North American Regional Action Plan on Mercury
                     PHASE II

     North American Implementation Task Force on Mercury
                    28 July 1999

                                   WASHINGTON D.C., 20460
                                                                          OFFICE OF
                                                                     PREVENTION, PESTICIDES
                                                                       TOXIC SUBSTANCES
 Dear Stakeholder:

        The US EPA invites you to review the draft of the second phase of the North American
 Regional Action Plan on Mercury (NARAP). This regional action plan stems from activities
 taken under the North American Agreement on Environmental Cooperation between the
 governments of Canada, Mexico, and the US. The action plan represents a mutually agreed upon
 framework for future actions, to be taken by each country either independently, or collaboratively
 under the direction of the Commission for Environmental Cooperation (CEC).

       The Mercury NARAP is being distributed for public/stakeholder review to allow
 interested parties the opportunity to provide guidance on the nature and direction that these three
 countries should proceed in addressing the various mercury issues in North America.  It is
 requested that you provide comments by October 1 8*.  Please return your comments to me via
 E-Mail if possible ( The Mercury NARAP can also be accessed
 electronically on the CEC Internet Home Page at  On the Home Page select
 "CEC Resources and Publications" and then look up the entry for this document under the
 "Regional Action Plans" section.

       If you have any questions please do not hesitate to contact me.  Thank you for your
 assistance in the North American Regional Action Plan on Mercury review process.


Greg R. Susanke
Office of Pollution Prevention and Toxics (7404)
401 M Street S.W. Washington, D.C. 20460

Phone: 202-260-3547
Fax: 202-260-3453

North American Regional Action Plan on Mercury
                     PHASE II

     North American Implementation Task Force on Mercury
                    28 July 1999


 The North American Regional Action Plan (NARAP) on Mercury is one of a number of such
 regional undertakings that stem from the North American Agreement on Environmental
 Cooperation (NAAEC) between the governments of Canada, Mexico and the United States of
 America. As a parallel side agreement to the North American Free Trade Agreement, the
 NAAEC came into force on 1  January 1994 as an overarching framework for environmental
 cooperation. The NAAEC established the Commission for Environmental Cooperation (CEC)
 to "facilitate cooperation on the conservation, protection and enhancement of the
 environment in their territories." The Council (of Ministers) of the Commission agreed to
 Resolution 95-05 on the Sound Management of Chemicals on 13 October 1995, at its second
 regular meeting held in Oaxaca, Mexico. The Resolution established "a working group
 composed of two senior officials selected by each Party whose duties pertain to the regulation
 or management of toxic substances and who shall work with the Commission for
 Environmental Cooperation (CEC) to implement the decisions and commitments set out in
 this Resolution." The Resolution specifically calls for the development of four regional action
 plans for selected persistent and toxic substances as a first priority in the Parties' common
 desire to address national and regional concerns associated with the sound management of
 chemicals. Mercury, as well as DDT, chlordane and PCBs, is one of the four priority
 substances identified by the Parties for action plan development.

 The Council directed the Working Group in its development of the action plans to incorporate
 as appropriate, pollution prevention principles and precautionary approaches in making
 recommendations to reduce risks associated with toxic substances. The Working Group was
 further instructed under Resolution 95-05 to recommend:

     concerted activities to reduce risks presented by toxic chemicals, taking into account
      the entire life cycle of the chemicals; and
     policies, regulatory and nonregulatory measures to identify and minimize exposure to
      toxic chemicals by replacing them with less toxic substitutes and ultimately phasing out
      the chemicals that pose unreasonable and otherwise unmanageable risks to  human
      health  and the environment and those that are toxic, persistent and bioaccumulative
      and whose use  cannot be adequately controlled.

 The action plans developed under Resolution 95-05 reflect a shared commitment by the
 Parties to work cooperatively by building upon international environmental agreements and
 existing policies and laws; by bringing a regional perspective to international initiatives that
 are in place or being negotiated with respect to persistent toxic substances; by promoting
 cooperation with Latin American and Caribbean nations and with countries that have
 territories in the high Arctic; and by encouraging mutually consistent trade and environment
 policies that are conducive to the conservation, protection and enhancement of the
 environment in their territories. At the same time, each action plan is unique and  recognizes
the differentiated responsibilities of each of the countries. The Resolution and the action
 plans also take into account each country's respective natural endowments, climate  and
geographical conditions, and economic, technological and infrastructure capabilities

An important dimension of the action plans is the formation of close working relationships
among the intergovernmental bodies that address persistent and toxic substances in the
three countries. As well, the North American Working Group on the Sound Management of
Chemicals will work closely during the implementation of the plans with another CEC working
group, the North American Working Group on Environmental Enforcement and Compliance

The action plans reflect a long-term commitment to regional action. The sharing and transfer
of information and best practices are seen as important means of enhancing national capacity
for the sound management of chemicals. Other important elements and outcomes of these
cooperative initiatives include collaboration and cooperation in the measurement, monitoring,
modeling, research and assessment of selected persistent and toxic substances in
environmental media. Such cooperation will improve the quality, availability and relevance of
the "environmental information" needed to make informed and  responsible decisions
throughout the implementation of the action plans.

The action plans are also intended to help facilitate the meaningful participation of the public,
including nongovernmental organizations; business and industry; native North Americans;
provincial, state and municipal governments; academia; and technical and policy experts, in
accordance with the spirit of cooperation reflected in the NAAEC and in Council Resolution
95-05 on the Sound Management of Chemicals. Regular public reporting of the progress that
has occurred with respect to each action plan will be important to its eventual success.

 North American Regional Action Plan on Mercury  Phase II
 North American Regional Action Plan on Mercury  Phase II
                               Table of Contents
      Background	               2
      Purpose	    3
      Goals	                  3
      General Ambient Mercury Objective:	        4
      General Mercury Release Objective:	4
      General Mercury Use Objective:	      4
 DEFINITIONS	           6
 ACTIONS	        8
      Action item 1 Management of atmospheric emissions of mercury	8
      Action item 2 Mercury management in processes, operations and products	10
      Action item 3 Mercury waste management approaches	15
      Action item 5 Communication activities	         22
      Action item 6 Implementation and compliance	      24
ANNEXES	    25
      Annex 1:   Major stationary sources	          27
      Annex 2:   Product control measures	   29
APPENDIX 1 Recommendations to the North American Implementation Task Force on
Mercury	                31
      Introduction	                    35
      Use reduction	                     35
      Control/recovery	                         35
      Release characterization (general recommendations)	37
      Release/emission characterization (sector-specific)	         38
      Mercury assessment-research	          41
      Fate and transport	                    42
      Environmental monitoring	                45
      Mercury management	          48
      Communications	                     4
      Recommendations specific to Mexico	         50

North American Regional Action Plan on Mercury  Phase II
North American Regional Action Plan on Mercury  Phase II

 North American Regional Action Plan on Mercury  Phase

 The Parties:
 Acknowledging the direction provided by Resolution 95-05 on the Sound Management
 of Chemicals;

 Recognizing that atmospheric emissions of mercury can be transported by air currents
 across national boundaries;

 Aware that mercury is a neurotoxin which can and has adversely impacted human
 populations and ecosystems within North America and elsewhere;

 Concerned that North Americans who frequently consume fish, especially women of
 childbearing age, may be exposed to dangerous levels of toxic methyl mercury

 Concerned that fetuses and children are more susceptible to harmful effects of
 mercury and its compounds at lower concentrations than adults;

 Noting that there is recent scientific evidence indicating that the viability of some
 predator species is compromised by consumption of mercury-contaminated fish;

 Recognizing that the most effective and efficient means of reducing mercury releases
 may include pollution prevention and control initiatives for emissions of other pollutants;

 Acknowledging that while mercury is a natural constituent of the earth's crust,
 atmospheric emissions of mercury from human activity have increased globally two- to
 five-fold over the last century;

 Aware that deposition of mercury in North America originating elsewhere is not under
 North American control;

 Aware of the need to set an example in the sound management of mercury globally
 given that anthropogenic sources of mercury from other nations contribute to the global
 pool and to deposition of mercury within North America;

 Building  on significant reductions of mercury releases  resulting from initiatives already
 underway in North America; and

 Determined to implement the NARAP on Mercury;


 undertake actions aimed at reducing mercury releases from human activities with the
goal of approaching naturally occurring levels in North America.
                                                                  28 July 1999

 North American Regional Action Plan on Mercury  Phase II


 The North American Implementation Task Force on Mercury, in the fall of 1997,
 submitted to the CEC Council for approval an overarching Phase I action plan to
 proceed with preliminary implementation of actions based on the following objectives:

       a) reduce mercury levels in and fluxes among, selected indicative environmental
         media in order to approach natural levels and fluxes and;

       b) target for reduction, through life cycle management approaches, the sources
         of anthropogenic mercury pollution.

 Recognizing the concerns expressed by stakeholders related to the general nature of
 the Phase I Mercury Action Plan, the Parties directed the Task Force on Mercury to be
 reconstituted as an Implementation Committee and agreed to develop the Phase II
 amendment to the initial plan.

 This Phase II North American Regional Action Plan on Mercury represents the
 considered recommendations of many contributors to three major workshops, and is
 fully supported by the Council of Ministers.


Phase II of the North American Regional Action Plan (NARAP) on Mercury fully
endorses the ultimate goals and overarching objectives of the first phase of the plan,
approved in October 1997, while providing additional guidance in the form of specific
goals, objectives and actions.

This NARAP on Mercury, in providing a strategic framework for action on mercury within
North America, does not preclude individual countries from taking action beyond what is
set forth herein, including development of national targets and timelines for reducing
and eliminating anthropogenic sources of mercury among sectors that utilize mercury in
products and processes or which generate mercury as a byproduct of a process. As
well, the Parties have committed, in this plan, to develop country-specific
implementation plans one year after signature. The country implementation  plans will
elaborate upon how and when each nation, in accordance with its unique regulatory
framework and capacity, will implement the actions  noted herein.

The Task Force for this NARAP on mercury is composed of government
representatives of the three Parties and participant observers representing industry,
environmental non-governmental organizations and academia.
                                                                    28 July 1999

 North American Regional Action Plan on Mercury  Phase II

 In developing this Action Plan, the Task Force made considerable use of
 recommendations received, during three 1998 CEC workshops, from participants,
 including representatives of governments, industry, environmental, healthcare and other
 interest groups, and North American scientists with expertise in mercury. These
 recommendations are noted in Appendix 1 of this plan.

 This document is a framework for action and does not preclude Parties, individually or
 collaboratively, from setting their own cooperative targets and timelines.


 The purpose of the North American Regional Action Plan (NARAP) on Mercury is to
 provide the governments of Canada, Mexico and the United States with  a path forward
 in their joint and differentiated efforts to reduce the exposure of North American
 ecosystems, fish and wildlife, and especially humans, to mercury through the
 prevention and reduction of anthropogenic releases of mercury to the North American


 The ultimate goal of the North American Regional Action Plans on  Mercury is to achieve
 a reduction in the anthropogenic releases of mercury to the North American
 environment through appropriate national and international initiatives, to amounts that
 can be attributed to naturally occurring  levels and fluxes. The Parties intend to attain
this goal by seeking to:

     reduce mercury releases from specific human activities. This includes, but is not
      limited to, reductions of mercury releases from combustion  sources, commercial
      processes, operations, products and waste streams;

     develop an enhanced capacity to measure and manage mercury,  assess its
      impacts7 and communicate concerns and successes;

     establish an equitable implementation and  compliance protocol; and

     promote continued appropriate and responsible mercury management initiatives
     on behalf of the governments, the industries and the citizens of North America
     This goal will be attained through:
     - recognition of the benefits of both regulatory and nonregulatory mercury
        management options;
     - recognition of the need for stewardship and extended responsibility of
        producers who use mercury or generate releases of mercury; and
     - meaningful participation of the public in  overseeing  and furthering the
        development of an sound management program for mercury.
                                                                   28 July 1999

 North American Regional Action Plan on Mercury  Phase II


 In keeping with the objectives specified in the original North American Regional Action
 Plan on Mercury, of October 1997, the Parties re-state their commitment to achieve the

 General Ambient Mercury Objective:
      Reduce mercury levels in, and fluxes among, selected indicative environmental
      media in order to approach natural levels and fluxes, thereby preventing or
      minimizing exposure of North American ecosystems, fish and wildlife, and
      humans to levels in excess of those that can be attributed to naturally occurring
      levels and fluxes of mercury in environmental media.

 General Mercury Release Objective:
      Recognizing that mercury is a naturally occurring element that can never be
      eliminated from the environment, reduce, or, when warranted, target for
      reduction through a life cycle management approach, the sources of
      anthropogenic mercury pollution so as to achieve naturally occurring levels.

This Phase II amendment to the original action plan also recognizes the requirement to
prevent or minimize releases of mercury used in commerce within the North American
economy and adds the following:

General Mercury Use Objective:
      Reaffirming the direction  provided  in  Resolution 95-05, consider initiatives such
      as promotion and use of products and technologies that pose less risk than
      those used at present. Facilitate product stewardship, product labeling, extended
      producer responsibility, use limitations, economic incentives, recycling, and,
      where there is an unreasonable or otherwise unmanageable risk of release to
      the environment or risk to human health, phase-out or ban specific mercury
                                                                    28 July 1999

 North American Regional Action Plan on Mercury  Phase
                            COMMON ACRONYMS
 CEC: Commission for Environmental Cooperation. The Commission is a trinational
 organization established under the North American Agreement on Environmental
 Cooperation to "facilitate cooperation on the conservation, protection and enhancement
 of the environment in their territories." Its members are Canada, Mexico and the United

 NAAEC: North American Agreement on Environmental Cooperation. This Agreement
 commits Canada, Mexico and the United States to effective enforcement of their
 environmental laws, to publicly report on the state of the environment within North
 America and to other actions aimed at protection and preservation of the environment.
 It came  into force on 1 January 1994, at the same time as the North American Free
 Trade Agreement (NAFTA).

 NAFTA: North American Free Trade Agreement. This a trinational accord between
 Canada, Mexico and the United States to establish a free trade area by eliminating
 trade barriers, promoting fair competition and increasing investment opportunities.

