dental amalgam (see Section 3.2); 

• batteries (see Section 3.3); 

• lighting (see Section 3.4); 

• measuring and control equipment (see Section 3.5); 

• electrical equipment (see Section 3.6); and 

• other products (see Section 3.7). 

 

There are few estimates of the current consumption of mercury in the EU. In the mid1990s, the usage of mercury within the above product groups was estimated as 

summarised in Table 3.5. Current usage (for 2000) for the EU-15 countries together 

with that for the three accession countries is also presented, based on the results of 

data collection carried out for this study. 

 

 9 By way of example, some dental products (including sachets of mercury) are imported from suppliers 

located in Australia and the US. 
Risk & Policy Analysts

Page 13

Table 3.5: EU Mercury Consumption by Product Group (t/year) 

20003

Product mid-1990s1 19962

EU-15 3ACs 

Dental amalgam not given 69 70 20 

Batteries not given 5 - 8 8 1 

Lighting 21 >12 5.2 0.7 

Measuring and control 

equipment 56 <63 28 5 

Electrical equipment 28 not given 8 1 

Sub-totals: >105 c150 119.2 27.7 

Other products <2 73 c50 c5 

All of the above: >107 c220 c170 c33 

Sources: 1) WS Atkins (1998); 2) Eurochlor (1999); and 3) based on information presented below 

where the 3ACs = Czech Republic, Poland and Slovenia. 
Mercury Products - Risks to Health and the Environment 

Page 14

3.2 Dental Amalgam 

3.2.1 Overview 

Mercury-based dental amalgam contains 40-50% mercury which is mixed with other 

powdered metals prior to insertion into the dental cavity. Mercury may be applied 

from a dispenser or from capsules (generally 400 or 600 mg). The typical filling uses 

0.7 g amalgam (i.e. 350 mg mercury) and the residual mercury (and associated waste) 

is usually collected in situ. 

3.2.2 Control Issues 

At the outset, it is important to emphasise that measures to control the use of mercury 

amalgam are primarily a result of concerns over subsequent releases to the 

environment rather than over health risks to patients. Nevertheless, it is recognised 

that oral health personnel may be exposed to mercury vapour during frequent 

amalgam preparation and insertion with an associated low level of risk. In order to 

minimise such risks, dentists are provided with authoritative advice on best practice 

for amalgam usage10. 

At an International Level 

The position of OSPAR (2000) is that the earlier PARCOM recommendation 93/2: 

“equipment should be installed to separate water and amalgam to enable collection of 

the amalgam as from 1 January 1997” has largely been implemented by OSPAR 

signatories. Reduction in mercury usage and increased use of amalgam separators is 

also encouraged by the Aarhus Protocol (UNECE, 1998). 

At a National Level 

 A summary of controls at a national level is provided in Table 3.6. 

Table 3.6: National Controls for Dental Amalgam 

Country Control Source & Comment 

Austria All surgeries are provided with amalgam separators consultation 

Belgium All surgeries in process of being provided with 

amalgam separators 

consultation 

Denmark Being phased out under Order 692 and may only be 

used in molar teeth to replace worn fillings. Amalgam 

separators in all public health dentists 

HELCOM (2001), 

consultation 

Finland In line with HELCOM Recommendation 6/4, waste 

water may only be discharged after 95% amalgam 

separation - Council of State Decision 112/1997. 

Currently, >90% surgeries have separators 

Submission to UNEP 

(2001), HELCOM 

(2001) and consultation 

France As of 2000, all surgeries require separators and 

amalgam used must be pre-dosed (thus avoiding 

‘loose’ mercury) 

INRS (2002) 

 

 10 See, for example, FDI World Dentist Federation (1999): Recommendations on Dental Mercury 

Hygiene, based on FDI General Assembly 1998 and available from www.fdi.org.uk. 
Risk & Policy Analysts

Page 15

Table 3.6: National Controls for Dental Amalgam 

Country Control Source & Comment 

Germany Since 1990, a minimum of 95% mercury collection 

required from amalgam separators which are provided 

in nearly all surgeries 

OSPAR (1997), 

submission to UNEP 

(2001) & consultation 

Greece Separators not required consultation 

Netherlands Since 1994, a minimum of 95% mercury collection 

required from amalgam separators 

OSPAR (1997) 

Portugal All surgeries in process of being provided with 

amalgam separators (currently 20%) 

consultation 

Sweden Since 1985, a minimum of 95% mercury collection 

required from amalgam separators. All surgeries 

provided with separators 

OSPAR (1997) 

United 

Kingdom 

As of 1997, 25% of surgeries provided with separator. 

New guidance recommends wider provision to 

implement PARCOM recommendation 93/2 

WS Atkins (1997) 

DEFRA (2001) 

Poland Separators not required but extracted amalgam fillings 

are collected and treated 

consultation 

Czech Republic Separators required for new dentist chairs from January 

2002. By January 2005, all surgeries must be provided 

with separators 

consultation 

3.2.3 Quantities Used 

EU Wide 

No estimate of mercury usage in dental amalgams is provided by WS Atkins (1998) 

nor by ERM (1998). Estimates for 1990 and 2000 based on the more detailed 

information presented below suggests that the mercury consumption in the EU in 

dental amalgam was likely to have been of the order of 110 t/year in 1990 which has 

now reduced to the order of 70 t/year with, perhaps, a further 20 t/year used in the 

three accession countries. 

 By Country 

More detailed information on the use of mercury dental amalgams by country is 

presented in Table 3.7. 

Table 3.7: Dental Amalgam Consumption by Country (t/year) 

Country c1990 c2000 Source & Comment 

Austria Amalgam usage has not changed in recent 

years (consultation) 

Belgium 3.7 (1990) OECD (1995). Amalgam usage reduced 

by >25% in recent years (consultation) 

Denmark 2.0 (1991) 

1.8 (1992/3) 

c1.0 (current) OECD (1995), HELCOM (2001) & 

consultation. Amalgam usage reduced 

>50% amongst children in recent years 

Finland 1.2 (1987) c1.0 (1996/97) 

<0.2 (current) 

OECD (1995), consultation. Amalgam 

usage reduced >50% in recent years - now 

very limited 
Mercury Products - Risks to Health and the Environment 

Page 16

Table 3.7: Dental Amalgam Consumption by Country (t/year) 

Country c1990 c2000 Source & Comment 

France 16.0 (1990-92) 20-25 (current) OECD (1995), detailed report with French 

submission to UNEP (2001) 

Germany 24.1 (1985) 

29 (1993) 

 OECD (1995), submission to UNEP 

(2001) and consultation. Amalgam usage 

reduced 30-40% in recent years 

Greece Usage reduced by >50% in recent years 

(consultation) 

Ireland 1.6 (1996) CTC (1999) 

Netherlands 5.5 (1989) 

5.2 (1990) 

 OECD (1995), Slooff et al. (1995) 

Portugal Usage reduced by >50% in recent years 

(consultation) 

Sweden 1.7 (1991) OECD (1995). Amalgam usage reduced 

by >50% in early 1990s (submission to 

UNEP (2001) 

United Kingdom 11.4 (1989-90) 12 (1997) OECD (1995), WS Atkins (1997) - 

amalgam usage reduced by >25% in 

period 1992-97 

EU Total c110 c70 RPA estimates 

Poland 13* 13* Amalgam used in about 60% of fillings. 

Similar practice to Germany of early 

1990s with no reduction (consultation) 

Czech Republic 5.8* 5.8 Amalgam usage not declining - and may 

even be increasing as covered by national 

health insurance (consultation) 

Note: * RPA estimate 

As a first estimate, it can be seen from Table 3.7 that about 70 t/year was used by 

about 65% of the EU-15 population in 199011 giving an EU-15 total consumption of 

the order of 110 t/year. Consultation with dental associations (and other sources) 

suggests that this value has dropped significantly in most EU countries in recent years 

- perhaps to 70 t/year with, perhaps, a further 20 t/year used in the three accession 

countries. 

3.2.4 Lifecycle and Emissions 

Manufacture 

Dental amalgam is formulated in the dental surgeries. The most common method is 

the use of mixing pre-packed capsules of alloy particles and mercury, although ‘bulk’ 

mercury is still used (particularly in the UK). 

The mercury used in dental surgeries may have passed through several stages (and 

several companies) as illustrated below: 

 

 11 Base information (such as population data) on the EU-15 and accession countries is taken from the 

Eurostat Yearbook (EC, 2001). 
Risk & Policy Analysts

Page 17

• Company A produces mercury (primary or secondary). Such producers include 

MAYASA and mercury recovery facilities. As discussed earlier, these may well 

now include some of the chlor-alkali facilities; 

• Company B refines mercury (in some cases) to produce high quality (tripledistilled) mercury which is packaged in capsule (or sachet) form. There are major 

facilities in Germany and the Netherlands; 

• Company C packages capsules with alloys for distribution. This is generally 

undertaken by national companies using supplies originating from within the EU - 

although there may be some imports as well; and 

• Company D distributes mercury amalgam to dentists together with a wide range of 

other dental supplies. Within the EU, this market appears to be dominated by two 

non-EU companies 

In relation to emissions of mercury to the environment, it can be seen that the focus of 

attention will be on Companies A and B since no emissions would (normally) be 

associated with Companies C and D. 

Usage 

The use of mercury amalgam for dental fillings generates waste. The waste includes 

excess amalgam, old fillings which have been drilled out and amalgam present in 

teeth being extracted. 

Although the new separators will recover 95% or more of the waste amalgam, it is 

sometimes claimed that the prior use of traps and filters provided a reasonably high 

recovery rate. A study in Denmark found that the mercury in waste water reduced 

from 57g to 8g per dentist per year with separators fitted (as reported in ArenholtBindslev, 1998). These figures can be used to indicate the recovery rate from traps 

and filters as illustrated in Box 3.1. 

Box 3.1: Recovery with & without Separators 

Suppose waste quantity was X g/dentist/year and the recovery rates without separators (but 

with traps and filters) and with separators were A and B respectively. Then, using the waste 

water figures of 57 and 8 g/dentist/year gives: 

for the ‘without separators’ situation: X - AX = X (1- A) = 57; and 

for the ‘with separators’ situation: X - BX = X (1 - B) = 8 

 Then, (1-A)/(1-B) = 57/8 = 7.1 which gives: 1 - A = 7.1 - 7.1B; which gives 7.1B - 6.1 = A 

Now, if the separators gave a recovery rate of, say, 95%, then B = 0.95, giving: A = 0.64 

and if the separators gave a recovery rate of, say, 98%, then B = 0.98, giving: A = 0.86 

In other words, the Danish work suggests that recovery rates using filters and traps would be 

of the order of 64-86%. 
Mercury Products - Risks to Health and the Environment 

Page 18

Taking account of the calculation presented in Box 3.1 and given the widespread 

implementation of separators within the EU, we estimate an overall recovery rate of 

around 90%. Once collected, most amalgam is sent to metal recycling plants for 

mercury recovery - although extracted teeth (which may contain amalgam fillings) 

tend to be disposed of as clinical waste. 

Crematoria

In 1999, 3.5 million people died in the EU and a further 0.5 million died in the three 

accession countries. Over 30% of the dead (1.2 million = 4 million x 0.3) were 

cremated. The cremation rates vary greatly from near 0% in Greece and Poland to 

over 70% in Denmark and the Czech Republic12. If it was assumed that there were 8 

fillings with 350 mg of Hg per person cremated, this would give a maximum emission 

(in the EU and three accession countries) of: 1.2 million x 8 x 350 x 10-9 = 3.4 tonnes 

of mercury vapour. 

Emissions to Environmental Media 

For this and the other products under consideration, the estimation of mercury 

releases has been based on the two-stage approach used in Sweden (KEMI, 1997): 

• the estimation of the distribution factors for the different pathways; and 

• the estimation of emission factors for the subsequent releases to air and water. 

Distribution factors 

 

For new fillings, the assumed distribution is 60% to new fillings, 20% excess 

amalgam (which is recovered), 20% amalgam to waste (90% of which is recovered 

and 10% to sewer). For a current usage of 90 t/year (in the EU and the three 

accession countries), this would lead to 54 t/year being inserted in new fillings. 

For existing fillings (which have a typical life span of around 10 years), the assumed 

distribution is: 65% to waste (i.e. old filings being drilled out); 10% in extracted teeth 

(or lost) which are then sent to (clinical) waste (with 25% incineration); and 25% in 

corpses (with a 30% cremation rate). As indicated in Table 3.7, the usage ten years 

ago was about 130 t/year (in the EU and the three accession countries), of which 78 

t/year (i.e. 60% of 130 t/year) would have been expected to have gone into fillings at 

that time. Ten years on, these fillings will have come to the end of their life which 

would give rise to a current ‘waste’ stream (from these now ‘old’ fillings) of 78 t/year 

- i.e. 144% of the current filling rate (= 78/54). 

In other words, when considering the quantity of mercury entering the environment, it 

is necessary to consider losses associated with the insertion of new fillings and the 

disposal of old fillings. The resultant ‘lifecycle’ of mercury used in dental amalgam 

is shown in Figure 3.1. The associated emission factors are discussed further below. 

 

 12 The Cremation Society of Great Britain: International Cremation Statistics, available from 

www.members.aol.com/CremSoc4/Stats. 
Risk & Policy Analysts

Page 19

Figure 3.1: Mercury in Dental Amalgam - Lifecycle & Emissions 

Emission factors 

We have assumed that (relatively, at least) there is negligible emission of mercury to 

any environmental compartment from recovered mercury. By way of example, the 

measured emissions at the Finnish plant (which produces mercury from zinc smelting) 

are less than 0.02% (Finnish Environment Institute, 1999). A current IPPC 

application for a UK mercury recycling company suggests that compliance with the 

recent IPPC Guidance Note on ‘Best Available Techniques in the Non-ferrous Metals 

Industries’ (EC, 2001) will lead to even lower emissions. Furthermore, mercury 

losses during the lifetime of a filling (i.e. when in the mouth) have been neglected. 

It should be noted that not all ‘recovered’ mercury will be recycled to re-enter the 

mercury supply chain. In some cases, recovered amalgam may be disposed of 

directly to landfill (as clinical waste) whilst elsewhere mercury may be recovered and 

then disposed of to landfill as mercuric sulphide (as happens with some plants in 

Finland where lamps are recycled - see S3.4.4). For the purposes of this analysis, we 

have assumed that 75% of mercury in recovered amalgam is recycled. 

As indicated above, 10% of waste amalgam will enter the sewer. WS Atkins (1998) 

utilise the following factors with regard to the fate of mercury ending up in sewage 

treatment plants: 

• watercourses: 20%; 

• agricultural soil: 38%; 

• landfill: 33%; and 

• incineration: 9%. 

Mercury Usage

in Dental

Amalgam

Excess

amalgam

To waste

recovery

Disposal of

Amalgam

Recovered

(including

separators)

Sewer

100%

90%

10%

60%

20%

20%

65%

Extracted

(or lost)

End-of-life

Incinerator

Landfill/

Burial

25%

75%

70%

10%

25%

Crematoria

30% 10%

20%

38%

Watercourses

Agricultural

9%

75%

Atmosphere

90%

1.4%

25%

33%

75% Recycled

25%

Old Fillings

144% of Current Filling Rate

New Fillings

10 years
Mercury Products - Risks to Health and the Environment 

Page 20

These figures were based on practices and trends in the EU in the early 1990s and 

take into account the treatment of sewage and the disposal of use of sludge for 

agricultural purposes and have been assumed to remain valid. 

In the case of batteries (discussed in S3.3.3), the Swedish report (KEMI, 1997) asserts 

that 0.5% of mercury disposed of to landfill finds its way to the atmosphere through 

volatilisation in the first year and, perhaps, 0.1% per year thereafter. Given the 

relative immobility of mercury in batteries, it will be assumed that these figures can 

also be applied to mercury in amalgam (and in sulphide form). An annualised figure 

of 1.4% (based on losses over 10 years) is used - as illustrated in Box 3.2. It is 

acknowledged that landfill leachate may contain mercury (and other heavy metals) 

and, for older ‘uncontained’ sites, may enter local ground/surface waters. However, 

the concentrations (associated with municipal waste sites, at least) tend not to be 

significant (Schmid et al., 2000). 

With regard to incineration, WS Atkins (1998) indicate that a retention rate of 

mercury of 50% is reasonable for incinerators across Europe (although possible rates 

of 90% are also mentioned13). The Swedish report however, indicates an overall 

retention rate of 30%. The consultants believe that advances in incineration 

technology since the time of those two reports as well as the tightening of emission 

 

 13 Indeed, in its submission to UNEP, Sweden notes that its single hazardous waste incinerator has now 

virtually eliminated mercury emissions with a 99.9% retention rate. 

Box 3.2: Annualised Losses to Atmosphere from Landfill 

In the case of batteries and dental amalgam disposed of to landfill, it has been assumed that there is a loss of 

0.5% in the first year and 0.1% per year for the next nine years. This is equivalent to an annual loss of 1.4% 

per year as the emissions will be comprise those from this and previous years’ disposal as shown in the table 

below. 

Year of Year of Emissions 

disposal 1992 1993 1994 1995 1996 1997 1998 1999 2000 2001 2002 2003 2004 

<1989 0.6% 0.5% 0.4% 0.3% 0.2% 0.1% 

1989 0.1% 0.1% 0.1% 0.1% 0.1% 0.1% 0.1% 

1990 0.1% 0.1% 0.1% 0.1% 0.1% 0.1% 0.1% 0.1% 

1991 0.1% 0.1% 0.1% 0.1% 0.1% 0.1% 0.1% 0.1% 0.1% 

1992 0.5% 0.1% 0.1% 0.1% 0.1% 0.1% 0.1% 0.1% 0.1% 0.1% 

1993 0.5% 0.1% 0.1% 0.1% 0.1% 0.1% 0.1% 0.1% 0.1% 0.1% 

1994 0.5% 0.1% 0.1% 0.1% 0.1% 0.1% 0.1% 0.1% 0.1% 0.1% 

1995 0.5% 0.1% 0.1% 0.1% 0.1% 0.1% 0.1% 0.1% 0.1% 0.1% 

1996 0.5% 0.1% 0.1% 0.1% 0.1% 0.1% 0.1% 0.1% 0.1% 

1997 0.5% 0.1% 0.1% 0.1% 0.1% 0.1% 0.1% 0.1% 

1998 0.5% 0.1% 0.1% 0.1% 0.1% 0.1% 0.1% 

1999 0.5% 0.1% 0.1% 0.1% 0.1% 0.1% 

2000 0.5% 0.1% 0.1% 0.1% 0.1% 

2001 0.5% 0.1% 0.1% 0.1% 

2002 0.5% 0.1% 0.1% 

2003 0.5% 0.1% 

2004 0.5% 

Total Emission: 1.4% 1.4% 1.4% 1.4% 1.4% 1.4% 1.4% 1.4% 1.4% 1.4% 1.4% 1.4% 
Risk & Policy Analysts

Page 21

limits may allow for a 25% value of emissions to the atmosphere to be considered 

reasonable for the present situation across Europe14. Subsequently, the remaining 

75% of mercury is likely to be disposed of as hazardous waste to landfill as part of the 

fly ash residue. In contrast, most crematoria have minimal controls to retain mercury 

discharges and a value of 90% discharge to atmosphere will be assumed, although 

about 40% of Sweden’s 68 crematoria have now been provided with filters to reduce 

mercury emissions by 95% or more (Swedish submission to UNEP, 2001). 

Summary 

Based on an annual consumption of 90 t/year within the EU and the three accession 

countries and the associated lifecycle and emissions outlined above, the overall endpoints were calculated to give the results presented in Table 3.8. 

Table 3.8: Dental Amalgam Emissions & End-Points (t/year) 

Parameter Amount (t/year) Comment 

Consumption 90 Based on S3.2.3 above 

End-points: 

Recycled 59.8 It has been assumed that 75% of recovered 

amalgam is recycled 

Water Course 1.4 After sewage treatment 

Agricultural soil 2.6 Associated with sewage sludge disposal 

Atmosphere 6.5 Dominated by crematoria 

Landfill/burial 43.5 

Accumulation1 -23.8 

This represents the additional flow entering the 

waste stream from ‘old’ fillings. As such, this 

equates to a reduction in the overall ‘inventory’ 

of mercury present in dental amalgam (within 

the EU and the three accession countries) as 

less mercury is used for new fillings than was 

the case ten years ago 

Check Totals: 90.00 

Note: 

1) Accumulation relates to the quantity of mercury in circulation within the product rather than to 

the total quantity of mercury present in the environment associated with the product.

 

 14 Under Directive 2000/76/EC on the incineration of waste, mercury stack concentrations would be 

limited to 0.05 mg/m3

. This would equate to a maximum mercury emission to atmosphere of the order 

of 25 kg/year for a 60,000 t/year municipal waste incinerator with a flow through the stack of 60,000 

m3

/hr. 
Mercury Products - Risks to Health and the Environment 

Page 22

3.3 Batteries 

3.3.1 Types of Battery 

There are numerous types of batteries which may be grouped as follows: 

• ‘flooded’ lead-acid batteries of which the most common form is the standard 

battery used to start engines in vehicles, and have been in use since the nineteenth 

century; 

• ‘sealed’ lead-acid batteries which appeared in the 1970s and may be used in 

vehicles but also are widely used in back-up power supplies for computers, etc.; 

• primary (disposable) portable batteries of which the vast majority are the 

standard disposable batteries used in the home (torches, toys, etc.); and 

• secondary (rechargeable) portable batteries of which most are used in electronic 

equipment (calculators, cameras, mobile phones, etc.). 

An indication of the relative scale of usage was derived from the Europroms data as 

shown in Table 3.9. 

Table 3.9: EU Imports and Exports of Batteries (1999) 

Numbers of batteries in 1999 which were Type of battery Imported1

 Exported2

Lead-acid batteries (flooded) 34 million 27 million 

Sealed lead-acid batteries 43 million 17 million 

Primary (disposable) portable batteries 4474 million 5270 million 

Secondary (rechargeable) portable batteries 619 million 393 million 

Source: Europroms data 

Notes 

1) The numbers of batteries imported are based on summing the data for intra-EU imports and 

extra-EU imports for each of the EU countries. As indicated in Section 1.3, these data provide 

an indication of relative usage (based on trade statistics) rather than a direct measure of 

consumption. 

2) The export figures were derived in the same way as those for imports. 

Since lead-acid batteries are much heavier than portable batteries (a typical car battery 

weighs 13 kg whilst the typical ‘C’ portable battery weighs 67g), the overall weights 

of material involved are much closer than Table 3.9 might suggest. 

3.3.2 Mercury in Batteries 

As discussed in Section 3.1.3, lead ores may contain small amounts of mercury. 

However, the mercury will be driven off during the smelting process. As such, 

mercury is not a significant impurity in the lead used in lead-acid batteries 

(particularly as most of the lead will be re-used and will therefore be re-refined). 

Furthermore, mercury is not a significant impurity of sulphuric acid (the electrolyte 

used in lead-acid batteries). In short, lead acid batteries are ‘mercury-free’ (ICON, 
Risk & Policy Analysts

Page 23

2001 and EC, 2001a). As a result, lead-acid batteries will not be affected by the 

requirement of the ‘end-of-life vehicles directive’ for the presence of mercury (not 

intentionally introduced) to be limited to 0.1% by weight15 (since the mercury 

concentrations in lead-acid batteries will be much lower than 0.1%). 

In relation to portable batteries, all lithium batteries and secondary (rechargeable) 

batteries have always been mercury-free. However, there are a number of portable 

batteries (both ‘cylinders’ and ‘button cells’) which contain (or have contained) small 

amounts of mercury which have been added to enhance performance as indicated in 

Table 3.10 

Table 3.10: Types of Portable Dry Batteries which Contain Mercury 

Type & 

Form Main Materials Mercury Present? Comment 

Primary 

(disposable): 

Cylinder 

Alkaline-manganese 

(Zn anode, MnO2

cathode) 

Previously, 

<0.025% by wt. 

Now mercury free1

Standard portable battery which 

makes up about half of the total 

numbers of primary portable 

batteries. Note that zinc-carbon 

batteries (the other main kind of 

cylinder battery) are mercury free 

Zinc-mercury (Zn 

anode, mercuric oxide 

(HgO) cathode) 

32% by wt. 

Formerly used where size is of 

importance (hearing aids, 

photography, etc.). Zinc-mercury 

cells were banned in EU from 1 

January 2000 

Primary 

(disposable): 

Button Silver oxide, Alkalinemanganese, Zinc-air 

(various designs with 

Zn anode) 

up to 2% by wt 

Silver oxide used in watches. 

Zinc-air particularly used for 

hearing aids 

Notes: 

1) Generally, to be ‘mercury free’ requires the mercury content to be less than 0.0005% (5 ppm) by 

weight - but see Nordic Ecolabelling requirements below. 

 

3.3.3 Control Issues 

Council Directive 91/157/EEC16 required Member States to prohibit, from 1 January 

1993, the marketing of: 

• alkaline manganese batteries for prolonged use in extreme conditions containing 

more than 0.05% mercury by weight; and 

• all other alkaline manganese batteries containing more than 0.025% mercury by 

weight. 

Alkaline manganese button cells (and batteries comprising button cells) with higher 

mercury concentrations were, however, permitted to remain on the market. The 

 

 15 Commission Decision 2002/525/EC of 27 June 2002 amending Annex II of Directive 2000/53/EC on 

end-of-life vehicles. 

 16 Council Directive 91/157/EEC of 18 March 1991 on Batteries and Accumulators Containing 

Certain Dangerous Substances, OJ L078, 26/03/1991. 
Mercury Products - Risks to Health and the Environment 

Page 24

Directive also required Member States to provide appropriate systems for the 

collection, recycling and disposal of spent batteries (and accumulators). These 

requirements (including mercury content limits) were also used in the Aarhus 

Protocol (UNECE, 1998). 

As of January 1994, the main EU suppliers had agreed to provide ‘mercury free’ 

general purpose (i.e. primary cylinder) batteries17 - although non-members of the 

European Portable Battery Association continued to import batteries with up to 

0.025% mercury by weight (as permitted by Directive 91/157). Commission 

Directive 98/101/EC18 required Member States to prohibit, from 1 January 2000, the 

marketing of: 

• batteries and accumulators containing more than 0.0005% (5 ppm) mercury by 

weight; and 

• button cells (and batteries made up of button cells) containing more than 2% 

mercury by weight. 

In Scandinavian countries, ecolabels for primary batteries require a strict limit of 1 

ppm of mercury (Nordic Ecolabelling, 2000) - although industry claims that this is 

below ‘natural levels’ in other battery materials. For rechargeable batteries, the limit 

is 5 ppm (Nordic Ecolabelling, 2000a). 

3.3.4 Quantities Used 

EU Wide 

As discussed in more detail below, it is estimated that in the mid-1990s, the quantity 

of mercury in battery usage in the EU was probably of the order of 40 t/year with over 

30 t/year associated with zinc-mercury button cells and over 5 t/year associated with 

other button cells. 

Given the actions of industry to move to mercury free batteries and the 

implementation of Directive 98/101/EC, the current mercury usage in batteries has 

probably dropped to the order of 8 t/year. Although zinc-mercury batteries are now 

effectively banned within the EU and global production has generally ceased, it is 

worth noting that such batteries are still available through specialist suppliers and, 

indeed, are still manufactured in the US. 

Recent trends in battery usage were explored using Europroms as illustrated in Figure 

3.2 (overleaf). Particular focus is given to figures for zinc-mercury batteries 

(predominantly button cells) and other button cells which may contain up to 2% 

mercury. As can be seen, the numbers (both imports and exports) for zinc-mercury 

buttons (‘PrimBut-ZnHg’) have declined sharply since 1997, although this decline is 

 

 17 EPBA (2000): Effective Recycling of Batteries: The EPBA Two Step Plan, available from EPBA 

website. 

 18 Commission Directive 98/101/EC of 22 December 1998 adapting to technical progress Council 

Directive 91/157/EEC on Batteries and Accumulators Containing Certain Dangerous Substances, 

OJ L001, 05/01/1999. 
Risk & Policy Analysts

Page 25

not so dramatic when considering all primary zinc-mercury batteries together 

(‘PrimAll-ZnHg’). In relation to the other kinds of button cell, the figures for silver 

oxide buttons have remained fairly constant whilst those for other buttons have shown 

increases in the last few years. 

As indicated above, most of the mercury in batteries is associated with button cells 

and an estimate of button cells sales and associated mercury content has been 

provided by the industry as shown in Table 3.11. It should be noted that lithium cells 

(which do not contain mercury) account for about 70% of the primary button sales. 

Table 3.11: Mercury Content in Button Cells Currently Sold in EU (& Switzerland) by 

Members of the European Portable Battery Association 

Button Cell Sales (million) % Mercury Quantity of 

Mercury 

Alkaline Button 12.3 0.45 205 kg 

Zinc-mercury Button 0 n/a 0 kg 

Silver oxide Button 295 0.34 295 kg 

Zinc-air Button 243 1.24 1628 kg 

Total 550 0.81 2128 kg 

Source: consultation - note that figures exclude goods imported with button cells fitted. 

There is some divergence between the figures presented in Table 3.11 and the 

Europroms data (as shown in Figure 3.2). In particular, the Europroms data suggest a 

significant trade in zinc-mercury batteries (which are no longer sold by EPBA 

members) although these 1999 pre-date the ban introduced on 1 January 2000. In 

addition, the Europroms data suggest a higher market share for alkaline button cells 

than that suggested by the EPBA data. 

1E0

1E1

1E2

1E3

Units (x10^6)

PrimBut-ZnHg PrimAll-ZnHg PrimBut-AlkMn PrimBut-AgO PrimBut-ZnAir

Battery Type

1995-Imp 1997-Imp 1999-Imp 1995-Exp 1997-Exp 1999-Exp

Figure 3.2: EU Trends in Primary

Batteries Containing Mercury
Mercury Products - Risks to Health and the Environment 

Page 26

As can be seen from Table 3.11, the EPBA figures suggest a mercury usage of over 

2,000 kg/year in button cells. For comparison purposes, data from ERM (2001) 

suggest an EU consumption of about 125,000 t/year of primary portable mercury-free 

batteries which, with a ‘natural’ level of, say, 3 ppm mercury, would correspond to a 

mercury flow of about 375 kg/year. 

By Country 

Germany, France and the UK are the prime consumers of (portable) batteries each 

accounting for nearly 20% of EU battery sales followed by Italy and Spain (each 

around 11%). Some further information on battery usage is presented in Table 3.12. 

Table 3.12: Mercury Usage in Portable Batteries (mainly Button Cells) by Country (t/year) 

Country c1990 late 1990s %EU button 

market1 Source & Comment 

Austria 2.0% 

Belgium (& 

Luxembourg) 

 3.7% 

Denmark 0.4 - 0.9 

(1992-93) 

 1.8% HELCOM (2001) 

Finland 0.75 (1996/97) 1.2% Consultation - primarily 

zinc-mercury button cells 

France 20.1% 

Germany 16.1 (1991) 3.1 (2000) 

125m button 

cells (excl. 

lithium) (1998) 

20.2% Submission to UNEP 

(2001) with 32% recycled 

leaving 2.1t to waste 

Greece 1.9% 

Ireland 0.5% 

Italy 11.0% 

Netherlands 2.6 (1990) 3.8% Slooff et al. (1995) 

Portugal 1.4% 

Spain 11.5% 

Sweden 0.8 (1997) 

0.1 (1998) 

2.6% Submission to UNEP 

(2001) - ban on zincmercury batteries led to 

dramatic reduction 

United Kingdom 27m button 

cells (1999) 

18.3% BBMA website (figure 

relates to ‘consumer 

sales’ and includes 

lithium cells) 

EU Total 75 8 RPA estimates 

Poland n/a 

Czech Republic 0.22 (2000) n/a Submission to UNEP 

(2001) 

Slovenia n/a 

Note: 

1) ERM (2001) estimate total EU button sales (i.e. including lithium) to be over 1,100 t/year (of 

the order of 500 million cells/year). The % figures presented relate to button cell waste arising 

based on sales in 2000. 
Risk & Policy Analysts

Page 27

3.3.5 Lifecycle & Emissions 

Manufacture

Inspection of batteries within a typical EU household will reveal batteries from 

various countries including the UK, Japan, Germany, Indonesia, China and the USA. 

