ISA Wins Exemption from Louisiana Neon Phase-out
On July 24, 2012, in response to ISA’s continuing advocacy, the Louisiana Department of Environmental Quality (LDEQ) formally approved the International Sign Association’s request for an exemption from the state’s phase-out for mercury-added neon signs. Prior to this decision, Louisiana statutes called for lowering the maximum dosage per neon tube to only 10mg, a level less than the minimum quantity necessary for proper tube operation. The Louisiana exemption is effective for a two-year period (until July 2014) after which ISA must reapply for extension of its exemption status.
Louisiana is the first member of the Interstate Mercury Education & Reduction Clearinghouse (IMERC) group of states to approve a comprehensive exemption which applies to all companies currently belonging to the ISA Manufacturer’s Designated Industrial Trade Group.
Trade group representation is an option provided by the IMERC states to facilitate broader compliance by industries that manufacture mercury-added products. The ISA group represents members not only in terms of any state exemptions but also for purposes of complying with state notification requirements applicable to all manufacturers of fabricated, mercury-added products.
ISA members may participate in this group by completing and forwarding to ISA a Mercury-Added Product Notification Form available at the following link:
http://www.signs.org/Portals/0/docs/mercury-added_product_notification_form_4-5.pdf
IMERC also requires participating companies to provide estimates of their annual mercury consumption for up to a 5-year period with quantities calculated in bottles or pounds of mercury used. Additionally, participating companies must comply with Louisiana’s product-labeling requirements which may be found in LDEQ OS077, Title 33, Chapter 27, §2713. Labeling of Mercury-Added Products:
http://www.deq.louisiana.gov/portal/portals/0/planning/regs/pdf/OS077finTA.pdf
Product labeling also should indicate the need for mercury-added neon signs to be properly collected and recycled at the end of their usable lifetimes. More information on product labeling requirements is available at the following link:
http://www.newmoa.org/prevention/mercury/imerc/labelinginfo.cfm
While other states have not granted similar exemptions, ISA’s July 2008 mercury exemption filing also provides a basis for certain states to restrict their originally planned mercury phase-outs. In particular, Connecticut and Rhode Island previously opted to limit their proposed phase-outs to the 100mg maximum dosage level acceptable for proper neon tube operation. ISA continues efforts to track the development of state mercury regulations and to engage effectively with state authorities on behalf of the sign industry.
Non-members wishing to participate in the ISA Manufacturer’s Designated Industrial Trade Group should contact Bill Dundas for further information.