 NARAP: North American Regional Action Plan. The development of various NARAPs is
 mandated under Council Resolution 95-05 for the Sound Management of Chemicals of
the Commission for Environmental Cooperation.

SMOC: Sound Management of Chemicals  Working Group. This working group was
established under Council Resolution 95-05 of the Commission for Environmental
Cooperation. The SMOC Working Group is composed of six senior officials, two from
each Party, whose duties pertain to the regulation or management of toxic substances
identified by the Parties for trinational action within North America.
                                                                 28 July 1999

 North American Regional Action Plan on Mercury  Phase II

 Annex. Any of the annexes attached to and forming an integral part of this NARAP.

 Appendix. Any of the appendices attached to this NARAP and not integral to it.

 Anthropogenic releases of mercury. Mercury discharged or released to air, water or
 land as a result of human activities.

 Best practices. Describe regulatory, nonregulatory and voluntary efforts, including
 policies, programs, technologies, and other measures that have been found to be cost-
 effective and environmentally appropriate. Best practices encompass and build upon
 measures that are embodied within7 local, national and international initiatives.

 Capacity building. Refers to the development and re-enforcement of the different
 elements required to improve and sustain the ability of governments and stakeholders
 to facilitate the advancement of the SMOG (Sound Management of Chemicals)
 obligations and commitments, particularly in promoting the North American Regional
 Action Plans (NARAPs). This may include any process leading to the enhancement or
 strengthening of a knowledge or skill base through the transfer, reciprocation or
 exchange of information between organizations or Parties.

 Council (of Ministers). The governing council of the Commission for Environmental
 Cooperation. The  Council is composed of cabinet-level or equivalent representatives of
 the three CEC Parties.

 Emission. A release to the atmosphere from a point or nonpoint source to the receiving

 Emission offsets. An emission reduction technique whereby selected anthropogenic
 activities with appropriate mercury controls in place be required to counterbalance
 remaining emissions by the reduction of the same, or greater, quantity of mercury from
 within the existing  North American source pool.  Such removals from the North
 American source pool must continue year to year as long as the emissions continue.

 Flux. The rate of transfer of mercury and mercury compounds across  all environmental

 Global atmospheric pool. The amount of mercury vapor suspended in the
troposphere at any given time.

 Regulatory jurisdictions. Those levels of government within the borders of Canada,
Mexico and the United States that have responsibility for promulgating legislation and
enforcing regulations therein.

                                       6                           28 July 1999

 North American Regional Action Plan on Mercury  Phase II
 Life cycle management. Refers to both process and product management and their
 associated risks based on assessments of all stages in the cycle of initial mercury
 production and product manufacturing through to final disposal.

 Major stationary source. Any fixed building, structure, facility, installation, or
 equipment that emits or may emit mercury directly or indirectly into the environment and
 which meet the criteria described in Annex 1.

 Mercury. Refers to both elemental mercury and any mercury compounds, including

 Neurotoxin. A substance poisonous to nerve cells.

 New mercury. Mercury produced from any mineral, mining, or processing activities not
 previously generated as a result of human activities.

 North American Working Group on the Sound Management of Chemicals. See
 SMOC under Common Acronyms.

 Parties. The governments of Canada, Mexico and the United States.

 Precautionary principle/approach. Principle 15 of the 1992 Rio Declaration, which
 states: In order to protect the environment, the precautionary approach shall be widely
 applied by States according to their capabilities. Where there are threats of serious or
 irreversible damage, lack of full scientific evidence shall not be used as a reason for
 postponing cost-effective measures to prevent environmental degradation.

 Region. North America (Canada, Mexico and the United States) unless otherwise

 Risk. The potential for a chemical or physical agent to cause adverse effects on the
 environment or human health.

 Task Force. The North American Implementation Task Force on Mercury, directed by
the North American Working Group for the Sound Management of Chemicals  formed
to develop and implement this action plan.

Virtual elimination of mercury. Reduction, through a life cycle management
approach,  of sources of anthropogenic mercury pollution so as to approach naturally-
occurring levels and fluxes of mercury in environmental media.
                                                                   28 July 1999

 North American Regional Action Plan on Mercury  Phase II


 The Parties acknowledge that anthropogenic releases of mercury to North American
 and global environmental media pose risks to human health and the environment. The
 Parties seek to reduce these risks by reducing exposure to mercury, based on the
 following risk-management approaches.

                                 Action item 1
               Management of atmospheric emissions of mercury

 The Parties will adopt policies and programs to enhance North American capacity
 aimed at controlling and minimizing atmospheric emissions of mercury from
 anthropogenic sources with the goal of effectively and efficiently reducing these
 emissions to naturally occurring  levels and fluxes.

Action item 1a     Guidelines/Regulations for maior stationary emissions sources

 Recognizing the need to promote the development and use of regulatory and voluntary
initiatives to minimize anthropogenic atmospheric emissions of mercury from major
stationary sources noted  in Annex 1, the  Parties will:

      i)     endeavor to attain  a 50 percent reduction nationally in mercury emissions
            by the year  2006 from existing major stationary sources based on 1990 or
            equivalent emissions inventories. This cumulative target  represents a
            minimum aggregate level of reductions that may be achieved most cost-
            effectively through  application of differential levels of control on emission

      ii)     implement, with due consideration of national interests and capacities, by
            no later than 2005, the most appropriate recommendations in Action Item
            1a iii below or an alternate maximum achievable atmospheric emission
            reduction technology or strategy, which is at least as effective for new
            major stationary emission sources noted in Annex 1.

     iii)     direct the North American Working Group on the Sound Management of
            Chemicals to collaborate with other regional jurisdictions  in North America
            regarding their relevant mercury management programs. The objective
           will be to evaluate and prepare appropriate recommendations for the
           adoption of the most efficient/effective atmospheric emission reduction
           protocols available  throughout North America. The North American
           Working Group on the Sound Management of Chemicals will ensure that
           recommended control technologies for mercury also promote significant
           reductions of a range of other pollutants, such as organics, acid gases
           and  particulates.
                                                                   28 July 1999

North American Regional Action Plan on Mercury  Phase
Action item 1b     Industrial/commercial and other atmospheric emission sources

Recognizing that appropriate management techniques will, over time, reduce
atmospheric emissions from major contributing sources and thus that lesser
anthropogenic sources will proportionally assume greater prominence, the Parties direct
the North American Working Group on the Sound Management of Chemicals to:

      i)     develop uniform data collection and reporting protocols to determine the
            significance of atmospheric mercury emissions from other regional
            sources. Some of the sources may include, but are not limited to, motor
            vehicle emissions, electronic assembly facilities,  residential wood burning,
            petroleum and natural gas extraction and processing, landfill
            leachate/gases, iron and steel processing, steel scrap recycling, smelting,
            mining/taconite production, device manufacturing and crematoriums.
                                                                   28 July 1999

 North American Regional Action Plan on Mercury  Phase II

                                 Action item 2
          Mercury management in processes, operations and products

 The Parties will promote policies and programs to reduce and, where warranted,
 eliminate mercury in processes, operations and products where there is a likelihood of
 releases throughout their life cycle.

 Action item 2a	Life cycle management practices for mercury

 Recognizing the need to promote the development and use of voluntary, nonregulatory,
 and regulatory initiatives to minimize anthropogenic releases of mercury to the
 environment, the Parties will:

      i)     review and assess the adequacy of existing methodologies and processes
            for tracking imports and exports of mercury designated for manufacture or
            use in processes and products, with the goal of stimulating life cycle
            management practices at the national level;

      ii)    further stimulate life cycle management practices within their various
            regulatory jurisdictions by developing a North American protocol for
            reporting a comprehensive inventory of the amounts of mercury being
            introduced, used, stored, lost and replenished  in  product manufacture and
            processing facilities; and,

taking into account the risk of release to the environment, the Parties will:

      iii)    support programs and consider incentives to encourage the substitution or
            phase-out of mercury use in products or processes. Substitutes should be
            cost effective and must pose less risk throughout the life cycle than the
            original mercury-containing product or processes; and

      iv)    where no substitutes to the use of mercury are available, promote the use
            of recycled or recovered mercury, including free movement of this mercury
            in trade.
                                       10                            28 July 1999

 North American Regional Action Plan on Mercury  Phase II

 Action item 2b	Automotive vehicle and equipment manufacturing sector

 Recognizing that the automotive vehicle and equipment manufacturing sector in North
 America has acknowledged the need to address anthropogenic sources of mercury and
 is currently engaged in mercury management efforts, the Parties will:

       i)     encourage the automotive vehicle and equipment manufacturing sector to
            adopt best practices across North America, in a manner consistent with
            the Society for Automotive Engineers International's Technical Paper
            Series 960409;

       ii)    encourage the automotive vehicle and equipment manufacturing sector to
            extend best practices mentioned in Action item 2a to vehicles imported
            into North America under the auspices of the International Automobile
            Manufacturing Association;

       iii)    work in partnership with the automotive vehicle and equipment
            manufacturing sector to develop, where warranted, substitutes for
            mercury. Where substitution is not possible, develop and implement a
            voluntary identification system (i.e., labeling, color coding) for automotive
            devices containing mercury; and

      iv)    work in partnership with the automotive vehicle and equipment
            manufacturing sector to assist in the removal of mercury-containing
            devices prior to scrapping or recycling operations by developing an
            outreach program targeted at scrapping and recycling operators that will
            improve awareness and provide assistance in identifying and removing
            mercury-containing devices on existing vehicles.

Action item 2c       Mercury cell chlor-alkali sector

Noting that the mercury cell chlor-alkali sector recognizes its role as a significant
contributor of mercury emissions and that sector members of the Chlorine Institute have
made important voluntary commitments to reduce such use, the Parties will:

      i)     monitor the industry-developed voluntary program to reduce mercury
            usage  in the mercury cell chlor-alkali industry by 50 percent to 80 tonnes,
            as defined by the Chlorine Institute, by the year 2005;

      ii)     collaborate to ensure that any new chlor-alkali facilities constructed after
            the year 2000 meet the limit value of 0.01 g Hg/tonne chlorine production
            capacity, or, where warranted, ban the mercury-cell process. This limit
            value effectively eliminates chlor-alkali production by the mercury cell
            process but leaves other production technologies as possible process
            options; and
                                       11                             28 July 1999

North American Regional Action Plan on Mercury  Phase
      iii)    direct the North American Working Group on the Sound Management of
            Chemicals to develop comparable guidelines for the decommissioning of
            mercury cell chlor-alkali sites, in a manner that respects the different
            economic, political and regulatory circumstances of the Parties.

Action item 2d	Dry cell battery manufacturing sector

Recognizing that most North American manufacturers of dry cell batteries have
effectively eliminated intentionally introduced mercury, the Parties will:

      i)     ensure, as a minimum, that the product control measures specified in
            Annex 2 for alkaline manganese batteries are applied to all manufacturers
            in North America, and will consider options for ensuring that similar
            batteries imported into North America meet the same or more stringent
            control values;

      ii)     ensure, through a standardized and uniform sampling and analysis
            protocol, that levels of mercury content in dry cell batteries imported to the
            NAFTA region do not exceed levels of mercury content agreed to by the
            Parties for the NAFTA region; and

      iii)    consider incentive programs, in cooperation with their various regulatory
            jurisdictions and industry, to encourage the development of technologies
            to find alternatives for mercury-containing dry cells, particularly mercury
            button cells.

Action item 2e	Electrical switches and relays sector

Recognizing that substantial reductions in mercury emissions may be achieved through
pollution prevention programs, including product stewardship and mercury substitution,
and that energy savings can be realized through upgrading to programmable electronic
devices, the Parties will:

      i)     encourage the substitution/replacement of mercury-containing electrical
            devices, such as switches, relays and thermostats, with non-mercury-
            containing devices through voluntary programs and partnerships with
            manufacturers and users;

      ii)     collaborate by cooperating in the development of a public awareness
            program and encouraging the establishment of recovery and recycling
            initiatives within their various regulatory jurisdictions;

      iii)    work in partnership with the electrical switches and relays sector to
            develop and implement a voluntary identification system (i.e., labeling,
                                       12                            28 July 1999

 North American Regional Action Plan on Mercury  Phase II

             color coding) for mercury-containing electrical devices, to assist in the
             removal of these devices prior to replacement or substitution;

       iv)     encourage the establishment of electrical products collection and recovery
             programs consistent with Action item 3 (Mercury waste management

 Action item 2f	Lamp manufacturing sector

 Recognizing that mercury in lamps (i.e., fluorescent, high-intensity discharge and neon)
 represents a significant contribution to North American mercury-in-use inventories and
 may be released to the environment through improper life cycle management, the
 Parties will:

     i)      take actions to promote use of high efficiency low-mercury lamps;

     ii)      work in partnership with lamp manufacturers to develop a common
            standard for the maximum mercury concentration in lamps manufactured
            in North America;

    iii)      assess and develop management options for other mercury containing
            lamps, such as specialty lamps and lamps used in "neon" signs; and

    iv)      encourage sound life cycle management, including the removal and
            recycling of mercury from waste lamps, and the disposal of these lamps in
            a manner that precludes release to the environment.

Action item 2q     Health and dental care sectors

Recognizing that the provision of health and dental care to North Americans should
include adoption of pollution-prevention measures by the institutions and professionals
that provide such care, the Parties will:

      i)     cooperate with their various regulatory jurisdictions and the health care
            sector in developing programs to encourage further development of
            mercury alternatives and establish programs to reduce, and, when
            warranted, eliminate mercury use in this sector;

      ii)     collaborate in the development of a trinational strategy for achieving the
            goal of virtual elimination of mercury-containing waste from the health
            care sector waste stream by 2005T; and
                                       13                            28 July 1999

North American Regional Action Plan on Mercury  Phase II

      iii)     promote advocacy programs within the dental care sector to promote
             advocacy programs within the dental care sector to minimize emissions to
             air and water from mercury used in dental processes

Action item 2h	Cultural and artisanat uses

Aware that certain members of North American society consider mercury to be a
symbol of health and prosperity but may be unaware of the potential health hazards of
exposure to mercury, the Parties will:

      i)      assist their various regulatory jurisdictions to identify populations whose
             cultural and artisanal practices involve the use of mercury and will assist
             with educational programs to raise awareness among these  populations
             of the hazards of mercury exposure; and

      ii)     consider voluntary, regulatory or other management options  to eliminate
             uses of mercury in cultural and artisanal settings, such as apparel, jewelry
             and children's games.