Major manufacturers include Duracell, Energizer, Rayovac, Philips, Sony, Varta, and 

Panasonic. Some countries (for example, Austria) have no production facilities and 

others (for example, Poland) have facilities for the domestic market. 

In relation to button cells specifically, there are only three manufacturing plants in the 

EU - two in the UK and one in Germany each operated by one of the major 

manufacturers. Button cells are not produced in any of the three accession countries 

under study. 

It is clear from the information outlined above that not only are large numbers of 

batteries (and button cells) manufactured within the EU (and some batteries in the 

three accession countries) but there would also appear to be large numbers of imports 

and exports (of roughly equal proportions as indicated by Figure 3.2). 

Detailed data on individual countries (beyond that presented in Europroms) and 

companies have been difficult to obtain. The most comprehensive data found relate to 

Germany which suggest that the current mercury usage in batteries is around 3 t/year. 

A more detailed inspection of the German submission to UNEP (and related 

documents) reveals a dramatic reduction in mercury consumption in batteries over the 

last decade which is associated with the decline in use of zinc-mercury button cells 

(which were banned from January 2000). However, these still accounted for 70% of 

Germany’s estimated consumption of 3.1 tonnes of mercury in batteries in 2000. 

Similarly, all EU-15 countries report some trade in zinc-mercury batteries (as reported 

by Europroms data) - albeit prior to the introduction of the EU ban on such batteries. 

Given that Germany accounts for about 20% of the button cell market and assuming 

that the German figures can be extrapolated to the EU as a whole, these data suggest a 

significantly higher figure for the EU as a whole - perhaps 15 t/year than that of 

around 2 t/year suggested by industry. Although the latter figure relates only to sales 

by EPBA members (and does not therefore include any sales of zinc-mercury batteries 

- see Table 3.11), there would appear to be a degree of uncertainty as to the quantities 

of mercury used in portable batteries - with particular reference to that associated with 

sales of zinc-mercury batteries (many of which are likely to be imported within 

products). 

In the absence of more detailed data, we shall opt, conservatively, for a current (i.e. 

2002) mercury usage in batteries of 8 t/year within the EU and a further 1 t/year in the 

three accession countries (note that the 50 million population of the Czech Republic, 

Poland and Slovenia is about 13% of that of the EU’s 376 million). 
Mercury Products - Risks to Health and the Environment 

Page 28

Recycling of Portable Batteries 

Although the vast majority of lead-acid batteries are recycled (and have been for 

many years), the recycling of portable batteries is not so well established. 

There are established (portable) battery collection/recycling operations in several 

countries. 1999 data from Austria, Belgium, Germany and the Netherlands suggest 

existing battery collection rates of 30% to 55% (EBPA, 2001). However, in 

Germany, the national ‘voluntary’ agreement initiated in 1988 was not considered to 

be an unqualified success (Jörgens & Busch, 2000) and, as a result, the Batteries 

Ordinance (BatV) was implemented in 1998 which requires: 

• retailers to take back all batteries; 

• retailers to advise customers of the take back scheme; and 

• customers to return batteries to retailers (or recycling centres). 

There is no national portable battery collection/recycling operation in the UK, 

although there are a number of local initiatives (SWAP, 2000). It is worth noting that 

the near exclusive use of silver oxide button cells in watches which are replaced in the 

UK, generally, by jewellers lends itself to a recycling scheme and a 75% target 

appears feasible (SWAP, 2000a). 

Consultation has indicated that, from 1 January 2002, a new law in Poland requires 

producers and importers of portable batteries to recycle 50% of the batteries sold. 

Emissions to Environmental Media 

As before, the estimation of mercury releases has been based on the two-stage 

approach used in Sweden (KEMI, 1997): 

• the estimation of the distribution factors for the different pathways; and 

• the estimation of emission factors for the subsequent releases to air and water. 

Distribution factors 

The fate of mercury in present in batteries (mainly button cells) is presented in Figure 

3.3. Given the relatively short life of a portable battery/cell (ERM (2001) in its report 

for the battery industry use a figure of three years), there is negligible accumulation 

and given the nature of batteries, the breakage rate is negligible. These assumptions 

concur with those used by KEMI. The assumed disposal route distributions (and 

again these concur with those used by KEMI) are: 20% recovery (as an overall 

average for the EU and accession countries), 20% to incineration and 60% to landfill 

(this corresponds to 25% of municipal solid waste (MSW) being incinerated). 
Risk & Policy Analysts

Page 29

Figure 3.3: Mercury in Batteries - Lifecycle & Emissions

Emission factors 

As for the dental amalgam, we have assumed that 75% of the recovered mercury is 

recycled and 25% sent to landfill. For batteries in landfills, the Swedish report 

(KEMI, 1997) asserts that 0.5% finds its way to the atmosphere through volatilisation 

in the first year and, perhaps, 0.1% per year thereafter. As before, an annualised 

figure of 1.4% is used (to represent average losses over 10 years). With regard to 

incineration (and as discussed in S3.2.4), an incinerator will emit 25% to atmosphere 

with the remaining 75% (mainly in fly ash) sent to landfill. 

Summary 

Based on an annual consumption of 9 t/year within the EU and the three accession 

countries and the associated lifecycle and emissions outlined above, the overall endpoints were calculated to give the results presented in Table 3.13. 

Table 3.13: Mercury in Batteries Emissions & End-Points (t/year) 

Parameter Amount (t/year) Comment 

Consumption 9.00 Based on S3.3.3 above 

End-points: 

Recycled 1.35 It has been assumed that 75% of recovered 

batteries are recycled 

Water Course 0.00 

Agricultural soil 0.00 

Atmosphere 0.55 Dominated by incinerator emissions 

Landfill/burial 7.10 

Accumulation 0.00 

Check Totals: 9.00 

Mercury Usage

in Portable

Batteries

Breakage

(negligible)

For

Collection 100% Recovered

100%

20%

0%

Disposed to

Solid Waste Incinerator

Landfill

75%

80%

Disposal of

Used

Batteries 75% Atmosphere

1.4%

25%

25%

25%

75% Recycled

New Batteries

Used

Batteries 3 years

100% of Current Usage
Mercury Products - Risks to Health and the Environment 

Page 30

3.4 Lighting 

3.4.1 Types of Lamp containing Mercury 

Mercury is present in a range of discharge lamps. Continuing technological 

development has resulted in not only increased lighting efficiency but also a reduction 

in mercury content (apart from high-pressure sodium lamps) as illustrated in Table 

3.14 by the ‘typical’ figures provided for the mercury content in lamps in 1993, 1997 

and currently. 

Table 3.14: Changing Mercury Content in Lamps 

Lamp Type Mercury Present Uses & Comment 

Fluorescent tube 

(double end) 

30-40 mg/tube (1993) 

15 mg/tube (1997) 

10 mg/tube (currently) 

Fluorescent tubes are the most widely used 

form of artificial light, particularly in 

commercial and industrial premises. Note 

that modern tubes use 10% of the mercury 

used 20 years ago 

Compact fluorescent 

lamp (CFL - single 

end) 

5 mg/lamp (1993, 1997 & 

currently) 

Energy efficient CFLs are widely used for 

general lighting 

High pressure 

mercury vapour 

75 mg/lamp (1993) 

39 mg/lamp (1997) 

30 mg/lamp (currently) 

Used where bright light is required - e.g. 

security lighting. Small lamps (with less 

than 1 mg/lamp) are also used for 

‘executive’ car headlamps 

Metal halide 

60 mg/lamp(1993) 

30 mg/lamp (1997) 

25 mg/lamp (currently) 

Homes and offices 

High-pressure 

sodium 

20 mg/lamp (1993) 

25 mg/lamp (1997) 

30 mg/lamp (currently) 

Used for high intensity lighting (note that 

low-pressure sodium lamps used in street 

lighting for example are mercury free) 

‘Neon’ 10 mg/tube (estimate) 

Low-pressure tubes used in shop signs, etc. 

Blue colours may contain neon or argon gas 

and mercury vapour 

Sources: International Association for Energy Efficient Lighting (1993): Mercury: A Broader 

Perspective, IAEEL Newsletter 3/93 (from www.iaeel.org); European Lighting Companies 

Federation (1997): Discharge Lamps and the Environment, Brussels, ELC; and consultation. 

3.4.2 Control Issues 

At an International Level 

The criteria for eco-labelling of light bulbs were revised in 199919 and further 

revisions are now being processed following a meeting of the European Eco-labelling 

Board (EUEB) in May 200220. The current specified maximum mercury levels (with 

those planned in brackets) in lights are as follows: 

 

 19 Commission Decision of 27 July 1999 Establishing the Ecological Criteria for the Award of the 

Community Eco-label to Light Bulbs. 

 20 As reported on the European Commission’s website: europa.eu.int/comm/environment/ecolabels/news/ 

news.htm. 
Risk & Policy Analysts

Page 31

• single-ended bulbs: 6 mg/bulb (to be reduced to 4 mg/bulb); and 

• double-ended bulbs: 7.5 mg/bulb (10,000-20,000 hour life) and 10 mg/bulb 

(>20,000 hour life). These will be reduced to 5 mg/bulb (>12,500 hour life) and 

8 mg/bulb (>20,000 hour life) respectively. 

Reduction in mercury content and increased recycling is also encouraged by the 

Aarhus Protocol (UNECE, 1998) as well as by OSPAR and HELCOM. In the longer 

term, all fluorescent lamps within the EU are likely to have to comply with mercury 

limits of 5 mg/lamp (single-ended) and 10 mg/lamp (double-ended) to comply with 

the proposed RoHS Directive21 

In view of the continuing drive to reduce the mercury content of lamps, it is worth 

noting an argument (advanced by industry) that the fossil fuel savings due to use of 

CFLs over ordinary incandescent mercury-free light bulbs results in net savings of 

mercury emissions (since mercury is emitted by fossil-fuel combustion for electricity 

generation). 

At a National Level 

Several countries have adopted (or are considering) measures to further reduce the 

mercury usage in lamps as illustrated in Table 3.15. 

Table 3.15: Controls for Mercury in Lamps by Country 

Country Control Source & Comment 

Austria There has been a ‘deposit’ on fluorescent lamps since 

1991 with a 15 mg/lamp limit implemented in 1996 (Note 

a similar system for mercury lamps is used in Latvia) 

CTC (1999) & OECD 

(1995) 

Denmark Being phased out under Order 692 (see Section 1.2) HELCOM (2001) 

Sweden Further restrictions on mercury in light sources is under 

consideration (see Section 1.2) 

HELCOM (2001) 

3.4.3 Quantities Used 

EU Wide 

The lighting industry is dominated world-wide by three manufacturers which produce 

over 65% of all lamps - Philips, Osram (Siemens) and GE Lighting. 

European Lighting Companies Federation (ELC) figures from 1997 suggest 5.2 t/year 

of mercury was supplied in lighting units22 - mainly (over 85%) in fluorescent tubes 

as illustrated in Table 3.16. More recent figures suggest that although the average 

mercury content per lamp has declined, this has been more than offset by the increase 

 

 21 Proposed Directive on the Restriction of the Use of Certain Hazardous Substances in Electrical 

and Electronic Equipment, COM(2000) 347, OJ C365E pp 195-197 dated 19 Dec 2000 - which is 

currently progressing through the European Parliament. 

 22 No specific quantitative data have been obtained for ‘neon’ tubes but the mercury usage is expected to 

make a negligible contribution to the overall use. 
Mercury Products - Risks to Health and the Environment 

Page 32

in the number of lamps produced giving a current estimate of 5.9 t/year of mercury in 

lamps. This figure represents the mercury used in ‘European’ (rather than EU) lamp 

production and also includes those lamps destined for export. 

The figures quoted above are significantly lower than that of 21 t/year used by WS 

Atkins (1998). 

Table 3.16: Mercury Usage in European Lamp Production 

Mercury Used in 1997 Mercury Used Currently 

Lamp Type mg Hg 

/lamp 

millions 

produced 

Hg used 

(kg/year) 

mg Hg* 

/lamp 

millions* 

produced 

Hg used 

(kg/year) 

Fluorescent tube 

(double end) 15 300 4,500 10 500 4,000 

Compact fluorescent 

lamp (CFL - single end) 5 40 200 5 140 600 

High pressure mercury 

vapour 

30 10 300 30 

High-pressure sodium 25 6.4 160 30 

Metal halide 60 2.7 80 25 

45 1,300 

Totals: 5,240 5,900 

Source: European Lighting Companies Federation (1997): Discharge Lamps and the 

Environment, Brussels, ELC; and consultation - note * indicates approximate figures. 

Recent trends in lamp usage were explored using Europroms as illustrated in Figure 

3.4. 

From Figure 3.4, several observations can be made: 

1E1

1E2

1E3

Units (x10^6)

Fluorescent (double) Fluorescent (single) Hg Vapour Na Vapour Discharge - other

Lamp Type

1995-Imp 1997-Imp 1999-Imp 1995-Exp 1997-Exp 1999-Exp

Figure 3.4: EU Trends in Lighting
Risk & Policy Analysts

Page 33

• imports of single-ended fluorescent lamps (CFL) have increased significantly 

during the late 1990s; 

• imports of mercury vapour lamps have increased dramatically during the late 

1990s; and 

• in broad terms, the numbers of lamps involved are comparable (bar those for 

‘other’ discharge lamps) with those presented in Table 3.16. 

Closer examination of the data on mercury vapour lamps indicates that Germany is 

the lead importer. One potential explanation could be the increased use of mercury 

vapour headlamps (also referred to as xenon or HID headlamps) for ‘executive’ cars. 

However, the mercury content of these new lamps is very low (the order of 0.5 

mg/lamp) and work for DG Environment suggests that the overall usage of mercury 

would be a few kilograms23 - and this has been confirmed by consultation with a 

leading supplier. 

By Country 

Very few meaningful data on lamp use by individual country have been obtained.

3.4.4 Lifecycle & Emissions 

Manufacture 

Philips has over 40 lamp manufacturing sites in geographic Europe24 (i.e. including 

many more countries than those within the EU) although not all produce lamps 

containing mercury. Osram (Siemens) and GE Lighting have fewer production sites. 

There are believed to be manufacturing sites in Belgium, France, Germany, Ireland, 

Italy, Netherlands, Spain, UK and Poland. In recent years, there has been a move to 

reduce costs by relocating eastwards and this has resulted in the large companies 

establishing sites in Poland (Philips), Slovakia (Osram) and Hungary (GE Lighting). 

Overall, given the lack of detailed data, the overall figure of 5.9 tonnes of mercury per 

year in lamps will be used as a basis for subsequent calculations. 12% of this usage 

(0.7t) has been assigned to the three accession countries (based on relative population 

and a slightly lower consumption rate) leaving 5.2t used by the EU-15 countries. 

Use 

Lamps are distributed by wholesalers and retailers and are used directly by the 

consumer or in the assembly of other products containing lamps. 

 

 23 Sander K et al. (2000): Heavy Metals in Vehicles, report prepared for DG Environment and dated 27 

March 2000. 

 24 Philips presentation for the 3rd Quarter of 2001 (3Q01) available from www.investor.philips.com. 
Mercury Products - Risks to Health and the Environment 

Page 34

Disposal 

Most European countries have initiated collection and recovery schemes for used 

lamps. This may result from a desire to encourage recycling and/or from prohibitions 

on landfilling such items. In the longer term, such schemes are likely to be mandatory 

under the proposed WEEE Directive25. 

The recovered mercury may be reused as, for example, is done by a UK company 

which has a contract to recycle 1 million fluorescent tubes per year from UK 

Government buildings. By contrast, in Finland, there are three plants which recover 

mercury from fluorescent lights, convert it to mercuric sulphide (the same compound 

found in the natural ore, cinnabar) and dispose of it to landfill as hazardous waste 

(HELCOM, 2001). 

Emissions to Environmental Media 

As before, the estimation of mercury releases has been based on the two-stage 

approach used in Sweden (KEMI, 1997): 

• the estimation of the distribution factors for the different pathways; and 

• the estimation of emission factors for the subsequent releases to air and water. 

Distribution factors 

The mercury in lamps cycle is presented in Figure 3.5. 

Figure 3.5: Mercury in Lamps - Lifecycle & Emissions

 

 25 Proposed Directive on Waste Electrical and Electronic Equipment, COM(2000) 347 dated 19 Dec 

2000 as amended by COM(2001) 315 dated 28 August 2001. 

Breakage

For

Collection

Recovered

20%

5%

Disposed to

Solid Waste

Incinerator

Landfill

70% 75%

75% Atmosphere

5.9%

25% 25%

25%

Disposed

with Steel

Scrap

5%

5%

90%

10%

75% Recycled

95%

100%

Mercury Usage

in Lamps

100%

Disposal of

Used Lamps New Lamps

c3 years Used Lamps

100% of Current Usage
Risk & Policy Analysts

Page 35

Given the expanding lamp market and typical lamp lifetimes of several years, some 

accumulation might be expected. However, as indicated in Table 3.16, the average 

mercury content per lamp has declined giving rise to only a marginal increase in 

overall mercury usage. On this basis, no accumulation has been assumed. A small 

proportion of mercury containing lamps may enter the steel scrap recovery cycle (5%) 

whilst 20% may be recovered directly from collection/recycling schemes. Although a 

small proportion (5%) may be broken in service, the vast majority, perhaps 70%, will 

enter the solid waste disposal stream (of which 25% will be incinerated). 

Emission factors 

We have assumed that there is no emission of mercury to any environmental 

compartment from recovered mercury. However, as the Finnish operations indicate, a 

proportion of recovered mercury is then sent to landfill rather than re-entering the 

secondary mercury production stream (perhaps 25% in total). 

For lamps which enter landfills or are broken, most of the mercury vapour will be lost 

to atmosphere. However, in fluorescent tubes (which account for most of the mercury 

present in lamps), over 99% of the mercury present is embedded in the tube coating 

(NEMA, 2000). For lamp breakage, it is assumed, pessimistically, that 5% of the 

mercury vapour is lost to atmosphere. For landfilled lamps, it has been assumed that 

5% is lost in the first year with 0.1% per year thereafter giving an annualised rate of 

5.9% (over 10 years) and these values are also used for other landfill operations. 

With regard to incineration (and as discussed in S3.2.4), an incinerator will emit 25% 

to atmosphere with the remaining 75% (fly ash) sent to landfill. In the case of items 

entering the steel scrap system, the emissions to atmosphere are likely to be relatively 

higher from arc furnaces and an emission factor of 90% is used (as used by KEMI). 

Summary 

Based on an annual consumption of 5.9 t/year within the EU and the three accession 

countries and the associated lifecycle and emissions outlined above, the overall endpoints were calculated to give the results presented in Table 3.17. 

Table 3.17: Mercury in Lamps Emissions & End-Points (t/year) 

Parameter Amount (t/year) Comment 

Consumption 5.90 Based on S3.4.3 above 

End-points: 

Recycled 0.89 It has been assumed that 75% of mercury 

recovered from lamps is re-used 

Water Course 0.00 

Agricultural soil 0.00 

Atmosphere 0.82 Emissions associated with incineration (34%), 

scrap steel (32%) and landfill (32%) 

Landfill/burial 4.20 

Accumulation 0.00 

Check Totals: 5.90 
Mercury Products - Risks to Health and the Environment 

Page 36

3.5 Measuring (& Control) Equipment 

3.5.1 Overview of Use 

Measuring and control equipment that contains mercury includes: 

• temperature measurement and control (thermometers and temperature control 

devices); 

• pressure measurement (including sphygmomanometers, barometers, manometers, 

and vacuum gauges); 

• gyroscopes and compasses; and 

• other specialist uses (including sling psychrometers (for humidity measurement), 

steam flow meters, pH-meter and calomel reference electrodes, gas meter pressuresafety devices, air-flow measurement devices, diffusion pumps, carburettor-adjusting 

devices, sample collectors for offshore oil, Coulter counters for particle 

measurements, mercury porosimeters (for pore property measurements), etc.). 

Approximately 16% of all process instrumentation measures, indicates, or controls 

temperature. According to a recent survey, industrial temperature measurement is 

growing at a rate of 3.6% annually including both mercury and non-mercury equipment 

(Montgomery, 2001). 

The following paragraphs provide a brief overview of the technical characteristics of 

some of the main mercury-containing measuring equipment. 

Thermometers 

Traditional ‘mercury in glass’ thermometers used for domestic, medical and scientific 

purposes have now largely been replaced by alternatives - although mercury is still 

considered to be the ‘best’ medium for max-min ‘U’ thermometers (consultation). 

Furthermore, the presence of mercury cannot necessarily be excluded from industrial 

temperature control devices. In closed loop temperature control systems, for example, a 

device is needed to take the output from the temperature control device and convert it 

into heating or cooling production. This final control device may well be a mercury 

displacement relay, especially in industrial environments where heavy duty systems 

require the final control device to carry high currents, rather than a common 

electromechanical relay which may wear out quickly (Montgomery, 2001). 

Sphygmomanometers 

The mercury sphygmomanometer is still seen as the ‘gold standard’ and is often used as a 

reference for determining the accuracy of automated devices. However, environmental 

concerns have led to a change in attitude: in the UK, for instance, it is now generally 

recommended that consideration is given to the selection of a mercury-free product when 

opportunity arises (MDA, 2000). 
Risk & Policy Analysts

Page 37

Barometers

A mercury barometer consists of a one metre glass tube filled with mercury. One end of 

the tube is sealed while the other end of the tube is submerged in a container filled with 

mercury. The changes in the height of the mercury column (and, hence, atmospheric 

pressure) are measured in a scale attached to the mercury column. Although other types 

of barometers exist (such as aneroid barometers), mercury ones are still widely used. 

Manometers & Vacuum Gauges 

An extension of the mercury barometer is the mercury U-tube manometer. In practical 

terms, a mercury manometer or gauge is a glass or plastic tube, usually U-shaped 

containing a certain amount of the metal that moves up and down in response to vacuum 

(pressure) changes. The vacuum (pressure) is read from marks along the side of the glass 

or plastic tube. In non-mercury gauges the pressure is read from a dial or a digital 

display. 

An example of vacuum measurement is to be found in milking systems which have 

vacuum lines that remove and transport milk from cows’ udders to a bulk tank. As part 

of this system, vacuum gauges measure pressure in the vacuum line. By monitoring the 

gauges, farmers can be alerted to large pressure fluctuations in the vacuum line, which 

can result in health problems for the cows or indicate operational inefficiencies. 

Historically, such systems relied on mercury manometers but, generally, these are now 

only used for calibration (Maine State (US), not dated and consultation). 

Sling Psychrometers (Hygrometers)

Sling psychrometers (or hygrometers) are used in the measurement of relative humidity. 

They consist of two (often mercury) thermometers mounted together, one of which has a 

cloth wick over its bulb and is called a wet-bulb thermometer. When a reading is to be 

taken, the wick is first dipped in water and then the instrument is whirled around. During 

the whirling, the water evaporates from the wick, cooling the wet-bulb thermometer. The 

temperature difference provides the basis for estimation of the relative humidity. 

Coulter Counters 

Coulter counters are widely used in hospital laboratories for counting and measuring the 

size of microscopic particles. Some models contain mercury in the pressure gauge, onoff switch, timing count gauge, vacuum gauge, and possibly other gauges, depending on 

the model (SHP, 2000). 

The useful life of such equipment is usually of the order of 10 years. Data for other 

equipment from the University of Minnesota show the following lifespans: 

• thermometer: 5 years; 

• barometer: 10 years; 

• manometers: 10 years; and 

• sphygmomanometer: 10 years (UMN, not dated). 
Mercury Products - Risks to Health and the Environment 

Page 38

3.5.2 Control Issues 

At an International Level 

 

The position of OSPAR (2000) is that the earlier PARCOM Recommendation 89/3 - which 

proposed measures on the recycling of mercury contained in measuring (and control) 

equipment and promoted the replacement of the metal whenever suitable alternatives 

became available - is being acted upon. As such, OSPAR (2000) recommends that no 

further controls are necessary but will ask the EC to consider further controls under the 

Marketing and Use Directive26.

UNECE (1998) encourages consideration to be given to bans on mercury use in 

thermometers and other measuring equipment. It is worth noting that, in the longer term, 

although mercury will not be permitted in electrical and electronic equipment under the 

proposed RoHS Directive (see S3.4.2), ‘laboratory equipment’ will be exempted (which 

is likely to include some of the ‘specialist uses’ listed above) as indeed are atomic 

absorption spectrophotometer lamps. 

At a National Level 

As noted by OSPAR and as shown in Table 3.18, some countries have already taken action 

regarding the use of mercury-containing measuring equipment - with particular regard to 

thermometers. 

Table 3.18: Controls of Mercury in Measuring (& Control) Equipment by Country 

Country Control Source & Comment 

Denmark 

Statutory Order 692 of 1998 bans the use of mercury in products, 

although derogations for specialist uses in thermometers (to 

2004) and other measuring equipment (until further notice) are in 

place. Danish EPA may also grant exemptions. No mercury 

thermometers were found in Denmark during a 1996 

investigation by the authorities 

HELCOM (2001), 

consultation 

France Mercury thermometers banned under Order of 24 December 

1998 consultation 

Netherlands 

Thermometers being phased out under 1998 Decree (see S1.2) 

but exemptions for barometers (to 2005), calibration and other 

specialist equipment 

consultation 

Sweden 

Manufacture and sale of mercury in thermometers and other 

measuring equipment has been banned since 1993 - but with 

exemptions (Ordinance 1998: 944) 

HELCOM (2001), 

UNEP (2002) 

United 

Kingdom 

Indirect regulation of mercury in medical facilities (i.e. hospitals 

and doctors’ surgeries) through the COSHH Regulations (which 

govern the safe use and disposal of hazardous substances in the 

workplace). The cost of compliance is regarded as high which is 

driving medical staff to seek non-mercury alternatives 

MDA (2000), 

consultation 

 

 26 Council Directive 76/769/EEC on the Approximation of the Laws, Regulations and Administrative 

Provisions of the Member States relating to Restrictions on the Marketing and Use of Certain 

Dangerous Substances and Preparations. 
Risk & Policy Analysts

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3.5.3 Quantities Used 

Typical Mercury Quantities by Item of Equipment

Table 3.19 summarises the average content of mercury in different types of measuring 

equipment. It should be borne in mind that, in most cases, there are now non-mercury 

equivalents which tend to be used in preference. 

Table 3.19: Typical Quantities of Mercury Contained in Measuring Equipment 

Type of Equipment Quantity of Hg Contained (g) 

Medical thermometers 0.5 - 1.5 

Industrial thermometers – special application thermometers 10 

Household thermometers 0.5 - 2.25 

Gas debit meter up to 25 

Counter collectors ~70 

Sphygmomanometers 85 

Gyroscopes/compasses 15 - 400 

Manometer up to 150 

Barometer 40 - 1000 

Porosimeter 1,500 

Environmental manometer 3,000 

Pressure transmitter 8,000 

Sources: ERM, 1998; WS Atkins, 1998; Environment Canada (2000); and consultation. 

Previous EU Wide Estimates 

WS Atkins (1998) indicates that 55 t/year are used in measuring equipment27, based on data 

available from reports dating back to the mid-1990s. 

Another study performed in the late 1990s was the Swedish study on mercury in products as 

a source of transboundary pollution transport (KEMI, 1997). The Swedish report differs in 

the respect that measuring and control equipment are considered as one group of products. 

However, while this group includes thermostats (which in the other two reports - WS 

Atkins (1998) and ERM (1998) - belong to the electrical control equipment group), they do 

not include switches which are grouped with lighting equipment. The KEMI report uses 

the widely-quoted study by Maxson et al. (1991) as a starting point and estimates that in 

1997 the consumption of mercury in measuring equipment in Europe was 40% lower than 

the 1989 consumption reported by Maxson et al. With a 1989 consumption of just over 115 

t/year, the 1997 consumption was believed to be 70 t/year. 

Table 3.20 provides an overview of the most recently documented data on the consumption 

of mercury in measuring equipment. 

 

 27 Although ERM (1998) uses slightly different values, they are based on those derived by WS Atkins. 
Mercury Products - Risks to Health and the Environment 

Page 40

Table 3.20: Recent Estimates of EU Mercury Consumption in Measuring & Control Equipment 

Product type WS Atkins, 1998 KEMI, 1997 

Medical thermometers 23 t/year 

Other thermometers 28 t/year 

Other measuring equipment 4 t/year 

70 t/year* 

Total 55 t/year 70 t/year* 

*also includes thermostats and applies to all of Europe (i.e. not only EU Member States). 

 

Current Estimates at a National Level 

An indication of mercury usage in measuring (and control) equipment at a national level 

is given in Table 3.21. 

Table 3.21: Mercury Usage in Measurement (& Control Equipment) by Country (t/year) 

Country Commentary 

Austria Thermometers are believed to be the main source of mercury in the domestic waste 

stream. However, the mercury emissions are decreasing due to continuous 

replacement of mercury measuring devices with alternative ones (electronic and 

gallium ones are mentioned as the preferred options) (UNEP, 2002) 

Denmark The quantity of mercury used in measuring equipment in Denmark in 1993-93 was 

estimated to be 0.5 t/year (HELCOM, 2001). Consultation with the Danish EPA 

suggests that current usage is 0.1-0.2 t/year. This figure is believed to be equally 

divided between sphygmomanometers, laboratory equipment and chemical 

reagents. The decline in the use of mercury in Denmark was rapid in the early 

1990s. From the late 1990s, however, the levels of use of mercury have been 

largely stabilised. As the use of mercury in thermometers has been phased out, 

mercury in thermometers may account for only 10% or less of total mercury 

contained in measuring equipment 

Finland In 1987, the mercury consumption in measuring equipment was estimated as 1.6 

t/year (OECD, 1995). By 1996/97, this had reduced to about 300 kg/year 

(consultation) 

France In 1990/92, the mercury consumption in measuring equipment was estimated as 

12.5 t/year (OECD, 1995) 

Germany In 1987/90, the mercury consumption in thermometers was estimated as 11-15 

t/year with a further 20 t/year used in laboratories (OECD, 1995) 

Netherlands In 1989, the mercury consumption in measuring equipment was estimated to be 

less than 2.8 t/year (OECD, 1995) 

Sweden Usage has been reduced to tens of kg per year - see below 

United 

Kingdom 

Usage has been reduced to around 1.6 t/year - see below 

Poland It has not been possible to collect data on the use of mercury in measuring 

equipment in Poland. There is no central institution for registering products 

introduced to the market and the Polish Ministry of Health does not hold any 

information on the quantities of mercury used either. At present, there is no 

regulation requiring those who manufacture or import such articles to report on the 

quantities manufactured or imported. Therefore it is very difficult if not impossible 

to quantify the consumption of mercury in measuring equipment in Poland (based 

on information from team members in Poland) 

Czech Republic Consultation suggests that the quantity of mercury to be found in thermometers and 

sphygmomanometers in Czech hospitals to be 15-25t. Assuming that the annual 

consumption of mercury does not exceed 10% of this, the current consumption of 

mercury in the Czech Republic is assumed to be no more than 1.5-2.5 t/year 
Risk & Policy Analysts

Page 41

Sweden 

In 1997, the annual sales of mercury in ‘other regulated products’ was 40-50 kg. This 

category includes thermometers (0.2 kg) and other measuring equipment (including 

porosimeters (9 kg), switches, contacts, relays and thermostats (HELCOM, 2001). The 

low consumption in these applications was the result of legislation introduced in the early 

1990s (see Section 3.5.2). 

Since 1997, there has been a gradual decline in the already limited use of mercury in 

measuring equipment. Consultation with the Swedish authorities has revealed that in 

1998 only 250-300 mercury thermometers were still in use in all Swedish hospitals 

containing approximately 0.5-0.6 kg of mercury. Today, Swedish hospitals (effectively 

Swedish County Councils) do not purchase mercury thermometers or 

sphygmomanometers any more. It is believed that almost all mercury thermometers have 

been removed from Swedish hospitals and local authorities intend to remove the few 

remaining sphygmomanometers in the near future. 

Mercury collection programmes in Sweden have targeted thermometers over the years in 

the 1990s and about 0.69 tonnes of mercury were collected from 1992 to 1996 across the 

country. 

With regard to the use of mercury in sphygmomanometers, such equipment is used in 

both industrial and medical facilities, although mercury-based ones are only used in 

medical facilities over the last ten years. Those used are usually of small size and 

intended to be placed around toes and fingers. For the time being, the use of mercury in 

such equipment is exempt from mercury-related legislation, however fibre optic 

technology is being developed for medical use after showing good results in industrial 

applications. Consultation suggests that the estimated use of mercury in 

sphygmomanometers at present is considered to be lower that 1 kg per year. 

