EU Commission Light Bulb Ban Review 4: Rik Gheysens

Update 28 November with extracts and comment section   Original post: 25 November

To continue the reaction to the EU proposals as detailed previously, some other voices, as promised.

Belgian researcher Rik Gheysens has a good bilingual website (version in Dutch here) with plenty of documentation, particularly on fluorescent lighting and problems.
Includes an excellent extensive EU Q and A section, with questions put by EU MPs to the Commission also on the light bulb ban in general, and the answers received.

He has in the last week also covered the light bulb ban review in depth with a critical analysis - which in many ways complements the comments made here in the earlier post, in going more deeply into CFL and mercury issues and also LED environmental problems.


As should be seen below, the press release document (pdf, alt copy). If the view looks messy, try clicking on it to reduce the internal page size etc (seems to work differently in different browsers and their various versions).
As always, downloading the document may work better.






Comment

While much focuses on CFLs and mercury - and for the understandable quoted reasons - it is my belief that the Commission and lighting companies are actively moving away from such lighting: The recent Commission proposal, as linked above and in the document itself, hardly mentions CFLs and the LightingEurope (Philips, Osram, GE etc) statement as previously posted also entirely focuses on the "Ledification" of society.

This is likely also borne out by Commissioner Oettinger's statement, as in the document:

Answer given by Mr Oettinger on behalf of the Commission

The regulation is to be reviewed by 2014.
That will be the time to consider how the EU framework for energy saving lighting should be further developed. In the meantime, the Commission would draw the Honourable Member's attention to the fact that, under Directive 2011/65 (2), the mercury content of Compact Fluorescent Lamps (CFL) in the EU was halved as from January 2013 to a maximum of 2.5 mg (compared to 50 milligrams in cell batteries and 500 milligrams in amalgam dental fillings)

Halving the allowable mercury content makes fluorescent lighting still harder to make with acceptable performance for a given price - which perhaps is the intention, moving towards a "de facto" ban, just as with energy usage standards on incandescents, without actually calling it a "ban".
Personally, while understanding the health, environmental and other arguments against fluorescent lighting, I find it a shame to ban any lighting, and I remain (very) unconvinced that the Commission is doing this out of some bleeding-heart-sympathy-for-consumers.
The greater profitability including self-admitted heavy EU subsidisation (see EU proposal) of LED manufacture has the Commission-Manufacturer tandem working nicely again.


The LED section of the document should therefore also be noted.
Again good points, with plenty of new references not used in this blog before.
As for health, environmental and light quality issues with LEDs, also see the preceding posts in this blog, with illustrations and references.

Some slight editing of the below quote:

Light-emitting diodes

- These lights have a continuous spectrum.

- They have a CRI of only 80-85. Nick Farraway, international sales manager at Soraa, wants a CRI of 95 or greater. But he agrees that it will be difficult and at high costs. [http://ledsmagazine.com/features/10/10/10]

- They have a power factor of 0.5 –0.9 for lamps between 5W and 25W.

- They contain rare earth metals.

- They have a very complex manufacture and the disposal needs special measures.

- They have a spectral imbalance within the blue:
The white light of LEDS has generally a blue peak, which makes it unsuitable to use it at evening. Medical research indicates that blue light is very effective in reducing naturally occurring human melatonin levels. The real impact of light depends on three features: color, intensity and duration.
Melatonin secretion is reduced to 50% after:
  - 403 hours of exposure to an monochromatic RED light at 100 lux
  - 66 min to a candle
  - 39 min to a 60W incandescent bulb
  - 15 min to a 58W daylight fluorescent lamp
  - 13 min to a pure white high-output LED
(Angeles Rol de Lama, e.a., Contaminación lumínica y salud: El lado oscuro de la luz, Dpto. Fisiologia, Universidad de Murcia)

- SCENIHR [ed- the European Commission Scientific Committee on Emerging and Newly Identified Health Risks, link] shows the following opinion:
Despite the beneficial effects of light, there is mounting evidence that suggests that ill-timed exposure to light (light-at-night), possibly through circadian rhythm disruption, may be associated with an increased risk of breast cancer and also cause sleep disorders, gastrointestinal, and cardiovascular disorders, and possibly affective states. Importantly, these effects are directly or indirectly due to light itself, without any specific correlation to a given lighting technology.(SCENIHR, 2012, p. 59)We disagree with this last sentence.