Action item 2i	Analytical, testing, measurement and calibration sector

Recognizing that various testing and calibration facilities and equipment, educational
centers and laboratories may have stores of mercury or mercury-containing devices
and reagents, the Parties will:

      i)  promote the establishment of initiatives to ensure that persons handling
         mercury are adequately trained to minimize their exposure and eliminate
         release to the environment;

      ii)  implement programs, in facilities for which they are directly responsible, to
         assess the feasibility  of replacement of mercury or mercury-containing
         devices and reagents with non-mercury containing alternatives,  and initiate
         subsequent recommendations where appropriate alternatives are indicated;

      ii)  encourage similar programs, as described above, at facilities for which the
         Parties are not directly responsible; and

      iii) assist with the development of programs to inventory stores of mercury or
         mercury-containing devices and reagents in this sector, including such uses
         as dairy manometers, gas pipeline pressure manometers and sewage
         treatment trickling-filter plants, and recommend alternatives.
                                       14                            28 July 1999

 North American Regional Action Plan on Mercury  Phase II
                                Action item 3
                    Mercury waste management approaches

The Parties agree that mercury-containing wastes are generated from combustion and
industrial processes, pollution control operations and from disposal of mercury-
containing products in quantities sufficient to warrant the development of mercury waste
management programs.

Action Item 3a	Wastes from combustion and industrial processes and pollution
                  control operations

Recognizing  that the management of mercury-containing wastes is an integral part of
the life cycle  management of the materials combusted or treated, and that quantities of
mercury stocks may be generated as a consequence of this action plan, the Parties will:

      i)     encourage the development of waste-management programs to address
            the storage, handling, processing and disposal of wastes from combustion
            and industrial processes and pollution-control operations in order to
            minimize or eliminate mercury emissions to the environment;

      ii)     encourage the treatment of wastes from combustion and industrial
            processes and pollution-control operations to recover, stabilize, or retire
            mercury in the waste where there is a risk of mercury being released to
            the environment through any subsequent waste storage, transfer or
            disposal operation;

      iii)     encourage the maintenance of waste-management records from
            combustion and industrial processes and pollution-control operations as
            described in Action item 6 (Implementation and Compliance), to enable
            public disclosure of the operations' waste-management practices; and

      iv)     direct the North American Working Group on the Sound  Management of
            Chemicals to  undertake a review of national programs to determine the
            adequacy of national reporting mechanisms used to track the ultimate fate
            of mercury-containing wastes within North America, particularly waste
            transported across national boundaries for storage, handling, processing,
            disposal or long-term containment, and to make recommendations to
            improve such  mechanisms. .
                                     15                           28 July 1999

 North American Regional Action Plan on Mercury  Phase II

 Action item 3b	Incinerator waste streams

 Recognizing  that it is technically difficult to remove mercury from combustion source
 emissions, the Parties will:

       I)     collaborate with their various regulatory jurisdictions in the coordination of
             pollution prevention programs outlining the hazards of mercury and
             suggesting methods to reduce risks through source separation programs
             and other public involvement initiatives; and

       ii)     develop waste management policies and programs within their regulatory
             jurisdictions to ensure that, to the degree possible, mercury is separated
             and segregated from waste streams prior to incineration.
Action item 3c	Wastewater treatment

Recognizing that wastewater treatment facilities, by the nature of their operation,
accumulate mercury in both wastewater and sludge that may become bioavailable or be
emitted when discharged, applied to land or incinerated, the Parties will:

       i)    develop pollution-prevention policies and programs within their regulatory
            jurisdictions aimed at reducing the amount of mercury entering
            wastewater treatment facilities;

       ii)    initiate protocols for identifying, analyzing and reducing these sources of
            mercury to wastewater treatment facilities; and

       ii)    encourage the development of appropriate management techniques to
            reduce the release of mercury from sludges or effluents from wastewater
            treatment facilities.
Action item 3d      Mercury waste collection and handling

Recognizing that the collection of mercury is essential to controlling its release, and that
proper handling of mercury-containing wastes is needed to prevent accidental releases
of mercury, the Parties will:

      i)     encourage sectors noted in this action plan to develop product
            stewardship programs for the collection, recovery, recycling and
            retirement of mercury in mercury-containing products;

      ii)     assist their various regulatory jurisdictions with the establishment of
            mercury collection depots and incentives to encourage the collection,

                                        16                             28 July 1999

 North American Regional Action Plan on Mercury  Phase II

             recovery and recycling or retirement of holdings of mercury; and

       iii)     encourage mercury education and collection programs including proper
             cleaning, handling, replacing or storing procedures for all mercury-
             containing devices and equipment.

 Action item 3e      Mercury retirement program

 Recognizing that North American anthropogenic activities contribute to the increasing
 global burden of mercury and that there is a need to consider options for removal and
 permanent disposal of mercury from contributing sources and stockpiles so that it is no
 longer available to the global pool, the Parties will:

      i)      encourage development and  use of effective mercury waste-stabilization
             and disposal techniques and  methods;

      ii)     promote emissions offsets whereby new or modified sources of mercury
             emissions are encouraged to remove an equivalent, or greater, amount of
             mercury from the North American pool;

      iii)    direct the North American Working Group on the Sound Management of
            Chemicals to evaluate and assess the technical and socio-economic
            feasibility of consolidating and permanently retiring quantities of mercury
            removed from commerce.

Action item 3f	Continuation of reduction measures

Understanding that the application of the proposed action items is essential to the
continued reduction of anthropogenic inputs of mercury to the environment, the Parties
will make financial and scientific resources available to further promote reductions of
anthropogenic mercury to the environment with the goal of ultimately approaching
naturally occurring levels.

Specifically, the Parties will:

      i)     promote the development of research into new reduction technologies-

      ii)     promote incentives to encourage adoption of emerging technologies for
            release reductions.
                                       17                            28 July 1999

 North American Regional Action Plan on Mercury  Phase II

                               Action item 4
     Research, monitoring, modeling, assessment and inventories

 The Parties have agreed that there is a need to develop and refine a collective North
 American capacity and capability to assess ambient levels, exposure and toxicity of
 mercury to minimize human health and ecosystem effects through appropriate
 research, monitoring,  modeling, assessment and inventory programs.

 Action item 4a      Development of consistent/comparable data

 Recognizing the importance of having and sharing comparable data and information on
 mercury and recognizing the critical importance of developing the trinational capacity to
 generate, share and use such data and information, the Parties direct the North
 American Working Group on the Sound Management of Chemicals to:

      i)     improve the comparability, precision, availability, reporting and quantity of
            data on mercury through increased trinational cooperation in the planning,
            collection, use and assessment of data on mercury releases to the
            environment, its atmospheric deposition, its ambient levels in
            environmental media, and the exposure of, and risks to,  humans, fish and

      ii)     initiate a trinational quality assurance/quality control program to produce
            comparable and mutually acceptable analytical measurements of mercury
            in samples of environmental media.

Action item 4b      North American Mercury Monitoring Network

Aware that adequate long-term monitoring is important for the development of
scientifically sound information to guide policies and programs aimed at reducing levels
and fluxes of mercury in the environment, the Parties direct the North American
Working Group on the Sound Management of Chemicals to:

      i)      coordinate the planning, development and implementation of a North
            American Regional Action Plan on Monitoring that includes mercury in
            support of the Sound  Management of Chemicals initiative.
                                      18                           28 July 1999

 North American Regional Action Plan on Mercury  Phase II

 Action item 4c      North American Mercury Research Program

 Recognizing that well planned and coordinated research can contribute substantially to
 improved understanding of the impacts of mercury on human health and the
 environment and to the collective capacity of Canada, Mexico and the United States to
 develop and implement policies and programs to prevent and minimize the exposure of
 North American ecosystems, fish and wildlife, and humans to mercury, the Parties
 direct the North American Working Group on the Sound Management of Chemicals to:

       i)     work with the Commission for Environmental Cooperation and others, as
            appropriate, to promote collaborative mercury research programs to
            increase our understanding of bio-geochemical cycling, speciation,
            bioavailability, exposure pathways, environmental fate and transport, toxic
            effects, and risks to wildlife and humans, and, in particular, susceptible

       ii)    assess:

            a) the relative contributions of natural and anthropogenic inputs to the
               global atmospheric pool and fluxes of mercury;
            b) differences, if any, in the relative toxicity and bioavailability of the
               various forms and compounds of mercury to receptor ecosystems;
            c) the impact of atmospheric dynamics (e.g., ozone depletion,
               acidification, and global warming) on characterization of mercury
               speciation and reactions; and
            d) releases of mercury from contaminated soils and sediments and the
               need to control such releases;

      iii)    develop more cost-effective approaches for reducing releases of mercury
            from anthropogenic sources; and

      iv)    encourage research directed towards the development of cost-effective
            substitutes for mercury that pose  less risk.

Action item 4d     North American modeling of the atmospheric transport of mercury

Recognizing the importance of atmospheric modeling in linking information on sources
and receptors of mercury, in calculating back trajectories of atmospheric transport
pathways after deposition events and in the understanding of global mercury cycling
the Parties:

      i)     instruct the North American Working Group  on the Sound Management of
            Chemicals to work with the Commission for  Environmental Cooperation to
            increase cooperation between and among experts involved in  monitoring
            and modeling the anthropogenic emission and atmospheric transport and
                                       19                            28 July 1999

North American Regional Action Plan on Mercury  Phase II

            transformation of mercury and those involved in monitoring and research
            on the atmospheric deposition of mercury.

Action item 4e	Inventories, reporting standards and criteria

Recognizing that standardized and comparable reporting mercury releases is critical to
the development of a comprehensive and effective mercury action plan, the Parties will:

      i)     identify ways to increase comparability of mercury emissions reporting
            standards and criteria by directing the North American Working Group on
            the Sound Management of Chemicals to coordinate a trinational plan of
            action for the monitoring and assessment of mercury emissions in the
            North American region and make the results of such a plan publicly

      ii)     direct the North American Working Group on the Sound Management of
            Chemicals to identify ways to increase comparability of data in order to
            assess, in the case of mercury, progress toward the national goal of a 50
            percent emission reduction by 2006. The three national pollutant release
            inventories for toxic substances are the National Pollutant Release
            Inventory (NPRI), the Toxics Release Inventory (TRI), and the Registro de
            Emisiones y Transferencia de Contaminantes (RETC).

      iii)     encourage the adoption of a mercury release reporting threshold for
            facilities that manufacture, process, use, release or otherwise manage 10
            pounds/5 kilograms or more of mercury on an annual basis through their
            existing national pollutant release inventories for toxic substances.

      iv)     direct the North American Working Group on the Sound Management of
            Chemicals to initiate the development of a North American inventory of
            sites  where elevated levels of mercury may occur due to either human
            activities or natural geological influences, (e.g., former mercury cell chlor-
            alkali facilities, former weapons production facilities, mercury stockpiles,
            mercury/precious metal amalgamation sites, mining sites that have used
            or produced mercury, contaminated sediments, and natural mercury "hot
            spots"). The geographical locations of these sites should be indicated on
                                      20                            28 July 1999

North American Regional Action Plan on Mercury  Phase II

Action item 4ff New major construction initiatives

Recognizing that new major construction initiatives have the potential to increase the
amount of mercury released to the environment, the Parties direct the North American
Working Group on the Sound Management of Chemicals to:

      i)     assess whether existing environmental impact assessment processes
            include the necessary criteria whereby an evaluation of potential mercury
            releases and the consequent impacts of such releases are included in the
            evaluation of any new major construction initiatives (e.g., hydroelectric
            reservoirs, new power generating facilities, new mining/smelting
            developments) in North America.
                                     21                            28 July 1999

 North American Regional Action Plan on Mercury  Phase II
                                 Action item 5
                           Communication activities

The Parties recognize that an important element of this Action Plan is the need to
inform and educate North Americans, particularly sensitive sub-groups, such as
pregnant women and subsistence fishermen, of the human and environmental risks
associated with exposure to mercury, such that informed assessments and decisions
can be made to reduce the risk of such exposures. Such a strategy must take into
consideration; sources, sites, exposure routes, toxic effects, risks to occupational and
consumer health, environmental and risk management options.

Action item 5a	Trinational educational awareness strategy

Recognizing that the diverse societies of North America need to be made fully aware of
the human and environmental risks related to mercury, the Parties direct the North
American Working Group on the Sound Management of Chemicals to:

      i)     develop a trinational communications strategy researching and outlining
            options for informing the North American public of how to reduce the risks
            of and exposure to mercury; building capacity to develop outreach
            programs and communicating this plan to the North American public.

Action item 5b	Communication of best practices

Recognizing that communication of successes and problems is an effective and
efficient mechanism to share technological advances, the Parties direct the North
American Working Group on the Sound Management of Chemicals to:

      i)     establish mechanisms for sharing success stories in mercury reductions,
            for developing an inventory of technological advances, such  as a data
            bank of industry best practices, and for maintaining an archive of other
            international mercury-reduction initiatives;

      ii)     establish a recognition program to publicly acknowledge those entities that
            are  contributing to the reduction of mercury use and releases, and/or
            contributing to public education, including, but not limited to:  initiating
            and/or participating in a voluntary initiative with their respective
            government, establishing partnerships with their international
            counterparts, incorporating life cycle management practices in
            manufacturing or use processes and operations and products,  creating
            and/or participating in public awareness and education initiatives aimed at
            minimizing health and environmental effects of mercury and mercury
            compounds; and
                                       22                            28 July 1999

North American Regional Action Plan on Mercury  Phase II

      iii)    generate and maintain a contact list of scientific, technical and sector-
            specific experts and organizations who may be contacted for assistance
            with mercury control initiatives.