 

Overall, it is likely that the current mercury consumption in measuring and control 

equipment will be of the order of 20-30 kg/year. 

United Kingdom 

Information on the use of mercury in measuring equipment in the medical sector of the 

UK is fragmented. There are separate Supplying Authorities for England, Scotland, 

Wales and Northern Ireland within the UK’s National Health Service (NHS). Moreover, 

individual Health Trusts (hospitals) may bypass the central state authorities and purchase 

equipment directly from suppliers and manufacturers. 

The English branch of NHS Purchase and Supply Services confirmed that mercury use in 

measuring equipment is declining. Figures for 2001 show a 50% decrease in the number 

of supplied thermometers (82,320) and sphygmomanometers (1,224) compared to 2000 

figures. Naturally, some hospitals may have simply abandoned the central state suppliers 

and have opted for direct purchase from the manufacturers/merchants. Nevertheless, the 

downward trend is clear. As already indicated, one of the prime reasons behind this 

reduction is believed by consultees to be the requirements imposed by workplace safety 
Mercury Products - Risks to Health and the Environment 

Page 42

legislation and, in particular, the Control of Substances Hazardous to Health (COSHH) 

Regulations (as mentioned in Table 3.17). All of the thermometers supplied by the 

English NHS Supplies Agency in 2000 were manufactured in China. On the other hand, 

around 60% of the supplied sphygmomanometers were of EU origin with the rest 

originating mainly from Japan. 

Information from the Northern Ireland region also indicates a significant reduction in the 

number of mercury-filled units over the last 3-4 years, again mainly due to the 

requirements of the COSHH Regulations. The central NHS Supplies Agency in Northern 

Ireland no longer purchases mercury-filled thermometers nor sphygmomanometers - 

although such equipment is still in use. 

Other users of mercury-containing measuring equipment in the UK include laboratories, 

veterinary practitioners and educational establishments. In addition, there are a number 

of specialists who buy, sell, restore and repair antique barometers. 

Consultation with companies manufacturing and supplying mercury-containing 

measuring equipment has shown that: 

• in general, consumption of mercury has decreased over recent years and several 

consultees indicated that this reduction exceeds 50% compared to 1998 figures; 

• the decline in the use of mercury in the UK is expected to reflect EU trends; and 

• a significant proportion of measuring equipment originates from non-EU countries. 

The majority of clinical thermometers are imported from China, while Japanese and 

Indian products are also widely distributed. 

Initial estimates of the quantities of mercury used in the UK are given in Table 3.22. 

Table 3.22: Estimates of Present Use of Mercury in Measuring Equipment in the UK 

Product Estimated volume of UK 

sales Typical Hg content (g) Estimated consumption of mercury (kg/year) 

Medical 

thermometers 350,000 1

 0.5 - 1.5 300 

Domestic and 

industrial 

thermometers 

350,000 0.5 - 10 780 

Sphygmomanometers 5,700 85 485 

Barometers 875 40 35 

Total for above uses: 1,600 kg 

Source: Consultation with state authorities and private companies.

Note: 1) It has been assumed that the English NHS Supplies figure accounts for 80% of total NHSsupplied thermometers in the UK (England accounts for 50 million of the UK’s 60 million population). 

Additionally, it has been suggested that individual UK Health Trusts (hospitals) may have purchased 

collectively equal or even greater numbers of thermometers than those provided by the NHS. 

Furthermore, industry consultation suggests that there is a significant additional UK market for 

clinical/medical thermometers (presumably directly to consumers). 
Risk & Policy Analysts

Page 43

Summary

The use of measuring equipment that contains mercury has been shown to be on the 

decline, although insufficient data have been obtained to provide precise detail in most 

countries - particularly in southern Europe. 

In some countries, such as Denmark and Sweden, thermometers and other measuring 

equipment containing mercury are not imported nor sold any more while the use of 

mercury thermometers has been banned in France and the Netherlands. In the UK a 

significant reduction in mercury consumption has taken place since the mid-1990s. 

For the accession countries, limited information exists and the consultants have not been 

notified of any legislation imposed or other trend in the use of mercury in measuring 

equipment. For the Czech Republic, only an initial estimate of a consumption of 1.5 - 2.5 

t/year has been reached. 

Overall, a 50% reduction in the consumption figures quoted by WS Atkins in 1998 seems 

a reasonable scenario. This would bring mercury consumption in measuring equipment 

in the EU to about 28 t/year. For the three accession countries, a total of 5 t/year (on the 

basis of Czech data) could also be suggested as reasonable. 

3.5.4 Lifecycle and Emissions 

Manufacture 

As outlined above, many thermometers and other measuring equipment are imported, 

primarily from China, India and Japan. 

Within the EU, there are major manufacturers in the UK and Germany. In general, it is 

believed that emissions of mercury during the manufacture of measuring equipment are 

minimal and they do not contribute significantly to the total mercury load of the different 

environmental compartments. This is considered in more detail in Section 5. 

Product Use and Disposal 

 

For the estimation of mercury releases from the use of mercury-containing measuring 

equipment, two stages were followed based on the emission patterns indicated in the 

Swedish publication (KEMI, 1997): 

• the estimation of the distribution factors for the different pathways; and 

• the estimation of emission factors for the subsequent releases to air and water. 

The lifecycle and emission factors are shown in Figure 3.6 and discussed in more detail 

below. 
Mercury Products - Risks to Health and the Environment 

Page 44

Figure 3.6: Mercury in Measuring & Control Equipment - Lifecycle & Emissions

Distribution factors 

For collection, the Swedish report assumed a factor of 10%. Although this figure may 

have been seen as high if applied to EU countries in general a few years ago, there is little 

doubt that there has been a substantial increase in the awareness of the problems 

presented by mercury in recent years. As a result, we have assumed a distribution factor 

of 15% for the collection of manometers, barometers and sphygmomanometers which are 

due to be replaced (or possibly serviced) by specialist companies and for the recovery of 

mercury from industrial measuring equipment (where the bulk of mercury may be 

difficult to dispose of to the solid waste stream or to the sewer). 

With regard to disposal, it is assumed that 80% of mercury used will be disposed of as 

solid waste (75% of which will go to landfill). Additionally, 5% of equipment is 

assumed to break before it completes its useful lifetime. 

Although the current ‘inputs’ to mercury in measuring equipment have reduced 

significantly in recent years, typical lifetimes are of the order of 5-10 years. As a result 

the quantities of mercury ‘outputs’ (to the waste and recovery streams) will be 

significantly greater to reflect the greater consumption of 5-10 years ago. For the 

purposes of this analysis, the consumption of 5-10 years ago will be assumed to 

correspond to the earlier figure of 55 t/year derived by WS Atkins (for the mid-1990s) for 

the EU together with the 5 t/year for the three accession countries (which has been 

assumed to have remained relatively constant over the last few years). Five to ten years 

on, these items of equipment will have come to the end of their life which would give rise 

to a current ‘waste’ stream (from these now ‘old’ equipment) of 60 t/year - i.e. 182% of 

the current usage rate (= 60/33). 

Mercury Usage

in Measuring &

Control

Equipment

182% of Current Usage

Disposal of

equipment

New

equipment

Old

equipment

5-10 years

Breakage

For

Collection Recovered

15%

5%

Disposed to

Solid Waste

Incinerator

75% Landfill

80%

75%

9.5% Atmosphere

25% 25%

25%

75% Recycled

Sewer

20%

38%

Watercourses

Agricultural

20%

20%

50%

100%

10%

42%
Risk & Policy Analysts

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Emission factors 

As before, it has been assumed that there is no emission of mercury to any environmental 

compartment from recovered mercury and that 25% of the recovered mercury is sent to 

landfill. 

In the event of breakage, 10% is assumed to be lost to atmosphere, 20% to sewer, 20% is 

recovered and 50% enters the solid waste stream. The above figures are based on the 

assumption that the majority of mercury from broken measuring equipment is generally 

disposed of to landfill (or to sewer to a lesser extent) and it is only collected and recycled 

by medical and industrial facilities where proper equipment and procedures for recovery 

are invariably in place. 

For landfilled materials, it has been assumed that 5% is lost in the first year with 0.5% per 

year thereafter giving an annualised rate of 9.5% (over 10 years). It should be noted that 

in contrast to the products previously considered, much of the mercury entering the 

landfill (in measuring and control equipment) will be in liquid elemental form. 

With regard to incineration (and as discussed in S3.2.4), an incinerator will emit 25% to 

atmosphere with the remaining 75% (fly ash) sent to landfill. 

Summary 

Based on an annual consumption of 33 t/year within the EU and the three accession 

countries and the associated lifecycle and emissions outlined above, the overall endpoints were calculated to give the results presented in Table 3.23. 

Table 3.23: Mercury in Measuring and Control Equipment Emissions & End-Points (t/year) 

Parameter Amount (t/year) Comment 

Consumption 33.00 Based on S3.5.3 above 

End-points: 

Recycled 7.21 It has been assumed that 75% of mercury 

recovered from equipment is re-used 

Water Course 0.12 

Agriculture 0.23 

Atmosphere 8.08 Atmospheric emissions dominated by emissions 

from landfill (58%) and incineration (39%) 

Landfill/burial 44.43 

Accumulation1 -27.06 

This represents the additional flow entering the 

waste stream from ‘old’ equipment. As such, 

this equates to a reduction in the overall 

‘inventory’ of mercury present in measuring and 

control equipment (within the EU and the three 

accession countries) 

Check Totals: 33.00 

Note: 

1) Accumulation relates to the quantity of mercury in circulation within the product rather than to 

the total quantity of mercury present in the environment associated with the product.
Mercury Products - Risks to Health and the Environment 

Page 46

3.6 Electrical Control and Switching Equipment 

3.6.1 Overview of Use 

Mercury finds various applications in the field of electrical control and switching 

equipment primarily due to its excellent conductivity and its liquid state at room 

temperature. Stability and reliability coupled with low corrosion potential and relatively 

low price make mercury components for electrical and electronic equipment very useful 

and appealing. Types of products that may contain mercury include: 

• switches, contacts and relays: 

a) level (and motion) switches, which are used when switching on and off is 

triggered by movement; 

b) reed switches, known as circuit breakers, with their electrical contacts wetted 

with mercury to provide instant closure and opening of a circuit; 

c) multipoled switches, which are used in machinery with moving parts; 

d) thermo switches, which are used in thermostats; 

e) silent switches; 

f) mechanical switches (for example, solenoids), which are used when frequent 

switching is necessary; and 

g) contacts which are used to close, break, transfer or guide the current to different 

streams of current. A number of contacts forms a relay. 

• mercury vapour tubes and arc-rectifiers: 

a) valves that produce radiation of electromagnetic nature, such as X-rays, 

microwaves and radio waves, with the help of tubes containing mercury vapour; 

and

b) arc-rectifiers used in industrial control equipment and welding torches (OSPAR, 

2000; ERM, 1998).

The following paragraphs provide a brief overview of the technical characteristics of 

some of the main mercury-containing measuring equipment. 

Switches 

Switches are used to control (open and close) electrical circuits. They are activated by a 

change in temperature (temperature switch - i.e. a thermostat), pressure (pressure switch), 

or position/motion (tilt switch, float switch). 

Mercury switches frequently have far fewer components than mechanical type electrical 

switches with levers, springs, pivoting electrodes, etc. The use of a hermetically sealed 

container, inside which switching takes place, ensures that there is no exposed spark, thus 

these devices can be safely operated in explosive atmospheres (fuel areas, hospital rooms, 

coating booths, etc.) (Kahlsico, 2000). 

Silent/tilt switches are small tubes with an electrical contact at one end of the tube. As 

the tube tilts, mercury collects at the end where the electrodes are situated. Such switches 
Risk & Policy Analysts

Page 47

are used in numerous applications such as: light switches, sump pump float controls, 

automobile trunk lamps, chest freezer door lamps, and washing machine lift covers (Sass 

et al., 1994). Although consultation indicates that there is a general move away from 

mercury switches, they are still used widely in security applications (for example, motion 

alarms). 

Mercury safety valve/mercury flame sensors detect the presence of a pilot light for a gas 

burner and controls the flow of gas into the burner if the pilot light is out. They find 

applications in both residential and commercial equipment (e.g. ovens) (Environment 

Canada, 2000). 

Reed switches are small circuit controls with mercury wetted electrical contacts 

(Environment Canada, 2000). Mercury is able to provide an instantaneous circuit when 

the switch is closed and to permit instantaneous current interruption when the circuit is 

broken. Reed switches eliminate the static produced in ordinary hard-contact-type 

switches. Such equipment is used in applications where static would impair the operation 

of the electronic device. Reed switches are reported to be less expensive than solid-state 

alternatives and therefore are still favoured by some users. However, solid-state relays 

and electro-optical switches are rapidly replacing mercury-wetted switches (Sass et al., 

1994 and consultation). Mercury-wetted reed switches are often used for applications 

where electronic noise and interference from switch ‘bounce’ are a concern (Inland Ispat 

Indiana Harbor et al., 2001). 

Relays 

Relays are devices in which low power signals (from control devices) are used to actuate 

larger power operations (such as motorised valves) by opening or closing electrical 

contacts in a circuit. Mercury-wetted ‘reed’ relays are used for switching of signals and 

power levels since the load does not affect either contact life or performance as no solid 

metal-to-metal contact occurs. They are primarily used in test, calibration and 

measurement equipment where stable contact resistance over the life of the product is 

necessary. They are usually produced in relatively small quantities as they are intended to 

be used in specialist equipment (Inland Ispat Indiana Harbor et al., 2001). 

Displacement/plunger relays are generally used for high-current, high-voltage 

applications, resistance heating, welding, lighting, power supply switching, and industrial 

process controllers (Inland Ispat Indiana Harbor et al., 2001). 

Other Applications 

The transistor, developed in 1947, has replaced most vacuum tubes and some gas-filled 

tubes. Some tubes, however, have not been replaced by solid-state devices, although 

inroads are being made. Examples of such applications include microwave ovens, radar 

installations, X-ray machines, or mercury-arc rectifiers. Gas-filled mercury tubes use a 

pool of mercury as the cold cathode pool (Sass et al., 1994). 

Mercury arc rectifiers were extensively used in the past to provide DC in high power 

applications, powers ranging from kilowatts up to a few megawatts, at voltages ranging 
Mercury Products - Risks to Health and the Environment 

Page 48

from 110V to 30kV. An arc between a pool of mercury and a metal anode which only 

allows current to pass in one direction are the basic components of the rectifier. Multiple 

anodes are typically used, fed from a multiple-phase transformer, with the arc jumping 

from the cathode pool to each anode in sequence. There may be three, six or even twelve 

transformer phases, each feeding one anode. Six and twelve-phase systems used starconnected three-phase transformers with interphase transformers between the star 

common connections. Construction is either a glass bulb, cooled by an external fan or 

water jacket, or a steel tank for very large units with capacities above about 500 amperes. 

However, mercury arc rectifiers have now been made totally obsolete by semiconductors, 

although there are a few still in service in old installations (Harrison, 2001 and 

consultation). 

3.6.2 Control Issues 

At an International Level 

PARCOM Recommendation 89/3 proposed, among others, measures on recycling mercury 

used in electrical equipment; it also promoted the use of equipment not containing mercury, 

where the cost of replacement is not extremely high (OSPAR, 2000). HELCOM 

Recommendation 18/5 was concerned with the reduction of emissions and subsequent 

pollution of mercury resulting from electrical (and light) equipment (CTC, 1999). 

Reduction in mercury usage and increased recycling is also encouraged by the Aarhus 

Protocol (UNECE, 1998). 

Although there is a general presumption against future mercury usage in switches and 

relays under the proposed RoHS Directive, many current uses will be exempted including 

not only laboratory/medical equipment but also thermostats and heating regulators. 

Consultation with the association representing the European manufacturers of (electrical) 

domestic equipment (CECED) has shown that a relatively recent CENELEC28 safety 

standard (EN 60335-1:1994/A13:1998) which gives presumption of conformity of domestic 

appliances (refrigerators, washing machines, toasters, etc.) to the EEC Low Voltage 

Directive (LVD) 73/23/EEC contains the following provision: 

“Appliances shall not incorporate components containing liquid mercury” 

(sub-clause 22.41). 

Additionally, a new IEC29 standard (IEC 60355-1:2001), which is being currently 

transposed to Europe, indicates that: 

“Appliances shall not incorporate components, other than lamps, 

containing liquid mercury” (sub-clause 22.41). 

 

 28 European Committee for Electrotechnical Standardisation. 

 29 International Electrotechnical Commission. 
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The CECED secretariat has notified the consultants that their member associations have 

confirmed that their member companies duly conform with the above standards and 

therefore, mercury is no longer used in domestic electrical appliances. It should be noted 

that associations from Finland, Greece, Ireland, Luxembourg and Portugal do not appear in 

the list of members of CECED (although national associations of manufacturers from 

Norway, Switzerland and Turkey are included) (CECED, 2002). 

At a National Level 

Specific controls over limiting mercury use in electrical equipment have been 

implemented in various countries as indicated in Table 3.24. 

Table 3.24: Controls for Mercury in Electrical Equipment by Country 

Country Control Source & Comment 

Denmark Being phased out under Order 692 (see Section 1.2) 

although some switches, relays and electrodes exempt 

until further notice 

HELCOM (2001) and 

submission to UNEP 

(2001) 

Netherlands Under the 1998 Decree (see Section 1.2), most mercury 

containing electrical equipment now banned 

consultation 

Sweden Manufacture and sale of mercury in electrical equipment 

has been banned since 1993 (with some exemptions). 

Manufacture and sale of all such equipment now banned 

by The Chemical Product Ordinance 1998:944 

HELCOM (2001) and 

submission UNEP 

(2001) 

3.6.3 Quantities Used 

Typical Quantities of Mercury Contained in Electrical Control Equipment 

The typical quantities of mercury contained in electrical and switching equipment are 

given in Table 3.25. As for measuring equipment, there are now non-mercury equivalents 

in most cases, which tend to be used in preference. 

Table 3.25: Typical Quantities of Mercury Contained in Electrical Control Equipment 

Type of equipment Quantity of Hg contained (g) 

Modern mercury switch 0.01 - 1 

Flame sensor (for gas installations) 2.5 

Silent switches* (for lights) 2.6 

Displacement switch and solenoids* up to 130 

Thermostat (old mercury tilt switch*) 3 - 6 

Freezer light* 2 

Washing machine* (power shut off) up to 2 

Automobile light switch* 0.7 - 1.5 (average 0.8) 

Automobile ABS switch ~3 

Automobile ride-control switch 1 

Mercury vapour tubes and arc-rectifiers* up to 5000 (average 250) 

Sources: Inland Ispat Indiana Harbor et al., 2001; Ecology Center et al., 2001; US EPA, 2000a; and 

consultation. 

Note: * indicates items that are now believed to be obsolete. 
Mercury Products - Risks to Health and the Environment 

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Previous EU Wide Estimates 

The ERM (1998) and WS Atkins (1998) reports provide slightly differing figures of 

mercury consumption in electrical control equipment. ERM indicates a consumption of 

24 t/year, while WS Atkins assumes a 29 t/year consumption. The KEMI report (1997) 

has incorporated electrical control equipment into electrical and lighting equipment and 

has considered thermostats as part of the measuring equipment group, hence a 

comparison of the Swedish estimates with those made by the former two reports is 

unrealistic. Additionally the estimated Swedish report figure of >230 t/year of mercury 

consumption in electrical lighting and control equipment in 1997 is applicable to all 

Europe (i.e. both EU and non-EU countries). 

Current Markets 

The European markets for electrical control and switching equipment are large. Those for 

switches and relays are each of the order of a billion euros per year (EPIA, 2002 & VDC, 

2000). Of course, these markets cover the full range of equipment (ranging from simple 

mechanical switches to solid-state relays) and it is unlikely that the mercury containing 

equipment30 market accounts for more than 1% (consultation). 

Despite numerous approaches to companies and trade associations, very little definitive 

information has been provided. Although there remains a considerable degree of 

uncertainty, it would appear that: 

• the current EU mercury switch market is of the order of five to ten million switches 

per year - split between those with up to one gramme of mercury per switch and 

smaller switches with the order of 0.1 gramme of mercury per switch; 

• the current mercury consumption is perhaps several tonnes of mercury per year; 

• the mercury switch market has declined by about 25% in recent years as customers 

have moved to non-mercury alternatives; 

• although there are manufacturing facilities in Belgium and Germany (and possibly 

elsewhere), there are many imports, primarily from the US; and 

• mercury vapour tubes and arc rectifiers are no longer supplied. 

 

Against this background, the current consumption of mercury-containing equipment will 

be taken, perhaps conservatively, as 8 t/year for the EU with a further 1 t/year in the three 

accession countries (i.e. 12% of EU figure). Although these figures are uncertain, these 

findings would suggest that the figures advanced in the earlier reports (as outlined above) 

were unduly conservative.

Current Estimates at a National Level 

An indication of mercury usage in electrical control and switching equipment at a 

national level is given below. 

 

 30 Note that a simple modern mercury switch sells for about one euro. 
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Denmark 

The 1992-93 consumption of mercury in electrical control and switching equipment in 

Denmark was estimated to be 0.2-0.4 t/year with a decreasing trend given that in 1990 the 

respective figures were 0.3-1.6 t/year. 

According to the Danish EPA, electrical switches and relays have been banned since 1 

July 1994. The use of mercury is only allowed in small film-wetted switches. A realistic 

estimate of the present situation in Denmark indicates that the use of mercury in electrical 

components is only marginal.

Sweden 

Swedish legislation which came into force in 1993 prohibits the manufacture, import and 

sale of mercury containing electrical components. Therefore, the consumption of mercury 

in Sweden is believed to be negligible. However, consultation with the Swedish authorities 

yielded information on the quantities of mercury which are still present in Sweden as 

illustrated in Table 3.26. 

Table 3.26: Mercury Stored in Electrical Components in Sweden (2002 estimates) 

Type of equipment Estimated Hg quantity (tonnes) 

Electrical and technical products stored in industry 1 27 - 32 

Electronics built into products (dealt with by dismantlers) 2 - 3 

General household uses (heating oil-level indicators, doorbells, other 

unusual applications) 2 1 - 2 

Rectifiers for power sea cables 1.8 

Mercury components in cars 1 

White goods switches 0.3 

Source: Consultation 

Notes: 1) also includes thermometers and other measuring devices 

 2) also includes indoor/outdoor thermometers and barometers 

It is worth noting that European carmakers have reportedly phased-out mercury light 

switches in automobiles since 1992 in order to meet the Swedish ban on vehicles 

containing mercury (Ecology Center et al., 2001 and consultation). Furthermore, the EU 

ELV Directive bans the use of mercury in vehicles from 1 July 200331.

United Kingdom 

Consultation suggests that the UK market for mercury switches is of the order of a 

million switches per year, which represents a significant portion of the EU market. The 

leading UK supplier imports the ‘basic’ switches from the US which are then 

incorporated into further casings and/or mountings for resale. 

 

 31 Although, the presence of small amounts of mercury in HID (xenon) headlamps (as discussed in S3.4.3) 

now being fitted to some Swedish cars will be exempt. 
Mercury Products - Risks to Health and the Environment 

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3.6.4 Lifecycle and Emissions 

Similarly to measuring equipment, the basis for emissions estimates for mercury 

contained in switching and electrical control equipment is the KEMI (1997) report and 

the WS Atkins 1998 report (the latter for product manufacture only). 

Product Manufacture 

In general, it is believed that emissions of mercury during the manufacture of switching 

and electrical control equipment are limited. This is discussed further in Section 5. 

Product Use and Disposal 

For the estimation of mercury releases from the use of mercury-containing switching and 

electrical control equipment, two stages were followed: 

• the estimation of the distribution factors for the different pathways; and 

• the estimation of emission factors for the subsequent releases to air and water. 

Distribution Factors 

The lifetime of mercury switches and other mercury containing electrical control 

equipment could extend to decades. In practice, the lifetime will be determined by that of 

the item within which the equipment is contained - which is more likely to be of the order 

of 5 - 10 years. For the purposes of this assessment, it will be assumed that the quantity 

of mercury requiring disposal will be 150% of the current usage - i.e. 13.5 t/year which is 

equivalent to current usage (9 t/year) plus 50% additional inputs from ‘old’ equipment. 

The 1997 Swedish report assumed an arbitrary 10% distribution factor for re-collection of 

mercury-containing switches and electrical equipment. Switches and other mercurycontaining electrical equipment are rarely collected for recycling when they are replaced 

by owners but are more likely to end up in the recycling stream if replaced by 

professionals. Additionally, some switches and thermostats and especially vapour tubes 

and arc-rectifiers are bulky items that cannot simply be disposed of to the solid waste 

stream as they are. As for measuring equipment, a factor of 15% will be used here to 

accommodate more recent practices in the recycling of hazardous substances like mercury 

from electrical equipment. 

An additional 5% factor is used to account for the quantities of mercury in switches and 

other equipment which are being recovered by the steel scrap industry and used in steel 

production. 

Physical breakage is a very infrequent occurrence with respect to mercury switching and 

electrical control equipment. Such articles may fail to perform but they seldom break and 

release their mercury contents. Hence, ‘breakage’ emissions will be negligible. 

The remaining 80% of the mercury has been assumed to enter the solid waste stream. 
Risk & Policy Analysts

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The lifecycle (and emission factors) are shown in Figure 3.7. 

Figure 3.7: Mercury in Electrical Control and Switching Equipment - Lifecycle & 

Emissions 

Emission factors 

As before, it has been assumed that there is no emission of mercury to any environmental 

compartment from recovered mercury and that 25% of the recovered mercury is sent to 

landfill. 

For landfilled materials, it has been assumed - as for measuring and control equipment 

considered previously - that 5% is lost to atmosphere in the first year with 0.5% per year 

thereafter giving an annualised rate of 9.5% (over 10 years). 

With regard to incineration (and as discussed in S3.2.4), an incinerator will emit 25% to 

atmosphere with the remaining 75% (fly ash) sent to landfill. 

In the case of items entering the steel scrap system, the emissions to atmosphere are likely 

to be relatively higher from arc furnaces and an emission factor of 90% is used (as for 

lamps - see S3.4.4). 

Mercury Usage

in Electrical

Control &

Switching

Equipment

Breakage

(negligible)

For

Collection

Recovered

15%

c0%

Disposed to

Solid Waste

Incinerator

Landfill

75%

80% 75% Atmosphere

9.5%

25%

25%

25%

Disposed

with Steel

Scrap

5%

10%

75% Recycled

100%

150% of Current Usage

Disposal of

equipment

New

equipment

Old

equipment

5-10 years

90%
Mercury Products - Risks to Health and the Environment 

Page 54

Summary 

Based on an annual consumption of 9 t/year within the EU and the three accession 

countries and the associated lifecycle and emissions outlined above, the overall endpoints were calculated to give the results presented in Table 3.27. 

Table 3.27: Mercury in Electrical Control and Switching Equipment 

Emissions & End-Points (t/year) 

Parameter Amount (t/year) Comment 

Consumption 9.00 Based on S3.6.3 above 

End-points: 

Recycled 1.52 It has been assumed that 75% of mercury 

recovered from equipment is re-used 

Water Course 0.00 

Agriculture 0.00 

Atmosphere 2.30 

Atmospheric emissions associated with 

emissions from landfill (44%), incineration 

(29%), and scrap steel processing (26%) 

Landfill/burial 9.68 

Accumulation1 -4.50 

This represents the additional flow entering the 

waste stream from ‘old’ equipment. As such, 

this equates to a reduction in the overall 

‘inventory’ of mercury present in electrical 

control and switching equipment (within the EU 

and the three accession countries) 

Check Totals: 9.00 

Note: 

1) Accumulation relates to the quantity of mercury in circulation within the product rather than to 

the total quantity of mercury present in the environment associated with the product.

 
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3.7 Other Products 

3.7.1 Overview 

It is claimed that mercury is (or has been) used in a variety of other products including 

‘executive toys’, pads to absorb rifle recoil, arm/leg weight bands, golf balls, etc. Other 

uses include cosmetic and pharmaceutical products - although, as indicated in S3.1.6, the 

latter are beyond the scope of this study. 

During the course of this study, the most comprehensive listing of mercury containing 

products found was one prepared for the Minnesota Pollution Control Agency which is 

reproduced as Annex 3. Although most of the products listed are covered in the 

preceding sub-sections, the following paragraphs outline some of the other uses of 

mercury which cannot be readily classified under the main usage categories which have 

been examined in this report. Only limited information is available on these uses and 

little or no information on the consumption of mercury has been obtained. 

3.7.2 Golf Balls 

There is often anecdotal evidence that mercury is used in golf balls. However, research 

indicates that although mercury filled centres were experimented with in the early 1900s, 

there have been no golf balls with mercury centres on the market for many years32 - and 

this has been confirmed by consultation with a number of well known golf ball 

manufacturers. 

3.7.3 Pigments 

Natural (and synthetic) cinnabar (mercuric sulphide) has been used as the red pigment, 

vermilion, for thousands of years (in China, at least). In Europe, the use of vermilion was 

a vital part of paintings by Monet, Rembrandt and Titian. Given the concerns over health 

and the environment associated with the use of mercury and its compounds in recent 

decades, its commercial use has practically disappeared. 

However, although becoming increasingly hard to find, artists in Europe can still buy 

vermilion pigment (some of which is still natural cinnabar imported from China). 

Historically, mercury pigments have been used in plastics (as indicated in Annex 3). 

Although it would appear that the French company specifically identified still sells 

cadmium pigments, there is no indication that mercury pigments are sold. 

 

 32 See, for example, www.erupegolf.com 
Mercury Products - Risks to Health and the Environment 

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3.7.4 Childrens’ Shoes 

Many references33 may be found to the use of mercury in shoes which have flashing lights 

- mainly designed for children. However, few of these references provide the requisite 

detail to permit informed comment. It would appear that although some of the earliest 

versions of these shoes (dating from the early 1990s) did incorporate a liquid mercury tilt 

switch, these were soon replaced with a non-mercury pressure switch. The lights tend to 

be powered by lithium (non-mercury) button cells. 

3.7.5 Lighthouses 

Lighthouses around the world rely on rotating a large lens assembly, weighing up to a few 

tonnes, every 10 seconds or so. Traditionally, the lens assembly floats in a bath of a few 

hundred kilograms of mercury. Although there is anecdotal evidence that the presence of 

the mercury may have contributed to depression and, even, suicide amongst lighthouse 

personnel, most lighthouses are no longer manned. 

Although some such arrangements have been replaced with non-mercury alternatives, 

others retain their mercury baths. No estimate of the number of lighthouses still using 

mercury baths in the EU has been derived although the Swedish authorities estimate that 

there is 1t in use in Swedish lighthouses (consultation). 

3.7.6 Gold Mining

Mercury may be used to extract gold from crushed ore through the formation of an 

amalgam. The amalgam is then decomposed by the addition of nitric acid or, more 

simply, by heating. Although this is a significant use of mercury which accounts for 5-

10% of the global mercury supply (as suggested by Vonkemann, 2000), gold mining 

within the EU is minimal. 

In South America, there is widespread artisanal gold mining in which mercury is used 

and released to the environment. Of note is that one of the countries involved is French 

Guiana (or Guyane) which is an overseas department of France. Current gold production 

is estimated to be about 3 t/year (of up to 200 t/year for South America as a whole) and it 

is estimated that for each tonne of gold produced, one tonne of mercury is released to the 

environment (representing up to 50% of the mercury used in the process) (Veiga, 1997). 

On this basis, mining in French Guiana could result in the emission of around 3 t/year of 

mercury to the environment. 

3.7.7 The Use of Mercury in Medicines 

Although technically outside the scope of this study, this section has been included to 

indicate the relative usage of mercury in medicines. Studies undertaken by the US Food 

and Drug Administration (FDA) have shown that several ophthalmic, otic, injectable and 

topical drugs and vaccines for humans may contain mercury compounds such as 

 

 33 See, for example, http://sneakers.pai.com/lightup.htm. 
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thiomersal (thimerosal in the US), phenylmercuric acetate, and phenylmercuric nitrate. 