- When dimming a LED,some problems may arise.
(More information in Review study, p. 71-72)

- The lifetime of the LEDs depends on the temperature of the junction and the electric current intensity, without forgetting the quality of production and integration. At present, the definition of the lifetime of a LED and the measuring method are not standardized.
(Effets sanitaires des systèmes d’éclairageutilisant des diodes électroluminescentes (LED), Rapport d'expertise collective, Octobre 2010, p. 40)
The heat is "enemy No. 1" of LEDs, more specifically of white LEDs. LED operation at too high a temperature (and therefore high junction temperature of the semiconductor) has a dramatic effect on efficiency but also on other characteristics and performance of LEDs such as the flux, the spectrum (and thus the color), the polarization voltage, and the life. To take advantage of the interesting properties of LED (flux, efficiency, durability, quality of light emitted), integrators must take into account the heat generated by the LED and qualities of this component to evacuate the heat.(Ibid., p. 207)

- High luminance: (i.e. the high brightness density per surface unit emitted by these very small sources.) LEDs are point sources of light that can be aggregated in lighting units to achieve high luminous flux. Because the emission surfaces of LEDs are highly concentrated point sources, the luminance of each individual source produces very high luminance, at least 1 000 times higher (107cd/m2) than that from a traditional lighting source.

- Stroboscopic effect: Depending on their architecture, the electrical power supplied to LED lighting systems can vary, causing fluctuations in the intensity of the light produced that are more or less perceptible to the naked eye.
(Opinion of the French Agency for food, environmental and occupational health & safety in response to the internally-solicited request entitled "Health effects of lighting systems using light-emitting diodes (LEDs)"19 October 2010)

- The number of EU citizens with light-associated skin disorders that would be affected by exposures from CFLs was estimated in the report to be around 250,000. Clearly, the risk for this group of patients is not limited to CFLs, but includes all light sources with significant UV/blue light emissions. The lack of proper data precludes any improvement of the estimate of the size of the affected group.
(SCENIHR, 2012, p. 11) It is a shame that without further knowledge of the effects of LEDs, the precautionary principle is not applied.

- Because the lemon and primrose yellow are extra sensitive to blue and green, it is risky to illuminate some artworks with LEDs due to the high proportion of blue light. LEDs can damage the paintings of great masters!
(Dutch newspaper De Volkskrant, 4 January 2013)

- The luminous efficiency of LEDs was estimated between 4.2 and 14.9%.
[https://en.wikipedia.org/wiki/Luminous_efficacy#Overall_luminous_efficacy]

How Regulations are Wrongly Justified
14 points, referenced:
Includes why the overall society savings aren't there, and even if they were, why alternative policies are better, including alternative policies that target light bulbs.
 

EU: Allow Frosted Halogen Bulbs!

Last update 24 November. Original post 22 November

Earlier posts in this series have dealt with the EU review of the light bulb ban, with the details of the EU proposal concerning the future of halogens in the first post.

Recent very good comments on other websites, which I will expand on shortly, include:
• Rik Gheysens with a special press release (pdf, alt copy). This complements earlier posts here in particularly covering the health and environmental effects relating to CFLs and LEDs.
• The Greenwashing Lamps contribution, again with documentation (pdf, alt copy) including well laid out photographic comparisons of using LEDs compared to Halogens, showing the latter in a much better light, as it were.


Clearly the position of this blog is that restrictions on all lighting and indeed other products should be lifted, which are not connected with danger in their use but simply to reduce energy consumption, itself better achieved in other ways.