Action item 5c	Recycling directory

Recognizing the need to establish permanent disposal/retirement options for mercury in
North America and that there is a need in the short term to inform enterprises disposing
of or purchasing mercury of those facilities that are capable of recycling mercury, the
Parties direct the North American Working Group on the Sound Management of
Chemicals to:

      i)     generate a database of North American enterprises interested in ventures
            to recycle mercury from various sources of mercury products and
                                      23                            28 July 1999

 North American Regional Action Plan on Mercury  Phase

                                 Action item 6
                        Implementation and compliance

The Parties are aware that comprehensive actions to minimize the amount of mercury
in the environment require confirmation that programs and initiatives are achieving the
anticipated results.

Action item 6a	Country implementation

Recognizing that the NARAP provides a framework for action agreed to by the Parties,
and that each Party has unique regulatory frameworks and capacities to implement the
actions described herein, the Parties will:

       i)     develop country-specific implementation plans one year after signature to
            address how and when the actions described in this NARAP will be

       ii)    direct the North American Working Group on the Sound Management of
            Chemicals to report publicly to the CEC Council one year after signature
            and on a biannual basis thereafter on progress made toward
            implementing the commitments and actions in the NARAP on mercury;

       iii)    consider the development of regulations/guidelines for mercury use- and
            release-reduction if voluntary reduction programs and commitments fail to
            achieve their stated objective.

Action item 6b	Verification of success

Recognizing that detailed implementation plans will be initiated, procedures are
required to verify compliance with voluntary commitments, guidelines, and regulations.
Accordingly, the Parties direct the North American Working Group on the Sound
Management of Chemicals to:

      i)     coordinate the development of appropriate audit processes among the
            Parties to ensure mercury reduction initiatives are meeting the objectives
            of this Action Plan;

      ii)     develop a capacity-building strategy that meets the long-term needs and
            priorities of each country to implement the NARAP; and

      iii)    periodically and collaboratively assess the effectiveness of voluntary and
            regulatory considerations to further enhance capacities for reducing
            anthropogenic releases of mercury.
                                      24                            28 July 1999


28 July 1999

 North American Regional Action Plan on Mercury  Phase II


 Annex 1:    Maior stationary sources

 Special session of the Economic Commission for Europe- Executive Body for the Convention on Long-
 Range Transboundary Air Pollution (Aarhus, Denmark, 24 June 1998).

 Item 2 of the provisional agenda: Draft protocol to the convention on long-range transboundarv air
 pollution on heavy metals.

 Annex II of the protocol:


 1.      Installations or parts of installations for research, development and the testing of new products
and processes are not covered by this annex.

2.      The threshold values given below generally refer to production capacities or output Where one
operator carries out several activities falling under the same subheading at the same installation or the
same site, the capacities of such activities are added together.


Description of the category
Combustion installations with a net rated thermal input exceedinq so MW
Metal ore (including sulfide ore) or concentrate roasting or sintering installations with a
capacity exceeding 150 tonnes of sinter per day for ferrous ore or concentrate and 30
tonnes of sinter per day for the roasting of copper, lead or zinc, or any gold and mercury
ore treatment.
Installations for the production of pig-iron or steel (primary or secondary fusion
including electric arc furnaces) including continuous casting, with a capacity exceedinq
2.5 tonnes per hour. "
Ferrous metal foundries with a production capacity exceedinq 20 tonnes per dav
nstallations for the production of copper, lead and zinc from ore, concentrates or
secondary raw materials by metallurgical processes with a capacity exceeding 30
onnes of metal per day for primary installations and 15 tonnes of metal per day for
secondary installations, or for any primary production of mercury
nstallations for the smelting (refining, foundry casting, etc.), including the alloying of
copper, lead and zinc, including recovered products, with a melting capacity exceeding
\ tonnes per day for lead or 20 tonnes per dav for copper and zinc
nstallations for the production of cement clinker in rotary kilns with a production
capacity exceeding 500 tonnes per day or in other furnaces with a production capacity
exceedinq 50 tonnes per day.
nstallations for the manufacture of glass using lead in the process with a melting
apacity exceeding 20 tonnes per day.
                                                                            28 July 1999

North American Regional Action Plan on Mercury  Phase II
Installations for chlor-alkali production by electrolysis using the mercury cell process
Installations for the incineration of hazardous or medical waste with a capacity exceeding
1 tonne per hour, or for the co-incineration of hazardous or medical waste specified in
accordance with national legislation.
Installations for the incineration of municipal waste with a capacity exceeding 3 tonnes per
hour, or for the co-incineration of municipal waste specified in accordance with national
28 July 1999

 North American Regional Action Plan on Mercury  Phase II


 Annex 2:     Product control measures

 Special session of the Economic Commission for Europe: Executive Body for the Convention on Long-
 Range Transboundary Air Pollution (Aarhus, Denmark. 24 June 1998)

 Item 2 of the provisional agenda: Draft protocol to the convention on long-range transboundary air
 pollution on heavy metals

 Annex VI of the protocol, item 5 of Product Control Measures:

 5.     Each Party shall, no later than five years, or ten years for countries with economies in transition
 that state their intention to adopt a ten-year period in a declaration to be deposited with their instrument of
 ratification, acceptance, approval or accession, after the date of entry into force of this Protocol  achieve
 concentration levels which do not exceed:

 (a)     0.05 per cent of mercury by weight in alkaline manganese batteries for prolonged use in extreme
 conditions (e.g. temperature below DEC or above 50EC, exposed to shocks); and

 (b)     0.025 per cent of mercury by weight in all other alkaline manganese batteries.

The above limits may be exceeded for a new application of a battery technology, or use of a battery in a
new product, if reasonable safeguards are taken to ensure that the resulting battery or product without an
easily removable battery will be disposed of in an environmentally sound manner. Alkaline manganese
button cells and batteries composed of button cells shall also be exempted from this obligation.
                                       29                                      28 July 1999

North American Regional Action Plan on Mercury  Phase II
                              30                              28 July 1999

          APPENDIX 1

Recommendations to the North American
 Implementation Task Force on Mercury
     (Workshop recommendations)

28 July 1999

 North American Regional Action Plan on Mercury  Phase II

 Introduction	35
 Use reduction	35
 Control/recovery	35
   Technological controls	      35
   Non-technical control activities	         35
 Release characterization (general recommendations)	37
   Disposal	                37
   Recycling	                            37
   Retirement	                      38
 Release/emission characterization (sector-specific)	38
   Waste combustion/incineration (municipal and medical)	          38
        Combustion/incineration-research	38
        Combustion/incineration/waste streams-policy	".	39
        Municipal solid waste	!!!!""!!!!"!!!"!	39
        Medical waste	"I!!"!""!!"!!!!"!"!!!!!"	39
   Coal-fired utilities-research	                    39
   Coal-fired utilities-policy	                  40
   Integrated approach	                      40
   Cost-benefit approach	                        41
 Mercury assessment-research	         41
   Environmental effects	                       41
   Health effects (See also Human health monitoring below)	   41
   Exposure	                           42
 Fate and transport	               42
   Atmospheric fate and transport	                  42
   Aquatic and terrestrial fate and transport	             43
 Environmental monitoring	              45
   Monitoring network	                           45
   Monitoring targets	                      46
   Monitonng-policy	                             46
   Human health monitoring	                            47
   Risk assessment development	                        47
Mercury management	                  48
   Hydro-electric development	                        4g
   Mining/smelting	                         4g
   Cement/calcine	                      4g
  Health care	                           50
  Mining industry	;                            50
  Chlor-alkali	    50

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North American Regional Action Plan on Mercury  Phase II

Recommendations specific to Mexico	50
  Data gathering/monitoring/laboratory QA/QC	50
  Background geochemistry	51
  Hydrology	51
  Speciation of mercury	51
  Atmospheric deposition	52
  Sediment sampling	52
  Biomonitonng: People	53
      Screening procedures for general/susceptible populations	53
  Biomonitoring: Wildlife	54
  Occupational health and safety	54
  Reprocessing	54
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 North American Regional Action Plan on Mercury  Phase II

 Recommendations to the North American Implementation Task Force on Mercury


 In developing proposed actions for the draft North American Regional Action Plan on Mercury (Phase II),
 the North American Implementation Task Force on Mercury made considerable use of recommendations
 received during three 1998 workshops sponsored by the Commission for Environmental Cooperation.
 The workshops were attended by more than 265 participants, including representatives of governments;
 industry; environmental, healthcare and other interest groups; and North American scientists with
 expertise in mercury. These recommendations are noted in this appendix.

 The Mercury Assessment Workshop was held Feb. 25-27,1998, in Zacatecas, Mexico, to develop/build
 North American capacity for management of mercury, as well as to provide proposals for a pilot project
 specific to Zacatecas. The second Partnerships/Voluntary Initiatives workshop was held in Mexico City
 Sept. 9-11, 1998, to discuss the potential for building on and initiating voluntary initiatives between
 Canadian, Mexican and US industries  A third Science Experts Workshop on Mercury, held Oct. 6-8,
 1998, at the EPA's National Exposure Research Laboratory office, located at the University of Reno
 Nevada campus, focused on the current scientific understanding of mercury and the risks it poses to
 human health and the environment. The workshop also considered current and emerging technologies for
 reducing the releases of mercury to the environment. The major sources of mercury in the three countries
 were also discussed. The science workshop was co-sponsored by the US EPA and included a session on
 control technologies for major combustion sources (i.e., coal-fired electrical utilities, municipal and medical
 waste  incinerators) co-sponsored by the Canada-United States International Joint Commission.

 The recommendations from all three workshops are presented together here, grouped according to sub-
 heads provided for ease of reference.

                                       Use reduction

 1.   Consider using levels of mercury by industries as a means of determining research priorities for
     source emissions.
 2.   Endorse the continuing voluntary efforts to reduce mercury in products, as these reductions will
     result in lower levels of mercury in discarded products.
 3.   Encourage hospitals and the medical profession to reduce their dependence on mercury-containing
     products. Encourage medical equipment manufacturers to hasten the replacement of mercury in
     their products.
 4    The CEC recommends that a common procedure be used in all three countries to identify the
     movement of mercury into the commercial/industrial sector, to  identify mercury in manufactured
     products and potential sources of mercury releases.
 5.   Support mercury source characterization.
 6.   Seek/develop dental mercury amalgam substitutes in Canada and the United States and share the
     results with Mexico.
 7.   Have the CEC track reporting on an industry-by-industry basis, including reductions of mercury use.
 8.   Encourage sectors that have achieved reductions and elimination of mercury to challenge other
     industries, including the electrical power generation sector, to do their fair share.
 9.   Develop time lines and commitments for mercury reductions in remaining products.
 10.   In setting  mercury use reductions, consider the purpose of using mercury (i.e.. safety issues),
     environmental tradeoffs, and the costs and benefits of mercury reduction.
 11.   Emphasize voluntary use reductions along with partnerships and stewardship programs.


Technological controls

 12.   Consider  proposing/promoting joint implementation programs in North America via the CEC to
     ensure that traditional measures,  i.e. electrostatic precipitators  (ESPs) or fabric filters, followed by
                                        35                                       28 July 1999

 North American Regional Action Plan on Mercury  Phase II


      fluid gas desulfurization (FGD) installations, are applied at all major point sources of anthropogenic
      mercury emissions, including electric and heat power plants, incinerators, smelters and cement
      kilns. Include applicability, efficiency and cost as major criteria when selecting the appropriate
      measures to reduce mercury emissions.
 13.   Add-on measures, such as selenium filters and scrubbers, carbon filter beds and carbon injection
      are highly efficient (exceeding 95% recovery) in recovering mercury from exhaust gases, but can be
      very expensive. Preliminary studies suggest that, taking into account the efficiency and cost of
      mercury removal, the most promising application of such measures would be further reduction of
      mercury emissions from waste disposal plants and non-ferrous metal smelters. The CEC could
      propose case studies in the three countries to obtain more information on the applicability, cost and
      potential environmental effects of by-products generated during and  after application of the add-on
 14.   Support applied research for the purpose of developing better methods for eliminating mercury at
 15.   Require immediate actions, such as injection of activated carbon, to  reduce reactive gaseous
      mercury emissions from major point sources.
 16   The chlorine industry, after 2005, should commit to time lines for switching from mercury-cell to
      membrane-cell technology or for phasing out mercury-cell plants.