Furthermore, a large variety of mercury compounds was identified in human and animal 

homeopathic products and in traditional medicine products (such as herbal pills from 

China). It was estimated that about 1,000 homeopathic products in the US market may 

contain small amounts of mercury. The mercury compound content of the above 

products varied from 1 ppm to more than 100 ppm and the total quantity of those 

compounds used in all products was estimated to be approximately 75-80 kg/year (FDA, 

2001). 

In Ireland, the Health and Safety Authority identified a plant which uses mercury as a 

preservative in eye care products. Recent mercury consumption has been about 5 kg/year 

with emissions of less than 0.5 g/year to waste water (emission factor: <0.01%) and zero 

emissions to other environmental media (Irish submission to UNEP, 2001). 

Thiomersal 

Mercury is used in medicinal products, mainly in the form of thiomersal. The substance 

finds applications particularly in vaccines either as a preservative to avoid microbial 

contamination due to repeated withdrawal of doses from a container or for other reasons. 

In Sweden, it has been calculated that by taking the yearly consumption of these vaccines 

and a mercury concentration of 25 μg per dose, the total amount used is around 20 grams 

per year (Swedish submission to UNEP, 2001). 

A thorough toxicological assessment of the use and potential risk of thiomersal, when 

administered to humans, has been made by the European Agency for the Evaluation of 

Medicinal Products (EMEA). The assessment concluded that there was no risk of acute 

toxic reactions in the doses used. However, a risk of sensitisation was identified and all 

products containing thiomersal should carry a warning statement in the catalogue text. 

Furthermore, the EMEA recommends the use of thiomersal-free vaccines for young 

children (EMEA, 2000).

3.7.8 Mercury in Cosmetic Products 

Mercury and its compounds are not permitted in cosmetics marketed within the EU34, 

although trace amounts are permitted in preservatives (as discussed above) for eye makeup and eye make-up remover35. 

A study undertaken by the Danish National Environmental Research Institute (NERI) in 

1999 found that several brands of soap and cream with significant levels of mercury are 

sold in Tanzania. These products are used to make skin and hair lighter in colour and 

their origin was found to be the EU. Soaps usually contain 1-3% mercury iodide, while 

the creams contain 1-10% mercuric ammonium. 

 

 34 Council Directive 76/768/EEC of 27 July 1976 relating to cosmetic products. 

 35 Eighth Commission Directive 86/1999/EEC of 26 March 1986 adapting Council Directive 76/768/EEC to 

technical progress permits up to 0.007% (70ppm) of mercury as thiomersal or phenylmercuric salts in eye 

products. 
Mercury Products - Risks to Health and the Environment 

Page 58

The distribution of mercury-containing cosmetics products is prohibited in the EU, North 

America and many African countries. In Tanzania, the import of soap containing 

mercury is forbidden although large volumes of such products are smuggled into the 

country and are used for the bleaching of skin and hair. During this study, three brands of 

soap and two brands of cream were found in Tanzanian markets. All three soaps were 

marketed as antiseptics and had a declared concentration of 2% mercury iodide (or 0.88% 

mercury). On the other hand, the two creams claimed to produce a lighter skin colour and 

contained hydroquinone, allantoine and vitamins. Analyses revealed that the three soaps 

contained on average 0.69% mercury (i.e. slightly less than labelled), while the suspicions 

about the presence of mercury in the two creams were not confirmed. Four of the 

samples belong to products made in the UK while the fifth was of Italian origin (NERI, 

1999). 

The Danish report indicates that such products can also be found in areas of the EU. By 

way of example, the Danish EPA issued a press release on 22 March 2000 according to 

which seven brands of mercury-containing soap had been found in shops in Copenhagen. 

At the time it was believed that the products were made in the UK and Spain and were 

sold to the Danish companies either directly or through dealers in France (Danish EPA, 

2000a). The soaps were intended to be used as bleaching agents and contained 1-3% 

mercury iodide. Later that year (in December 2000), the Danish authorities issued a new 

press release according to which five shops in Copenhagen had been notified to the police 

for marketing soaps containing mercury. New brands of such soaps were identified (apart 

from those known since Spring 2000) and their origin was Italy and Spain (Danish EPA, 

2000b). 

An Irish company is reported to produce mercuric iodine soap. The company uses 95 

t/year of potassium mercuric iodine solution which is equivalent to 17.2 t/year of 

mercury. No effluent discharges of air emissions were detected during on-site 

investigations by the Irish authorities while solid waste is forwarded for disposal off the 

company’s site (Irish submission to UNEP, 2001). 

In summary, although the sale of mercury soap is prohibited in the EU (as it is a cosmetic 

product), its manufacture for export outside the EU is not. However, it would appear that 

some of these products are sold within the EU (perhaps after being exported to and then 

re-imported from a non-EU country). 

3.7.9 Mercury in Chemical Agents 

Another significant ‘other’ use of mercury is the use of mercury containing chemicals. In 

the laboratory, the standard COD ‘dichromate’ test involves the use of mercuric sulphate 

to suppress chloride interference (if chloride levels are high). It is worth adding that, in 

light of concerns over mercury, one of the leading suppliers now offers an alternative 

manganese III method. In the chemical industry, mercury compounds are used as 

catalysts for the production of, for example, vinyl chloride and urethane foams. In the 

fireworks and explosives industry, mercuric fulminate is sometimes used as a detonator. 
Risk & Policy Analysts

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The Swedish government is considering an amendment of Ordinance 1998:944, by which 

the use of mercury in chemicals for analysis and reagents would be banned from 1 

January 2004, since earlier information campaigns for phasing out reagents such as those 

used in the determination of COD in laboratories have been unsuccessful (Swedish 

submission to UNEP, 2001). 

Mercury in Hospital Laboratory Reagents

Two tissue fixatives used in medical laboratories contain significant amounts of mercury: 

Zanker’s solution and B5. While the former contains 72 g of mercury per litre, the latter 

contains 37 g of mercury per litre. These reagents can be substituted in many cases by 

other fixatives but not in all. Different fixatives have different fixative and staining 

properties and require the preparation of different specimens, therefore practitioners may 

still show some preference to mercury-containing fixatives for reasons of convenience 

(Torke, 1994). 

3.7.10 Other Mercury-containing Hospital Equipment 

Significant amounts of mercury may be found in Bougie tubes and Canter tubes used by 

medical practitioners in hospitals. The Bougie tube is a mercury weighted instrument 

that is used to ‘pound’ an opening in the oesophagus when there are cancerous growths or 

other obstructions. The Canter tube is a tube almost 2 meters long which is filled with 

mercury and is inserted down the patient’s gastrointestinal tract. Information from the 

US indicates that non-mercury alternatives are now available for both these devices 

(Torke, 1994). 

3.7.11 The Use of Mercury as an Archery Stabiliser 

Stabilisers aim to provide a smooth feeling of the bow, to reduce the possibility of torque 

affecting arrow flight and to reduce vibration during and after shots. Mercury-filled rods 

were introduced as anti-torque stabilisers in the late 1960s along with other liquids - 

although the use of mercury was never popular in Europe (consultation). 

Later, liquids were replaced by foam and sand. Many modern bows use lightweight, stiff 

aluminium or carbon rods with rubber mountings which are fitted between the rod and 

the end-weights in order to dampen vibration. The most up-to-date stabilising system 

consists of multiple thin rods with a moveable weight which allows the archer to tune the 

stabiliser (Elliot, 2000). 

3.7.12 Rifle Recoil 

Recoil suppression systems in rifles and shotguns usually incorporate a lead or steel 

weight mounted on springs to reduce recoil. There are, however, alternative systems 

which use liquid mercury (170g or more per gun) which are widely marketed in the US. 

 
Mercury Products - Risks to Health and the Environment 

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3.7.13 Mercury-containing Lamps in LCD Monitors 

Liquid Crystal Displays contain mercury due to the presence of back lamps that contain 

the metal. The typical number of back lamps in a portable (laptop) computer is 2 but a 38 

cm (15 inch) LCD monitor will normally contain 4 lamps and an even larger monitor 

could contain 6, 8 or more lamps in order for the appropriate levels of brightness to be 

maintained. The mercury content of an LCD back light was reported in 2001 to be 

between 2.5 and 3.5 mg. It is worth noting that the updated EC eco-label criteria for 

personal computers which were issued on 22 August 2001 require that the background 

lighting of LCD monitors should not contain more than 3 mg of mercury per lamp on 

average (Commission Decision 2001/686/EC) (AEA Technology, 2001). 

Screens using organic light emitting diodes could replace mercury-containing LCD 

monitors, however their use is considered more feasible in mobile phones at the moment 

rather than computers. It is expected that this technology will be introduced to portable 

computers by the year 2004. 

Within the EU, laptop sales are of the order of 7 million per year and account for about 

20% of personal computer sales. This would give a mercury consumption of: 

 7 million laptops x 4 lamps/laptop x 3 mg/lamp = 84 kg/year 

With regard to televisions (for which the introduction of an EC eco-label is currently 

under way), LCD technology is also applicable - although CRT displays are to be found 

in the great majority of equipment. From an environmental point of view, LCD 

technology is superior in that it allows for the mercury back lights to be easily separated 

from the display and be recycled (AEA Technology, 2002). 

It should be noted that the contribution of such lights is probably included in the overall 

‘lamp’ figures presented in Section 3.4. 

3.7.14 Summary 

From the preceding discussion, it is clear that mercury has been or may continue to be 

used in a diverse range of products. Although determining the quantities involved is very 

uncertain, Table 3.28 provides some preliminary estimates. 

Table 3.28: Mercury Usage in Other Products 

Type of product Estimated Mercury Usage in the EU 

Golf balls Negligible 

Pigments Perhaps up to 50 kg/year 

Children’s shoes Negligible (as most shoes containing mercury will have been disposed 

of) 

Lighthouses 

Number of lighthouses with mercury baths not known but quantity of 

mercury in use could be of the order of 10-15 tonnes. The associated 

mercury consumption will be low, perhaps up to 100 kg/year 
Risk & Policy Analysts

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Table 3.28: Mercury Usage in Other Products 

Type of product Estimated Mercury Usage in the EU 

Gold mining Mercury usage (in French Guiana) likely to be 6 t/year or more with 3 

t/year emitted to the environment 

Medicines Based on US data of 75 - 80 kg/year, the EU consumption is not 

expected to exceed 100 kg/year as a worst case scenario 

Cosmetic products 

From the Irish data of 17.2 t/year and given that several UK, Italian 

and Spanish companies are active in the business (given the large 

African market), a consumption of 50 t/year is possible, although 

some UK companies deny that they manufacture soap in the UK. 

However, the use of such products (and associated emissions) will 

tend to be outside the EU. 

Chemical agents and hospital 

laboratory reagents 

Perhaps of the order of 100-200 kg/year (note that agents are 

gradually being replaced with non-mercury alternatives) 

Archery stabiliser Negligible 

Rifle recoil Probably, small to negligible use in the EU 

LCD monitors 80-100 kg/year in laptops but may well have already been accounted 

for in ‘lamps’ 

All the above The order of 50 t/year within the EU with, perhaps, a further 5 

t/year in the three accession countries 
Mercury Products - Risks to Health and the Environment 

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3.8 Summary of Product Usage and Emissions 

The overall consumption of mercury in the products under study is of the order of 200 

t/year within the EU and the three accession countries being considered (Czech Republic, 

Poland and Slovenia). 

Although much of the mercury is recovered for re-use from the disposal of mercury 

containing products, most of the mercury will end up in landfills. Since mercury usage is 

generally declining, the quantities of mercury entering the waste stream are now greater 

than those entering into product use. This, in turn, is leading to a reduction in the total 

‘inventory’ of mercury within the products in circulation. However, since mercury 

cannot be simply destroyed, there will continue to be a mercury build up in the 

environment - most noticeably in landfills. 

The results of the analyses presented in the previous sub-sections are summarised in 

Table 3.29 

Table 3.29: Mercury Usage in Products within EU and Three Accession Countries1

End-points and Quantities (t/year) 

Product 

Current 

Usage 

(t/year) Re-use Air Water Soil Landfill 

Change 

in Inv Q2

(t/year) 

Dental 

Amalgam 90.0 59.8 6.5 1.4 2.6 43.5 -23.8 

Batteries 9.0 1.35 0.55 0 0 7.1 0 

Lighting 5.9 0.9 0.8 0 0 4.2 0 

Measuring 

Equipment 33.0 7.2 8.1 0.1 0.2 44.4 -27.1 

Electrical 

Equipment 9.0 1.5 2.3 0 0 9.7 -4.5 

All the 

above 146.9 70.7 18.3 1.5 2.8 108.9 -55.3 

Other 

Products3

 c55 not determined 

Notes: 

1) Czech Republic, Poland and Slovenia. 

2) Inv Q represents ‘inventory quantity’ - i.e. the quantity of mercury in circulation within products. 

3) Likely to dominated by cosmetic products (see S3.7.8 and Table 3.28). 
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4. OVERVIEW OF EXPOSURE TO MERCURY

4.1 Background to Discussion 

This section provides a general discussion of the sources of environmental and human 

exposure to mercury. It is intended to provide an overview of the total exposure to 

mercury, from all sources. Section 5 then provides an estimate of the environmental 

exposure and exposure of humans via the environment for the uses of concern for this 

study. The remainder of this section is structured as follows: 

• consideration is given first to environmental releases, both anthropogenic and 

natural with quantitative data presented on releases, based on a review of recent 

literature; 

• fate and behaviour of mercury in the environment is then discussed, with 

information presented on speciation in the environment and transport within and 

between environmental media; 

• a summary of relevant data on environmental concentrations is provided together 

with an indication of changes over time. This provides a basis on which to put the 

estimated exposure for the uses of concern into context; and 

• finally, an overview of human exposure - both occupation and non-occupational - 

is given. 

4.2 Releases of Mercury to the Environment 

4.2.1 Introduction 

The natural releases and anthropogenic emissions of mercury have been investigated 

over the years and estimates on the relevant figures have been reached. However, 

these estimates are under constant revision as more monitoring data become available, 

as knowledge of the complex lifecycle of mercury improves and as additional up-todate information is collected. As will be shown in the next paragraphs, while 

anthropogenic emissions of mercury have reduced in real terms due to increased 

awareness, controls and regulation as well as advances in technology, the contribution 

of anthropogenic sources to the global mercury load seems to have increased recently. 

The underlying reason is that there has been a dramatic fall in the estimates of the 

contribution of natural sources. This does not mean that the actual natural releases 

have been reduced, but instead, reflects the realisation by scientists that earlier 

estimates had probably been unduly conservative. 

4.2.2 Natural Releases of Mercury into the Environment 

There is a variety of natural sources of mercury released into the environment, 

including forest fires, volcanoes, evaporation from soil or water and volcanoes, 

amongst others. As detailed by UNEP (2002), historical deposition of mercury from 

anthropogenic sources contributes significantly to global mercury cycling, making 

estimation of natural sources problematic. As indicated above, estimates of natural 
Mercury Products - Risks to Health and the Environment 

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emissions (as opposed to the emissions themselves) reported in the literature have 

declined in recent years. For example: 

• Jones and Slotten (1996) report global estimates from the 1980s for atmospheric 

emissions of 60 t/year from volcanic activity, 1-2,000 t/year from other 

continental sources (crustal degassing, forest fires and biological mobilisation), 

2,000 t/year from the world’s oceans and 200 t/year as fluvial input; 

• Lindquist et al. (1991) estimate total global natural emissions to be of the order of 

3,000 t/year; 

• more recent emissions estimates are provided by Mason et al. (1994) who reported 

global natural emissions of 1,050 t/year; and 

• Within the EU, the most recent estimate for natural emissions is of the order of 

200 t/year (EC, 2001b). 

Most ‘natural’ emissions are in elemental form - although those from volcanoes tend 

to be mercuric oxide. In broad terms the emissions from the oceans are roughly equal 

to the atmospheric deposition over the oceans (based on Lee et al., 2000)

4.2.3 Anthropogenic Releases of Mercury into the Environment 

There are a number of sources of anthropogenic mercury emissions into the 

environment. Until relatively recently, it was considered that the anthropogenic 

emissions were of a similar order to ‘natural’ emissions. However, it has recently 

been suggested that anthropogenic emissions account for 60-80% of the total mercury 

emissions (EC, 2001b and UNEP, 2002). Within Europe (both EU and non-EU 

countries), it has been estimated that the total anthropogenic emissions have reduced 

from 860 t/year in 1980 to about 340 t/year by 1995 due, largely, to a combination of 

improved emission control measures and changes in industrial processes (EC, 2001b). 

At a global level, recent estimates of anthropogenic releases are of the order of several 

thousand tonnes (UNEP, 2002). 

Apart from those associated with the production and use of mercury-containing 

products which are the focus of this study (as discussed in Section 3), other 

anthropogenic sources of mercury emissions include: 

• combustion of fossil fuels - mercury is a natural component of both coal and 

oil at concentrations typically of the order of 0.1 to 1 ppm and 0.01 to 1 ppm 

respectively. The EU consumes about 600 and 300 million t/year of oil and 

coal respectively (mainly in power stations36). Taking (geometric) mean 

mercury concentrations of 0.3 ppm for coal and 0.1 ppm for oil would lead to 

potential emissions of the order of 150 t/year. 

 

 36 It must be emphasised that the mercury emissions from oil-fired power stations are much lower than 

those from coal-fired power stations. This is because the fuel oil used in power stations has a very low 

mercury content. In other words, the mercury emissions will be associated with the processing of the 

crude oil in the refineries and combustion of other products rather than with the combustion of the fuel 

oil. The behaviour of mercury in oil processing is complex as described in NRM (2001). 
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• chlor-alkali plants - only four countries out of those of interest (Denmark, 

Luxembourg, Ireland and Slovenia) do not have chlor-alkali plants using 

mercury cells - with Germany having by far the greatest number. The total 

quantity of mercury involved is of the order of 10-15,000t (Vonkeman, 2000 

and ERM, 2000). Within the EU, the 1999 mercury consumption in chloralkali plants was of the order of 150 t/year (based on OSPAR, 2001 and 

Vonkeman, 2000). The associated emissions (mainly to atmosphere) have 

been steadily reducing over the past 20 years to less than 10 t/year in 2000 

(Eurochlor, 2001). However, significant quantities of mercury, perhaps 40 

t/year, are unaccounted for37 (OSPAR, 2001); 

• other industrial processes - with particular reference to pig iron and steel 

production and cement production which together generated estimated (EC, 

2001b) emission of around 35 t in 1995 across Europe (i.e. both EU and nonEU countries); and 

• (old) submarine ballast tanks - mercury used to be used in submarine ballast 

tanks and was a major source of near-shore marine contamination. There are a 

number of lost submarines which are rumoured to still contain significant 

amounts of mercury. 

Mercury also enters the environment through the disposal of solid and liquid wastes, 

some of which will be associated with the production and use of mercury-containing 

products (as indicated in Section 3). 

4.3 Fate and Behaviour in the Environment 

4.3.1 Speciation and Transformation of Mercury in the Environment 

Overview 

Mercury is a liquid under standard conditions but it occurs in a variety of different 

forms in the environment, with transformation processes between forms depending 

upon the conditions in the environmental medium in question. These forms include 

elemental mercury, mercuric (Hg2+) compounds and organomercurials (particularly 

methyl and dimethyl mercury). The main source of organic mercury compounds is a 

microbial conversion of inorganic mercury entering surface water. In the air, 

dimethyl mercury, which is volatile, readily dissociates (by photolysis) to form 

methyl mercury. Methyl mercury is stable and bio-accumulates - particularly in 

aquatic organisms - and is the most toxic form of mercury. 

Mercury in the Atmosphere 

In the atmosphere, the main form present - and the majority of that emitted - is 

elemental mercury. Elemental mercury has a half-life in the atmosphere of several 

 

 37 Similar situations are found elsewhere. For example, detailed figures for 1996 determined a mercury 

consumption in US chlor-alkali plants of 150 tonnes, emissions of 8 tonnes and 101 tonnes 

unaccounted for (Sznopek & Goonan, 2000). 
Mercury Products - Risks to Health and the Environment 

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months to a year. Due to its relatively long lifetime in the atmosphere, elemental 

mercury in the vapour phase can be transported over large distances. 

Whilst monovalent mercury is not found in the atmosphere, bivalent mercury may be 

present in organic form (methyl or dimethyl mercury) or inorganic form (for example, 

mercuric chloride). Bivalent forms may be attached to particulate matter (especially 

in the sub-micron range) and may result from (slow) oxidation of elemental gaseous 

mercury. The bivalent forms have a much shorter half-life in the atmosphere (days) 

as they undergo both dry and wet deposition (Lee et al., 2001). 

Methyl mercury may constitute a few percent of the atmospheric mercury - but its 

source and associated chemistry have yet to be fully demonstrated38. 

Mercury in the Aquatic and Terrestrial Environments

Elemental mercury is oxidised in water to Hg2+ in the presence of oxygen, a process 

enhanced by the presence of organic substances in the aquatic environment. Bivalent 

mercury can react in a number of ways in the aquatic environment, such as: 

• formation of HgS in anaerobic conditions in the presence of hydrogen sulphide; 

• reaction to form elemental mercury, which is then readily lost to the atmosphere, 

thought to be a key process in natural loss to air through degassing39; and 

• reaction to form methyl mercury via biochemical processes (WHO, 1976). 

Methyl mercury is key species of interest for the current study, due to its greater 

potential for entry into food chains and subsequent bioconcentration, as compared to 

elemental or inorganic mercury. It is also the most toxic form of mercury. Methyl 

mercury is formed naturally in the environment, mainly in the freshwater and marine 

sediments, although it may also be formed in the water column (WHO, 1990). A 

wide range of microorganisms is capable of methylating mercury, including some soil 

organisms in addition to those in the aquatic environment. 

In the terrestrial environment, the majority of mercury present is in inorganic form 

with relatively less organic mercury than in the aquatic environment. 

4.3.2 Uptake of Mercury by Organisms 

In the aquatic environment, mercury is taken up readily by invertebrates and by fish, 

with accumulation in the former being greater than in the latter. Organic mercury and 

salts of bivalent mercury can be readily taken up by organisms in the aquatic and 

terrestrial environment. Generally, organic mercury is taken up more readily than 

inorganic mercury and is also released more slowly. 

 

 38 One suggested source is landfills, see Lindberg SE et al. (2001): Methylated Mercury Species in 

Municipal Landfill Gas Sampled in Florida, USA, Atmospheric Environment, 35(Aug):4001. 

 39 Elemental mercury may also be formed from organomercurial compounds, through chemical or 

enzymatic cleavage of the carbon-mercury bond. 
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Values for bioconcentration factors40 reported in the recent literature range up to 

several thousand and several tens of thousands for inorganic and organic mercury 

respectively. It should be noted, however, that the measured bioconcentration ratios 

are not a result of environmental partitioning (as is the case with many organic 

chemicals), but rather as a result of biomagnification in the food 

chain. Bioconcentration factors for use in the current assessment are considered in 

more detail in Section 5. 

Accumulation of mercury in plants is generally far less pronounced than for aquatic 

organisms, with concentrations in plants generally being significantly lower than 

those in the soil. Bioconcentration factors may be greater for methyl mercury, as 

indicated by Gnamuš et al. (2000) who report of value of 1.8 in Idrija, near to the 

former mercury mining complex. Bioconcentration factors may also be higher for 

certain plant species, such as mushrooms, and Falandysz et al. (2002) report BCF 

values for caps or whole fruiting bodies of mushrooms between 130±78 to 

160±120. The value for Claviata excipulformis, an inedible mushroom, was 910±330 

(Gucia et al., 2002). 

It is generally thought that uptake to and concentrations in plants are dictated 

primarily by soil, rather than air, concentrations. Uptake is limited by the binding 

characteristics of soil , the solubility of specific compounds and by the physiology of 

plant roots. 

 

 40 Ratio of the concentration of mercury in the organism to the concentration in the environment or food. 
Mercury Products - Risks to Health and the Environment 

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4.4 Measured Levels in the Environment 

4.4.1 Overview 

Table 4.1 details the concentrations of mercury in each of the major environmental 

compartments. 

Table 4.1: Mercury Levels in the Environment

Levels (measured as mercury) 

Compartment Typical Global1 rural 

Netherlands2 Elsewhere 

Air 1 - 4 ng/m3 (rural) 

20 - 50 ng/m3 (urban) 1.5 - 2.0 ng/m3

 (UK3) 

Soil 0.03 - 0.15 mg/kg dw 0.3 mg/kg dw 

rural: 0.03-0.06 mg/kg 

urban: 0.09-0.16 mg/kg 

(means, Germany4

) 

0.033-0.058 mg/kg 

(Polish regions5

) 

Ground Water 

(>10m depth) 0.5 - 15 ng/l 50 ng/l 98% sites < 100 ng/l4

Surface Water 

0.01 - 6 ng/l (dissolved - rivers) 

2 - 12 ng/l (dissolved - lakes) 

0.04 - 0.8 ng/l (methyl mercury -

lakes) 

10 ng/l 

(dissolved) 

60 ng/l (total) 

Sediment 0.2 - 0.4 mg/kg dw 0.3 mg/kg dw 

mean: c0.3 mg/kg4 

main river/lake means: 

<0.05 - 0.28 mg/kg5

Sea Water 0.05 - 3 ng/l 0.2 - 4 ng/l (North Sea6) 

Marine 

Sediment 0.2 - 0.4 mg/kg dw 

Sources: 

1) OECD (1995): Risk Reduction Monograph No. 4 - Mercury 

2) VROM (2001): Environmental Quality Standards in the Netherlands 

3) Lee et al. (2000): Sources, Sinks and Levels of Atmospheric Mercury in the UK 

4) German submission to UNEP (2001) 

5) Central Statistics Office (2000) supported by a detailed review of Polish scientific literature 

from the 1990s 

6) OSPAR (2000)

4.4.2 Atmospheric Levels 

Background mercury levels across Europe are generally in the range 1.3 - 2.1 ng/m3

. 

As would be expected the levels tend to be higher (by an order of magnitude or more) 

in industrial areas and in areas close to emission sources such as smelters and chlorakali plants (EC, 2001b and Lee et al., 2000). Generally, elemental mercury accounts 

for more than 90% of the total mercury present whilst organic mercury accounts for 

less than 2% (EC, 2001b). 

Currently, there are inadequate data to robustly demonstrate how atmospheric levels 

of mercury are changing over time. However, given the recent suggestions that 

anthropogenic sources dominate the global emissions of mercury and that these are 

now reducing (see S4.2.2), it would be expected that this would be reflected in 
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environmental measurements. Evidence of an increased mercury flux to the 

atmosphere over the past 100 years or so has been found in the Arctic by the Arctic 

Monitoring and Assessment Programme (AMAP). These findings were one of the 

main drivers for the establishment of UNEP’s Global Mercury Assessment (AMAP, 

2001). 

Until relatively recently, there have been few instruments capable of measuring the 

range of mercury forms present in the atmosphere. As a result, there would appear to 

be no comprehensive long term monitoring records. 

Within the UK, particulate phase mercury (i.e. bivalent forms bound to fine 

particulate matter) which accounts for less than 10% of the total atmospheric mercury 

has been monitored at a number of sites since the early 1970s. It should be noted that 

particulate phase mercury tends to be associated with coal combustion (both in power 

stations and in the home - EC, 2001b). The monitoring results (Lee et al., 2000) 

indicate fluctuating levels over the period from the early 1970s to around 1990 but 

neither an upward nor downward trend - although there is a noticeable peak in 

1983/84. 

Although the data are far from conclusive, there is other evidence to suggest that the 

reduction in EU mercury emissions is now being reflected in atmospheric mercury 

levels. Monitoring data for mercury levels (annual averages) in precipitation from 

two sites in the Netherlands (NL Sites 1 & 2) and four sites in Sweden (Sweden S1 - 

S4) (from RIVM, 1999 and EC, 2001b respectively) are shown in Figure 4.1. 

0 

5 

10 

15 

20 

25 

30 

Hg in Precipitation (ng/l)

1995 1996 1997 1998 1999

Year

NL Site 1

NL Site 2

Sweden S1

Sweden S2

Sweden S3

Sweden S4

Figure 4.1: Hg Levels in Precipitation

in the Netherlands and Sweden
Mercury Products - Risks to Health and the Environment 

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4.4.3 Levels in the Aquatic Environment 

As for levels in the atmosphere, there are few data sets which can be used to show 

changes of mercury levels over time. However, data from the Netherlands (RIVM, 

2001) indicate a reduction in fresh water concentrations in recent years as shown in 

Figure 4.2. 

In relation to the presence of methyl mercury in the aquatic environment, extensive 

monitoring in the 80km of river from the Idrija mine to the Gulf of Trieste (Horvat et 

al., 2000) shows methyl mercury levels in the range 0.02 - 0.6 ng/l which correspond 

to about 0.5% of the total mercury concentrations (ranging from 3 to >300 ng/l at the 

mine). Similarly, in the Everglades in Florida, methyl mercury has been found to 

contribute from <0.2% to 2% of the total mercury content in sediments (Gilmour et 

al., 1998). However, in lakes, the relative concentrations may well be higher - as the 

USEPA (2001) reports that methyl mercury accounts for 10% of the mercury present. 

Levels in Fish 

As already noted, most mercury present in the aquatic environment is of the inorganic 

bivalent form. However, the bioconcentration of methyl mercury tends to lead to 

relatively higher concentrations in fish (and other aquatic organisms) - particularly 

amongst fish at the top of the food chain (such as sharks). Levels of mercury in fish 

may be of the order of 0.1 mg/kg wet weight and this is usually associated with 

methyl mercury. 

4.4.4 Levels in the Terrestrial Environment

Most terrestrial mercury is in the form of inorganic salts with minimal organic 

mercury present. Typical concentrations in soil are of the order of 0.1 mg Hg/kg dry 

weight (dw). As would be expected there are reports of much higher concentrations 

0.01 

0.10 

1.00 

Concentration (microg/l)

1984 1988 1992 1996 2000 

Year

Rhine

Meuse

Scheldt

Ijsselmeer

Figure 4.2: Hg Levels in Freshwater

in the Netherlands (90%ile Values)
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on contaminated industrial sites and mean values of 2.5 mg/kg and 0.065 mg/kg have 

been reported for total mercury and methyl mercury respectively in the Idrija area of 

Slovenia, near to the mine-smelter area (Gnamuš et al, 2000). Similarly, the German 

submission to UNEP reports high localised concentrations at sites which used to 

impregnate telegraph poles, railway sleepers, etc. with mercuric chloride. 

Levels in Plants & Food 

Typical mercury levels in plants are less than <0.1 mg Hg/kg fresh weight as 

illustrated by crop samples listed in Table 4.2. Higher concentrations are again 

reported in contaminated areas, such as in Almaden (Spain) near to the mercury mine, 

where concentrations in vegetation of over 100 mg/kg were reported in the 1980s 

(WHO, 1989). 

Table 4.2: Mercury Levels in Crops (mg/kg fresh weight) 

Crop UK1 Poland2

Fresh Fruit 0.0006 (mean) 0.0001 - 0.0134 (max) 

Green Vegetables 0.0004 (mean) 0.0001 - 0.0039 (max) 

Potatoes 0.0010 (mean) 0.0001 - 0.0030 (max) 

Other Vegetables (eg Carrots) 0.0006 (mean) 0.0001 - 0.0058 (max) 

Cereals 0.0040 (mean) 0.0001 - 0.0070 (max) 

Sources: 1) MAFF (1999) and 2) CSO (2000) 

Note that 1 mg/kg is equivalent to 1 part per million 

4.5 Human Exposure 

4.5.1 Overview 

For typical citizens of the EU and the three accession countries, uptake of mercury is 

dominated by inhalation of vapours from dental amalgam and by ingestion of 

foodstuffs (particularly fish). As would be expected, exposure is greater where past 

industrial activities have led to significant mercury emissions to the environment. 

4.5.2 Non-Occupational Exposure 

Typical mercury intakes within the EU (and three accession countries) are of the order 

of 10 μg/day as shown in Table 4.3. 

As can be seen from Table 4.3, a significant contribution to the human uptake of 

mercury is associated with dietary intake of fish (and fish products). In view of this, 

the EU has established a maximum mercury content of 0.5 mg/kg (wet weight) for 

‘fishery products’ with a higher limit of 1 mg/kg for a range of specified fish 

species41. 

 

 41 As specified in Commission Regulation (EC) No. 466/2001 Setting Maximum Levels for Certain 

Contaminants in Foodstuffs dated 8 March 2001 (as amended by Commission Regulation (EC) No. 