But the focus at this time is on halogens:
The initial part of the review process deals with the stage 6 proposed ban on remaining halogen replacement bulbs.
As seen from the posts, it seems likely that at least some halogen lighting will be allowed to continue:
But if so, the type of allowed bulbs should be considered.

Specifically, the ban on frosted (non-clear) halogen and similar energy efficient incandescent bulbs should be lifted.
Frosted (matte, pearl) light bulbs and their more opaque (white, opal, soft-tone) varieties generally go by the name "non-clear" bulbs in legal EU terminology:
In comparison with clear, transparent light bulbs the brightness in lumen output and thereby the energy efficiency varies slightly depending on the luminescence of the coating and its thickness, 5-10% either way.
That is, frosted bulbs can be brighter than clear varieties.

The EU research report itself mentions this, by one of the consultants behind it.

Paul van Tichelen replies that we have to make distinction between clear and frosted equivalent.
A clear lamp is always in the lower lumen output.
The lamps we found with above 800 lumen output were for frosted lamps (higher lumen output than clear lamps).

[Note: "(higher lumen output than clear lamps)" albeit emphasized, is the original quote, it is not a comment addition]
Clear LED lamps as referred to more commonly have lower brightness than clear incandescents in comparison with their respective alternatives, but the overall point remains.

The outsider might therefore be reasonably perplexed why the EU - and the EU as sole worldwide jurisdiction - banned frosted lighting in the first place.

Frosted bulbs are, or were, the dominant form of incandescents desired by consumers, especially in Northern Europe (90% of pre-ban incandescent sales, Philips/Osram data). They spread the light more evenly and reduce the point-source glare of clear bulbs.

As always, the irony of popularity making Commission people happier to ban, for supposed greater savings.
No point in banning what people don't want to buy!
Accordingly, in their memorandum to the original 2009 legislation, the Commission stated that those "who want non-clear lamps can buy CFLs and LEDs", presumably feeling that it would help push people to those lighting types, and ignoring all other aspects of why a particular form of lighting is chosen.

But the case here remains a peculiar one.
At least the bans on regular incandescents (and certain TV sets, washing machines, vacuum cleaners, etc)
are straightforward "legitimate" bans in terms of energy efficiency standards.

The ban on frosted bulbs, in this case halogens, is pure Orwellian social engineering, without justification in itself,
and without comparison in any other countries.
Will that make the European Commission think again, on the grounds of (shock, horror) showing some magnanimity to consumers and their choices?
Is the moon a balloon?




Making a "light connection" to add to the above...





As always, when politicians and their bureaucrat cronies come up with petty pointless bans, people will try and get around them.
Hence, in this case, the famous (infamous) euro-condoms, as thought up by lighting designer Ingo Maurer, and as covered in earlier posts on this blog:

Screwing the EU with a Condom
Screwing the EU with a Condom... again



How Regulations are Wrongly Justified
14 points, referenced:
Includes why the overall society savings aren't there, and even if they were, why alternative policies are better, including alternative policies that target light bulbs.
 

Update on Rik Gheysens CFL study

 
Update on the Update, June 7.... see Kevan comments below




As covered on Send Your Light Bulbs to Washington, following up on the previously mentioned mercury in fluorescent bulbs study

Relating to the post May 17 Research Report: Mercury in Fluorescent Lighting, the author has let us know some recent news on his website
(slight editing of the translation used):

May 2012


Website Test-Aankoop, May 24 2012:
CFLs (in the lab and in the waste collect centers): not always energy saving or environmentally friendly

In the June issue of the periodical "Test-Aankoop/Test-Achats", 13 double shell compact fluorescent lamps with a brightness between 500 and 700 lumen and with an E-27 fitting were investigated.

Some conclusions are:

• A certain model should, according to the packaging, have a lifetime of 8000 hours (= 8 years).
Four of the five test samples were already broken down before they burned 5000 hours.
The only still burning lamp reached at that moment only 70% of its brightness.