 Non-technical control activities

 17.   Non-technological methods may be an efficient way to decrease emissions and  exposure to
      mercury Direct the CEC to design and promote energy conservation and pollution prevention
      solutions. Case studies can be organized with similar structures in Canada,  Mexico and the United
      States to study mercury emission  reductions through.
          materials separation (using the  experience gained already in  some states in the United
           States and  provinces in Canada); and
          labeling mercury-containing products,  which would help customers select the ones which are
      After completion of the case studies the CEC could scale up results for application to the North
      American context.
 18.   Establish national programs to determine sources of mercury to the solid waste stream, mercury
      concentrations and constituents of mercury in all types of materials.
 19.   Consider incentive programs (payback on cans, etc.).
 20.   Segregate mercury wastes to prevent release through sanctioned or unsanctioned combustion
 21.   Labeling.
           label all products that contain mercury;
           create a North American logo for "mercury free" products,
           place a health advisory and disposal information on products;
           develop a recognition program to reward initiative; and
           require clear labeling of all mercury-containing products that must continue to be used in
           care facilities to ensure that they  can be segregated from waste sent for incineration.
22.   Institute a collection program for mercury-containing dental amalgams.
23.   Consider further regulatory limitations (beyond Phase II of the 1991 US Clean Air Act) on sulfur
      emissions as a method of reducing methylmercury production in North American waters.
24.  Collaboratively, the Parties should:
            take strong, comprehensive, efficient measures to prevent further mercury pollution by
          seeing that mercury is routinely removed from emissions at the sources of pollution (e.g., coal-
          burning power plants, waste incinerators and smelters);
           require strict national laws and international protocols that are strongly and conscientiously
           consider tax incentives and grants to defray at least some of the cost of installing pollution
          control equipment;
           cooperate fully with one another in this undertaking, preferably coordinating activities; and
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  North American Regional Action Plan on Mercury  Phase II
           widen the scope of this enterprise and seek to establish and implement global agreements for
           the prevention and abatement of mercury pollution throughout the world, especially in countries
           where mercury pollution is particularly severe

                     Release characterization (general recommendations!
 25.   Estimate emissions for the following source sectors:
             secondary sources, including decommissioned industrial sites (i.e., chlor-alkali plants);
             iron and steel industry;
             motor vehicles and auto waste oil;
             refining processes for petroleum and coal;
             coke ovens;
             electronic assembly; and
             natural sources (to determine degree to which fluxes are underestimated).
 26.   Measure re-emissions of mercury from old industrial mining sites.
 27.   Search for potential missing sources of mercury emissions to air, water and soil-including
       supposedly "closed" sites-such as currently operating and closed chlor-alkali plants, and solid
       waste sites, as well as lesser-known sources such as taconite processing facilities, steel mills and
       refineries (see also 24 above).
 28.   Develop a better inventory of fugitive emissions of mercury (e.g., from mercury switch
       manufacturing, mercury thermometer manufacturing, automobile scrap yards, mercury from
       demolition materials, landfill emissions, waste haulers,  improperly disposed of sump pumps  mobile
       sources, currently operating and closed chlor-alkali sites).
 29.   Analyze interactions of mercury.with other pollutants.
 30.   Characterize  emissions from areas with high mercury levels.
 31.   For stack gas sampling, include dilution sampling in profiles.
 32.   Develop a process to compile a list of priority sources that emit reactive gaseous mercury.
 33.   There are a number of technological measures for achieving further reduction of mercury emissions
       from anthropogenic sources in North America. Before proposing the reduction strategy and
       reduction measures, a North American-wide emission inventory is needed for mercury from both
       anthropogenic and natural sources. Information on chemical and physical forms of mercury from
       various source categories is also needed. The CEC's role should be to launch such an emission
       inventory as a joint research project for Canada, Mexico and the United States.
 34.    Improve characterization of sources of mercury in the waste stream.
 35    Require before-and-after baseline information for all industries that emit mercury.
 36.    Place a high priority on the inventory of mercury releases so as to track reductions and strive for tri-
       national compatibility, given that inventories are the backbone of any reduction effort.


 37.    Improve municipal waste separation programs that collect mercury waste prior to incineration
 38.    Legislation is  required  for properly constructed landfills.
 39.    For municipal wastewater, require that:
           caustic soda be membrane grade;
           municipal wastewater treatment plants analyze sources of mercury (as Western Lake
           Superior District has done);
           municipal wastewater treatment plants request from vendors a Certificate of Analysis that
           notes mercury in parts per billion concentrations; and
           detection limits be used.


40.   Create a list of companies interested in joint ventures, especially those that involve recycling of
      electronic equipment, lamps, etc.
41.   Promote recycling by establishing economic incentives.
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 North American Regional Action Plan on Mercury  Phase II


 42.   Store mercury in its elemental liquid form in a steel flask and place it in an existing, non-operating
      deep mine repository While not as stable as mercury sulfide, elemental mercury is more compact.
      The technology exists to extract elemental mercury from activated carbon. If mercury sulfide were
      preferable to liquid mercury, it would be possible to react liquid mercury with sulfur to create a more
      stable form, which then could be stored in a deep mine.
 43.   Long-term storage of mercury or mercury-contaminated wastes should be dry. Burial under wet
      conditions could lead to methylmercury production by microorganisms. This recommendation
      applies to mercury in any form. As well, mercury-contaminated wastes should not be processed
      through sewage treatment plants as they readily methylate.
 44   Once a good North American recycling and recovery program is in place, embark on partial
      permanent retirement of mercury and refuse further imports. Enough recycled mercury exists in
      North America at this time to meet market demand. There will remain sufficient residual use of
      mercury for the commodity market to persist.
 45.   Store permanently, rather than sell, mercury in US Department of Defense stockpiles.
 46.   Develop a North American policy for byproduct mercury recovered from mine tailings (i.e.,
      recovered during gold and silver extraction, etc.). North America will need a policy for the byproduct
      mercury that is recovered. Consider permanent retirement as part of this policy.
 47   Develop a North American program for purchasing supplies of elemental mercury at low prices.
      Prevent sales of mercury on the world market where such  mercury could contribute to problems in
      the Amazon, the Arctic, etc.
 48.   Risk assessments should go beyond evaluation of leachate, taking all media and pathways into
 49   Consider the most sustainable way to retire surplus mercury.
 50.   Develop an automatic process for reporting/recording so that the product line can be tracked, as for
      example with the chlor-alkali sector. Public reporting of mercury sold at the wholesale level would
      link the commodity with the waste side.
 51.   When assessing the validity of entombing wastes,  determine how mercury in tied up in the sorbent.
 52.   For the global market, review the amount of mercury that is produced from virgin mines, activities,
      sales and resales to  determine pressure points and where marketable mercury could be withdrawn
      from the global pool.
 53.   Consider an offset retirement program for mercury.
 54.   In developing an offsetting program, take into account increased emissions from existing power

                    Release/emission characterization (sector-specific)

Waste combustion/incineration (municipal and medical)
55.   Address recent trends in mercury vapor concentrations (since 1990) from municipal waste
      incinerators in Western Europe. Look at test methods used for air emissions from municipal waste
      incinerators when comparing data.
56.   Research is needed on contribution of environmental sources, i.e., yard wastes such as grass
      clippings and leaves, to determine contribution of mercury to waste stream given data from KMS
      Peel, Essex, etc.
57.   Research is needed to determine whether high sulfur dioxide content in stack gases promotes
      efficiency of powder activated carbon (PAC), whether cross-media pollution is occurring, and
      whether dioxins and furans are being generated
58.   Analyze samples of activated carbon from coal-fired flue gas using EPA's Method 29 prescribed for
      mercury in carbon to determine the form of mercury in carbon.
59.   Support work that increases understanding of mercury speciation  in combustion  systems. There is
      not much information about mercury speciation in the gas phase or mercury in fly ash.
60.   Determine whether to replace electrostatic precipitators at the end of their life or sooner, given
      superior capture of mercury with baghouses.
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 61.    Monitor elemental mercury in the atmosphere over period 3 to 5 years at selected stations.
 62.    Interpret early data (through mid-1980s) with caution, given the inadequate test methods that
       missed the impact of carbon in the ash stream. Emission numbers derived from this data are
 63.    In determining control measures for incinerators, determine background levels for sodium sulfide.

 Combustion/incineration/waste streams-policy
 64.    The CEC should encourage reductions in mercury emissions now by encouraging conservation of
       electric power, recommending an increase in the use of flue gas desulfurization (FGD) in coal
       burning plants.
 65.    Recommend source separation of mercury-containing material in municipal, medical waste,
       hazardous waste streams and incinerator feedstock. (Source separation results in 80% reductions
       of mercury to the waste stream.)
 66.    Develop model legislation to prohibit mercury in the  municipal and medical waste streams. Local
       control (i.e.. county) is important with regard to flow control and enforceability. Set a flat rate
       emission limit for mercury, for example, 0.028 microgram per dry standard cubic meter (ng/dscm)
       appears to be achievable for facilities with the capacity to burn 250 tons per day. Imposition of
       emission limits should be undertaken in conjunction with a good source separation program
 67.    Remove the environmental component (yard waste, etc.) from the waste stream.

 Municipal solid waste
 68.    Have the CEC endorse the adoption of uniform performance standards for all Municipal Solid
       Waste (MSW) incinerators in North American, and, in particular, state that any new facility must be
       equipped with advanced mercury control features such as powder activated carbon (PAC) or
       sodium sulfide injection.
 69.    In terms of performance standards, have the CEC endorse current US national standards as an
       achievable and realistic target that can be met within the economic constraints of most facilities.
 70.    Encourage, via the CEC, a review of appropriate national and continental standards at such time as
       it becomes apparent that the MSW incineration industry accounts for more than a stated
       percentage of the direct anthropogenic emissions on the continent.
 71.    Address the long-term behavior of mercury-containing air pollution control (ARC) residues, with the
       goal of determining their potential contribution to global mercury emissions.
 72.    Determine if there are environmental benefits to selecting powder activated carbon over sodium
       sulfide-based mercury control reagents.
 73.    Develop criteria for disposal of mercury-containing materials in order to minimize releases to the

 Medical waste
 74.    Encourage medical waste facilities utilizing incinerators to improve their emission control systems in
      order to reduce the release of mercury and other contaminants from their facilities. This is
      particularly critical in regions of the country (United States) that might be more vulnerable to
      releases of reactive mercury due to the presence of water bodies or wetlands.

 Coal-fired utilities-research

 75.   Address mercury fate (scrubber sludge, species).
 76.   Determine whether retirement of captured mercury via sequestration is viable.
 77.   Address disposal of captured mercury in sludge and  scrubber waste.
 78.   Consider liming lakes to lower methylmercury concentrations. Sweden implemented receptor
      control such as liming after source reductions were achieved.
 79.   Require pilot-scale studies of control technologies (first 2-3 years) followed by full-scale studies (3-5
80.   Examine more closely the correlation between  mercury emission reductions and reductions of
      mercury in fish. (EPA will be conducting a fish tissue study )
81.   As a means of correlating controls on  industries with mercury levels in fish, track effects of mercury
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      releases using prescribed sampling methods
 82.   Continue fundamental parametric studies
 83   Undertake proof-of-concept testing of novel concepts.
 84.   Conduct field evaluations.
 85.   Examine efficiencies of new control technologies so that these technologies can be directly
 86.   Determine what mercury release levels are acceptable.
 87.   Conduct a comparative assessment of all power generation technologies.
 88.   Via a multi-agency, multi investigator study, quantify the plausible link between mercury emissions
      from a coal-fired power plant to elevated local (10 km-100 km) mercury deposition to sensitive

 Coal-fired utilities-policy

 89.   Take all reasonable measures in the short term to reduce mercury from sources prior to phasing in
      other options.
 90.   Provide  a reasonable schedule for achieving reductions in the electrical generation industry.
 91.   The CEC should encourage as a long-term measure switching to clean fuels that require less stack
      controls on emissions.
 92.   Develop measures for a North American-wide emissions inventory on sources and categories
 93.   Apply cradle-to-grave life-cycle analysis to examine treatments as part of a totality of
 94.   Encourage consideration of pros/cons of all technologies involved in the coal combustion process,
      from feedstock delivery to final disposal of waste, including examination of mercury in residues
      (sludge, etc.).
 95.   Develop an interim strategy to define the problem of mercury in coal while promoting conversion to
      alternative technologies that do not use coal. Examine the role of coal. In Ontario, coal provides a
      limited transition role en route to implementing alternative technologies.
 96.   Adopt standardized emission reporting criteria (particularly in  Canada and the United States) and
      make the results publicly available.
 97.   Promote pollution prevention.
 98.   Standardize monitoring methods. Discuss the monitoring methods used in Sweden where emission
      reductions to "zero" are reported.
 99.   Determine within two to three years whether to regulate the coal-fired utility sector (US EPA).
 100.  When examining this sector, include coal-fired boilers.
 101.  Link efforts to the CEC continental pollutant pathways work on mercury.
      Address  recent trends in mercury vapor concentrations (since 1990) from coal-fired utilities in
      Western Europe.
 103.  Assess the waste disposal/stability issue.
 104.  Assess,  especially at a full scale, the impact of power plant operation and waste disposal of
      mercury emissions reduction policies/options.
 105.  List the pros/cons of burning coal in the framework of a life-cycle assessment.
 106.  Require  time lines and commitments from the coal-fired electrical sector regarding reduction of
      mercury emissions

Integrated approach

107.  Take an integrated approach to multi-pollutants (mercury, hazardous air pollutants  (HAPs) and acid
      gases) when examining further actions and their economic feasibility.
108.  Approach controls from a multi-pollutant, life-cycle point of view. Technologies that are not
      considered to be economical when looking at mercury recovery alone will likely be found to be cost-
      effective when evaluated  in this context.
109.  Endorse the multi-pollutant approach, which is critical in determining human health impacts.
110.  Integrate controls for mercury with other pollutant control processes.
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 Cost-benefit approach

 111.  Undertake an integrated cost-benefit analysis and multi-pollutant study of mercury controls; conduct
      full-scale tests of proposed controls.
 112.  Engage an objective third party to establish a common basis for cost-benefit studies using
      international guidelines and with the objective of arriving at an agreed-upon base cost. At this time,
      numbers are not easily comparable. All claims, including those by other nations, must be thoroughly
 113.  Define model, full-scale design operations, and cost estimates.
 114.  Verify promising concepts in reducing  mercury in different flue gases via scale-up and analysis of
      their cost effectiveness.
 115.  Guidelines are required to define 'cost effective1. What is the path? Societal cost?
 116.  Establish a cost-benefit analysis liaison between CEC and European experts.
 117.  Determine when technology costs become prohibitive and provide direction to researchers
      regarding the economic parameters for developing systems to remove mercury.
 118.  Determine the economic consequences of changing technology in short-, intermediate- and long-
      term time frames.

                               Mercury assessment-research
 Environmental effects

 119.  Support research to determine effects of mercury on biota, including fisheries production.
 120.  Obtain new toxicity data; existing toxicity data is twenty years old. Toxicity testing with supporting
      documentation is required to determine reproductive, developmental and neurological changes.
 121.  Support field research to observe/determine reproductive, developmental, and neurological effects.
 122.  Support/conduct field studies to verify projections of increased risk to wildlife living in immediate
      proximity to emissions point sources.
 123.  Develop a defensible reference dose for wildlife.
 124.  Develop a comprehensive tn-national environmental effects database.
 125.  Support research/conduct studies to better characterize the effect that selenium plays on
      methylmercury-related neurotoxicity and fetal toxicity.
 126.  Via the CEC, sponsor dosage/response research to determine sound methods of detecting sub-
      lethal mercury poisoning in key species that concentrate mercury. Unequivocal indicators of
      mercury poisoning are required in key resource species (and probably also in people). Include
      experiments that explore the implications of varying intakes of selenium on mercury toxicology.