221/2002 dated 6 February 2002). 
Mercury Products - Risks to Health and the Environment 

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Table 4.3: Daily Uptake of Mercury by Humans 

Pathway Global1 UK Data2 Europe3

Direct Inhalation negligible negligible < 0.2 μg/day 

Inhalation of Dental 

Amalgam Vapours 3 - 17 μg/day 1 - 10 μg/day 3 - 17 μg/day 

Dermal Absorption negligible negligible negligible 

Ingestion of Foodstuffs 

(excluding fish products) - 

mainly as inorganic salts 

0.25 μg/day 1-2 μg/day 0.36 μg/day 

Ingestion of Fish Products - 

mainly as methyl mercury could be >100 μg/day >5 μg/day for some 2.3 μg/day 

Sources: 1) OECD (1995): Risk Reduction Monograph No. 4 - Mercury; 2) Based on Lee et al. 

(2000); and 3) WHO (2000): Air Quality Guidelines - Mercury. 

Mercury levels in blood and urine provide are often used as (short term) ‘biomarkers’ 

for mercury intake while hair provides a proven (long term) guide to methyl mercury 

intake. Detailed data on mercury levels in blood in the Czech Republic have been 

provided42. The median for 1,207 adults was found to be 0.78 μg/l with a range of 

0.01 - 7.13 μg/l. The median for 764 children was slightly lower at 0.46 μg/l but with 

a very similar range. Similar values are reported for Germany (German submission to 

UNEP, 2001) with median values of 0.6 and 0.4 μg/l and 95% values of 2.1 and 1.4 

μg/l amongst 3,958 adults and 712 children respectively. The corresponding median 

value of mercury in urine was 0.5 μg/l (with a 95% value of 3.9 μg/l) for both children 

and adults. ATSDR (1999) reports similar levels amongst the general US population 

and that elevated mercury levels in blood of 109 μg/l have been found amongst 

women using skin-lightening creams (as discussed in S3.7.8). Similar elevated levels 

have been found in amongst those eating contaminated fish and amongst workers (see 

below). 

4.5.3 Occupational Exposure 

As would be expected, occupational exposures are somewhat greater than ‘typical’ 

general population exposures due to greater environmental concentrations. By way of 

example, atmospheric mercury levels of 300 ng/m3 are still measured around the 

abandoned Idrija mine (compared to 1-2 ng/m3 typical background levels). 

Data from mercury miners and workers in a range of industries (including chlor-alkali 

works, lamp manufacture, thermometer manufacture, metal processing, etc.) provide 

useful indicators to the human toxicity of mercury. In broad terms, chronic exposure 

to mercury levels in the workplace above 0.1 mg/m3

 were found to lead to classic 

symptoms of mercury poisoning (tremors, mental disturbance, etc.) in a range of 

studies from the 1930s through to 1970 (WHO, 1976). Such studies have led to 

increased controls on occupational exposure. 

However, the key data on the effects of exposure to mercury and its compounds were 

derived from studies on the consumption of foodstuffs with elevated levels of mercury 

and, more importantly, methyl mercury as discussed in Section 6.3. 

 

 42 The data are also published: Central European Journal of Public Health, Vol 8 #2, pp 117-119 (2000). 
Risk & Policy Analysts

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5. CALCULATIONS OF PREDICTED ENVIRONMENTAL 

CONCENTRATIONS (PECS)

5.1 Introduction 

The EUSES software model generates predicted environmental concentrations (PECs) 

based on estimated releases on all spatial scales which are derived from the use 

patterns and substance properties. 

In order to undertake the analysis, EUSES considers emissions associated with 

production, formulation, processing, private use and recovery. Some of these aspects 

have been considered in Section 3 and these provide a robust basis for estimation of 

release factors. Therefore, default values indicated by the Technical Guidance 

Document (European Commission, 1996) have been substituted, where appropriate, 

with calculated emission factors. The emission factors used in the EUSES analysis 

are summarised in the subsections below. 

Modelling the behaviour of mercury emissions is not straightforward as the initial 

release is usually in the form of elemental mercury which becomes inorganic mercury 

in the environment. A portion may then be methylated to form methyl mercury - 

particularly in the aquatic compartment. As indicated in Section 4, methyl mercury 

may make up to 10% of the mercury present (particularly in lakes) - which will be 

taken as a worst case scenario in the analysis which follows. 

This section concludes with a description on the use of EUSES and a summary of the 

PEC results together with an associated commentary. 

 

5.2 Production 

The ‘production’ step has been taken as the collection and refining of mercury from a 

gas (or vapour) stream after heating ore (mercury or other non-ferrous metal) or 

recovered mercury-containing items. All mercury production sites (whether primary 

or secondary) are covered by the requirements of IPPC. Recent guidance (European 

Commission, 2001a) suggests 1997 emission factors of: 

• primary production: 0.01 to air; 7.8 x 10-6 to water; and 0 to waste; and 

• secondary production: 2 x 10-6 to air; 3 x 10-7 to water; and minimal solid waste. 

Clearly, the impact of the primary production emission factor to air could have a 

significant impact on the analysis. A much lower figure may be appropriate given the 

IPPC requirements. It is worth noting that MAYASA claim43 an overall emission 

factor of less than 0.00l. 

 

 43 Lopez FA et al. (2000): Considerations on the Implementation of IPPC and the Primary Mining 

of Mercury, CSIC (National Centre of Mining, Spain) Report 2399 prepared on behalf of MAYASA 

and submitted to European IPPC Bureau. 
Mercury Products - Risks to Health and the Environment 

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A further indication of lower emission factors is provided by the Finnish zinc 

processing plant. The Kokkola plant produces about 225,000 t/year of zinc and about 

65 t/year of mercury. The zinc ore is roasted which drives off the mercury which is 

then cleaned from the gas stream using sulphuric acid. The precipitate is mixed with 

lime and heated to 700o

C to distil off the metallic mercury vapour. The associated 

emissions to the environment are estimated to be less than 10 kg/year to air and 3 

kg/year to water (sea) (Finnish Environment Institute, 1999). These figures 

correspond to emission factors of <1.5 x 10-4 to air and 4.6 x 10-5 to sea. 

In relation to secondary production (which includes the refining of mercury from 

chlor-alkali plants), consultation suggests that the above figures of a few grammes per 

tonne44 of mercury can be achieved and are consistent with the BAT requirements 

(essentially enclosed handling and scrubbing of ventilation gases). 

The EUSES model requires the use of emission factors for emissions to the air, 

wastewater, surface water and industrial soil. The above figures account for on-site 

wastewater treatment and there is no discharge to industrial soil. Solid waste residues 

(including waste water sludges/residues) are generally returned to the furnace. 

Residues requiring off-site disposal will be sent directly to engineered landfills. 

Table 5.1 summarises the emission factors used for the production of mercury. 

Table 5.1: Release Fractions for Mercury Production used in EUSES Modelling 

Production 

Route 

Fraction of 

tonnage released to Value Source & Comment 

Air 0.001 Report for MAYASA 

Wastewater 0 Emissions processed on site 

Surface Water 4.6 x 10-5

Although EC (2001a) data suggest lower 

figure, source uncertain. Higher value 

derived for ‘by-product’ production used 

Primary Mined 

Production 

Industrial soil 0 No discharge to land 

Air 1.5 x 10-4 Finnish Environment Institute (1999) 

Wastewater 0 Emissions processed on site 

Surface Water 4.6 x 10-5 Finnish Environment Institute (1999) 

By-product of 

other NonFerrous Primary 

Production Industrial soil 0 No discharge to land. 

Air 2 x 10-6 EC (2001a), supported by consultation 

Wastewater 0 Emissions processed on site 

Surface Water 3 x 10-7 EC (2001a), supported by consultation Secondary 

Production 

Industrial soil 0 No discharge to land (minimal solid 

waste to landfill) 

For the purposes of the analysis which follows it has been assumed that these 

emission factors should be applied to the total current EU consumption of mercury in 

the products under study - i.e. 119.2 tonnes. Whilst it is recognised that some 

products are imported (e.g. thermometers), it is possible that the mercury used will 

have originated in the EU. 

 

 44 Note that an emission factor of 1 x 10-6 corresponds to an emission of 1 g per tonne produced. 
Risk & Policy Analysts

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It is further assumed, in the absence of detailed evidence of the sources of mercury 

used in the products under study, that the production quantity will be divided equally 

amongst primary production, by-product production and secondary production - i.e. 

39.7 t per production route. 

5.3 Formulation and Processing (Product Manufacture) 

5.3.1 Dental Amalgam 

It has been assumed that, generally, no ‘formulation’ stage is involved in the 

manufacture of the various products under study. Instead, product manufacturing 

operations are considered to take place at the ‘processing’ stage where mercury is 

used and processed along with other substances in order to produce the end products 

which are then forwarded to the consumers. The exception is that mercury used in 

dental amalgam must be of the highest quality and may be re-refined (through triple 

distillation) prior to ‘processing’. It would be expected that the emission factors 

would essentially be the same as for ‘secondary production’ (see Table 5.1). Limited 

data from consultation suggest only minor atmospheric emissions and for the 

purposes of this analysis, the same factors will be used as those shown in Table 5.1. 

For this analysis it has been assumed (conservatively) that the current EU 

consumption of mercury used in dental amalgam (70 t/year) is formulated within the 

EU and that, as discussed in S3.2.4, the ‘formulator’ provides pre-packed mercury for 

the use by the ‘processor’. As such it has been assumed that there are no emissions 

associated with ‘processing’ (i.e. packaging the mercury with the other amalgam 

materials). The associated emission factors are shown in Table 5.2. 

Table 5.2: Release Fractions for Dental Amalgam used in EUSES Modelling 

Process Step Fraction of 

tonnage released to Value Source & Comment 

Air 2 x 10-6 EC (2001a), supported by consultation 

Wastewater 0 Emissions processed on site 

Surface Water 3 x 10-7 Formulation EC (2001a), supported by consultation 

Industrial soil 0 No discharge to land (minimal solid 

waste to landfill) 

Processing All media 0 Zero emissions assumed 

5.3.2 Other Products 

For batteries and other products, the default EUSES emission factors have been 

overridden and replaced with emission factors adapted from the estimates presented in 

the WS Atkins report (1998) on product manufacture emissions. It should be noted 

that attempts to obtain more site-specific data to refine these figures have not been 

successful. It has been assumed that all solid waste arisings from product 

manufacturing facilities (i.e. for batteries, lamps, etc.) are disposed of to landfill (as 

opposed to a portion going to incinerators as would occur with municipal waste). 

Given that the mercury used in product manufacture will tend to be in elemental form, 
Mercury Products - Risks to Health and the Environment 

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it has been assumed that 9.5% of the mercury disposed to landfill will be released to 

atmosphere (using the same approach as used in Section 3.5.4). By way of example, a 

solid waste stream of 140 g waste per kg of mercury used would lead to atmospheric 

emissions of 13.3 g/kg which is equivalent to emission factor of 0.0133. 

No emission estimates are given in the WS Atkins report with regard to batteries 

manufacture. It has been assumed that the emissions from manufacture will be 

similar to those for the electronics industry as in both cases, production essentially 

entails the incorporation of a small amount of mercury into the product. The emission 

factors used in ‘processing’ are summarised in Table 5.3. 

Table 5.3: Release Fractions for ‘Processing’ used in EUSES Modelling 

Product 

Manufacture 

Fraction of 

tonnage released to Value Source & Comment 

Air (plant) 3.0 x 10-7

Air (landfill) 4 .75 x 10-4

Based on WS Atkins (1998) with 

additional landfill emissions 

Wastewater 3 x 10-5 Based on WS Atkins (1998) 

Surface Water 0 

Batteries and 

Electrical 

Control & 

Switching 

Equipment 

Industrial soil 0 

Discharges to water and soil associated 

with sewage treatment plant discharges 

(calculated by EUSES) 

Air (plant) 0.022 

Air (landfill) 1.33 x 10-2

Based on WS Atkins (1998) with 

additional landfill emissions 

Wastewater 3 x 10-5 Based on WS Atkins (1998) 

Surface Water 0 

Lamp Production 

Industrial soil 0 

Discharges to water and soil associated 

with sewage treatment plant discharges 

(calculated by EUSES) 

Air (plant) 3.0 x 10-7

Air (landfill) 1.33 x 10-2

Based on WS Atkins (1998) with 

additional landfill emissions 

Wastewater 3 x 10-5 Based on WS Atkins (1998) 

Surface Water 0 

Measuring & 

Control 

Equipment 

Industrial soil 0 

Discharges to water and soil associated 

with sewage treatment plant discharges 

(calculated by EUSES) 

These emission factors are applied to the quantities of mercury used in the 

manufacture of products within the EU. For most of the products listed in Table 5.3, 

there are significant imports and, in some cases, exports as illustrated in Table 5.4. 

Based on the discussions presented in Section 3 for each of the product groups, 

estimates have been made as to the likely quantities of mercury used in product 

manufacture within the EU (as opposed to the quantities consumed (i.e. sold) in the 

products within the EU). Clearly, such estimates carry a degree of uncertainty. 
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Table 5.4: Quantities of Mercury used in EU Product Manufacture 

Tonnes of Hg/year used in EU for 

Product 

Consumption Production 

Comment 

Batteries 8.0 3.0 

As discussed in Section 3.3, 

although batteries are imported and 

exported in similar quantities, most 

of the mercury consumed is likely to 

be associated with imported zinc 

mercury cells 

Lamp Production 5.2 5.2 

Lamps are both imported and 

exported. As shown in Table 3.16 

and Figure 3.4, most mercury is 

associated with double-ended 

fluorescent tubes which appear to be 

imported and exported in similar 

quantities. 

Measuring & 

Control 

Equipment 

28 8.0 

As discussed in Section 3.5, it 

would appear that most measuring 

equipment is now imported 

Electrical 

Control & 

Switching 

Equipment 

8.0 4.0 

As discussed in Section 3.6.3, a 

significant portion of mercury 

switches are now imported 

5.4 Private Use and Recovery of Mercury in Products 

The emission factors which were calculated in Section 3 for each of the products 

under study were carried forward to the EUSES analysis. Since EUSES requires 

inputs to atmosphere, wastewater, surface water and industrial soil, a degree of 

backtracking was required for ‘dental amalgam’ and ‘measuring and control 

equipment’ in order to generate values for release fractions to waste water45. 

The calculations in Section 3 have also taken into account any recovery and recycling 

issues within each of the application categories. Where recovery takes place (with 

subsequent re-use of mercury), this has been incorporated in the respective flowchart 

and the emission calculations have been adjusted. Therefore, the ‘recovery’ life cycle 

step has not been included in the EUSES modelling as the effects are taken into 

account in the ‘private use’ step. 

Table 5.5 summarises the emission factors for releases during ‘private use’ of 

mercury-containing equipment. In each case, the values have been based on 

emissions per tonne (of current consumption) used in the EU. It should be noted that 

these figures account for emissions associated with the disposal of ‘old’ products and 

equipment. As discussed in Section 3, this ‘disposal’ stream may be significantly 

greater (in terms of mass flow rate) than the current consumption since the usage of 

mercury is declining in some sectors. 

 

 45 In essence and with reference to Figures 3.1 and 3.6, emissions ‘downstream’ of sewer were not used 

and the input to sewer was used as the input to wastewater for EUSES. 
Mercury Products - Risks to Health and the Environment 

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Table 5.5: Release Fractions for ‘Private Use’ used in EUSES Modelling 

Product 

Manufacture 

Fraction of Tonnage 

Released to Value Source & Comment 

Air 0.0702 

Wastewater 0.0762 

Surface Water 0 Dental Amalgam 

Industrial soil 0 

Based on Section 3.2 calculations 

(adjusted to account for discharges to 

wastewater) 

Air 0.0612 

Wastewater 0 

Surface Water 0 

Batteries 

Industrial soil 0 

Based on Section 3.3 calculations 

Air 0.1388 

Wastewater 0 

Surface Water 0 Lamps 

Industrial soil 0 

Based on Section 3.4 calculations 

Air 0.2436 

Wastewater 0.0182 

Surface Water 0 

Measuring & 

Control 

Equipment 

Industrial soil 0 

Based on Section 3.5 calculations 

(adjusted to account for discharges to 

wastewater) 

Air 0.2554 

Wastewater 0 

Surface Water 0 

Electrical 

Control & 

Switching 

Equipment Industrial soil 0 

Based on Section 3.4 calculations 

5.5 Predicted Environmental Concentrations 

5.5.1 Introduction 

The EUSES model was used to generate PECs which when combined with toxicity 

data (as discussed in Section 6) enabled the risks to the environment and to humans to 

be characterised. This exercise was undertaken for the main product groups used in 

the EU. At the outset, it must be emphasised that the behaviour of mercury and its 

compounds does not lend itself to analysis using the EUSES model and the results 

generated must be treated with a degree of caution. 

5.5.2 Approach to EUSES 

Emissions from the different types of mercury production sites (primary production in 

Spain, production from non-ferrous metal primary production and secondary 

production) were considered separately. It was assumed that each of the three 

mercury production routes produced 39.7 t/year of mercury (to give a combined 

figure of 119.2 t/year which is the EU consumption of the products under study). 

Product manufacture was modelled for each of the five main product groups data 

under study to give a further five scenarios. In order to account for the degree of 

imports associated with batteries, measuring equipment and electrical equipment, the 

runs were based on the quantities of mercury used in EU product manufacture 
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(assumed to be 3, 8 and 4 t/year respectively). For all the product manufacture 

activities (bar dental amalgam), it was necessary to account for both local plant losses 

and atmospheric losses associated with the disposal of solid waste. 

Finally, the ‘private use’ of each product group was also modelled (using the total 

consumption figures). The listing of the modelled ‘use patterns’ is shown in Table 

5.6. 

Table 5.6: Use Patterns Modelled with EUSES

Use Pattern Modelling Stage Mercury Emissions Modelled 

Production From primary production 

1. Production Formulation From non-ferrous by-products 

Processing From secondary production 

2. Dental Formulation From re-refining mercury to be used in dental amalgam 

Amalgam Private Use From use and disposal of dental amalgam (as described in S3.2) 

Formulation From plants producing batteries within EU 3. Batteries 

Processing From disposal of plant waste (see Table 5.3) 

4. Batteries Private Use From use and disposal of batteries (as described in S3.3) 

Formulation From plants producing lamps within EU 

5. Lighting Processing From disposal of plant waste (see Table 5.3) 

Private Use From use and disposal of lamps (as described in S3.4) 

6. Measuring Formulation From plants producing measuring equipment within EU 

Equipment Processing From disposal of plant waste (see Table 5.3) 

7. Measuring 

Equipment Private Use From use and disposal of measuring equipment (as described in 

S3.5) 

8. Electrical Formulation From plants producing electrical equipment within EU 

Equipment Processing From disposal of plant waste (see Table 5.3) 

9. Electrical 

Equipment Private Use From use and disposal of electrical equipment (as described in 

S3.6) 

Note: Since EUSES can model a maximum of ten ‘use patterns’, it was necessary to combine some 

‘uses’ into a single ‘use pattern’ by adapting some of the modelling steps.

The EUSES model was run twice:

• Run 1: 100% of emissions considered to be as elemental mercury; and 

• Run 2: 100% of emissions considered to be as inorganic mercury (mercuric 

chloride). 

Although attempts were made to extend EUSES to organic mercury, the analysis was 

considered to be rather tenuous (since organic mercury is not released but forms in the 

environment). Instead, consideration is given to using the PECs for inorganic 

mercury as a basis on which to estimate the potential PECs for organic mercury. 
Mercury Products - Risks to Health and the Environment 

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5.5.3 Properties Used 

As noted in the TGD (EC, 1996), care must be taken when applying EUSES to metals 

and their compounds. EUSES requires basic data on the properties of the mercury 

compounds (as presented in Section 2) and these were entered. However, the ‘flow’ 

of mercury through the environment is complex and a number of further data points 

and assumptions were required as outlined below. 

Partition Coefficients 

EUSES estimates partition coefficients from log Kow (the octanol-water partition 

coefficient). However, such methods are not directly applicable to metals (and their 

compounds) and, as a result, specific values for each of the partition coefficients must 

be provided. These specific values are based on theory and/or observations. A listing 

of those values used in EUSES for elemental and inorganic mercury is presented in 

Table 5.7. 

Table 5.7: Partition Coefficients used in EUSES Modelling 

Compound Partition 

Coefficient Value Source & Comment 

Henry’s Law 

constant (airwater) 

680 

Pa.m3

/mole 

A range of values was found including around 500 

(USEPA, 1997); 700 (Sunderland & Gobas, 2001); 

720 (INERIS, 2000); and 860 (PhysProp database1

). A geometric mean value was selected 

Solids-water 

in suspended 

sediment and 

sediment 

126,000 l/kg 

(log K = 5.1) 

The same values were used as derived for 

inorganic mercury 

Elemental 

Mercury 

Solids-water 

in soil 1,000 l/kg Value quoted in INERIS, 2000 

Henry’s Law 

constant (airwater) 

680 

Pa.m3/mole 

Wide ranging values were found from 0.32 

(PhysProp data-base) to 3.6 x 10-5 (INERIS, 2000). 

However, the value for elemental mercury was 

used since, in practice, >90% of atmospheric 

mercury is elemental and it takes time for the 

elemental mercury convert to its bivalent state 

(see, for example, Lee et al., 2000 and EC, 2001b). 

Thus, use of this value will more accurately 

predict the environmental fate following a release 

(most of which are to atmosphere) 

Solids-water 

in suspended 

sediment 

126,000 l/kg 

(log K = 5.1) 

Log K values found include 4.9 (Sunderland & 

Gobas, 2001) and 5.23 (Eurochlor, 1999 & 

INERIS, 2000). A geometric mean of 5.1 was 

used 

Solids-water 

in sediment 

126,000 l/kg 

(log K = 5.1) 

The same K values tend to be used for this and the 

SS-water partition coefficients. Hence, the same 

value was used 

Inorganic 

Mercury 

Solids-water 

in soil 

60,000 l/kg 

(log K = 4.8) 

Values quoted in INERIS (2000) range from 6,800 

- 60,000 and the highest value was used. 

Data-base sources: 

1) SRC PhysProp Database on http://escsyrres.com/interkow

2) Hazardous Substances Data Base on http://toxnet.nlm.nih.gov 
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Vapour Pressures 

The true vapour pressures for mercury and mercuric chloride were used since a 

(minimal) degree of evaporation would be expected. The values were 0.267 Pa and 

0.1 Pa respectively - although these were not used by EUSES to derive Henry’s Law 

constants. 

Aerosol Particles 

A feature of inorganic mercury is that a significant proportion is bound to particles in 

the atmosphere which are deposited more rapidly than elemental mercury. For the 

purposes of this analysis a value of 9% was selected which is consistent with 

observations reported by Lee et al. (2000) and EC (2001b). 

 

Bio-concentration 

To reflect the importance of bio-concentration in fish, a bio-concentration factor 

(BCF) of 5,000 for inorganic mercury was used. A BCF value of 50,000 was used for 

organic mercury in later stages of the analysis. These values are towards the higher 

end of the ranges suggested by ATSDR (1999) and INERIS (2000). 

5.5.4 PECs - Air Compartment 

For the air compartment, the values derived from using elemental mercury were used. 

The results are summarised in Table 5.8. 

Table 5.8: PEC Values for Air (ng/m3) for Mercury & Products

Parameter Value Comment 

Typical measured value in EU 1.3 - 2.1 See Section 4.4.2 

Continental PEC associated with 

manufacture and use of mercury in 

products under study 

0.10 This represents about 5-10% of typical EU 

levels 

Regional PEC associated with 

manufacture and use of mercury in 

products under study 

0.27 For the ‘worst’ region, this represents 10-

20% of typical EU levels 

Local PEC values associated with mercury production: 

Primary production (Spain) 30.5 Level significantly above ‘background’ 

Production from non-ferrous byproducts 1.18 

Secondary production 0.30 

Local PEC values associated with product manufacture: 

Dental amalgam 0.28 Level marginally above regional PEC value 

Batteries 0.28 Ditto - note that level is associated with 

landfill emissions rather than from plant 

Lamps 3.62 

Measuring equipment 1.28 

Electrical equipment 0.31 

Levels are associated with landfill 

emissions rather than from plant 
Mercury Products - Risks to Health and the Environment 

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Overall, the use of mercury in the products under study, the associated product 

manufacture as well as the associated production of mercury make, as would be 

expected, a minor contribution to mercury in air concentrations at continental and 

regional levels. 

In terms of ‘local’ concentrations, the PEC values are dominated by those associated 

with the primary production of mercury in Spain. Otherwise, the PEC values tend to 

be within the ‘typical’ range of values found in the EU although those for lamp 

manufacture are slightly higher, due primarily to the relatively high air emission 

factor used (see Table 5.3). As noted in Table 5.8, the PEC values for some of the 

product manufacture sites are associated with subsequent losses to atmosphere from 

solid waste disposal rather than from the product manufacturing site itself. 

5.5.5 PECs - Soil Compartment 

For the soil compartment, the values derived from using inorganic mercury were used. 

The results are summarised in Table 5.9. 

Table 5.9: PEC Values for Soil (μg/kg dw) for Mercury & Products

Parameter Value Comment 

Typical measured value in EU 50 - 100 See Section 4.4.4 & Table 4.1 

Continental PEC associated with 

manufacture and use of mercury in 

products under study 

1.63 This represents a few % of typical EU 

levels 

Regional PEC associated with 

manufacture and use of mercury in 

products under study 

4.34 For the ‘worst’ region, this represents 4 -

8% of typical EU levels 

Local PEC values1 associated with mercury production: 

Primary production (Spain) 6.18 

Production from non-ferrous byproducts 4.66 

Secondary production 4.61 

Values essentially close to ‘regional’ PEC 

value - although higher around the primary 

production site 

Local PEC values1 associated with product manufacture: 

Dental amalgam 4.61 

Batteries 4.61 

Lamps 4.78 

Measuring equipment 4.66 

Electrical equipment 4.61 

Values essentially close to ‘regional’ PEC 

value 

Note: 1) Local values based on agricultural PEC averaged over 180 days

As can be seen the scenarios considered make a minor contribution to mercury in soil 

concentrations at continental and regional levels. Furthermore, there is very little 

‘local’ effect on soil concentrations associated with emissions from mercury 

production and product manufacture facilities. 

This findings appear consistent with the emissions to ‘soil’ being much lower than 

those to atmosphere (see Table 3.29). 
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5.5.6 PECs - Aquatic Compartment 

Water 

For the water compartment, the values were first derived for inorganic mercury using 

EUSES. As a ‘worst case’ estimate, it was assumed that the organic mercury 

concentration would be 10% of the inorganic concentration (as this is an upper limit 

of that observed in the aquatic environment). The associated results are summarised 

in Table 5.10. 

Table 5.10: PEC Values for Water (ng/l - dissolved) for Mercury & Products

Value Parameter 

Inorganic Organic 

Comment 

Typical measured value in EU 1 - 10 <10% of 

inorganic See Table 4.1 & Section 4.4.3 

Continental PEC associated with 

manufacture and use of mercury in 

products under study 

0.03 0.003 This represents perhaps 1% of 

typical EU levels 

Regional PEC associated with 

manufacture and use of mercury in 

products under study 

0.64 0.064 

For the ‘worst’ region, this 

represents a significant fraction 

of typical EU levels 

Local PEC values associated with mercury production: 

Primary production (Spain) 

Production from non-ferrous byproducts 

Secondary production 

0.64 0.064 

Values the same as ‘regional’ 

PEC value (due to minimal 

discharges to water) 

Local PEC values associated with product manufacture: 

Dental amalgam 0.64 0.064 

Batteries 0.69 0.069 

Lamps 0.67 0.067 

Measuring equipment 0.67 0.067 

Electrical equipment 0.67 0.067 

Values very close to ‘regional’ 

PEC value (due to minimal 

discharges to water) 

Overall, a similar pattern emerges as for the air and soil compartments. Contributions 

to continental and regional concentrations are dominated by product use. The 

contributions of the various product groups are dominated by those associated with 

dental amalgam and measuring equipment due to their higher levels of emission (see 

Table 3.29). 

As for the soil compartment, there is very little ‘local’ effect on water concentrations 

associated with emissions from production and product manufacture facilities. 

Sediment 

For sediments (as for the water compartment), the values were first derived for 

inorganic mercury using EUSES. As a ‘worst case’ estimate, it was assumed that - as 

for water - the organic mercury concentration would be 10% of the inorganic 

concentration. The associated results are summarised in Table 5.11. 
Mercury Products - Risks to Health and the Environment 

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Table 5.11: PEC Values for Sediment (μg/kg dw) for Mercury & Products

Value Parameter 

Inorganic Organic 

Comment 

Typical measured value in EU 300 <10% of 

inorganic See Table 4.1 & Section 4.4.3 

Continental PEC associated with 

manufacture and use of mercury in 

products under study 

4.2 0.42 This represents about 1% of 

typical EU levels 

Regional PEC associated with 

manufacture and use of mercury in 

products under study 

81 8.1 

For the ‘worst’ region, this 

represents about 25% of typical 

EU levels 

As before, contributions to continental and regional concentrations are dominated by 

product use. As for water, the overall significance is of the order of 1% as indicated 

by the continental concentrations. The results indicate that the ‘worst’ region may 

experience sediment concentrations which are about 25% of ‘typical’ EU levels, 

which again is consistent with the results for water. 

Local PEC values for sediment are calculated by EUSES for an ‘emission episode’ 

and are not directly comparable to the longer term continental and regional values. 

The predicted effects of these emission episodes are explored further in Section 7. 

5.5.7 Summary 

The behaviour of mercury and its associated derivative compounds in the 

environment is complex. An attempt has been made to account for this behaviour by 

using EUSES for elemental mercury and inorganic mercury (mercuric chloride). As a 

worst case, the results for organic mercury (methyl mercury chloride) were assumed 

to be 10% of the inorganic mercury concentrations. 

Specific data on partition coefficients were derived - although some of the values are 

uncertain. However, some assumptions have been made to ‘force’ the model to 

reflect reality. In particular, the Henry’s Law constant for elemental mercury was 

applied to inorganic mercury since the balance of loads between the air and other 

compartments is mainly governed by the behaviour of the elemental mercury released 

(initially) to the atmosphere. 

As already indicated, the results of the modelling are dominated by the emissions 

associated with product use which total 22.6 t/year (from Table 3.29). For 

comparison, the corresponding emissions (for the EU-15 and three accession 

countries under study) from all anthropogenic sources are 161 t/year (from EC, 

2001b). Such figures suggest that, whilst there are clearly uncertainties in the results, 

it would be expected that the environmental concentrations associated with the 

products under study form a minor part of observed levels in the environment. 

 
Risk & Policy Analysts

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6. EFFECTS OF MERCURY 

6.1 Overview 

Mercury and its compounds are persistent, bioaccumulative and toxic and may pose 

risks to people and to the environment. The greatest risk to humans and wildlife is 

associated with the formation of methyl mercury and its bioconcentration in the 

aquatic food chain (USEPA, 2000). 

6.2 Environmental Toxicity 

6.2.1 Methodological Considerations 

Limited data are presented on environmental toxicity in WS Atkins (1998) and OECD 

(1995). However, more information on ecotoxicity (NOEC, LOEC, EC50, etc.) by 

species and compartment is presented by Eurochlor (1999a). Similarly, the French 

Institut National de l’Environnement Industriel et des Risques has compiled a review 

of toxicological and environmental data on mercury and its compounds (INERIS, 

2000). 

The Eurochlor (1999a) and INERIS (2000) documents have been reviewed so as to 

provide a range and comparison of NOEC values for input into the EUSES program 

(JRC, 1997) which, in accordance with the TGD, requires the selection of the most 

sensitive results for a range of taxonomic groups. 

It is a requirement of the TGD (European Commission, 1996) that the validity of tests 

and documentation should be taken into account when selecting values. As there is 

neither the time nor resources in this study to examine source documentation, prevalidated data points from the literature have been used in preference to other data. 

Both Eurochlor (1999a) and INERIS (2000) documents consider the quality of data 

points presented46 and data from these documents have been used in preference. 