• A sample of another model failed already after burning 1800 hours.
" The samples which reached 5000 hours, had lost at that moment more 35% to even 80% of their brightness. Moreover, this lamp could hardly be switched on and off 5000 times."
This lamp can actually no longer be named a 'low-energy light bulb'.

The Belgian newspaper "De Morgen", May 25, 2012:
"CFLs are not always environmentally friendly"

In the June issue of the periodical "Test-Aankoop/Test-Achats", 13 [double shell] CFLs were investigated.

The results are:

• No lamp reached half the full intensity of light within 30 seconds.
"These teething troubles can no longer be justified ", said spokesman Ivo Mechels.

• The lifetime of the lamps does not appear to correspond to the promised lifetime on the packaging. "Six of the thirteen species scored very poorly", said Mechels.

• The collection of broken bulbs is not always as it should.
"They usually end up in an ordinary plastic bin. In places lay broken lamps. That mercury is released in this way, is hardly realized."

Another Belgian newspaper "De Standaard", May 25, 2012, writes: "The CFL is almost dead"

" CFLs are less efficient and ecological than their manufacturers try to make you believe.
And they seem to have lost faith in them themselves."
Ivo Mechels of Test-Aankoop/Test-Achats:
"CFLs are more sparing and last longer than conventional incandescent bulbs.
But they still have teething problems that (no longer) should be allowed.
This is no new technology anymore, so manufacturers can no longer hide (behind that idea)."

According to Stefaan Forment, researcher of the Laboratory of Lighting Technology of Ghent's Catholic College St Lieven, manufacturers seem to believe much more in LED lamps...

Update
Kevan at Savethebulb.org adds, taken from a June 6 post:

CFL fail again!
The Belgian consumer organisation Test-Aankoop/Test-Achats published their report on CFLi [Google translated version] on May 24th. This organisation buy products from retail sources and have undertaken long term tests with rather disappointing but not unexpected results. This is exactly what individual governments in the EU are supposed to be doing to ensure that the products on the market meet the requirements of the Eco Design legislation however seem to be failing at.

The major problem identified was the time to full light output. Of the lamps tested none achieved 20% of full output within 10 second and none achieved 50% of full output within 30 seconds, the test sample included one lamp claiming to be “Quick Start” however its performance was no better than the others.

Life testing proved equally disappointing, one model of lamp with a claimed 8,000 hour life. 4 out of 5 tested lamps failed within 5,000 hours the remaining lamps only producing 70% of its claimed light output at that time. One example of another type tested failed after 1,800 hours others in that batch that were still operating at 5,000 hours only produced between 20% and 65% of initial light output.

Start up speed, life and light output at end of life are included in the requirements of the Ecodesign legislation. We have to ask why are these not being enforced with the same stringency as the ban on sale of incandescent lamps? The lamp industry is clearly losing interest in CFLi with a major push towards LED based lamp replacements that seem likely to deliver much higher profits than CFLi or incandescent judging by the current excessive retail prices for them.

Test-Aankoop/Test-Achats also tested the recycling process by taking dead CFLi lamps to various container recycling sites. In the 34 recycling sites in Belgium that accept hazardous waste they found that the lamps were deposited in general hazardous waste with the staff at the centre left with the problem of separating lamps for processing by Recupel, the company responsible for lamps an Waste electrical and electronic goods. They also found that many fluorescent lamps were being broken and therefore discharging mercury vapour at the container sites with no real precautions being taken to protect workers or visitors to the sites. They reported their findings to Recupel and the Ministry responsible.

Good points by Kevan.
The profit motive for banning simple cheap patent expired bulbs should not be forgotten, and LEDs, as mentioned below, may be even "better" in that regard...



Comment (as in original post)

As seen on Rik Gheysens news page,
it has more information going back in time - as with the EU (Swedish) scandal of unrecycled dumped fluorescent light bulbs end 2011, also covered in a report on the Ceolas.net website.