Health effects (See also Human health monitoring below)

127.  Conduct studies on human neurotoxicity of fish consumption to determine threshold levels for
      neurotoxic effects.
128.  Determine the adverse effects that are of concern (i.e., are cognitive effects a concern?). Reach
      agreement on which health effects are considered important.
129.  Determine which health effects will be used as the basis for standards.
130.  Determine whether a reference dose (RfD) is desirable. By setting an RfD it is implied that there is
      an acceptable level of mercury intake Note that there is no RfD for lead.
131.  Determine if there are synergistic effects with other pollutants.
132.  Develop a comprehensive tri-national health effects database.
133.  Support/undertake research to determine how mercury binds to protein.
134.  Determine whether different ethnic groups have different de-methylation capabilities.
135.  Via the CEC, sponsor a literature review or workshop on the problem of partitioning biological
      effects on people or animals when they have been exposed to mercury and other toxic substances
      (PCBs, for example) at the same time and to determine whether an effect was caused by mercury,
      other substances or a combination of substances.
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 136.  Determine bioavailability of mercury and species in reservoirs.
 137.  Support the development of better indicators of methylmercury toxicity in human populations. Make
      thorough use of available epidemiological and pharmacokinetic data to clarify the health risks to
      adult members of the community (and follow through to adulthood the effects in children exposed to
      methylmercury) particularly with respect to aboriginal communities. Review the pharmacokinetic
      assumptions involved in the computation of advisory notices issued for subsistence and
      recreational consumers of fish.
 138.  Determine concentrations of mercury at high elevations.
 139.  Consider use of large mammals, sharks and tuna as indicators for bioaccumulation of mercury
      They integrate information on mercury in oceans and are at the top of food chain. (If whales are
      used, blood must be normalized to red cell content of people.) Given that oceans are the final
      repository for mercury, and considering the importance of coastal zone fisheries to all three
      countries, such indicators are necessary.
 140.  Consider a trinational workshop to determine whether existing fish data can be translated into a
      usable risk assessment database for wildlife and human risk assessment. The data must indicate
      the size distribution of fish and variances over geographic areas. Scientific defensibility is required
      for this project.
 141.  Bivalves should be an indicator species for the Gulf of Mexico.
 142.  Predictive models should be developed that permit extrapolations.
 143.  Determine appropriate endpoints to be used in health assessments, e.g., fetus and/or yogng
       children; maternal/fetal pair.
 144.  Gauge the extent of human exposure to methylmercury via fish consumption.
 145.  Consider whether fish advisories provide adequate coverage for lakes.
 146.  Determine the exposure level associated with the onset of adverse effects. Then determine which
      sub-populations should be of concern
 147.  The three North American countries or the CEC should fund an epidemiological study that
      examines consumption of fish and the effects of methylmercury.
 148.  Determine concentrations of methylmercury in fish in the market place.
 149.  Improve data-gathering on infant exposure (i.e. through breast milk) and effects.
 150.  Conduct research to determine whether atmospheric inputs of anthropogenic mercury can drive
      accumulations  in key species of fish and other animals.  (Proposed experiments at Canada's
      Experimental Lakes Area should address this.)
 151.  Calibrate different, independent estimates of inputs of mercury to aquatic systems more rigorously
      and frequently
 152.  Focus special attention on highly exposed animals (top aquatic predators that live a long time).
      These exposures provide case histories from which we can learn how to evaluate risks to other
      populations. Also make special provision for high-risk human populations (children, young women).
 153.  Through the CEC, provide a forum through which the medical community can explore correlations
      of subtle neurological variations with mercury exposure.
 154.  Develop a bioengineered organism with a  reporter gene to allow simple 'dip stick'-type tests for
      mercury in food products. It may be possible announce the mercury content of food on each
 155.  Obtain improved  information on worker exposure at mining sites.
 156.  Undertake studies to determine the extent of cultural and ritual uses of mercury in North America.
 157.  Include mercury assessments in the medical history of patients/clients who use botanicals.

                                     Fate and transport

Atmospheric fate and transport

 158.  Determine whether ozone depletion, acidification and climate warming are contributing factors to
      mercury increases (i.e., examine for possible synergistic effects).
 159.  Support/conduct more assessments on ambient and speciated mercury within North America.
 160.  Support/conduct more receptor-source research, bearing in mind that in urban areas particulate
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      mercury is most important.
 161.  Determine the role of diagenesis in mercury cycling.
 162.  Consider mercury pollution within a multi-pollutant context (acid rain, hazardous air pollutants, etc.)
 163.  Approach emission trading with caution, taking into account that the contribution of landfill venting
      of mercury approaches that of mercury in flue gas. Isolated bacteria are capable of oxidizing
      elemental mercury in landfills. Consider also the implications of the contributions to total gaseous
      mercury (TGM) from mercury deposits in landfills and chlor-alkali plants.
 164.  Consider banning landfilling of mercuric wastes given research findings pertaining to oxidation of
      elemental mercury in landfills and potential venting of mercury.
 165.  Obtain better information on fluxes of mercury from landfills, especially where there are inputs from
      unregulated industrial sources. There may be significant unregulated industrial inputs to landfills.
 166.  Simulate a controlled landfill study, including flux data.
 167.  Map surface fluxes.
 168.  Identify major mercury 'pools,' resulting from past practices, such as landfills. Determine what
      options are available to risk managers to keep mercury in the pools.
 169.  Determine whether natural sources are significant sources of mercury on the local scale.
 170.  Re-examine the contribution of volcanoes. Look for indices that allow scaling mercury source-
 171.  Direct the CEC to explore parameters that could be used to study linkages between  climate
      change and mercury kinetics/global fluxes. For example, changes in soil temperature, moisture and
      growing season could reasonably be hypothesized to change soil/air exchanges of mercury.
 172.  Support an improved spatial network to evaluate regional and super-regional effects of mercury.
      This information, coupled with atmospheric monitoring, could enable scientists to examine current
      and past gross spatial patterns.
 173.  Support a Geographic Information System (GIS) for predicting mercury deposition from the
 174.  Characterize mercury emissions during petroleum and diesel life cycles.
 175.  Develop/identify tracers to better characterize mercury releases from oil combustion in motor
 176.  Improve Reactive Gaseous Mercury (RGM) technology.
 177.  Make a quantitative and direct measurement of the fraction of mercury deposition to sensitive
      aquatic ecosystems as a result of local and regional anthropogenic mercury air emissions.

Aquatic and terrestrial fate and transport

 178.  Determine whether mercury re-emission rates in arid areas are different from those in less arid
      regions of the United States and Mexico
 179.  Using an inter-disciplinary approach, determine speciation and bioavailability of mercury in different
      natural environments.
 180.  Inform  North America's policy makers that continued decreases in sulfate emissions should help
      reduce mercury, given that acid deposition stimulates methylmercury formation.
181.  Determine how ecosystems respond to changes  in mercury loadings. (It is known that
      methylmercury is generally higher in acid lakes, wetlands and reservoirs than in other water bodies.
      but it is not known how mercury loadings can be decreased.) Consider adding more mercury to test
182.  Increased sampling of lakes for methylmercury/bio-geochemistry is needed as there is a dearth of
      data and adequate  sampling methods have only been available in the past five to six years.
183.  Mechanistic information on methylmercury production in lakes and estuaries is needed. What forms
      of mercury in sediments are available to bacteria for methylation? Does the mercury species affect
      methylation? If  upstream sources of mercury are more available than atmospheric mercury, what is
      the implication to the ecosystem?
184.  Support/gather more data on methylation processes in estuaries, which may be sources of
      methylmercury  to oceans. This data can help determine if the source of mercury is in situ or
      originates from the  land
185.  The first priority for  funding research regarding effects of deposition from anthropogenic sources
      should  be to identify which of these sources are located near ecosystems that are conducive to
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      methylation  This priority recognizes that local deposition from anthropogenic mercury sources may
      have a more significant impact where methylation is high. In South Florida, for example, declines in
      methylmercury have been measured following reduced releases from anthropogenic local sources.
 186.  To set priorities for ecosystems or regions, use the percent of total mercury as methylmercury in
      sediments, and/or use methylmercury in a few standard sizes and species of fish to evaluate the
      degree of methylation production from mercury inputs. As well, a survey of sediment
      methylmercury among ecosystems and over time should be established to provide sufficient data
      for use in predicting the variability of methylmercury production among water bodies.
 187.  Large-scale, ecosystem-level studies of mercury biogeochemistry are needed that integrate
      processes, examine processes in watersheds related to land cover and hydrology and examine
      under-studied types of ecosystems (coastal; temperate water bodies; export of mercury and
      methylmercury from estuaries, rivers and coastal zones to oceans)
 188.  Defunct industrial sites in North America, including "remediated" sites could be major sources of
      mercury and methylmercury to receiving waters.
 189.  When considering the creation of reservoirs, take into account that simply adding water and
      increasing the microbial decomposition rate results in tremendous production of methylmercury in
      the lake or flooded areas.
 190.  Determine whether degraded methylmercury converts to Hg (II+) or Hg (II).
 191.  Pursue integrative projects with a multi-disciplinary approach.
 192.  Research supports regulation as the most effective means for ensuring that mercury concentrations
      will be measured From a regulatory standpoint, mercury in effluences  should be measured. Method
      1631 or a general mercury method should be accepted as the standard North American method for
 193.  Streamline techniques for methylmercury analysis in North America.  It  is now possible to include
      methylmercury in regulatory  sampling.
 194.  The CEC could promote pressure-state-impact models. It could undertake a case study for
      promoting translation of research to policy.
 195.  The CEC could facilitate flue gas characterization efforts in  North America instead of add-on
 196.  Determine the impact on human health of mercury releases from point sources.
 197.  Use comprehensive models  now available for the prediction of mercury concentrations in fish based
      on decreases in atmospheric mercury concentrations by a set amount  (i.e., by a factor of 2 or 4).
 198.  Improve the characterization of mercury fate in yard waste that enters landfills or composting yards.
 199.  Research is needed to determine which bacteria has the highest oxidation potential.
200.  Promote/support research on the fate of mercury in oceans in order to  permit more accurate
      perform modeling.
201.  Promote/support research on methylation processes in saturated soils.
202.  Promote/support research on de-methylation processes.
203.  Establish the relative importance of methylation from new mercury inputs versus old mercury inputs.
      How long does the methylation process take?
204.  Develop a conceptual model for methylation.
205.  The principal exposure of humans to methylmercury in North America is through the consumption
      of marine fish, shellfish and fish products. Because of the paucity of knowledge regarding the
      sources and cycling of mercury in the marine environment, trinational support is urged for
      comprehensive investigations focused on anthropogenic impacts and their influence on the bio-
      geochemical cycling of mercury in the critically important coastal marine regions (i.e., containing
      significant commercial and recreational fisheries) of Canada, Mexico and the United States.
206.  Sponsor/conduct more basic research (e.g., research on the bio-geochemistry of mercury in various
      environments). Detailed, in-depth investigations are required, together with a broad, interdisciplinary
      approach so as to achieve a  synthesis of different kinds of observations and concepts.
207.  Further research should be carried out to settle the current controversy over the interpretation of
      mercury profiles in lake sediment cores. This would require, among other things, more work on
      pore water (which has been largely neglected in analysis of  core sections) and more detailed and
      higher-resolution analysis of  various sediment compartments and characteristics that have a
      bearing on the distribution of mercury Comparative study of core data  representing many different
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      lake environments is needed

                                 Environmental monitoring

 Monitoring network

 208.  Develop a broad monitoring deposition network to show where models need additional work.
 209.  Include in the broad North American deposition network a core number of master research stations
      that have parameters for a variety of pollutants and a few satellite stations more limited to mercury.
      A few sites measuring mercury in combination with these other parameters, metals, etc., are more
      valuable than many mercury-specific sites
 210.  Jointly fund a North American network of sites that determine wet deposition (concentration and
      speciation) and atmospheric gaseous  speciation and particulate mercury. These sites should be
      chosen to provide regional average values for parameters (for example, six US sites: New England,
      mid-Atlantic, Midwest, Florida, South West Coast and Pacific Northwest; four Canadian sites and
      four in Mexico These sites should  couple air-water exchange measurements. These sites require
      trained operators Additionally, a survey of land-air fluxes at representative sites are needed at
      perhaps 30 sites to estimate flux variability across terrains.
 211.  Develop a widespread, long-term monitoring network involving the use of multiple variables and an
      interdisciplinary approach.
 212.  Expand monitoring networks for total gaseous mercury (TGM) and mercury deposition on the West
      Coast to determine if the Pacific Ocean is a major source of mercury to the North American
 213.  Expand the Mercury Deposition Network (MDN), which will greatly aid developers of continental
      atmospheric mercury models. It will also provide temporal and spatial long-term trends in mercury
      deposition An expanded MDN will  be  invaluable as feedback to reflect the expected downward
      trend in mercury emissions and resultant decreases in mercury deposition. Ideally, an expanded
      MDN will include a number of "super-sites" that can be used to measure a full range of high
      frequency atmospheric mercury, trace metals and meteorological parameters to quantify source
      apportionment. The super-sites will provide a long-term regional-based mechanism to quantify the
      fraction of mercury deposition to sensitive aquatic ecosystems as the result of anthropogenic
      mercury emissions.
 214.  Work with  regulators and managers to enable inter-comparison of different mercury monitoring
 215.  Standardize measurement methods as much as possible and inter-calibrate to confirm methods
216.  Develop automated systems of measurement where possible.
217.  Use/develop monitoring protocols that ensure samples can be used for trend analysis.
218.  Develop inter-calibration exercises to compare and contrast techniques so that data can be
219.  Develop a regional and super-regional network of terrestrial core samples.
220.  Extend the sediment core network of northern and eastern North America to central and western
      North America and to Mexico, and ideally to all of the Americas.
221.  Because mercury uses associated  with human activities will lead to a general, though variable,
      volatilization of mercury to the atmosphere, and because of the uncertainty as to whether mercury is
      increasing or decreasing in the environment, give trilateral endorsement to the implementation of an
      international research program, [e.g , AMNET or Atmospheric Mercury Network (Fitzgerald,  1995)].
      whose principal focus would be the accurate determination of the spatial and temporal variations in
      atmospheric elemental  mercury, and the assessment of the influences from natural sources, and
      interference from human-related emissions on the global and local atmospheric mercury cycle. A
      three- to five-year program is required  and stations must be carefully selected (free of local
      sources) to ensure that secular trends can be resolved (1% resolution). AMNET stations can
      provide opportunities for intensive studies of chemical reactions and processes affecting the
      behavior and fate of mercury in the atmosphere.  AMNET stations can be coordinated with mercury
      deposition  sites in Mexico, the United States and Canada, especially in locations where the impact
      from local sources is a minimum
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Monitoring targets