However, there remains a paucity of data for the terrestrial compartment and NOECs 

have been supplemented, where necessary, with data from other sources. In relation 

to the aquatic environment, a review of ecotoxicology data from AQUIRE (the 

USEPA data-base for the aquatic environment) was undertaken and a comparison 

made with the validated data in Eurochlor (1999a). This found no significant 

difference in the most sensitive values for this most complete data set (i.e. the aquatic 

compartment). This provides a degree of reassurance over the use of the data 

provided in Eurochlor (1999a) and INERIS (2000). A summary of this review is 

provided in Annex 4. 

 

 46 Eurochlor (1999) ranks sources on the basis of validity. All values appearing in INERIS (2000) have 

been validated by RIVM (1999): Environmental Risk Limits in the Netherlands, RIVM. No. 

601640 001, and Slooff et al. (1995): Integrated Criteria Document Mercury, RIVM. No. 601014 

008. 
Mercury Products - Risks to Health and the Environment 

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6.2.2 Micro-organisms 

The EUSES software model requires data on NOECs (No Observed Effect 

Concentrations) for micro-organisms which could affect the operation of sewage 

treatment plants. The TGD refers to specific populations to be considered such as 

Pseudomonas putida. INERIS (2000) reports a (geometric) mean NOEC of 11 μg/l 

for inorganic mercury (based on 6 and 16 hr NOEC values). For organic mercury, 

INERIS (2000) provides a NOEC of 0.2 μg/l for bacteria (based on an 18 hr NOEC 

value). These values have been used in the analysis for inorganic (and elemental) and 

organic mercury respectively. 

6.2.3 Aquatic Compartment 

Ideally, the TGD and EUSES software model require data on long-term NOECs (No 

Observed Effect Concentrations) for fish, Daphnia, algae and other aquatic species. It 

is considered that there are sufficient NOEC data to provide such information in 

relation to inorganic and organic mercury in the freshwater environment. For the 

purposes of this study, we have derived freshwater NOEC values for inorganic 

mercury (typically mercuric chloride) and organic mercury (typically methyl mercury 

chloride) as indicated in Table 6.1. 

Table 6.1: Aquatic (Freshwater) Data used in EUSES Modelling 

Inorganic Mercury NOEC μg/l Source Document 

NOEC Fish 0.3 INERIS (2000) Geometric mean for Pimephales 

promelas (fathead minnow) 

NOEC Daphnia 0.7 INERIS (2000) Geometric mean for Daphnia magna

(water flea) 

NOEC Algae 2.5 Eurochlor (1999a) and INERIS (2000) for Microcystis 

aeruginosa (blue-green algae) 

NOEC Other aquatic 

species 

0.62 Eurochlor (1999a) for Hyalella azteca (an amphipod) 

Methyl Mercury 

NOEC Fish 0.07 INERIS (2000) for Pimephales promelas (fathead 

minnow) 

NOEC Daphnia 0.09 INERIS (2000) and Eurochlor (1999a) for Daphnia 

pulex (water flea) 

NOEC Algae 1 No direct data, so used ‘marine’ value from Eurochlor 

(1999a) for Laminaria saccharina (oarweed) 

NOEC Other aquatic 

species 

0.03 Eurochlor (1999a) for Dugesia dorotocephala 

(turbellarian flatworm) 

Fuller information on the sources, test duration and associated end-points (where 

available) is presented in Table 6.2 for inorganic and organic mercury in the 

freshwater environment. Since it is understood that marine environmental risk 

assessments will be required when the revised TGD (currently in draft form) is 

formally adopted, further data on the marine environment have been presented. As 

can be seen, there are relatively fewer marine data for organic mercury but it would 

appear that the NOEC values for the two environments are broadly comparable. 
Table 6.2: Summary of NOECs for Aquatic Organisms 

Group Mercury Form Marine Data NOEC μg/l Freshwater Data N

10 Fundulus heteroclitus (mummichog) - Sharp & Neff, 1980 (32d - hatching success) 0.68 - 1 

Low: Geometric Mean 

(fathead minnow); low Olson, 1982 (41 wk - grHigh: Brachydanio rer

Xiu, 1991 (14d - mortal

inorganic 

mercury 

10 as above 0.3 

Geometric Mean – Pimeminnow); low [0.09] ba1982 (30d - growth of p

no data 0.15 - 29 

Low: Geometric Mean 

(brook trout); low value (248d - growth of larvaeHigh: Oncorhynchus kiDevlin & Mottet, 1992 

Fish 

methyl 

mercury 

no data 0.07 Pimephales promelas (f

19743 (60d - mortality, r

0.25 - 6 

Low: Crepidula fornicata (slipper limpet) - Thain, 1984 (112d - reproduction) High: Penaeus indicus (Indian prawn) - McClurgh, 1984 (28d - growth) 

0.62 - 54 

Low: Hyalella azteca (et al, 1993 (6-10 wk - re

High: Geometric Mean 

(snail) - Muley & Mane

inorganic 

mercury

0.1 - 70 

Low: Clavopsella michaeli (a coelenterate) - Piraino, 1991 (8d) High: Ophryotrocha diadema (a marine worm) - Reish, 1978 and Reish & Carr, 1978 (geometric mean) (28d) 

0.7 Geometric Mean - Daph

low [0.07] Enserink et a

0.3 Mytilus edulis (blue mussel) - Pelletier, 1988 (32d - growth) 0.03 - 0.1 

Low: Dugesia dorotoce

flatworm) - Best et al., 

neurotoxic effects) High: Daphnia pulex (wMcNaught, 1992 (30d - 

Crustaceans 

& Other 

Invertebrates

methyl 

mercury

0.3 ditto 0.09 Daphnia pulex (water fl
Mercury Products - Risks to Health and the Environment 

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Table 6.2: Summary of NOECs for Aquatic Organisms 

Group Mercury Form Marine Data NOEC μg/l Freshwater Data N

0.9 - 330 

Low: Fucus serratus (toothed wrack) - 

Strömgren, 1980 (10d - growth) High: Dunaliella tertiolecta (green algae) - Portmann, 1972 (18d - growth) 

5 TT - 250 

Low: Microcystis aerugBringmann & Kühn, 19growth) High: Anacystis nidulanet al, 1992 (14d - growt

inorganic 

mercury 

0.9 Fucus serratus (toothed wrack) as above 2.5 Microcystis aeruginosa 

1 

Laminaria saccharina (oarweed) - Thompson & Burrows, 1984 (14d - development of zoospores, growth of sporophytes) 

1 based on saltwater data 

Aquatic 

Plants 

methyl 

mercury 

no data no data 

2.5 Cristigera sp. - Gray & Ventilla, 1973 (4-9 hr - reproduction) 16TT- 87 

Low: Chilomonas paraBringman & Kühn, 198High: Geometric Mean (ciliate) based on Calabmortality) 

inorganic 

mercury 

2.5 ditto 8 Chilomonas paramecium 

no data 14 Tetrahymena pyriformis 

1972 (2-6 hr - growth) 

Protozoa 

methyl 

mercury no data 0.2 Poterioochromonas ma

Röderer, 1983 (3d) 

Notes: 1) Eurochlor values are NOECs (unless otherwise indicated) as presented in Eurochlor (1999a): Risk Assessment for the Marin

4a, 4b and 6). TT refers to ‘toxicity threshold’ which appears to be equivalent to 2 x NOEC (as interpreted by INERIS) 

 INERIS values are NOECs as presented in INERIS (2000): Compilation of Toxicological and Environmental Data on Chemic

2) This value appears in the Eurochlor report but was rejected on grounds of validity as it was from a secondary source. Howev

Sloof et al. (1995) and RIVM (1999)
Risk & Policy Analysts

Page 89

Fish 

In terms of fish, both Eurochlor (1999a) and INERIS (2000) provide geometric mean 

values for the fathead minnow Pimephales promelas of 0.68 μg/l and 0.3 μg/l 

inorganic mercury respectively. The lower of these values (INERIS, 2000) has been 

used since the geometric mean includes a reported result of 0.09 μg/l (from Snarski & 

Olson, 1982) which was not considered by Eurochlor to be of sufficient reliability to 

be included in their analysis. 

As regards methyl mercury, Eurochlor (1999a) reports the most sensitive species as 

the brook trout Salvelinus fontinalis with a NOEC of 0.15 μg/l methyl mercury, 

having eliminated the lower NOEC value of 0.07 μg/l for the fathead minnow 

Pimephales promelas owing to secondary reporting and consequent low validity. 

INERIS (2000), however, validates this lower value and, as such a NOEC for fish of 

0.07 μg/l methyl mercury has been used in the EUSES modelling. 

Crustaceans and Other Invertebrates (including Daphnia)

The lowest NOEC value found for crustaceans and other invertebrates is 0.07 μg/l 

inorganic mercury for the water flea Daphnia magna reported in INERIS (2000). 

However, given the range of values reported for this species, INERIS (2000) provides 

a geometric mean value of 0.7 μg/l. This is higher than the 0.62 μg/l inorganic 

mercury value reported by Eurochlor (1999a) for Hyalella azteca (an amphipod). The 

values of 0.7 and 0.62 are used for Daphnia and ‘other aquatic species’ respectively 

(as shown in Table 6.1).

In terms of methyl mercury, the most sensitive species is the turbellarian flatworm 

Dugesia dorotocephala with a NOEC of 0.03 μg/l reported in Eurochlor (1999a). The 

most sensitive NOEC endpoint for the water flea Daphnia pulex of 0.09 μg/l is 

reported in both Eurochlor (1999a) and INERIS (2000). The values of 0.09 and 0.03 

are used for Daphnia and ‘other aquatic species’ respectively (as shown in Table 6.1).

Aquatic Plants (including Algae) 

Eurochlor (1999a) reports a threshold value of 5 μg/l for inorganic mercury for the 

most sensitive freshwater species, the blue-green alga Microcystis aeruginosa. Using 

the same original source material, INERIS (2000) reports a NOEC value of 2.5 μg/l. 

As regards methyl mercury, there is no NOEC value in the literature for the 

freshwater environment and Eurochlor (1999a) uses the value of 1 μg/l methyl 

mercury found for the oarweed Laminaria saccharina. This value has been taken 

forward to EUSES modelling. 

Protozoa

 

A range of NOECs for protozoa are reported in Eurochlor (1999a). The most 

sensitive freshwater result is a ‘toxicity threshold’ value of 16 μg/l for the 

cryptomonad Chilomonas paramecium which is reduced to 8 μg/l in the INERIS 

(2000) documentation using the same source data for inorganic mercury. 
Mercury Products - Risks to Health and the Environment 

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In terms of methyl mercury, Eurochlor (1999a) reports that the ciliate Tetrahymena 

pyriformis is the most sensitive species with a NOEC value of 14 μg/l. INERIS 

(2000) reports a lower NOEC value of 0.2 μg/l for the protozoan Poterioochromonas 

malhamensis. 

PBT Assessment for the Marine Environment 

As already indicated, marine environmental risk assessments are likely to be required 

when the revised TGD (currently in draft form) is formally adopted. These, in turn, 

are likely to require a PBT (persistence, bioaccumulation and toxicity) assessment 

which will involve two steps: 

• identification of PBT substances using specific criteria; and 

• an evaluation of the sources, major emissions and pathways to the marine 

environment to sufficiently establish the most appropriate and effective measures 

to reduce the releases to the marine environment. 

Table 6.3 summarises the proposed PBT and vPvB (very persistent and very 

bioaccumulating) criteria that it is understood will be used in the first step. 

 

Table 6.3: Proposed Criteria for Identification of PBT and vPvB Substances 

Criterion PBT Criteria vPvB Criteria 

P 

Half-life > 60 d in marine water or > 40 d 

in freshwater1

 or half-life > 180 d in 

marine sediment or > 120 d in freshwater 

sediment1

Half-life > 60 d in marine or freshwater 

or >180 d in marine or freshwater 

sediment 

B BCF > 2,000 BCF > 5,000 

T 

Chronic NOEC < 0.01 mg/L or CMR 

(carcinogenic, mutagenic or toxic for 

reproduction) or endocrine disrupting 

effects 

Not applicable 

Notes: 

1) For the purpose of marine environmental risk assessment, half-life data in freshwater and 

freshwater sediment can be overruled by data obtained under marine conditions. 

It is intended that, generally, such criteria will be applied to organic compounds. 

Since metals (including mercury and its compounds) do not ‘biodegrade’ in the usual 

sense of the word, they would all be classified as (very) persistent (however defined). 

As noted in Section 5.5.3, BCF factors of 5,000 and 50,000 have been used in this 

analysis for inorganic and organic mercury respectively. As such, mercury and its 

compounds would be expected to meet the proposed ‘very bioaccumulating’ criterion. 

For completeness, it can be seen from Table 6.3, that the (PBT) toxicity criteria would 

be met for both inorganic and organic compounds. 

The conclusion that mercury and its compounds are likely to be classified, at least, as 

PBT substances is not surprising and is, of course, one of the key drivers for the 

activities of OSPAR and other bodies to limit mercury discharges to the marine 

environment and for the designation of mercury and its compounds as priority 

hazardous substances under the Water Framework Directive. 
Risk & Policy Analysts

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6.2.4 Terrestrial Compartment - Soil 

Within the terrestrial compartment, the focus of interest is on the effects of inorganic 

mercury since methylation appears to be mainly limited to the aquatic environment. 

However, historically, organomercurials have been used as anti fungal agents for 

seeds and plants - although this use has been banned for some time within the EU. 

As a result, the presence of organic mercury in the terrestrial compartment is likely to 

be associated with contamination (UNEP, 2002). Interestingly, work is under way to 

develop genetically-modified crops which can be planted in contaminated areas (not 

necessarily within the EU) to break down the organic mercury into the less harmful 

inorganic mercury (as discussed in Petra & Sharma, 2000). 

On this basis, the analysis has been restricted to inorganic mercury and, ideally, the 

TGD and EUSES software model require data on NOECs for plants, earthworms, 

micro-organisms and other terrestrial species. Table 6.4 summarises the NOEC 

values used with further detail provided below. 

Table 6.4: Terrestrial Data used in EUSES Modelling 

Inorganic Mercury NOEC 

mg/kg dw Source Document 

NOEC Plants 0.125 Pennisetum thypoideum (cereal) - Mhatre et al, 1984 

(quoted in Eurochlor, 1999) 

NOEC Earthworms <0.5 Octochaetus pattoni (earthworm) - various sources 

quoted in Eurochlor, 1999. 

NOEC Micro-organisms 1.4 Microorganisms ATP - Zelles et al., 1985 (quoted in 

INERIS, 2000) 

NOEC Other terrestrial 

species (excluding birds 

& mammals) 

0.121 Eyrepocnemis plorans (grasshopper) - Devkota & 

Schmidt, 1999 (quoted in USEPA ECOTOX data-base) 

 Plants 

Data on NOECs for plants from three studies are presented by Eurochlor (1999) for 

inorganic mercury. No data are presented by INERIS (2000). Searches of the 

USEPA’s ECOTOX data-base and a more general search of the Web of Science

abstract data-base produced some further information. Petra & Sharma (2000) review 

the results of numerous studies on the impacts of mercury (both inorganic and 

organic) upon plants. As would be expected, there is a consensus that organic 

mercury is more toxic to plants than inorganic mercury. 

For inorganic mercury (mercuric chloride), the lowest NOEC found was that of 0.125 

mg/kg dw presented in Eurochlor (1999) based on the effects on leaf area and leaf 

injury of short-term (24 hr) exposure to mercuric concentrations in the range 1 - 1,000 

μg/l. It is considered that this value may err on the side of pessimism as it is 

noticeably lower than the values reported elsewhere (and, indeed, was assigned a 

‘validity score’ of 3 by Eurochlor to indicate a low level of reliability). 

 
Mercury Products - Risks to Health and the Environment 

Page 92

 Earthworms 

Limited data on NOECs for earthworms are presented by Eurochlor (1999) and 

INERIS (2000). As for plants, searches of ECOTOX and the Web of Science were 

undertaken but produced limited information. 

For inorganic mercury (mercuric chloride), the lowest value found was that of 0.5 

mg/kg dw presented in Eurochlor (1999) for Octochaetus pattoni based on a 60d 

LCLo (lowest lethal concentration) for inhibition of reproduction (and an LC50 of 

0.75 mg/kg dw). Clearly, the NOEC value will be lower. 

Of note is that for organic mercury (methyl mercury chloride), the only NOEC found 

was that of 3.7 mg/kg dw presented in INERIS (2000) for the ‘standard’ manure 

worm (Eisenia foetida) based on an 84d test. This value can be compared with the 

corresponding inorganic NOEC of 100 mg/kg dw47. 

 Micro-organisms 

Limited data on NOECs for micro-organisms are presented by INERIS (2000), 

although not by Eurochlor (1999). As before, searches of ECOTOX and the Web of 

Science were undertaken but produced no significant findings. 

For inorganic mercury (mercuric chloride), the lowest NOEC found was that of 1.4 

mg/kg dw presented in INERIS (2000) for effects on levels of ATP (adenosine 

triphosphate) based on a 48d test. 

NOEC for other terrestrial species 

Limited data on NOECs for other species are presented by Eurochlor (1999) for 

inorganic mercury. No data are presented by INERIS (2000). As before, searches of 

ECOTOX and the Web of Science were undertaken. 

For inorganic mercury (mercuric chloride), the lowest NOEC found48 was that of 

0.121 mg/kg dw for development effects on Eyrepocnemis plorans (grasshopper). 

The same result was also obtained for another grasshopper species, Aiolopus 

thalassinus. 

 

 47 Fischer E & Koszorus L (1992): Sublethal Effects, Accumulation Capacities and Elimination Rates of 

As, Hg and Se in the Manure Worm, Eisenia Fetida (Oligochaeta, Lumbricidae), Pedobiologia, Vol 36 

pp 172-178 (as reported on the USEPA ECOTOX data-base). 

 48 Devkota B & Schmidt GH (1999): Effects of Heavy Metals (Hg2+, Cd2+, Pb2+) during the Embryonic 

Development of Acridid Grasshoppers (Insecta, Caelifera), Archives of Environmental Contamination 

and Toxicology, Vol 36 pp 405-414 (as reported on the USEPA ECOTOX data-base). 
Risk & Policy Analysts

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6.2.5 Terrestrial Compartment - Birds 

The TGD and EUSES software model require data on NOECs for birds. NOEC 

values were derived for inorganic mercury (typically mercuric chloride) and organic 

mercury (typically methyl mercury chloride). Table 6.5 summarises the NOEC 

values used with further detail provided below. 

Table 6.5: Bird Data used in EUSES Modelling 

Inorganic Mercury NOEC Source Document 

NOEC (Feed) 1.1 mg/kg feed Starlings - Nicholson et al., 1984 (quoted in Eurochlor, 

1999 and INERIS, 2000) 

Methyl Mercury 

NOEC (Feed) 0.36 mg/kg feed Pheasants (& chickens) - Gardiner, 1972 (quoted in 

INERIS, 2000) 

For inorganic mercury (mercuric chloride), the lowest NOEC found was that of 1.1 

mg/kg feed presented in Eurochlor (1999) and in INERIS (2000) for starlings based 

on a 56d test. 

For organic mercury (methyl mercury chloride), the lowest NOEC found was that of 

0.36 mg/kg feed presented in INERIS (2000) for pheasants and chickens based on a 

20d test. 

6.2.6 Terrestrial Compartment - Mammals 

The EUSES software model requires data on NOAELs (no observed adverse effect 

level) for oral, dermal and inhalation routes for mammals. NOAEL values have been 

derived for inorganic mercury (typically mercuric chloride but also including 

elemental mercury vapour) and organic mercury (typically methyl mercury chloride). 

ATSDR (1999) presents an authoritative overview of the toxic effects of mercury and 

its compounds on mammals and humans and has been used as the source document 

for the values used in EUSES. Comparisons were also made with data presented in 

Eurochlor (1999) and INERIS (2000). 

Table 6.6 summarises the NOAEL values used with further detail provided below. 

Table 6.6: Mammal Data used in EUSES Modelling 

Inorganic Mercury NOAEL Source Document 

Oral 0.23 mg/kg/day Rat - Dieter et al., 1992 & NTP, 1993 (quoted in 

ATSDR, 1999) 

Dermal 0.23 mg/kg/day Taken to be the same as for oral route (EUSES default) 

Inhalation 0.075 mg/m3 Warfvinge et al., 1995 (quoted in ATSDR, 1999) 

Organic Mercury 

Oral 0.011 mg/kg/day Monkey - by Kawaski et al., 1986 (quoted in INERIS, 

2000)

Dermal 0.011 mg/kg/day Taken to be the same as for oral route (EUSES default)

Inhalation 0.0075 mg/m3 Taken to be 10% of corresponding value for inorganic 

mercury 
Mercury Products - Risks to Health and the Environment 

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Oral Route 

For inorganic mercury, the lowest NOAEL was found to be 0.23 mg/kg/day (as 

reported in ATSDR, 1999) for renal effects after a 26 wk test. 

For organic mercury, the lowest ‘systemic’ NOAEL reported in ATSDR (1999) is 

0.02 mg/kg/day (based on renal effects for a 2 year rat study undertaken by 

Verschuuren et al., 1976). The same value is derived for neurological effects (based 

on the ‘hopping reaction’ of cats after a 2 year study undertaken by Charbonneau et 

al., 1976). Reference is also made to Bornhausen et al., 1980 in which the NOAEL 

for developmental effects (performance in offspring) after 4 days exposure was 

determined to be 0.004 mg/kg/day. However, ATSDR (1999) notes that this finding 

has yet to be confirmed by other studies. 

INERIS (2000) reports a NOEC of 0.22 mg/kg feed (based on a 1 year monkey study 

undertaken by Kawaski et al., 1986). Using the NOEC (feed) to NOAEL (oral) 

conversion (for monkeys) provided by EUSES gives a NOAEL of 0.011 mg/kg/day 

and it is this value which will be taken forward in the analysis. 

Dermal Route 

No data on the effects of dermal exposure are reported by ATSDR (1999) nor by 

Eurochlor (1999) and INERIS (2000). For this route, the NOAEL has been assumed 

to be the same as for the oral route (which is the EUSES default). 

Inhalation Route 

Data on inhalation toxicity generally relates to exposure of elemental mercury vapour. 

ATSDR (1999) reports an inhalatory NOAEL of 0.1 mg/m3 (for renal effects based on 

an 18 month study of various mammals undertaken by Ashe et al., 1953). For 

immunological/lymphoreticular effects, ATSDR (1999) reports a slightly lower value 

of 0.075 mg/m3 (based on a 10 wk study on mice undertaken by Warfvinge et al., 

1995) and this value will be taken forward in the analysis for inorganic mercury. 

No data have been located for the effects on animals of inhalation of organic mercury 

vapours. In the absence of such data, the NOAEL value has been assumed to be 10% 

of that for inorganic mercury derived above. 
Risk & Policy Analysts

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6.3 Human Toxicity 

6.3.1 Overview 

Limited data are presented on human toxicity in WS Atkins (1998). There is a wealth 

of information on human toxicity of mercury and mercury compounds and much of it 

has been reviewed in a comprehensive US report (ATSDR, 1999). Furthermore, an 

authoritative review of mercury toxicity has been recently published by the World 

Health Organisation (WHO, 2000). A further review of these and other key 

documents has also been published recently by the UK Government (DEFRA, 2002). 

Recent reviews which concentrate on the assessment of health effects of exposure to 

methyl mercury include NIEHS (1999), National Research Council (2000) and US 

EPA (2001). In broad terms, methylated mercury is more toxic than inorganic 

mercury salts, which, in turn, are more toxic than elemental mercury. Interestingly, 

the ingestion of elemental mercury (from, say, thermometers) is very unlikely to result 

in adverse effects due to the very low absorption by the intestine (less than 0.01%) 

The prime effects of exposure to mercury and its compounds are: 

• for mercury vapour (via inhalation), effects on the nervous system (for example, 

tremors and memory loss) although these are often reversible; 

• for inorganic mercury compounds (via ingestion), the kidney is the target organ; 

and 

• for organic mercury compounds (via ingestion), the damage is mainly to the 

central nervous system and the effects are irreversible. Such effects have been 

observed in children whose mothers were exposed to methyl mercury when 

pregnant. 

Mercury and its compounds are not considered to be carcinogenic. 

The EUSES software model requires data on NOAELs (no observed adverse effect 

level) for oral, dermal and inhalation routes for humans. NOAEL values have been 

derived for inorganic mercury (typically mercuric chloride but also including 

elemental mercury vapour) and organic mercury (typically methyl mercury chloride). 

Table 6.7 summarises the NOAEL values used with further detail provided below. 

Table 6.7: Human Data used in EUSES Modelling 

Inorganic Mercury NOAEL Source Document 

Oral 2 μg/kg/day ATSDR (1999) 

Dermal 2 μg/kg/day Taken to be the same as for oral route (EUSES default) 

Inhalation 0.2 μg/m3 ATSDR (1999) 

Organic Mercury 

Oral 0.1 μg/kg/day USEPA (2001) 

Dermal 0.1 μg/kg/day Taken to be the same as for oral route (EUSES default)

Inhalation 0.02 μg/m3 Taken to be 10% of corresponding value for inorganic 

mercury 
Mercury Products - Risks to Health and the Environment 

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6.3.2 Inhalation 

About 80% of inhaled mercury vapour is absorbed via the lungs and retained by the 

body. The absorption rate for inorganic mercury is about half of this value (although 

it does depend on other factors - such as associated particle sizes). As already 

mentioned (see Section 4.5.3), systemic effects have been observed after long-term 

(occupational) exposure to levels of the order of 0.1 mg/m3. Some studies have 

observed other effects, notably neurological, at lower concentrations (ATSDR, 1999) 

- down to 0.026 mg/m3. On this basis and after various adjustments and safety 

factors, the US has set an MRL (minimal risk level) for long term exposure to 

mercury vapour as 0.2 μg /m3

. 

Although WHO (2000) reports some (human) effects at lower workplace exposure 

levels - down to 0.01 mg/m3

 - WHO has recommended a ‘safe’ guideline of 1 μg/m3. 

These various calculations are illustrated in Box 6.1. 

Several studies during recent decades demonstrated that mercury vapours are released 

from dental amalgam filling into the oral cavity. The estimate for the rate of release 

in people with amalgam fillings is 3 - 17 μg Hg/day (WHO, 1990). The concentration 

of mercury vapour in the oral cavity can reach occupational health danger levels, but 

the quantity of vapour is small because the volume of the cavity is small (Clarkson, 

2002). Two well conducted epidemiological studies demonstrated that dental 

amalgam did not affect mental health (Bjorkman et al., 1996; and Saxe et al., 1995). 

The value taken forward in the analysis is a NOAEL value of 0.2 μg/m3 for inhalation 

for inorganic mercury. No data have been located for the inhalation of organic 

mercury and a value of 0.02 μg/m3

 is assumed. 

6.3.3 Dermal Exposure 

Dermal exposure is not generally considered to be a significant route when 

considering the toxicity of mercury and its compounds. However, ATSDR (1999) 

reports a case in which the accidental spillage of a few drops of dimethyl mercury on 

the latex gloves of a chemistry professor led to death within several months (via both 

Box 6.1: Deriving a ‘Safe’ Level from Occupational LOAELs 

1) WHO (2000): LOAEL (workers): 20 μg/m3

Increase by a factor of three to correct for ‘true’ exposure: 60 μg/m3

Reduce by a factor of three to adjust for longer ‘public’ exposure: 20μg/m3

Divide by 10 to account for variations in population sensitivity 2 μg/m3

Divide by 2 for LOAEL uncertainty: 1 μg/m3

2) ATSDR (1999): LOAEL (workers): 26μg/m3

Reduce by a factor of 168/40 to adjust for longer ‘public’ exposure 

(40 hours worker exposure vs 168 (24 x 7) hours public exposure): 6.2 μg/m3

Divide by 10 to account for variations in population sensitivity 0.6 μg/m3

Divide by 3 for LOAEL uncertainty: 0.2 μg/m3
Risk & Policy Analysts

Page 97

dermal exposure - as the gloves were readily penetrated by the dimethyl mercury - 

and inhalation). 

The NOAEL values taken forward in the analysis are assumed to be the same as those 

derived for the oral route (which is also the EUSES default). 

6.3.4 Ingestion 

Overview 

As already noted, absorption of elemental mercury in the intestine is very low while 

that for inorganic mercury compounds is of the order of 10-15%. By contrast, there is 

almost complete absorption of methylated mercury compounds (WHO, 2000). 

 

The greatest amount of work undertaken on mercury toxicity is in relation to ingestion 

of mercury contaminated foodstuffs. This has been spurred by various tragedies 

including Minamata and Niigata in Japan in which industrial discharges of methyl 

mercury and other mercury compounds (during the late 1950s and early 1960s) led to 

elevated levels of methyl mercury in fish. By 1971, 269 cases of Minamata disease49

had been reported of which 55 proved fatal and by 1989, there were 2217 confirmed 

cases in Minamata and 911 in Niigata. In Iraq in 1971-72, ingestion of bread made 

with cereals treated with organic mercury fungicides led to 6,000 hospital admissions 

and 500 deaths (WHO, 1996). 

Inorganic Mercury 

Many of the ingestion toxicity tests relate to mercuric chloride which has been found 

to be more toxic than the natural ore mercuric sulphide. Inspection of the results 

presented in ATSDR (1999) suggests that the effects are dependent on the ingestion 

rate (mg/kg bw/day50) rather than on the dose (ingestion rate x time). The most 

susceptible part of the body appears to be the kidneys with reported NOAELs of 0.93 

and 0.23 mg/kg/day for acute and intermediate exposures respectively. On this basis 

and after various adjustments and safety factors, the US has set MRLs for acute and 

intermediate ingestion exposures (to inorganic mercury) as 7 and 2 μg/kg/day 

respectively. The latter value has been taken forward as the NOAEL value for the 

oral route for inorganic mercury. 

Organic Mercury 

In relation to organic mercury, the greatest public health concern relates to methyl 

mercury exposure from ingestion of contaminated food, particularly the edible tissue 

of fish. All exposure intake values estimated for methyl mercury are presented in 

Table 6.8. 

 

 49 The symptoms of Minimata disease are those of methyl mercury poisoning and include uncoordinated 

movements, abnormal reflexes, speech problems and seizures. 

 50 mg/kgbw/day refers to mg ingested per kg of bodyweight per day (and is usually shortened to 

mg/kg/day). 
Mercury Products - Risks to Health and the Environment 

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Table 6.8: Exposure Estimates for Methyl mercury and Percentage (%) of Total Exposure 

Based on Adults in the General Population

Exposure Source Exposure Estimate 

(mg/kg/day)

Percent of Total 

Exposure Percent of RfD1

Ambient water intake 4.3 x 10-9 0.005% 0.004% 

Drinking water intake2 5.6 x 10-8 0.061% 0.056% 

Nonfish dietary intake 0 0% 0% 

Freshwater/estuarine 

fish intake 6.5 x 10-5 70.6% 65.0% 

Marine fish intake 2.7 x 10-5 29.3% 27.0% 

Air intake 4.6 x 10-9 0.005% 0.005% 

Soil Intake 1.3 x 10-9 0.001% 0.001% 

Total intake 9.2 x 10-5 100% 92.1% 

Source: US EPA (2001) 

Notes: 

1) The USEPA’s ‘reference dose’ (RfD) is set at 0.1 μg/kg/day (i.e. 1 x 10-4 mg/kg/day). 

2) This represents the high end of the range of estimates. Because the contribution of ambient water 

or drinking water intake to total exposure is so negligible in comparison to the sum of intake from 

other sources, there is no difference in the total exposure estimated using either of these two 

alternatives.

The major toxic effects of methyl mercury are on the central nervous system. The 

mechanisms and outcomes of toxic effects on the developing brain differ from those 

on the mature organ. 

In adults, paresthesia (prickling sensation) is the first symptom to appear at the lowest 

dose. This may progress to cerebellar ataxia (clumsiness or unsteadiness), dysarthria 

(speech disorder), constriction of the visual fields and loss of hearing. These signs 

and symptoms are caused by the loss of neuronal cells in specific anatomical regions 

of the brain (Clarkson, 2002). Although, most epidemiological studies and clinical 

reports on adults demonstrated signs and symptoms of toxic effects of methyl mercury 

associated mainly with the central nervous system, recent reports indicate the 

possibility that methyl mercury may have adverse effects on the cardiovascular 

system (Salonen et al., 1995; Salonen et al., 2000). 