As for LED lighting being so much better, that is not necessarily so:
RGB types are effectively combinations of pure red green and blue sources, without the smooth light output spectrum of incandescents.
Meanwhile the now popular and generally simpler/cheaper "white LEDs" have additional issues from effectively mimicking the light quality of fluorescents, that is, from bluey (relatively bright) type LED source light hitting phosphorescent wall coating.

More on LED issues here.
And that is of course without going into the not always warranted "great upfront expense for long term savings", for many less often used bulbs.
 

Research Report:Mercury in Fluorescent Lighting

From Send Your Light Bulbs to Washington blog May 17


Research Report: Mercury in Fluorescent Lighting
Continuing on with the recent excellent additions to Howard Brandston's website, http://www.concerninglight.com/commentary.html, it links to an extensive study (alt link) by Rik Gheysens about mercury on fluorescent lighting, the preliminary report now being available, it will have an eventual final version, meanwhile the author welcomes comments to it via the email in the document.

The latest update is available here: http://users.skynet.be/fc298377
Direct document link to the last version, at the time of writing.
It is much the same as on Howard's site, but the below extracts are from the that version:
 

Mercury in Fluorescent Lighting

CONTENTS

1. Impact of mercury exposure on human health
2. Mercury: demand and supply
3. Mercury in fluorescent lighting
4. Does mercury in lighting result in less mercury in the environment compared to traditional light bulbs?
5. UNEP and EU intertwined with private interests
6. Health problems during production phase, use and disposal of fluorescent lighting
7. Ethical consuming and freedom of choice
8. Conclusion


Summary (of each section)

1. Impact of mercury exposure on human health
It is an accepted fact that mercury and methyl mercury in particular are very dangerous to human health. An overview is given of the characteristics of mercury, the health effects and the origin of methyl mercury in fish.

2. Mercury: demand and supply
Some facts are summed up about the reduction of the global primary mercury production, the global consumption, the emission of mercury to the atmosphere, and the average emission in some countries. The chapter ends with a short discussion about actions which have been undertaken to reduce mercury emission in power plants.

3. Mercury in fluorescent lighting
We bring into focus the demand of mercury by the lighting sector. The directive 2002/95/EC has exempted the fluorescent lamps from the requirement for the substitution of mercury.
What is the amount of mercury in fluorescent lamps and in particularly in CFLs?
At this moment, no alternatives for fluorescent tubes and HID lamps are available. But CFLs can be very easily substituted. We ascertain that the most suitable alternative for the CFL is the halogen lamp and the incandescent lamp but in some countries the incandescent lamp has been banned.

4. Does mercury in lighting result in less mercury in the environment compared to traditional light bulbs?
We try to answer the question if the argumentation to justify CFLs in the U.S. and in EU-27 is valid.
We find that today, an average of mercury between 0.006 and 0.009 mg/kWh is emitted during the generation of electricity in EU-27 (instead of 0.016 mg/kWh) and about 0.009 or 0.010 mg/kWh in the U.S. (instead of 0.012 mg/kWh).
Comparing a clear incandescent bulb, a new halogen lamp and a CFL, we find that the new halogen lamp is the best choice and the CFL the worst choice. So, the CFL cannot be justified. Because of these findings, an immediate ban has to be ordered on CFLs. In regions with a low emission of mercury, the net result is that only CFLs are spreading mercury. In regions with a huge emission of mercury, other measures than the distribution of CFLs are needed to reduce the pollution.

5. UNEP and EU intertwined with private interests
UNEP has given undue preference to Philips Lighting and OSRAM AG through the en.lighten iniative. The partnership with UNEP is not only intended to promote CFLs over the whole world but also to develop a road-map for the global phase-out of incandescent bulbs. Under the pressure of CFL manufacturers, the U.S. and the E.U. took measures to ban incandescent lamps. The world has to be freed from the undue obtrusiveness with which some lighting manufacturers are spreading their CFLs. The lobby of the private industry in the decision making in the E.U. must urgently be restrained.