222.  Measure ancillary parameters and metals/metalloids. These atmospheric constituents are needed
      to understand mercury fate and transport. Measure Total Particulate Mass (TPM): paniculate size
      distribution. Take fine particle samples with any automated mercury measurements so these can
      be correlated with rain events.
223.  Reactive gaseous mercury should be measured at all sites.
224.  Wet deposition should be monitored. The existing network for this could be expanded with a
      minimum number of sites.
225.  Emphasize sediment over water sampling. There is not much sense in sampling total mercury in
      water, unless near a major industry source for compliance purposes. Sediment sampling is superior
      for determining trends and, although more expensive than fish sampling, it eliminates confusion
      over bioaccumulation in food webs. Methylmercury monitoring  in sediments should be used for
      policy issues rather than concentrations in water.
226.  Sample lake sediments to complete the global map of mercury deposition.
227.  Air emissions should be speciated. This will help determine if reactive gaseous mercury rivals wet
      deposition. Currently, data indicates there is low reactive mercury in rain, yet it is thought there are
      high reactive concentrations in the atmosphere. Speciation is required rather than total mercury
      measurements. However,  Total Gaseous Mercury (TGM) measurements would still be useful as
      regards long-term trends. Therefore, scientists concur they should continue to measure wet
      deposition, participate and gaseous ionic species.
228.  A monitoring study along the Mexican/US border is needed to measure the mercury emissions from
      the electronics industry located there  Data from Mexico's northern border is required to verify origin
      of sulfite concentrations noted around El Paso, Texas, and Tucson, Arizona.
229.  For large-scale monitoring studies, consider using mink and otter fur as indicators of mercury in
      internal organs  (This could be implemented across the continent in conjunction with food sources
      of mercury ) Larger samples are required for mink and otter in  marine habitat.
230.  Repetitive fur sampling of tagged individuals is needed.
231.  When monitoring for mercury it may be helpful to also analyze  for other substances in order to help
       investigators better understand mercury (e.g  , lead and zinc are tracers for municipal waste in
232.  Re-examine terrestrial and submarine volcanic mercury releases.
233.  Determine re-emission rates from  landfills, sludges, etc.
234.  Obtain both short-term intensive and long-term measurements at urban and rural locations to
      capture anthropogenic and natural emission sources.
235.  Re-emission and natural sources clearly contribute reactive mercury to the environment and must
      be a research priority in future programs. Quantify mercury emissions from  area-surface sources to
      assess the effects of mandated emission reductions of airborne mercury. Unified approaches to
      scale are needed to obtain reasonable estimates of regional and global emissions. These sources
      are not readily controllable, and they will effectively reduce the  overall benefits of active emission
      controls if not considered up-front in a control strategy.
236.  Map surface fluxes.
237.  While all mercury is natural in the sense that is all the same element, the CEC should sponsor a
      review to find out what ways exist to help distinguish between natural and anthropogenic
      contributions to global fluxes. The best method available appears to be inferential through sediment
      cores  This effort should include mercury that emanates from soils since some of that is probably
      the result of past anthropogenic fallout being re-emitted.


238.  Incorporate the 'polluter pays' principle in network development across North America.
239.  Employ entirely disinterested, independent workers having no connection with the companies
      causing the pollution to conduct the actual monitoring and assessments. Such workers should also
      be independent of any consultants hired directly by these companies. Otherwise, a conflict of
      interest will exist and the results and conclusions may be distorted by conscious or unconscious
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       bias in favor of polluters.
 240.   Support training sessions for use of automatic mercury analyzer vaporizers (Tekran, etc.) that
       enable characterization of emissions (temporal and spatial resolution, and continuous emissions
       monitoring)  These units are easily transportable (they are about the size of a microwave oven) and
       permit accurate sampling outside of factory grounds.
 241.   Better define natural and anthropogenic sources.
 242.   The CEC should recommend the three best cost-effective methods for monitoring and analysis.
 243.   The CEC should become involved  in the joint Federal-State Lake Superior Basin Study, which is
       studying  a variety of issues (e.g., continuous emissions monitoring (CEM), plume studies, flu gas.
       transport, deposition).
 244.   Consider within CEC developing/identifying financial mechanisms for cooperation in monitoring as
       is done in Europe with eastern and western European countries.
 245.   Use monitoring to show environmental improvements based on present reductions in mercury.
 246.   Bivalves  should be considered as a possible biological indicator for North America. There is a long
       history of using them as indicators  in Mexico and they inhabit all three countries.
 247.   Determine the relationship between atmospheric deposition of inorganic mercury and the
       concentration of methylmercury in fish.
 248.   Establish baseline assessments prior to the operation of new mercury use facilities. Mercury
       sampling should be done prior to and following start-up of new facilities in order to determine the
       effectiveness of the facilities' emission control technologies.

 Human health  monitoring

 249.   Better characterization of human intake and levels of mercury in human hair are required:
       speciation and source, long-term exposure and high vs. low exposure levels.
 250.   Integrate human data.
 251.   Integrate test animal data with data on humans.
 252.   Conduct/obtain exposure estimates of people living near contaminated sites.
 253.   There is limited information on human biokinetics of methylmercury. Can data obtained from one
       part of world be translated to another? Data is sparse.
 254.   Conduct/sponsor research on biokinetics of mercury in children. Although young child, infants and
       the fetus  comprise the most vulnerable group, next to nothing is known about mercury effects.
 255.   Data is needed on indoor air as an  exposure path of elemental mercury due  to accidents, religious
       uses, etc.
 256.   Biomonitoring data are very sparse. It is uncertain what the US distribution looks like. More
       biomonitonng data on high exposure populations in North America are needed. This will help
      determine the magnitude of health effects in North America.

 Risk assessment development

 257.  Continue to improve risk assessment methods.
 258.  Standardize  risk assessment methodology in North America.
 259.  Integrate  all available data (i.e., benchmark levels, dose-response, field studies).
 260.  Base wildlife risk assessments on fish These should be site-specific and should accommodate US
      EPA legislative requirements regarding concentrations in water.
 261.  Extrapolation of large fish tissue concentrations to concentrations in small prey-sized fish is needed.
 262.  Place emphasis on  major studies conducted over a period of years to assess trends.
 263.  Within the next three years, integrate data already available on fish (such as  trapping data
      maintained by states). Also integrate this data across borders.
264.  Support the development and promotion of standardized protocols that can be used for monitoring
      mercury levels in fish
265.  Recognize that standards for fish consumption will set policy.
266.  Decide which uncertainty factors should be applied to NOEL (no observed effects levels) designed
      to protect humans on a population basis
267.  Reduce the uncertainties surrounding the selection of wildlife Bio-accumulation Factors (BFs).
268.  North American Environmental Impact Studies (EISs) should include the presence of mercury.
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 269.  EIS's should be harmonized within North America and be transparent.
 270.  EIS's should not be harmonized  Instead, consider bilateral sharing of Canada's and US EIS
      information with Mexico
 271.  Criteria for defining areas at risk'
          Via the CEC, develop a series of criteria to define environments that could be at risk from
           increased mercury exposure
          Develop these criteria within a GIS mapping system that would identify areas where increased
           precautions should be taken
          In situations where all the criteria used to assess the potential for damage from mercury
           releases are not available, those that are available should be used to develop priority
           locations for work to complete the  criteria.
          Using these data, sources releasing high concentrations of reactive mercury in critical areas
           could be targeted for enhanced control measures that would reduce their impacts.
 272.  Design field studies that accommodate many different approaches within the same  location so that
      these approaches can  each benefit from the presence of the other and they can be evaluated
      against each other to assess accuracy of results.
 273.  Examine mercury's linkages to other kinds of pollution, including acid rain precipitation, recognizing
      there are linkages which may aggravate the biological effects of the mercury besides doing harm in
      their own right

                                    Mercury management

 274.  Conduct case studies rather than cost projections.
 275.  The CEC and others should promote the development of tools for translating results from research
      projects and mercury monitoring programs to policy making. These tools can be developed within
      the Pressure-State-Impact-Response (P-S-I-R) format. Case studies can be organized within the
      CEC structure to test the application of the P-S-I-R model in the selected regions in North America,
      such as the Everglades, the Great Lakes, Chesapeake Bay, the Lake Champlain area and the Gulf
      of Mexico After completion of the above-mentioned case studies, the CEC could approach
      upscalmg results into the North American format.
 276.  The CEC should ensure that internationally developed guidelines on emission
      estimates/measurements and control-cost estimates, particularly the guidelines developed within
      the United Nations Economic Commission for Europe (UN ECE) and European Union format, are
      adjusted and applied, if needed, in North America. A small liaison unit between the CEC and the
      European experts should be established to carry out this task.
 277.  Develop and support a  worldwide strategy to minimize initial mobilization of geologically stable
      mercury by  human activities, including strategies for decreasing both the demand for mined
      mercury and the burning of fossil fuels.  First-world countries should take the lead and subsidize
      emerging economies and third-world countries through technology transfer, education and the like.
 278.  Determine the importance to society of localized species' failure to reproduce/extinction caused by
      mercury, such as now appears to be occurring in several regions within North America
 279.  Respect for cultural identity  and tradition should not be used as a reason to avoid limit activities that
      may release mercury
280.  Set priorities for spending based on an integrated assessment of anthropogenic sources located
      adjacent to sensitive ecosystems and put together a priority program as a starting place.
281   Research should be conducted on determining what types of fish, how many fish, and when fish
      can be eaten. This is important for informing consumers.
282.  Determine whether changing technology will create new problems.
283.  The CEC should develop a mechanism that allows for trading environmental debt.
284.  Review anti-trust laws to determine whether they present a barrier to reducing and eliminating
      mercury from products  and processes.
285.  A policy for new emission sources in North America is required.
286.  All NARAP actions should include time frames for specific activities and target dates for achieving
287.  All recommendations should have a goal statement, objective, and time frame.
288.  Used a stepped process to set recommendation priorities as follows. (1) identification of priority

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      sites/sources, and (2) determine how the effect of regulations on people and the environment.
 289.  Public involvement is important. Include public participation as much as possible.
 290.  Create a staff of specialists (from the CEC or other entity) who could assist in application of clean
      technologies in the three countries.
 291   North American goals should be the recovery or retirement of mercury from the global pool via
      education, solid continental inventory, including fate and prevention, and waste minimization.
 292.  Track the progress of voluntary projects. Lack of progress may demonstrate a need for regulation.
 293.  Conduct a mercury mass balance for North America.

 Hydro-electric development

 294.  The CEC should consider in its action plan for mercury the implications of hydro-electric
      development  In particular, impoundment-related increases in methylmercury levels in fish should
      be incorporated as factors in utility industry strategies for the control of mercury contamination.


 295   Mining  issues should be examined and compared between the three countries.
 296.  Define geographical problem areas for mining.
 297.  The CEC should have a position on the creation of such new mercury sources as new mines and


 298.  The North American Regional Action Plan on Mercury must address the cement and calcine


 299.  Foster awareness  of tools such as automatic mercury vapor analyzers, (such as the differential
      optical adsorption spectrometer, or DOAS) as community-right-to-know tools. Tools can  be used to
      gather data on input values that allow mass-balance checks on input measurements to better
      characterize emissions
 300.  Examine risk communications to ensure they are reaching the desired population(s) and that they
      can be  used to help people change exposure patterns as sources of mercury and mercury available
      to the environment are being addressed.
 301.  Reach a baseline consensus on communication of fish advisories.
 302   The CEC could take the lead in developing/implementing a trinational educational awareness
      campaign that informs the public of mercury content in products, mercury-free alternatives and
      which explains linkages with mercury in fish.
 303.  The CEC should develop a communications strategy to publicize the dangers of mercury (effects,
      treatment, occupational & consumer health, sites, sources, etc).
 304.  The CEC should publish a sport fish consumption guide for North America that is comparable to the
      one Ontario, Canada uses.
 305.  Via the  CEC, sponsor a small workshop to facilitate better coordination of quality assurance/quality
      control (QA/QC) efforts and data management among Canada, the United States and Mexico, not
      just for mercury but for all contaminants of common interest. The US National Oceanic
      Atmospheric Administration or NOAA is trying to do this on the QA/QC side.
306.  Via the  CEC. sponsor a workshop on mercury in coastal zones and estuaries. These areas are
      often highly productive and heavily fished and mercury problems there are largely undefined.
307.   If inputs of mercury are being driven by combustion of mercury-containing fuels like coal,  then
      inputs of mercury should be at least partially linked to other combustion byproducts (e.g. PAHs).
      Organize a literature survey or small workshop to explore this.
308.   Identify non-essential uses of mercury and target users via educational efforts, with the aim of
      reducing and eliminating these uses of mercury.
309.   Compare analytical methods for consistency among the three North American countries, and
      improve data comparability
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 310  The CEC should establish mechanisms to share success stories in mercury reductions, such as a -
      data bank of industry best practices (to help establish benchmarks). It should maintain a contacts

 Health care

 311  Develop a tri-national, collaborative process within the medical community to promote voluntary
      elimination of mercury in the healthcare industry.
 312.  Undertake training and workshops for consumers and health care providers.
 313.  Ensure that health education is linguistically appropriate and culturally sensitive.
 314.  Provide health (risk) information to the public in a timely manner (expect generational turnover  


 315.  Request that universities and dental education associations play a role in educating dental students
      about mercury
 316.  Consider a discussion/training group for dentistry similar to the USEPA, Environment Canada risk
      evaluation course that could be distributed in the three countries in the appropriate languages.