A number of epidemiological studies involving new-borns and children from mothers 

exposed to methyl mercury indicated higher susceptibility of the developing brain, 

compared to the mature organ. The first such indications come from the studies of 

Minamata and Iraq outbreaks of methyl mercury poisonings. It was possible to 

construct a dose-response relationship between peak hair mercury levels in pregnancy 

versus number of abnormal offspring showing developmental delays and abnormal 

neurological findings (Marsh et al., 1987; Cox et al., 1989). There are no data to 

indicate that methyl mercury is carcinogenic in humans. 

The quantitative health risk assessment for non-carcinogenic chemicals is based on 

the reference dose (RfD). This is an estimate of a daily exposure of the human 

population, including sensitive subgroups, that is likely to be without an appreciable 

risk of deleterious health effects during a lifetime. The earlier RfD of 0.1 μg/kg/day 
Risk & Policy Analysts

Page 99

was established in 1995 by the US EPA as the Agency’s consensus estimate. Marsh 

et al. (1987) was chosen as the most appropriate study at that time for determination 

of an RfD to protect infants born to mothers exposed to methyl mercury during 

pregnancy. 

 

Since that time, considerable new data on the health effects of methyl mercury have 

appeared in the literature. Neurotoxicity, particularly in developing organisms, has 

been observed as the adverse effect at the lowest dose of methyl mercury. The 

National Research Council (NRC) of the National Academy of Sciences in the USA 

and US EPA considered three epidemiological studies most suitable for quantitative 

risk assessment: the Seychelles Child Development Study (Davidson et al., 1998 & 

2001); studies of Children in the Faroe Islands (Grandjean et al., 1997; Murata et al., 

1999); and the study of Children in New Zealand (Mitchell et al., 1982). All cohorts 

consisted of children exposed in utero through maternal consumption of contaminated 

marine food. In both the Faroe Islands and the New Zealand studies, 

neurodevelopmental toxic effects of methyl mercury were found to be dose-related. 

These effects include developmental deficits in memory, attention and language. No 

evidence of impairment associated with exposure was found in the Seychelles study. 

In 1999, ATSDR published a revised Minimal Risk Level for methyl mercury of 0.3 

μg/kg/day, based on a dose of 1.3 μg/kg/day derived from the Seychelles study data, 

which does not necessarily reflect the NOAEL. 

The Committee on Toxicological Effects of Methylmercury, established in 1999 by 

the US National Research Council, reviewed and evaluated scientific data on health 

effects of methyl mercury. In its published report, NRC (2000) concluded that 

differences in the study designs and in the characteristics of the study populations 

might explain the differences in findings between the Faroe and Seychelles studies. 

 

Taking into account that a large body of scientific evidence showing adverse 

developmental neurotoxic effects was available from well-designed epidemiological 

studies, the Committee concluded that a RfD should not be derived from a study such 

as the Seychelles study which did not observe any associations with exposure to 

methyl mercury. Given the strength of the Faroe Islands study, the Committee 

concluded that it would be most appropriate if a RfD was derived from this critical 

study. 

US EPA followed the recommendations of the NRC in the subsequent development of 

a RfD. The critical endpoint was drawn from the series of neuropsychological test 

results from the Faroese cohort. The RfD derived in this assessment is 0.1 μg/kg 

bw/day. In the published document (US EPA, 2001), the authors emphasise that there 

are currently no data that would support the derivation of a RfD applicable to children 

specifically. The derived RfD is applicable to lifetime daily exposure for all 

populations including sensitive subgroups - with particular reference to preventing the 

occurrence of developmental effects amongst children whose mothers are exposed to 

methyl mercury during pregnancy. 
Mercury Products - Risks to Health and the Environment 

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7. RISK CHARACTERISATION

7.1 Overview 

The purpose of the risk characterisation is to assess whether the predicted 

concentrations in the environment exceed those concentrations which produce adverse 

effects in either the environment or in humans. The TGD procedure (as incorporated 

into EUSES) involves: 

• selecting the lowest NOEC for the area of interest (based on the toxicity data 

presented in Section 6); 

• dividing the lowest NOEC by an assessment (or safety) factor to derive the PNEC 

(predicted no-effect concentration); 

• selecting the appropriate PEC (based on the results of the EUSES analysis 

presented in Section 5); and 

• dividing the PEC by the PNEC to give an indication of the level of the associated 

risk. 

Where there are several relevant NOECs (as in this case), the TGD (and EUSES) 

recommends an assessment factor of 10. However, in the case of metals, it is 

anticipated that a lower factor will be incorporated into the revised TGD. At an 

expert workshop51, it was agreed that a value between 1 (exceptionally) and 5 would 

be more appropriate. For this analysis, an assessment factor of 5 will be used to err 

on the side of caution and to reflect some of the uncertainties in both the analysis and 

the derivation of NOECs. 

7.2 Risks to the Environment 

7.2.1 Aquatic Environment 

The lowest NOECs derived for the aquatic environment were 0.3 and 0.03 μg/l for 

inorganic and organic mercury respectively (see Table 6.1). Applying an assessment 

factor of 5 gives PNECs of 0.06 μg/l (60 ng/l) and 6 ng/l respectively. Since 

measured concentrations (for inorganic mercury) are typically in the range 1 - 10 ng/l 

(see Table 4.1), it can be seen that only PECs which are far in excess of existing 

concentrations will to lead to PEC/PNEC ratios of greater than one. 

The resultant PEC/PNEC ratios for the PECs associated with mercury production, 

product manufacture and product use are presented in Table 7.1. Since the ‘local’ 

PEC values are very similar to the regional PEC value (see Table 5.10), the regional 

and local PEC/PNEC ratios are very similar. 

 

 51 Report of the Expert Consultation Workshop on Statistical Extrapolation Techniques for 

Environmental Effects Assessment held in London, 17/18 January 2001 to discuss aspects of the 

revised TGD. 
Mercury Products - Risks to Health and the Environment 

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Table 7.1: PEC/PNEC Ratios for the Aquatic Environment (Water) for Mercury & Products

Mercury Species Parameter 

Inorganic Organic 

Regional PEC/PNEC associated with 

manufacture and use of mercury in products 

under study 

0.011 0.011 

Local PEC/PNEC ratios associated with mercury production: 

Primary production (Spain) 

Production from non-ferrous by-products 

Secondary production 

0.011 0.011 

Local PEC/PNEC ratios associated with product manufacture: 

Dental amalgam 0.011 0.011 

Batteries 0.012 0.012 

Lamps 0.011 0.011 

Measuring equipment 0.011 0.011 

Electrical equipment 0.011 0.011 

EUSES also derives a PNEC for sediments (based on the PNEC for water), which for 

inorganic mercury was estimated to be 7.56 mg/kg dw and for organic mercury, a 

PNEC of 21.3 μg/kg dw was derived52. The associated PEC/PNEC ratios are 

presented in Table 7.2. 

Table 7.2: PEC/PNEC Ratios for the Aquatic Environment (Sediment) for Mercury & Products

Mercury Species Parameter 

Inorganic Organic 

Regional PEC/PNEC associated with 

manufacture and use of mercury in products 

under study 

0.011 0.38 

Local PEC/PNEC ratios associated with mercury production: 

Primary production (Spain) 

Production from non-ferrous by-products 

Secondary production 

0.006 0.22 

Local PEC/PNEC ratios associated with product manufacture: 

Dental amalgam 

Batteries 

Lamps 

Measuring equipment 

Electrical equipment 

0.006 0.22 

 

 52 The calculation of the PNEC in sediment (TGD Eqn. 54) depends directly on the solid-water partition 

coefficient in sediment - i.e. the resultant PNEC varies with the value used. Whilst Eurochlor (1999) 

and INERIS (2000) use the same value (126,000 l/kg) derived for inorganic mercury, Sunderland & 

Gobas (2001) suggest a much lower value of 100 l/kg. In this analysis, a geometric mean of 3,550 was 

used. 
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It may be noted that as local PEC values were not generated by EUSES (see Table 

5.11), it was necessary to have a ‘shadow’ EUSES run based on methyl mercury 

chloride and then to scale the ‘local’ results against the pre-derived ‘regional’ values 

(i.e. 10% of the inorganic values as presented in Table 5.11). 

As can be seen from Tables 7.1 and 7.2, the PEC/PNEC ratios are generally well 

below unity in all cases. The exceptions are the results for organic mercury in 

sediments where relatively higher results were obtained due, in part, to the choice of 

partition coefficient. 

7.2.2 Terrestrial Compartment 

The lowest NOEC derived for the terrestrial environment was 0.121 mg/kg dw for 

inorganic mercury (see Table 6.4). Applying (as for the aquatic compartment) an 

assessment factor of 5 gives a PNEC of 24 μg/kg dw. Since existing concentrations 

are typically in the range 50 - 100 μg/kg dw (see Table 4.1), it can be seen that PECs 

which contribute significantly to the existing concentrations may lead to PEC/PNEC 

ratios of greater than one. 

The associated PEC/PNEC ratios are presented in Table 7.3. 

Table 7.3: PEC/PNEC Ratios for the Terrestrial Environment for Mercury & Products

Parameter Mercury Species: Inorganic 

Regional PEC/PNEC associated with 

manufacture and use of mercury in products 

under study 

0.18 

Local PEC/PNEC ratios associated with mercury production: 

Primary production (Spain) 0.25 

Production from non-ferrous by-products 0.19 

Secondary production 0.19 

Local PEC/PNEC ratios associated with product manufacture: 

Dental amalgam 0.19 

Batteries 0.19 

Lamps 0.20 

Measuring equipment 0.19 

Electrical equipment 0.19 

As can be seen from Table 7.3, the PEC/PNEC ratios are below unity in all cases. 

7.2.3 Secondary Poisoning 

EUSES considers two routes to secondary poisoning of birds or mammals: 

• water to fish to fish-eating birds or mammals; and 

• soil to earthworm to worm-eating birds or mammals. 
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These food chains are associated with organic mercury in the aquatic environment and 

with inorganic mercury in the terrestrial environment. PNECs are derived from 

NOEC data presented in Section 6 on birds (Table 6.5) and mammals (Table 6.6) as 

well as accounting for the bio-concentration factors. These values are then compared 

to the water and soil PECs at a ‘local’ level and the results are summarised in Table 

7.4. 

Table 7.4: PEC/PNEC Ratios for Local Secondary Poisoning for Mercury & Products 

Scenario Aquatic Food Chain 

(Organic Mercury) 

Terrestrial Food Chain 

(Inorganic Mercury) 

Local PEC/PNEC ratios associated with mercury production: 

Primary production (Spain) 

Production from non-ferrous by-products 

Secondary production 

0.92 <0.001 

Local PEC/PNEC ratios associated with product manufacture: 

Dental amalgam 0.92 

Batteries 

Lamps 

Measuring equipment 

Electrical equipment 

0.93 

<0.001 

As can be seen from Table 7.4, PEC/PNEC ratios are predicted to approach unity for 

the aquatic food chain due not only to the low PNECs for organic mercury but also to 

the high bio-concentration factor used (50,000). By contrast, there is a negligible risk 

of secondary poisoning via the terrestrial food chain. The results of the risks to the 

environment are discussed further in Section 7.4. 

7.3 Risks to Humans 

7.3.1 Direct Risks

No attempt has been made to quantify risks in the workplace due to the high level of 

awareness of mercury risks and the (generally) strict measures which have been taken 

to reduce worker exposures. 

7.3.2 Man Exposed via the Environment 

The ‘margins of safety’ (MOS) for man exposed via environmental routes are shown 

in Table 7.5 using the ‘reference doses’ of 2 and 0.1 μg/kg bw/day for inorganic 

(including elemental) and organic mercury respectively (see Table 6.7). The MOS 

values are simply the ratios of the reference dose to the human intake of the substance 

via the environment (including inhalation, dietary intake, etc.) for each scenario. 
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EUSES calculates the MOS for both inhalation (MOS-air) and total environmental 

exposure (MOS-total) and both are presented in Table 7.5. For mercury, the MOS-air 

values will tend to be associated with elemental mercury whilst the MOS-total values 

will tend to be associated with dietary intake of inorganic and organic mercury. 

As can be seen from Table 7.5, the MOS values exceed unity in all cases. 

Table 7.5: Margin of Safety (MOS) Values for Human Exposure via the Environment for 

Mercury & Products at Regional and Local Levels

Parameter MOS-Air 

(Mercury) 

MOS-Total 

(Inorganic) 

MOS-Total 

(Organic) 

Regional MOS values associated with 

manufacture and use of mercury in products 

under study 

>100 >100 18 

Local MOS values associated with mercury production: 

Primary production (Spain) 6.5 

Production from non-ferrous by-products >100 

Secondary production >100 

>100 18 

Local MOS values associated with product manufacture: 

Dental amalgam >100 

Batteries >100 

Lamps 55 

Measuring equipment >100 

Electrical equipment >100 

>100 18 

7.4 Discussion

As detailed in the Technical Guidance Document (TGD), there are three broad 

conclusions that can be drawn from an environmental risk assessment of an existing 

substance. 

• Conclusion (i) there is a need for further information and/or testing; 

• Conclusion (ii) there is at present no need for further information and/or testing 

and no need for risk reduction measures beyond those which are being applied 

already; or 

• Conclusion (iii) there is a need for limiting the risks; risk reduction measures 

which are already being applied shall be taken into account. 

As stated in the TGD, where the PEC/PNEC ratio is found to be less than or equal to 

one for each compartment, Conclusion (ii) shall apply. As can be seen from Tables 

7.1 to 7.4, this condition is met for the use of mercury in the products under study - 

although the PEC/PNEC ratio approaches unity in relation to secondary poisoning via 

the aquatic food chain. In other words, further risk reduction measures (over and 

beyond those already planned) would not be required on the basis of the risk 

assessment alone. 
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However, it is recognised that there is widespread concern over the presence of 

mercury in the environment and a desire to further limit the potential impacts of 

mercury usage. Although it would appear that the broad objective of the Aarhus 

Convention (see Section 1.2) to reduce mercury emissions to below 1990 levels has 

been met (since most uses show a significant decline during the 1990s), the 

Convention requires further precautionary measures to be considered. Similarly, 

HELCOM and OSPAR have an interest in reducing mercury emissions to the marine 

environment. 

Under the revised TGD, which is in preparation, there is little doubt that mercury and 

its compounds will be designated PBT (persistent, bioaccumulative and toxic) 

substances in respect of the marine environment. Such factors led to the designation 

of mercury and its compounds as priority hazardous substances under the Water 

Framework Directive which will necessitate consideration to be given to further 

reductions in usage and emissions. 

In relation to human toxicity, the assessment of human exposure via the environment 

suggests that there is a considerable margin of safety (i.e. MOS >1) associated with 

the products under study as shown in Table 7.5. However, the developmental 

toxicity effects of methyl mercury may result in further pressures to limit the use and 

emissions of mercury and its compounds. 

Of the estimated 160 t/year of mercury emitted to the environment from 

anthropogenic sources in the EU and the three accession countries (EC, 2001b), the 

products under study account for less than 25 t/year. There may, however, be areas 

where further reductions could be achieved in usage and/or associated emissions 

across the range of products examined here. Such reductions should be proportional 

to the relative emissions within the context of the overall anthropogenic use of 

mercury and the associated emissions. 

 

In relation to the products under study, dental amalgam is the largest use with over 10 

t/year of mercury being emitted to the environment. The dominant source of 

emissions is releases from crematoria and this may be an area for further 

investigation. Measuring and control equipment would also appear to be a key source 

with emissions of 8.5 t/year - primarily to the atmosphere from landfills. Within this 

sector, there may be areas where usage and/or emissions could be reduced. The other 

three products areas (batteries, lighting and electrical equipment) have significantly 

lower usage and associated emissions. 

 

More generally, it is worth noting that the production of skin lightening creams 

involves the consumption of mercury in greater quantities than those used for 

measuring and control equipment - although as discussed in Section 3.7, this may be 

an area where more enforcement rather than more controls is required. 

Finally, it is important to stress that any proposed controls would need a further 

investigation of the advantages and drawbacks under the requirements of the 

Marketing and Use Directive (76/769/EEC). 
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8. OVERALL FINDINGS

8.1 Mercury Use in Products under Study

It has been possible to characterise the use of mercury in the main product groups 

which are the subject of this study - dental amalgam, batteries, discharge lamps, 

measuring (and control) equipment and electrical control and switching equipment. 

Although research and consultation has enabled aspects of the various lifecycles to be 

quantified, comprehensive data were not obtained for all areas with particular 

reference to the last two product groups (measuring (and control) equipment and 

electrical control and switching). 

The mercury used in the products within the EU (and the three accession countries) 

comes: from primary production (in Spain); as a by-product of non-ferrous metal 

production; from a mercury recycling plant; or as an import (usually within the 

product, as in the case of thermometers). Some data on these production routes (and 

associated emissions) were obtained but determining the precise scale and extent of 

the mercury ‘business’ proved difficult. However, it would appear that the recovery 

of mercury from decommissioned chlor-alkali facilities is rapidly become the major 

source of mercury within the EU. 

 

Overall, there is clear evidence that the use of mercury in batteries and lamps has 

significantly reduced in recent years. There has also been a decline in the use of 

dental amalgam and, as importantly, there has been a significant increase in the use of 

mercury recovery devices (separators) in dental surgeries. Although there has been a 

reduction in the use of mercury thermometers and sphygmomanometers (for 

measuring blood pressure), it has been difficult to estimate the overall use of mercury 

within this sector. Similarly, whilst there has been a move away from the extensive 

use of mercury tilt switches in domestic products (including cars, white goods, etc.), 

the extent of mercury use in other applications within this sector has been difficult to 

determine. 

For each product group, it was possible to develop a flowchart for the lifecycle and 

associated emissions (based on an approach adopted by the Swedish authorities). 

It is estimated that the current usage of mercury in these product groups is about 120 

tonnes per year (60% of which is associated with dental amalgam) in the EU with, 

perhaps, a further 50 tonnes per year used in the three accession countries under study 

(Czech Republic, Poland and Slovenia). It is estimated that the emissions to the 

environment associated with the production of mercury used in these products, 

product manufacture and product use is less than 25 tonnes per year. 

8.2 Mercury Use in Other Products 

Mercury is used in numerous diverse products and applications, ranging from its use 

in lighthouses (some lights revolve in a bath of mercury) to recoil suppression 

systems in rifles. However, these account for a relatively low consumption with one 
Mercury Products - Risks to Health and the Environment 

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notable exception. It would appear that, perhaps, 50 tonnes per year of mercury is 

used in the manufacture (within the EU) of skin lightening creams and other cosmetic 

products, most of which are exported to, and consumed in, Africa. It should be noted 

that the marketing of mercury containing cosmetic products (with the exception of 

trace amounts in eye products) is not permitted within the EU. 

8.3 Other Sources of Mercury 

Large quantities (thousands of tonnes) of mercury are used in chlor-alkali plants 

throughout the world. Most EU countries have such plants (as does the Czech 

Republic and Poland) and current estimates of mercury consumption (within the EU) 

are of the order of 150 tonnes per year. As indicated above, the planned phase-out of 

mercury usage in chlor-alkali plants will lead to a substantial flow of recovered 

mercury onto the market over the next 20 years (perhaps 650 tonnes per year within 

Europe). The associated emissions (primarily to atmosphere) are estimated to be less 

than 10 tonnes per year although significant amounts of mercury are unaccounted for. 

 

Although mercury is a trace constituent of fossil fuels, fossil fuel consumption within 

the EU may release in the order of a further 150 tonnes per year into the environment 

which is comparable to a recent estimate that total anthropogenic emissions from the 

EU (and the three accession countries) are of the order of 160 tonnes per year. 

Apart from anthropogenic sources of mercury, there are ‘natural’ releases from forest 

fires, volcanoes and ‘evaporation’ from the oceans. Within the EU, recent estimates 

suggest that ‘natural’ emissions within the EU may amount to 200 tonnes per year. 

8.4 Predicting Environmental Concentrations 

The behaviour of mercury in the environment is complex. Most releases are in 

elemental form to atmosphere which is then slowly oxidised to bivalent mercury 

(inorganic mercury). The inorganic mercury enters the terrestrial and aquatic 

environments through deposition. A portion of the inorganic mercury is methylated 

(particularly within sediments) to produce methyl mercury (organic mercury) which 

enters the water column. 

Extensive research is ongoing into the precise reactions (physical, chemical and 

biological) which govern the rates of transformation amongst the three main forms of 

mercury in the different environmental compartments. There is, however, a general 

consensus that the key concern is organic mercury, which is highly toxic and bioaccumulates - particularly in fish. 

For this study, the EUSES model was used (with some modifications) to predict 

mercury concentrations in the three main environmental compartments. In essence, 

the model was run twice: 
Risk & Policy Analysts

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• Run 1: 100% of emissions considered to be as elemental mercury in order to 

obtain predictions for the atmospheric compartment; and 

• Run 2: 100% of emissions considered to be as inorganic mercury (mercuric 

chloride) to obtain predictions for the terrestrial and aquatic compartments. 

The key inputs to the EUSES model were emissions (derived from an analysis of 

mercury production, product manufacture, product use and subsequent recovery or 

disposal) and toxicity data for humans and the environment. It was assumed, as a 

worst case, that the organic mercury concentrations would be 10% of the inorganic 

mercury concentrations. 

The PECs (predicted environmental concentrations) for each compartment showed 

that the products’ use, their manufacture and the production of the associated mercury 

contributed a percent to typical existing concentrations at continental level. At a 

regional level, the contribution was higher. 

At a ‘local’ level (i.e. close to production facilities), significant air concentrations 

(elemental mercury) were predicted close to the primary production site in Spain. 

Otherwise, local values were very close to the regional values. 

8.5 Risks Associated with Products under Study 

Typical intakes of mercury are of the order of 10 μg/day. About 75% is elemental 

and inorganic mercury, most of which is associated with the inhalation of vapours 

from dental amalgam used in fillings. The remaining 25% is organic mercury 

(primarily methyl mercury in fish and fish products). For this study, reference doses 

of 2.0 and 0.1 μg per kg of bodyweight per day have been used as ‘safe’ levels for 

inorganic (including elemental) and organic mercury respectively. The ‘margin of 

safety’ (MOS) values can then be derived for the typical EU adult intake of 10 μg/day 

as follows: 

for inorganic mercury, 

• intake = 7.5 μg/day = 0.11 μg/kg bw/day (for a 65 kg adult); 

• ‘safe’ level = 2.0 μg/kg bw/day; and 

• therefore, MOS = 2.0/0.11 = 18 (in other words, daily intake is 18 times below 

safe levels) 

for organic mercury, 

• intake = 2.5 μg/day = 0.04 μg/kg bw per day (for a 65 kg adult); 

• ‘safe’ level = 0.1 μg/ kg bw/day; and 

• therefore, MOS = 0.1/0.04 = 2.5 (in other words, daily intake is 2.5 times 

below safe levels) 
Mercury Products - Risks to Health and the Environment 

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At a regional level, MOS values associated with elemental and inorganic mercury 

were found to be in excess of 100 (i.e. mercury intake is more than 100 times below 

‘safe’ levels) whilst the MOS value for organic mercury was 18. 

At a local level, MOS values associated with elemental mercury and inorganic 

mercury were generally found to be in excess of 100 although the higher atmospheric 

emissions close to the primary production site in Spain led to an MOS value of 6.5 

and that for lamp production was found to be 55. For organic mercury, the local MOS 

values were essentially the same as the regional value (18). 

In terms of risks to the environment, the criterion of importance is the ratio of the 

predicted environmental concentration (PEC) to the predicted no-effect concentration 

(PNEC). PEC/PNEC ratios of greater than unity are indicators that there may be a 

risk of concern and these were calculated at both regional and local levels. 

PEC/PNEC ratios were derived for water, sediment, soil and (local) secondary 

poisoning (poisoning through the predatory food chain). The key findings may be 

summarised as follows: 

• for water, the PEC/PNEC ratios for inorganic and organic mercury were 

significantly less than unity; 

• for sediment, the PEC/PNEC ratios were significantly less than unity for inorganic 

mercury whilst those for organic mercury were in the range 0.2 - 0.4; 

• for soil, the PEC/PNEC ratios for inorganic mercury were about 0.2; and 

• for secondary poisoning, the PEC/PNEC ratios were significantly less than unity 

for the terrestrial food chain (inorganic mercury) whilst those for the aquatic food 

chain (organic mercury) approached unity (0.9). 

8.6 Recommendations 

Overall, using the TGD/EUSES approach (with modifications), it would appear that 

there are unlikely to be significant risks to the environment associated with the 

mercury containing products under study - with particular reference to dental 

amalgam, batteries, lamps, measuring and electrical equipment. Of the products 

under study, the key contributor is dental amalgam, which accounts for over half of 

the mercury used. 

The modelling results suggest that the risks are primarily associated with organic 

mercury. However, given the complexity of the behaviour of mercury in the 

environment, the modelling has necessitated simplifying assumptions which clearly 

introduces a degree of uncertainty. Furthermore, changes to some critical parameters 

(such as partition coefficients) can make significant changes to the results. 

Nevertheless, in accordance with the TGD, the results suggest a Conclusion (ii) which 

states that there is at present no need for further information and/or testing and no 

need for risk reduction measures beyond those which are being applied already. To 
Risk & Policy Analysts

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this, could be added or are already planned, since there are a number of Directives 

(Water Framework Directive, RoHS Directive, ELV Directive, etc.) which will lead 

to further controls on the usage and emissions of mercury. 

However, it is recognised that there is widespread concern over the presence of 

mercury in the environment and a desire to further limit the potential impacts of 

mercury usage. Of the estimated 160 tonnes per year of mercury emitted to the 

environment from anthropogenic sources in the EU and the three accession countries, 

the products under study account for less than 25 tonnes per year. There may, 

however, be areas where further reductions could be achieved in usage and/or 

associated emissions across the range of products examined here. Such reductions 

should be proportional to the relative emissions within the context of the overall 

anthropogenic use of mercury and the associated emissions. 

 

In relation to the products under study, dental amalgam is the largest use with over 10 

tonnes per year of mercury being emitted to the environment. The dominant source of 

emissions is releases from crematoria and this may be an area for further 

investigation. Measuring and control equipment would also appear to be a key source 

with emissions of 8.5 tonnes per year - primarily to the atmosphere from landfills. 

Within this sector, there may be areas where usage and/or emissions could be 

reduced. The other three products areas (batteries, lighting and electrical equipment) 

have significantly lower usage and emissions. 

 

More generally, it is worth noting that the production of skin lightening creams 

involves the consumption of mercury in greater quantities than those used for 

measuring and control equipment - although this may be an area where more 

enforcement rather than more controls is required. 

It is important to stress that any proposed controls would need a further investigation 

of the advantages and drawbacks under the requirements of the Marketing and Use 

Directive (76/769/EEC). 

Finally, it is recommended that consideration should be given to classification and 

labelling under Directive 67/548/EEC based upon the developmental toxicity of 

methyl mercury and, perhaps, of other organic mercury compounds. 
Mercury Products - Risks to Health and the Environment 

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Risk & Policy Analysts

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AMAP (2001): Heavy Metals, Fact Sheet 3 produced by the Arctic Monitoring and 

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Cox C et al. (1989): Dose-response Analysis of Infants Prenatally Exposed to 

Methylmercury: an application of a single compartment model to single-strand hair 

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Danish EPA (2000a): Warning: Sale of Mercury Soaps is Banned, press release of 22 

March 2000, Danish Environmental Protection Agency, Copenhagen and available 

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Davidson PW et al. (1998): Effects of Prenatal and Postnatal Methylmercury Exposure from 

Fish Consumption on NeuroDevelopment: Outcomes at 66 months of age in the 

Seychelles child development study, JAMA, Vol 280, pp 701-707. 

Davidson PW et al. (2001): Methylmercury and Neurodevelopment: Reanalysis of the 

Seychelles Child Development Study Outcomes at 66 Months of Age, JAMA, Vol 285, 

pp 1291-1293.

DEFRA (2001): Dental Amalgam: An Environmental Code of Practice, consultation 

document issued by UK Department for Environment, Food & Rural Affairs. 
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DEFRA (2002): Contaminants in Soil: Collation of Toxicological Data and Intake 

Values for Humans - Mercury, R&D Publication TOX 7 published by the UK 

Department for Environment, Food & Rural Affairs and Environment Agency. 

Ecology Center et al (2001): Toxics in Vehicles: Mercury - Implications for Recycling 

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Risk & Policy Analysts

Page 115

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Mercury Products - Risks to Health and the Environment 

Page 116

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DC, National Academy Press. 
Risk & Policy Analysts

Page 117

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and available from www.nema.org/papers/enviimpact.doc. 

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2001. 

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Commission. 

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379-422. 

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eastern Finland, Atherosclerosis, Vol 148, pp 265-273. 

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Technical Report No. 38, dated February 2000 and available from www.eea.eu.int.
Mercury Products - Risks to Health and the Environment 

Page 118

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Household Hazardous Waste Forum, dated March 2000. 

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Waste and Paper Ltd. for the UK National Household Hazardous Waste Forum, dated 

January 2000. 

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the United States and the World, US Geological Survey Circular 1197 and available 

from http://greenwood.cr.usgs.gov/pub/circulars/c1197. 

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Alto Regional Water Quality Control Plant, Palo-Alto, California and available from 

www.city.palo-alto.ca.us/cleanbay/pdf/hosp.pdf. 

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and available from www.purchasing.umn.edu/documents/Methods/Equip.html. 

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Economic Commission for Europe in June 1998 and available from 

www.unece.org/env. 

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can be inspected (and downloaded) from www.chem.unep.ch/mercury. 

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and downloadable from www.chem.unep.ch/mercury. 

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Mercury in the Environment, Office of Air Quality Planning and Standards and 

Office of Research & Development Report dated December 1997. 

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EPA Great Lakes Binational Toxics Strategy, draft report dated September 2000. 

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Methylmercury, EPA 0823-R-01-001, Washington, DC. 

US Geological Survey (2001): Minerals Yearbook - 2000, available from www.minerals. 

usgs.gov/minerals/pubs. 

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- Volume II: Europe. Report Highlights, Venture Development Corporation, 

Natick, Massachusetts, January 2000 and available from www.vdc-corp.com/ 

components/archives/99/ br99-16a.html. 
Risk & Policy Analysts

Page 119

Veiga MM (1997): Mercury in Artisanal Gold Mining in Latin America: Facts, Fantasies 

and Solutions, paper prepared for the UNIDO Expert Group Meeting for the 

Abatement of Global Mercury Pollution Deriving from Artisanal Gold Mining, 

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International EUPHEMET Workshop: Toward an Integrated EU Policy for Heavy 

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Organisation, International Programme on Chemical Safety. 

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Health Organisation, International Programme on Chemical Safety. 

WHO (1996): Guidelines for Drinking-Water Quality - Mercury, Geneva, WHO (pp 285-

298) available from www.who.int/water_sanitation_health/GDWQ/Chemicals/ 

mercuryfull.htm. 

WHO (2000): Air Quality Guidelines - Mercury, Copenhagen, WHO Regional Office for 

Europe and available from www.who.nl/aqg/6.9-Mercury.pdf 

WS Atkins (1997): Amalgam Purchase, Use, Recovery and Release, report for the UK 

Department of the Environment, Transport and the Regions and dated December 

1997. 

WS Atkins (1998): Assessment of the Risk to Health and to the Environment of 

Mercury Contained in Certain Products, report prepared for DG Industry (now DG 

Enterprise) and dated August 1998. 
Mercury Products - Risks to Health and the Environment 

Page 120
Risk & Policy Analysts 

ANNEX 1 

TECHNICAL SPECIFICATION FOR STUDY
Mercury Products - Risks to Health and the Environment 
Risk & Policy Analysts 

Page A1-1 

Extract from Tender Documentation: 

4. TECHNICAL SPECIFICATIONS

4.1. INTRODUCTION - CONTEXT OF THE CONTRACT

The reduction of risks to human health and the environment related to the use of 

mercury has been an objective of a wide range of regulations in the European Union. 

There are several Directives setting emission standards for industrial and other 

combustion plants or immission standards for water quality. In addition, there are 

specific rules governing the use of mercury in specific applications or products, e.g. 