6. Health problems during production phase, use and disposal of fluorescent lighting
Serious health problems are recorded during the production phase of CFLs, in particularly in China, where most CFLs are produced. Research is going on to investigate if ultraviolet and electromagnetic radiation from CFLs is a risk factor for the aggravation of light-sensitive symptoms in some patients. Broken CFLs mean a danger to the health, especially for children.
The measures issued by the governments or institutions of different countries are not univocal.
Not recycled CFLs are a serious problem for the environment and for health.

7. Ethical consuming and freedom of choice
The consumer has the right to acquire the most appropriate product to meet his well-considered demands. The ban on incandescent lamps means a violation of the free market principles. Certain preferences cannot be fulfilled by CFLs.
The Cradle to Cradle principle suggests that every product should have a complete cycle mapped out for each component. This is not the case with CFLs, due to the fact that most of these lamps end up in a landfill and due to the losses during exploitation of mercury, production phase and breakage.
Ethical minded consumers don’t want to buy fluorescent lamps because these lamps do not comply with an ethical production, i.e. with a minimal harm to the natural environment.
This chapter ends with a small test of CFLs. The conclusion is that in the given circumstances, to buy a CFL is somehow to take part in a lottery.

8. Conclusion
The production of CFLs should be banned immediately. We demand an immediate lift of the ban on incandescent lamps and clear notices on the package about the content of mercury and about the dangers intrinsic to fluorescent tubes.
Each habitant should be able to receive data about the emission of fine particles, nitrogen oxides, sulfur dioxide, mercury, etc. in his region. Especially in Europe, a lack of such information is ascertained.



In a nutshell

• Coal fired power plants are by far the largest source of mercury to air.
• A range of widely available, technical and economically feasible practices, technologies, and compliance strategies are available to power plants to meet the emission limits.
• A VITO-study concluded: "(…) even in the worst possible case that a CFL goes to the landfill, during its lifetime it will have saved more mercury emissions from electricity production in coal power plants (compared to the mercury emissions related to the conventional incandescent bulbs’ electricity need) than is contained in the CFL itself, so the overall mercury pollution balance will be positive." (VITO-report 2009)
This mantra, based on outdated figures, is still repeated without further research. Meanwhile, in any developed country or state, emission limits are valid. Nowadays in Europe and in the U.S., all base is lacking to justify the use of CFLs and to ban the incandescent light bulb.
• In other countries with a higher power plant mercury emission, it would witness of malicious pleasure to distribute mercury containing CFLs to tackle the problem of mercury pollution.
One has to deal with the problem of the power plant mercury emission, and one has not to add
a new problem. If one would fully consider the ‘way of mercury’, - the exploitation of mercury mines, the manufacturing and recycling of CFLs inclusive - , then one should discover how noxious this whole process is.
• U.S. EPA must stop to spread wrong information about the mercury pollution in landfills.
Their assertion that CFLs reduce the amount of mercury released in the environment is not correct.
The new halogen lamps and even the incandescent bulbs are better than CFLs, regarding the environmental impacts.
• The E.U. must stop to use the outdated number of mercury pollution by power plants.
With the correct number, they cannot prove that CFLs are better than the halogen and incandescent lamps. The ban on incandescent lamps has to be lifted!
It was a great mistake to design the mercury containing CFLs.

A well researched review,
with an interesting if rather extreme conclusion even for this SYLBTW blog taste ("the production of CFLs should be banned immediately"!).

But a welcome counter to all the usual defence arguments about "other mercury sources" etc being worse, which is always a weak justification at the best of times - to the extent mercury is a problem, wherever found, then 2 wrongs don't make a right.
Not even in Washington!


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The whole document can be read in the frame below.
The author welcomes comments, as seen.