 Mining industry

 317.  Foster partnerships among government agencies to standardize maps of mercury deposits to
      identify priorities for action on a North American  scale. (There is already much information available
      but it is not all compatible)
 318.  The CEC should facilitate exchanges of information among the three governments and the mining
      industry on mine abandonment practices (site-remediation, acid-mine drainage, soil remediation
 319.  Mining associations are encouraged to promote  exchanges of environmental information among
 320.  The CEC can bring to the attention of the mining companies the problems associated with
      reprocessing mine tailings


 321.  Within the chlor-alkah industry, strengthen existing technology transfer mechanisms.

                           Recommendations specific to Mexico
 Data gathering/monitoring/laboratory QA/QC

 322.  Undertake more environmental and trend studies.
 323.  Include different matrices (sediments, biota) in samples analyzed and develop a database on
      mercury concentrations in complex matrices
 324.  Mercury monitoring in Mexico (and for other metals/ POPs) should be national in scope, inclusive of
      the country's 10,000  km of coastline.
 325.  Involve academic laboratories, at least initially: infrastructure and capabilities are strongest at the
      moment in academic labs
 326   Once a foundation for measurements has been established, look at biological effects (biomarkers).
327   Link with similar programs in the United States and Canada.
328.  Continue development of the national network of certified laboratories, including laboratories that
      can analyze both for  mercury and methylmercury.
329   A strong QC/QA component is required that includes a strong training and capacity-building
      component with the United States and Canada for equipment,  etc.
330.  Reinforce quality assurance/quality control programs in North America through inter-comparison
      exercises that include independent verification and exchanges with laboratories in Canada and the
      United States, and among Mexican laboratories on mercury sampling and analysis.
331   Governmental and private laboratories are encouraged to participate in exchanges with Canadian
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       and US laboratories/associations in working toward trinational comparability as regards capacities
       for analyzing mercury in fish, sediment, air, etc.
 332.  Initiate a standardized process and inter-laboratory comparison procedures for analysis and
       sampling of mercury both as regards analysis of biological (people/fish and wildlife tissue) and
       environmental media samples (mercury in core samples, suspended sediment, water, air, etc.).
 333.  Use quality assurance/quality control samples to generate process control data. It is recommended
       that quality assurance/quality control procedures always use blanks; run duplicates and between-
       run duplicates, spikes and reference samples.
 334.  Encourage laboratories to work for national accreditation under the system that is now in place
       (Sistema Nacional de Acreditamiento de Laboratories de Pruebas or SINALP). As of 26 February
       1998, 49 laboratories have been certified  under SINALP, of which six are in the government sector,
       two in universities and the remainder in the private sector
 335.  Designate a person to calibrate instruments and check results at laboratory sites rather than having
       instruments shipped to a site for calibration.
 336.  Ensure that health measures (objectives,  sampling and analysis procedures) are coordinated with
       laboratory measurements and training plans

 Background geochemistry

 337.  Obtain a baseline geochemistry of Mexico to establish a foundation for establishing natural
       background levels of mercury and to predict where methylation may occur naturally. (This
       information will be useful in predicting contamination pathways, making determinations regarding
       sampling, etc)
 338.   Determine the natural movements and migrations of mercury in Mexico independent of human
 339   Determine if mercury is present naturally in ores mined in Mexico.


 340.   Determine or report on groundwater reserves in central Mexico: are they connected or are there
       several independent reservoirs?
 341.   Determine the organic content of water bodies to determine sites where conversion to
       methylmercury is most likely to occur.

 Speciation of mercury

 342.   Determine the speciation of metals in tailings at mining sites.
 343.   Determine whether tailings have any unique chemical or mineralogical "fingerprint" that could be
      used to identify their presence in environmental samples and distinguish  them from natural
      materials not associated with tailings.
 344.  Capacity-building is required to improve the pool of scientists (chemical, geophysical, etc.).
 345.  Develop financial mechanisms to raise money.
 346.  From El Paso to Mexico City there are approximately 200 small sites that may be contaminated with
      inorganic mercury and approximately 50 foundries that process lead and emit inorganic mercury.
      These should be assessed to determine the extent of concentrations in air, water and soil.
 347   Control or minimize open burning of municipal waste. (It was reported that municipal waste
      incinerators are not present in Mexico.)
348   Consider effects domestically within Mexico on consumption of tuna, shark, etc.. when sales to the
      United States are banned.
349.  Determine if there is a health problem in Mexico. Is there enough information to determine this?
350.  With the help of CEC, Mexico should start to develop projects concerning mercury,  its emissions,
      environmental fate, and the threat it poses to both environmental and public health. To this effect it
      is recommended that
         projects be coordinated and a network of studies of mercury be established. Possible
           members of this network could include researchers from the following institutions:
         -  Secretaria de Medio Ambiente, Recursos Naturales y Pesca (Semarnap),
         -  Institute Nacional de Ecologia (INE),
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          -   Institute Mexicano de Tecnologia del Agua (IMTA),
          -   Centro de Investigacion y de Estudios Avanzados (CINVESTAV),
          -   Umversidad Nacional Autonoma de Mexico (UNAM),
          -   Institute Politecmco Nacional (IPN),
          -   Comision Nacional del Agua (CNA),
          -   Institute Nacional de  Investigaciones Nucleares (ININ),
          -   Umversidad Autonoma  de San Luis Potosl (UASLP).
          -   Universidad Autonoma  de Zacatecas (UAZ), and
          -   the private sector (analytical laboratories, mining industry, chemical industry, etc.).
         the work to be done should  include'
          -   determine a mercury mass balance for Mexico, including identification of contaminated
          -   risk assessment of contaminated sites and proposals for remediation,
          -   review, adaptation, or formulation of emissions and exposure norms,
          -   adaptation of voluntary  initiatives for the reduction of mercury use and emissions already
              established elsewhere,
          -   investigation for the development of new technologies to replace those that involve
          -   environmental education of the general public, industrial and administrative sectors, and
          -   Establishment of a pilot project site (Zacatecas or some other site of interest).
           Impacts of these activities should be evaluated
351.  Within Mexico, conduct an assessment of the power generating and petroleum sectors to
      determine if they are sources of mercury. Look at other forms of electric generation and alternatives
      to coal.
352.  Develop a standard for mercury emissions.
353.  Amend legislation to alter the  requirement that hospital wastes containing mercury be incinerated.
354   Investigate use of tailings to determine if they are used to make flooring and tiles and whether they
      are baked in a  kiln/ incinerated.
355.  Coordinate efforts between Mexico's ministries of health, SEMARNAP and Education to inform
      general public of the general health risks of mercury.
356.  Educational program should include artisans and potters who currently use tailings.
357.  Consider if there are any components of Mexico's successes in educating the public about dangers
      of lead-based paints that can  be applied to education on mercury in Mexico or North America
358.  Solicit partnerships with Mexico  on existing voluntary initiatives in the United States and Canada.
359.  Obtain baseline information to assess the current situation in Mexico.
360.  Since resources are limited, set  priorities for efforts pertaining to mercury within in Mexico.
361.  Determine whether an inventory exists of mercury imported to Mexico for mining.

Atmospheric deposition

362.  Determine if research has been  conducted on deposition of mercury to Mexico via the atmosphere.
363.  Establish total gaseous mercury monitoring and wet deposition site(s) in Mexico to provide reliable
      data on ambient concentrations  in air, to establish mercury transport pathways, and to ascertain
      deposition patterns
364.   Report both low- and high-end values of results for gaseous-phase samples.
365.   Atmospheric monitoring in Mexico should include a station to sample mercury from active seismic
      and volcanic events

Sediment sampling

366.   Biological monitoring to determine ecosystem health and pathways for exposure to people and
      wildlife should include a system for sampling benthic organisms. The initial national sampling
      should  include an uncontammated site as a reference. All organisms should be identified using a
      Reference Condition  Approach or Benthic Assessment (BEAST). The contaminated (Zacatecas
      pilot project) site can serve subsequently for all sites within Mexico (i.e., it indicates the drop in the
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      variety of species, number of species that one can expect at a contaminated site in contrast to an
      uncontammated site)
 367.  To determine whether lakes/rivers are a source of mercury to the environment or wildlife
      (bioaccumulation), lake sediment and water should be sampled for both methylmercury and total
      mercury. (High organic content, low pH and warmer temperatures are apt to result in higher
      methylation rates.)
 368  Sampling to obtain a total  mercury budget (mass balance) requires a portable "clean lab", and
      rigorous sampling procedures to be accurate.
 369.  Sampling sediment should be undertaken when mercury methylation is likely to be at its peak, at
      regular intervals and, in river systems, over a period of several years in order to acquire an
      understanding of fluid processes. Sediment is sampled to determine concentration and toxicity of
      sediment, which is of more importance than distribution.
 370.  Understanding of speciation of metals in tailings,  as well as in sediment in lakes/rivers is important
      in determining bioavailability.
 371.  Where floods or runoff are important events (e.g., Zacatecas), suspended sediment sampling
      should be undertaken at the start of ram events to determine whether and how much suspended
      sediment or tailings are moving into La Zacatecana lagoon.
 372.  Suspended sediment should also be sampled over time during a week or two-month period, for
      example by placing sampling tubes in the bottom of a lake to trap sediment as it settles out of the
      water column.
 373.  Core samples of sediment are  recommended where there is a need to determine loadings in
      sediment, metal mobilization in bottom sediment and bioavailability (via examination of core water).

 Biomonitoring: People

 Screening procedures for general/susceptible populations
 374.  Develop written sampling protocols.
 375.  Prior to undertaking sampling of people within a community, hold discussions about potentially
      contaminated sites with local authorities and citizens, obtain available data on mercury and consult
      with citizens to determine local  concerns and cultural habits.
 376.  Focus initial screening on potentially high-exposure populations.
 377.  Prior to sampling  people, develop a process that assures confidentiality of results (to protect
      workers against job loss, to encourage participation, etc.) Results of any analyses should a/ways
      be provided to those sampled. Explain the reason for sampling, ensure that forms used to gather
      information guarantee confidentiality, and notify people sampled of how and when feedback will be
      provided Where exposure has occurred, even if not significant, it is recommended that feedback
      be provided in person (Local health providers could be used to provide this service.)
378   Take both hair and blood samples to acquire a record of exposure over time (hair) and a "snapshot"
      of exposure to methyimercury from recent consumption of contaminated food or by inhalation
379.  Keep results of sampling confidential to protect workers against job loss, to encourage participation,
      and to maintain confidence in program and agencies.
380.  Base screening values on  characteristics of a particular population.
381.  For the national program, determine whether fish that are consumed are contaminated and. if so,
      whether the levels present pose a health risk. Risk factors used to develop guidelines for
      consumption of fish for the general population may need to be recalculated for vulnerable
      populations  based on local consumption patterns and cultural practices. (Species eaten, amounts
      consumed, time of year consumed and location should be taken into account when collecting field
      samples, calculating risk factors and setting consumption guidelines.) When sampling to measure
      health risks, the edible portion of a standardized filet is used.
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 382.  Base national reference doses (RfDs) for people on exposure to methylmercury, using the end-
      point or outcome of neurodevelopmental delays in children in utero.*

 Biomonitoring: Wildlife

 383.  Define specific sampling and analysis criteria / methodologies for mercury aimed at determining
      biouptake of mercury (i e , methylmercury) and extent of bioaccumulation.
 384.  Sample fish when they are most frequently harvested Fish collected for sampling should be of the
      same species and of standardized length (older fish are more likely to have accumulated mercury).
      Where sampling is to determine contamination of wildlife, the whole fish is prepared for analysis.
      Both replicate samples (several samples from the same fish) and composite samples (several
      samples from a group of fish) should be taken. A written record-keeping protocol should be
      developed and followed, inclusive of a field record form, identification labels and chain-of-custody
      labels. Sampling protocols should include descriptions of appropriate sampling gear and equipment
      to prevent contamination of samples (from ice coolers, engine exhaust, etc.).  Detection limits
      should be below screening values
 385.  Develop protocols for accurate record keeping (field record form, sample identification labels, chain
      of custody labels, etc ) and field sample handling (appropriate sampling gear; preventative
      measures to ensure contamination does not occur from engine exhaust, ice cooler evaporation,

 Occupational health and safety

 386.  Encourage  agencies to work with management and employees to establish protocol procedures for
      good housekeeping (Posting of written/pictograph spill clean-up procedures on site, personal
      hygiene such as hand washing, changing clothes before returning home, etc.)
 387.  Establish procedures for site inspections (sampling of work surfaces, especially in lunchroom
      areas, effectiveness of engineering controls, full-shift personal sampling; area air sampling, etc.)
 388.  Conduct routine environmental, biological and medical monitoring. Keep all medical testing results
      confidential and report/explain their significance in detail to workers


389.  Review procedures used to dispose of/process mine tailings and based on the findings propose
      legislation for new tailings (may or may not pertain to processing).
390.  Examine past and present mining and mine-tailing reprocessing practices and their implications to
      risks of dispersion of mercury.
391.  Determine if more efficient technologies could be used for reprocessing tailings  given the relatively
      poor recovery of mercury from tailings (something like 200 ppm  mercury prior to processing
      reduced to just 60ppm-80 ppm after processing).
        The US EPA Mercuiy Report to Congress notes that" A major uncertainty in identification of dose-
        response m susceptible populations is the lack of data to generate separate RfDs for in utero, childhood
        and adult exposures " Because the range of methylmercury's half-life is 35>189 days "all women of
        reproductive capacity can be considered as a sensitive subpopulation for the developmental effects of
        methylmercury " Mercury Study Report to Congress, Volume VI- Characterization of Human Health and
        Wildlife Risks from Anthropogenic Mercury Emissions in the United States, EPA Office of Air Quality
        Planning & Standards and Office of Research and Development. September 12,1995 draft, pp. 2-8.10.
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