Council directive 82/176/EEC on limit values and objectives for mercury discharges 

by the chlor-alkali electrolysis industry, Directive 89/677/EEC on the use of mercury 

in paint and Directive 91/157/EEC on batteries and accumulators containing certain 

dangerous substances (adapted to technical progress by Commission Directive 

98/101/EC). Further limitations for the marketing and use of certain products 

containing mercury are under consideration. Some Member States, namely Denmark 

and Sweden have initiated a more comprehensive phase-out of mercury in products on 

a national level. A recent Commission Proposal for a Council Directive on the 

restriction of the use of certain hazardous substances in electrical and electronic 

equipment takes a similar orientation for that sector on Community level. The 

requirements under this proposed Directive are to be reviewed by the Commission by 

1 January 2004 to take into account new scientific evidence. 

The regulatory measures and efforts from industry to substitute mercury have led to a 

sharp reduction in the use of this metal and this process of substitution is expected to 

continue. 

Against this background, the study will contribute to a better empirical and scientific 

basis for the future discussions on the possible need for further restrictions on the use 

of mercury. 

4.2. Objectives, tasks, requirements and information 

4.2.1. Objectives 

The aim of the study is to up-date earlier studies (see 4.2.2.) on the risks to health and 

the environment posed by mercury in certain products. All stages of the life cycle 

should be taken into account including e.g. production, formulation, use, and disposal. 

While the study is to focus on present use of mercury in products, it should also 

examine to which extent mercury concentrations measured (particularly in the 

waste-stream) at present are influenced by former uses and non-anthropogenic 

sources. The study should also assess the relative risks from mercury in products 

compared with the other sources of mercury. 

It is mandatory to complete the study within the time period specified under point 1.3. 
Mercury Products - Risks to Health and the Environment 

Page A1-2

4.2.2. Approach and tasks 

The methodology of the study should be based on the Technical Guidance Document 

in support of Commission Regulation (EC) No. 1488/94 on risk assessments of 

existing substances (ISBN 92-827-8011 to 8014), however, taking recent 

developments of methodologies for risk assessment of metals and the particular 

behaviour of mercury in the environment into account. 

Tasks

The study should adapt, up-date and extend an earlier assessment of the risks to health 

and the environment from mercury in certain products1 and use data contained in the 

pertaining study on advantages add drawbacks on marketing and use of certain 

products containing mercury2. In general, it is to be based on recent data in order to 

take account of the potential results of reduced mercury use. The scope of products is 

to be widened to batteries and consider the impact of policy measures taken in that 

field. The geographic area investigated is to include the Poland, the Czech Republic 

and Slovenia to the extent where data are available. 

Particular attention will be paid to the following points: 

• Human toxicity. The evaluation of toxicity to humans should be expanded and 

take recent information into account. 

• Derivation of PEC (Predicted Environmental Concentration) values. The 

derivation of PEC values should be revised with regard to methodology and based 

to the extent possible on monitored data. 

• Derivation of PNEC (Predicted No Effect Concentration) values. The derivation 

of PNEC values should be revised especially with regard to data used, aiming at 

an application of the probabilistic method. 

• Risk characterisation. The risk characterisation should be revised and could be 

further improved by addressing the effects of environmental characteristics of 

mercury toxicity and by the inclusion of PNEC values adapted to the water/soil 

conditions using probabilistic approaches for European water/soil characteristics. 

• The study should also assess the relative risks from mercury currently used in 

products in the European Union as compared with the other sources of mercury

(non-product use, natural, historical,). In this context the study should also discuss 

the potential influence of different use patterns of mercury outside the Union 

(imports via products and transboundary pollution). 

 

 1 Assessment of the Risks to Health and the Environment of Mercury in Certain Products, WS Atkins, 

Final Report, August 1998. 

 2

 Analysis of the Advantages and Drawbacks of Restricting the Marketing and Use of Mercury in 

Certain Products, Environmental Resources Management (ERM), December 1998. 
Risk & Policy Analysts 

ANNEX 2 

LIST OF CONSULTEES 
Mercury Products - Risks to Health and the Environment 
Risk & Policy Analysts 

Page A2-1 

The research team is particularly grateful to the assistance provided by the following 

organisations: 

AB Ardent 

Association of Public Health Dentists (Denmark) 

Asturiana del Zinc 

Austrian Federal Ministry of Environment 

Austrian Medical Association 

Bosch GmbH 

Britannia Zinc 

Bundeszahnärztekammer 

CAL Controls (UK) 

Claushuis Metaalmaatschappij BV (Netherlands) 

Cookson Precious Metals Ltd (UK) 

Danfoss (Denmark) 

Danish Environment Protection Agency 

Department for the Environment, Food & Rural Affairs (UK) 

Dutch Ministry of Housing, Spatial Planning and the Environment 

European Committee of Domestic Equipment Manufacturers (CECED) 

European Lighting Companies Federation 

FDI World Dental Association 

Finnish Dental Association 

French Ministry of Spatial Planning and the Environment 

French National Institute of Research and Safety (INRS) 

Fujitsu Components Europe BV (Netherlands) 

Gascoigne-Melotte (Belgium) 

GE Lighting 

Hella KG Huck & Co (Germany) 

Hellenic Dental Association 

Henry Schein 

HI Instruments (Finland) 

Instituto Superiore di Sanito (Italy) 

International Archery Association 

International Council for Mining & Metals 

International Zinc Association 

Irish Health and Safety Authority 

James Scientific Instruments Ltd (UK) 

Lead Development Association 

Mater Health Trust (Northern Ireland - UK) 

MAYASA 

Medical Devices Agency (UK) 

Mercury Recycling Ltd 

Miele (Germany) 

NHS English Purchase and Supply Agency (UK) 

Odin Research & Development 

Omron Electronics Europe 

Ordem dos Médicos Dentistas (Portugal) 

Osram (Siemens) 
Mercury Products - Risks to Health and the Environment 

Page A2-2

Philips 

Polamp-Warsaw 

Quicks Archery (UK) 

Ragim SrL (Italy) 

RIVM (Netherlands) 

Rota-Dent Ltd (UK) 

Russell Scientific Instruments (UK) 

S Brannan & Sons Ltd 

Southern Dental Industries (SDI) 

Shermond Surgical Supply Ltd (UK) 

Siemens AG 

Société de Médecine Dentaire (Belgium) 

Star Refining plc 

Swedish Environmental Protection Agency 

Swedish Federation of County Councils 

Swedish National Chemicals Inspectorate (KemI) 

Syndicat de al Measur (France) 

Tridonic (Austria) 

UNEP (Global Mercury Assessment) 

Universal Hospital Supplies Ltd (UK) 

Westfalia (Germany) 

In addition, we would like to acknowledge the assistance provided by a number of further 

companies which asked not to be named. 
Risk & Policy Analysts 

ANNEX 3 

LIST OF MERCURY CONTAINING PRODUCTS

Source: Original data presented in Gilkeson J (1996): Mercury Products 

Study, report for the Minnesota Pollution Control Agency dated April 1996 

(and revised August 1998) as reproduced in Land & Water Resources Council 

(1999): Labeling and Collection of Mercury-Added Products, report for 

the Maine Legislature dated January 1999. 

 
Mercury Products - Risks to Health and the Environment 
Risk & Policy Analysts

Page A3-1 

Uses of mercury for its mechanical properties as a high-density, low-friction fluid 

• telescope mirrors 

• Canter Tube: 6’ tube used in medical procedures to trace GI tract 

• Bougie Tube: used in medical procedures for esophageal dilation 

• lighthouse lamp bearing 

• waste water treatment plant pivot arm bearing 

• archery as a bow stabilizer; two models: 6” 8 oz.; 10” 11 oz. (Neutralizer®) 

• DC watt hour meters (no longer made but may still be in use) 

• bubbler or trap used in laboratories to seal reaction vessels for monitoring gas evolution 

• weights and counterweights in grandfather clocks 

Pressure and flow rate measurement and control devices (manometers), tube type and 

well type Note: devices in this category have extensive application in the natural gas industry 

• sphygmomanometers (blood pressure “cuffs”) 

• laboratory manometers (pressure measurement devices) 

• commercial-industrial manometers (many types and uses) 

• dairy barn manometers (tube type, measures milking system vacuum) 

• barometers - atmospheric pressure (well type, climatology and meteorology uses) 

• gas meter pressure safety device (tube device, likely no longer made but in use) 

• permeter - used to measure permeability of sand mass to flow of air (foundry application) 

• air flow measurement devices using a Pitot Tube and manometer (foundry and other 

applications; may also be called an airway controller) 

• mercury diffusion pump (laboratory/educational use) 

Temperature measurement and sensing devices 

• Mercury in glass thermometers, (ASTM and laboratory) 

• cup case (for tank sample temperature testing) 

• tapered bulb thermometers (armored) 

• sling psychrometer (for measuring relative humidity) 

• mason’s hygrometer (stationary, for measuring relative humidity) 

• oven temperature control (home and commercial) 

• candy/deep-fry thermometers (home and commercial) 

• weather measurement thermometers (home, commercial, scientific) 

• minimum/maximum thermometers (home, commercial, scientific) 

• fever thermometers (home, commercial, veterinary) 

• other specialty uses, e.g., Clerget sugar test, blood bank, incubator/water bath, dairy 

• Mercury flame sensor/mercury safety valve (stainless steel bulb, capillary tube, and 

bellows control device) used for ‘unsupervised burners’ in certain gas fired devices with 

standing pilot or electronic ignition pilot , e.g., residential and commercial 0vens/ranges, 

commercial griddle with concealed pilot, unit heaters, some light industrial oven 

applications, furnaces, infrared heaters, ‘cycle pilot’ devices) 

• Mercury thermostat sensors (w/stainless steel capillary tube) (used in gas ovens operating 

up to 750°F (not used in self-cleaning ovens), discontinued in 1970’s. Currently produced 

devices use oil or sodium-potassium mixture.) 

Thermo-electric devices (mercury movement opens and closes an electrical circuit at a 

preset or adjustable set point) 

• thermostats (1, 2 or 4 glass tubes of mercury are used in conjunction with relay control 

device); mercury-thallium models are used for temperatures to neg. 60°C 
Mercury Products - Risks to Health and the Environment 

Page A3-2 

• thermal switch with integral or remote mounted solid state control (similar to a 

thermostat) 

• thermoregulator (an adjustable mercury in glass device with an electrical output 

dependent on the position of the mercury column) 

Electrical properties (switches, relays, sensors) 

• cathode in mercury-cell chloralkali production facilities 

• dropping mercury electrode (DME) technique for polarography and analytical chemistry 

• displacement or plunger relays (generally for high current, high voltage applications, e.g., 

resistance heating, welding, lighting, power supply switching, and industrial process 

controllers 

• wetted reed relays (printed circuit board mount) - primarily used in test, calibration, 

measurement equipment where stable contact resistance over the life of the product is 

necessary. One industry source states that 90% of market is for specialized equipment 

produced in quantities of 10-200 units per year; mass production applications do not need 

mercury-wetted reed relays 

• telecommunications industry switching equipment and boards used in central facilities 

• tilt switches (including SPST, SPDT, NO, NC, wide angle, omni-directional, circuit board 

mount) 

• temperature control (mounted on bimetal coil or attached to bulb device) 

• pressure control (mounted on bourdon tube or on diaphragm) 

• fluid level control (mounted in float, on lever arm, on diaphragm or on plunger) 

• airflow/fan limit controls (mounted to vane in airflow) 

• pneumatic tube communication systems 

• ‘man down’ alarms 

• swimming pool alarms 

• safety shut off 

• steam irons 

• electric space heaters (may have been discontinued by early 1995) 

• outboard motors 

• limit switches for industrial machinery 

• automobile hood, trunk, vanity mirror, glove box, emergency brake lights 

• automobile automatic roll bar 

• automobile ‘ride control’ automatic leveling suspension 

• automobile security systems (tilt and trembler devices) 

• building security systems (tilt and trembler devices) 

• ‘silent’ wall switches, single pole and three-way; identifiable by “top” mark on one 

end of switch (discontinued by GE in 1991; Leviton only other reported 

manufacturers) 

• commercial popcorn poppers 

• film editing equipment 

• greenhouse louver positioning devices 

• washing machine spin cycle shut-off (no longer in production) 

• chest freezer lid light 

• security system applications (including automobile, computer and other applications 

where movement of a ‘momentary contact’ switch triggers an alarm) 

• anti-tamper device in gas meters and pay phones (unable to confirm gas meter 

application with major gas meter manufacturer) 
Risk & Policy Analysts

Page A3-3 

• automatic car washes (Ryko: treadle on/off switch and detection of top brush position) 

• ice fishing tip-up lights 

• fishing lure (manufactured in Canada possibly for tip-ups) 

• lawn tractor/riding mower fuel level indicator 

• electric organs - non-keyboard controls such as tone 

• fire alarm box switch 

• marine auto-pilot 

• level and rotation sensors and controls (automobile, aircraft, and defense applications) 

• laptop computer - screen shutoff when cover closed 

• portable phone mute/privacy switch when phone is in horizontal position 

• cameras (still, video, film); overridable position sensor to protect from sunlight 

damage 

• proximity sensors, magnetically activated, applications unknown 

• g-sensors 

• automobile ABS sensors (used to pulse system and disengage auto 4wd) 

• some older automobile air bag sensors 

• auto seat belt mechanisms (electrically activated inertia lock) 

• security system applications 

• rectifiers, oscillators, phanatrons, thyratrons, ignitrons, excitrons, cathode tubes; inverters 

• switches or relays in some remote reading devices for utility meters, purpose unknown 

Electrical Discharge Properties/Lighting 

• fluorescent lamps: general purpose straight, U-bent, circline, compact high output, 

bilirubin blue, blacklight, “bug-zapper” devices 

• high intensity discharge 

• mercury vapor lamps 

• high pressure sodium lamps 

• metal halide lamps used in automobile headlights (new use, xenon-mercury-halide) 

• ‘CS - compact source mercury lamps’ (photographic, lab uses) 

• ‘Special mercury lamps’ (UV properties) 

• neon lamps (most colors except red, orange, pink) 

• spectral lamps - monochromatic light source for laboratory and research applications 

• cold cathode lamps for illumination 

• germicidal lamps (hot cathode, cold cathode, slimline) 

Electronic Properties/Semiconductors 

• mercury-cadmium telluride semiconductors/infrared sensors Extensive defense and 

satellite uses; no substitute with comparable performance for many applications. One 

researcher estimates annual mercury consumption for this use at 100 pounds. Includes 

photovoltaic and photoconductive cells. 

Medical, pharmaceutical, cosmetic/human contact 

• vaccines and other biologic products 

• homeopathic medications (at least 17 compounds used, many applications) 

• over-the-counter (OTC) nasal sprays (preservative) 

• OTC ophthalmic and contact lens products (preservative) 

• eye-area cosmetics (up to 65 ppm mercury) (preservative) 

• hemorrhoid ointments and creams (preservative, discontinued early 1995) 

• OTC disinfectants: Mercurochrome® [merbromin], tincture of merthiolate 

• merbromin solution used in plastic reconstructive surgery as disinfectant and marker 
Mercury Products - Risks to Health and the Environment 

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• mercuric chloride peritoneal lavage in cancer surgery (Great Britain) 

• skin bleaching creams (OTC discontinued in US by early 1970s) 

• diuretic (mersalyl and salts are still manufactured, extent of use unknown) 

• traditional Chinese medicine (including herbal balls) 

• spiritist use 

• tattoo pigments (discontinued in US, likely in 1970’s) 

Medical and laboratory/no human contact (active ingredient or preservative) 

• tissue fixatives for pathology, histology (e.g., Zanker’s, B5) 

• tissue stains (Harris hematoxylin stain may be mercury-free) 

• Hayem diluting fluid for red blood cell count) contains mercuric chloride 

• reagents for various diagnostic and laboratory tests: 

• arsenic-calcium reagent (260 ppm) 

• Precision reagent (240 ppm) 

• CPK reagent (2.7 ppm) 

• colorimetric chloride analysis (mercuric thiocyanate or mercuric nitrate titration) 

• Nessler’s Reagent/Channing’s Solution (mercury potassium iodide); used for total 

• Kjeldahl nitrogen (no apparent alternate method) and nitrogen ammonia (USEPA 

• accepted/approved). 

• Millon’s Reagent (mercury-nitric acid solution, for albumin) 

• salinity (mercuric nitrate titration) 

• Radiometer (brand) blood gas analyzer reference electrode 

• ESA (brand) Model 3010B Lead Analyzer electrode (used for testing blood lead levels) 

• preservative in various products such as pregnancy test kits and possibly in similar 

diagnostic products 

• thimerosal used as preservative for sucrose buffers in disc electrophoresis 

Veterinary medicine and other veterinary/livestock uses: 

• vaccines for cattle, swine, and dogs 

• other medications: 

• Dip-A-Way (contains merbromin, mfd. by Universal Aquarium System) 

• Wound Control (contains merbromin, mfd. by Universal Aquarium System) 

• RX ICK Control (contains merbromin, mfd. by Wardley Corp.) 

• Aqueous Red Mercury Blister (contains mercuric iodide; mfd by QA Laboratories and 

P.C. Laboratories) 

• Phillips Corona Ointment antiseptic dressing for horses and other animals 

• udder wash with thimerosal - discontinued many years ago 

Pesticides 

• food uses canceled in 1969 and US pesticide registrations canceled by early 1995. Last 

four uses to be canceled were as a turf fungicide, a mildewcide for fresh cut wood, a 

fungicide and preservative in latex paint, and outdoor fabric treatment 

• marine anti-fouling paint (discontinued in 1970’s) 

Pigments (reds and oranges) 

• Used in engineering plastics where high temperature stability is required. Past uses 

included many automotive parts, vinyl, ABS, polycarbonate. The only remaining 

manufacturer is SLMC in France; one US auto manufacturer reports recently 
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discontinuing a mercury containing color concentrate used in plastic component 

manufacturing. 

Catalysts (primarily for urethane and vinyl) 

• polymer curing 

• monomer production 

• acetylene production (probably no longer used) 

• vinyl and anthraquinone production (unconfirmed) 

• Battery electrodes (mercuric oxide battery, mercury-cadmium battery) 

Other uses 

• battery anti-gassing (zinc anode coating in alkaline, carbon zinc batteries) 

• fireworks (no longer used by US manufacturers but may be used elsewhere) 

• Explosives: mercury fulminate, apparently no longer manufactured 

• School laboratory experiments and demonstrations 

Note: this use is prone to mismanagement and release, and generates hazardous 

nonrecyclable waste; chemical principles and phenomena can be demonstrated with less 

toxic or non-toxic substances. 

Amalgamating properties and amalgams 

• dental 

• gold mining/extraction (used in small scale artisanal’ mining, large scale mining 

reportedly uses other chemical or mechanical processes) 

• mirror silvering (discontinued about 1900) 

• gold porcelain paint (availability and use in US unconfirmed) 

• gun cleaning: mercury is poured into the barrel and then removed, reportedly to remove 

lead, copper and brass residues 

Home uses that have resulted in documented mercury poisoning (a sampling) 

• fabrication of fishing sinkers with mercury, lead, copper, and solder (heating) 

• gold smelting (heating) 

• recovery of silver from dental amalgam (heating) 

• recovery of mercury from products such as batteries (heating) 

• use of interior latex paints with high mercury preservative levels 

• vapor exposure from spilled mercury and broken products such as thermometers 

• consumption of treated grain or meat from animals fed treated grain 

• fluorescent lamp breakage/acrodynia in 2 year old (ingestion/inhalation) 

• use of ‘folk’ medicines containing mercury (ingestion/inhalation/dermal contact) 

• use of a beauty cream containing calomel (mercurous chloride) 

Note: mercury poisoning from use of the cream (“Crema de Belleza’ made in Mexico) 

was documented in individuals in California, New Mexico and Texas in 1995 and 1996. 

Total mercury content of the cream was 6 to 8%. 
Mercury Products - Risks to Health and the Environment 

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Risk & Policy Analysts

ANNEX 4 

ANALYSIS OF AQUIRE DATA FOR CONSISTENCY
Mercury Products - Risks to Health and the Environment 
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A4.1 Introduction 

This annex provides a brief description of an analysis of mercuric chloride toxic 

effects data for freshwater and saltwater taxa using data from the USEPA AQUIRE

database. These data are analysed in both the standard TGD fashion, by selecting the 

most sensitive results in three taxonomic groups, and by using the statistical 

extrapolation methodology of Aldenberg & Slob (1993), which is also allowed under 

the TGD. Results based on AQUIRE data are then compared with those presented by 

Eurochlor in two reports from 1999. 

A4.2 Analysis of Data from AQUIRE

A4.2.1 LC50 Data 

AQUIRE was searched for lethal and sublethal data on mercuric chloride. 

1197 data entries were found. These were separated into freshwater and saltwater 

species and the data for each species were consolidated. First, the most sensitive time 

period was found. Then, if more than one result for this time period was available for 

the same species, the geometric mean of these results was calculated. LC50 data (or 

EC50 data for lethality surrogates such as immobility) were available for 141 

freshwater and 64 saltwater species. 

Freshwater Data 

The most sensitive freshwater LC50 data were: 

• algae: Chlorella vulgaris 12-d EC50 of 128 μg/l; 

• invertebrates: Bosmina longirostris (waterflea) 96-h LC50 of 0.55 μg/l. The 

standard European test species Daphnia magna had a 21-d LC50 of 8.06 μg/l; and 

• fish or amphibians: the most sensitive species in the LC50 toxicity distribution 

was the clawed toad Xenopus laevis, with a 7-d LC50 of 0.16 μg/l. The next most 

sensitive species was a fish, the channel catfish, Ictalurus punctatus, with a 4-d 

post-hatch LC50 of 0.3 μg/l. The standard European test species Oncorhynchus 

mykiss (rainbow trout) had a 4-d post hatch LC50 of 0.69 μg/l. 

These data show that crustaceans, amphibians and the early life stages of fish are the 

most sensitive to mercuric chloride lethal toxicity. 

Saltwater Data 

The most sensitive saltwater LC50 data were: 

• algae: No standard European saltwater algal species results were reported on the 

AQUIRE database, but a 96-h EC50 of 4.0 μg/l was reported for the dinoflagellate 

Gonyaulax polyedra;.
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• invertebrates: The mollusc Villorita cyprinoides cochi was the most sensitive 

saltwater species, with a 96-h LC50 of 1.57 μg/l. The standard North American 

mysid shrimp test species, Americamysis bahia, was the next most sensitive, with 

a 35-d LC50 of 1.8 μg/l. A 24-h EC50 of 13 μg/l was found for the Pacific oyster 

Crassostrea gigas, a species often used in European risk assessments; and 

• fish: The most sensitive saltwater fish species found on the AQUIRE database 

was the spot, Leiostomus xanthurus, with a 96-h LC50 of 36 μg/l. 

These data show that invertebrates were the most sensitive species tested. However, 

early life stage tests with fish species are missing, so the relative insensitivity of 

saltwater fish may be an artefact. 

Statistical Extrapolation for LC50 Data 

A logistic distribution fitted the freshwater LC50 toxicity data and the Aldenberg & 

Slob (1993) statistical extrapolation method estimated a median HC5 (Hazardous 

Concentration to 5% of Species) of 3.4 μg/l, with a lower 95% confidence limit (95% 

CL) on the HC5 of 1.8 μg/l. A logistic distribution also fitted the saltwater data well. 

The Aldenberg & Slob (1993) approach produced estimated median HC5 and lower 

95% CL values of 4.7 and 2.5 μg/l respectively. 

A4.2.2 Sublethal Data 

There were far fewer sublethal data available in AQUIRE, and most of these were 

EC50 values for sublethal responses, rather than NOEC or LOEC values. These data 

were treated in the same way as the LC50 data, with the additional criteria that only 

the most sensitive endpoint was selected for each species (e.g., reproduction or 

growth) and results should be reported as mass per litre. Only endpoints of direct 

demographic relevance (i.e., growth and reproduction) were selected for analysis. 

Sublethal data meeting the above criteria were found for 32 different freshwater and 

saltwater species. 

Freshwater Data 

The most sensitive sublethal freshwater data were: 

• algae: a population growth rate LOEC of 5 μg/l for the blue-green alga 

Microcystis aeruginosa; 

• invertebrates: a 21-d reproduction EC50 of 6.7 μg/l for the waterflea Daphnia 

magna; and 

• fish: none found. 

Saltwater Data 

The most sensitive sublethal saltwater data were: 

• algae: a 5-d growth EC50 of 10 μg/l for the diatom Ditylum brightwellii; 
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• invertebrates: an 11-d population change LOEC of 1.65 μg/l for the saltwater 

hydroid Campanularis flexuosa; and 

• fish: a 32-d hatching success EC50 of 37.18 μg/l for the mummichog Fundulus 

heteroclitus. 

These most sensitive chronic data either do not differ substantially from the most 

sensitive acute data, or tend to be slightly higher, which may reflect either a low acute 

to chronic ratio or the paucity of chronic data on the AQUIRE database. There is also 

some confusion in the reporting of the algal data: it is likely that data in both the LC50

and the sublethal categories are from similar types of experiment on population 

growth rate, but have been reported differently on the database. This has no effect on 

an overall analysis of the data. 

Statistical Extrapolation of Sublethal Data 

Because of the relatively low number of data, freshwater and saltwater data were 

analysed together to estimate an HC5 according to the Aldenberg & Slob (1993) 

method. The data fitted a logistic distribution, with a median HC5 value of 1.8 μg/l 

and a lower 95% CL of 0.45 μg/l. 

A4.3 Comparison of Results with Eurochlor 

The results reported above were then compared with those from the Eurochlor reports 

(Eurochlor, 1999 & 1999a). The following points emerge: 

• Eurochlor followed the recommendations of the Technical Guidance Document 

(TGD) and concentrated on ‘chronic’ (i.e., long-term exposure) data. The 

AQUIRE database contained more data on lethal effects than those reported by 

Eurochlor, but fewer useful data on long-term effects; 

• Eurochlor divided mercury compounds into two categories: organic and inorganic, 

while we divided inorganic mercury into specific salts, such as mercuric chloride 

as reported here; and 

• there are some inconsistencies in the use of terminology between the Eurochlor 

report and our analysis. Eurochlor separate tests into LC50/EC50 and 

LOEC/NOEC results. We separated tests into lethal and sublethal results. 

However, in the overall analysis this distinction does not affect any conclusions 

drawn from either of the separate analyses. 

Conclusions on Most Sensitive Test Results for Different Taxonomic Groups 

Comparison of Eurochlor inorganic mercury conclusions and the results of this 

analysis suggest the following: 

• freshwater fish: Eurochlor found that the most sensitive lethality study was a 96-h 

LC50 of 26 μg/l for the guppy, Poecilia reticulata. In our analysis the channel 

catfish, Ictalurus punctatus, with a 4-d post-hatch LC50 of 0.3 μg/l, and 
Mercury Products - Risks to Health and the Environment 

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Oncorhynchus mykiss (rainbow trout) with a 4-d post hatch LC50 of 0.69 μg/l 

showed the most sensitive lethality results. However, the most sensitive 

vertebrate was the clawed toad Xenopus laevis, with a 7-d LC50 of 0.16 μg/l. 

Eurochlor found that the most sensitive chronic result was a 41 week growth and 

reproduction NOEC of 0.5 μg/l for the fathead minnow Pimephales promelas. 

Our analysis did not find any useful chronic freshwater fish data; 

• saltwater fish: Eurochlor found that the most sensitive lethality study was a 96-h 

LC50 of 67 μg/l for the mummichog, Fundulus heteroclitus. In our analysis the 

spot, Leiostomus xanthurus, was the most sensitive, with a 96-h LC50 of 36 μg/l. 

Eurochlor found that the most sensitive chronic study was a 32-d reproduction 

NOEC of 10 μg/l with the mummichog. Our analysis found a 32-d hatching 

success EC50 of 37 μg/l for the same species; 

• freshwater invertebrates: Eurochlor found that the most sensitive lethality value 

was a 96-h LC50 of 1 μg/l for the crustacean Crangonyx pseudogracilis. In our 

analysis, the waterflea Bosmina longirostris was the most sensitive, with a 96-h 

LC50 of 0.55 μg/l. Eurochlor found that the most sensitive chronic result was a 10 

week reproduction NOEC of 0.62 μg/l for the crustacean Hyalella azteca. Our 

analysis found that the most sensitive result was a 21-d reproduction EC50 of 6.7 

μg/l for the waterflea Daphnia magna; 

• saltwater invertebrates: Eurochlor found that the most sensitive lethality study 

was a 96-h LC50 of 10 μg/l with the copepod Acartia tonsa. In our analysis the 

mollusc Villorita cyprinoides cochi was the most sensitive saltwater species, with 

a 96-h LC50 of 1.57 μg/l. The standard North American mysid shrimp test 

species, Americamysis bahia, was the next most sensitive, with a 35-d LC50 of 1.8 

μg/l. Eurochlor found that the most sensitive chronic studies were a 112-d 

reproduction NOEC of 0.25 μg/l with the mollusc Crepidula fornicata and a 44-d 

reproduction NOEC of 0.8 μg/l for the crustacean Americamysis bahia. Our 

analysis found that an 11-d population change LOEC of 1.65 μg/l for the saltwater 

hydroid Campanularis flexuosa was the most sensitive; 

• freshwater algae: Eurochlor found that the most sensitive short-term result was 9 

μg/l for a static 96-h EC50 with Selenastrum capricornutum. In our analysis the 

most sensitive result was a 12-d EC50 of 128 μg/l with Chlorella vulgaris. 

Eurochlor found that the most sensitive longer-term result was an 8-d LOEC of 5 

μg/l with Microcystis aeruginosa. Our analysis agreed with Eurochlor's; and 

• saltwater algae: Eurochlor found that the most sensitive short-term result was a 5-

d EC50 of 10 μg/l for the diatom Ditylum brightwellii. Our analysis found a 96-h 

EC50 of 4.0 μg/l for the dinoflagellate Gonyaulax polyedra. Eurochlor found that 

the most sensitive longer-term results were a 10-d growth NOEC of 0.9 μg/l for 

Fucus serratus and a 13-d growth LOEC of 0.77 μg/l for Isochrysis galbana. Our 

analysis found a 5-d growth EC50 of 10 μg/l for the diatom Ditylum brightwellii. 

Comparison of Results Based Upon a Safety Factor Approach 

Eurochlor uses a safety factor approach to predict a safe concentration for inorganic 

mercury of 0.025 μg/l. This is based upon long-term NOEC data from at least three 

species representing three trophic levels, and a safety factor of 10. The important 
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datum in this set is the 112-d reproduction NOEC of 0.25 μg/l for Crepidula

fornicata, found by Thain (1984 - as reported in Eurochlor, 1999a). 

Using the same approach with data from the AQUIRE database suggests a safe 

concentration for mercuric chloride of 0.165 μg/l based upon an 11-d population 

change LOEC of 1.65 μg/l for the saltwater hydroid Campanularis flexuosa, found by 

Moore & Stebbing (19761

). However, caution must be exercised as this is a 

comparative value for this analysis only. This result is very close to LC50 values of 

0.3 μg/l for channel catfish early life stages, and 0.69 μg/l for rainbow trout early life 

stages. It is also the same as the 7-d LC50 of 0.16 μg/l for the most sensitive 

vertebrate, the clawed toad Xenopus laevis. 

Comparison of Results based upon Aldenberg & Slob Statistical Extrapolation 

Eurochlor (using studies ascribed a validity of 1 or 2) predicted a PNEC of 0.47 μg/l. 

Our comparative analysis (using all freshwater LC50/EC50 data, all saltwater 

LC50/EC50 data, and all ‘chronic’ sublethal data) estimated HC5s (Hazardous 

Concentration to 5% of Species) of 3.4 μg/l (with a lower 95% confidence level (CL) 

of 1.8 μg/l), 4.7 μg/l (lower 95% CL = 2.5 μg/l) and 1.8 μg/l (lower 95% CL = 0.45 

μg/l) respectively. 

As can be seen, the lower 95% CL for the HC5 derived from the chronic data is very 

close to the PNEC estimated by Eurochlor. 

A4.4 Overall Conclusions

The results presented here for mercuric chloride from the AQUIRE database compare 

well with the results Eurochlor found for all inorganic mercury salts. As such, it is 

considered ‘safe’ to use the data provided by Eurochlor (1999a) and INERIS (2000) 

in this analysis. Where additional data are available from other reliable data-bases, 

such as AQUIRE, these will also be used. 

 

 1 Moore MN & Stebbing ARD (1976): The Quantitative Cytochemical Effects of Three Metal Ions on a 

Lysosomal Hydrolase of a Hydroid, J.Mar.Biol.Assoc.U.K Vol 56 pp 995-1005. 
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