&EPA
United States
Environmental Protection
Agency
A Guide for Federal Agencies on Replacing
Mercury-Containing Non-Fever Thermometers
Office of Chemical Safety and
Pollution Prevention
Publication #740613001
June 2013
www.epa.gov
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Table of Contents
I. Introduction 3
A. Health and Environmental Issues 3
B. Federal Efforts 3
C. Costs to Clean up Mercury Spills 5
II. Where Mercury-Containing Non-Fever Thermometers May Be Found 5
III. Examples of Mercury-Free Non-Fever Thermometers 6
A. Resistance Temperature Detectors 6
B. Standard Platinum Resistance Thermometers 7
C. Thermistors 7
D. Thermocouples 8
E. Organic-Liquid-in-Glass Thermometers 9
F. Dial Thermometers and Bimetallic Thermometers 10
G. Infrared Thermometers 10
H. Comparison of Accuracies for Platinum Resistance Thermometers, Thermistors,
and Base-Metal Thermocouples 11
IV. Purchasing Mercury-Free Non-Fever Thermometers 12
V. Disposing of Mercury-Containing Non-Fever Thermometers 13
VI. References 14
Appendix: Sample Table for Tracking Mercury-Containing Thermometers Al
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I. Introduction
This guide provides federal agencies with information to help them identify and replace mercury-
containing non-fever thermometers in their facilities with mercury-free thermometers. The guide is also
intended to help federal agencies safely dispose of the removed thermometers. Fever thermometers
are not addressed in this document.
A. Health and Environmental Issues
Elemental (metallic) mercury primarily causes health effects when it is breathed as a vapor and
absorbed through the lungs. These exposures can occur when elemental mercury is spilled or products
that contain elemental mercury break and expose mercury to the air, particularly in warm or poorly-
ventilated indoor spaces. The factors that determine how severe the health effects are from mercury
exposure include the following: the chemical form of mercury; the dose; the age of the person exposed
(the fetus is the most susceptible); the duration of exposure; the route of exposure - inhalation,
ingestion, dermal contact, etc.; and the health of the person exposed.
Symptoms of exposure to elemental mercury can include these: tremors; emotional changes (e.g., mood
swings, irritability, nervousness, excessive shyness); insomnia; neuromuscular changes (such as
weakness, muscle atrophy, twitching); headaches; disturbances in sensations; changes in nerve
responses; performance deficits on tests of cognitive function. At higher exposures there may be kidney
effects, respiratory failure and death.
Mercury use in products such as thermometers can lead to releases to the environment during the
manufacturing of the products; from spills and breakage during use; and during the recycling, collection
and disposal of these products. Concerns about public health are primarily based on the risk of exposure
due to mercury spills not cleaned up properly and from improper disposal of broken thermometers
resulting in mercury releases through incineration or land application of sludge. Non-fever
thermometers are widely used in industrial, laboratory or health-care settings, but in most cases
effective non-mercury alternative products exist.
B. Federal Efforts
Executive Order 13514 (pdf) (11 pp, 151kb) About PDF ("Federal Leadership in Environmental, Energy and
Economic Performance") encourages federal agencies to advance environmental goals including
sustainable acquisition by acquiring products that are non-toxic or less toxic alternatives
(www.gpo.gov/fdsys/pkg/FR-2009-10-08/pdf/E9-24518.pdf). Replacing mercury-containing non-fever
thermometers with mercury-free devices is one way for federal agencies to work toward achieving this
goal.
As part of efforts to reduce the use of mercury in products, the U.S. Environmental Protection Agency
(EPA) is encouraging federal agencies, industry and others to phase out the use of mercury-containing
non-fever thermometers. An important barrier to phase-out has been the existence of industry and
government standards and test methods that specifically require laboratory and industrial mercury-in-
3
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glass thermometers. To address this technical problem, EPA has been working closely with other
standards-setting organizations to help revise government test methods or standards that require the
use of mercury-containing thermometers where effective and comparable mercury-free alternatives
exist.
The National Institute of Standards and Technology (NIST) is the primary U.S. government agency
devoted to advancing measurement science, standards, and technology. NIST has determined that
there are no fundamental barriers to the replacement of mercury-containing thermometers. As a result,
as of March 1, 2011, NIST no longer calibrates mercury-containing non-fever thermometers. This action
provides further incentive for government agencies to switch to mercury-free thermometers.
ASTM International, formerly known as the American Society for Testing and Materials (ASTM), develops
international voluntary consensus standards, and EPA incorporates many ASTM standards into its
regulations. ASTM is in the process of evaluating its approximately 839 standards that require mercury-
in-glass industrial and laboratory thermometers, and has begun updating its standards to allow use of
mercury-free thermometers wherever appropriate. For a list of updated ASTM standards, see ASTM
Standards Permitting Use of Alternative Non-Mercury Thermometers (pdf) (7 pp, 127 kb) About PDF
(www.epa.gov/hg/pdfs/astm_standards.pdf). Each time an ASTM standard referenced in an EPA
regulation is updated to allow increased flexibility to use mercury-free alternatives; EPA must then
update references to these methods in its regulations in order to allow a person subject to the
regulation to use the updated standard to fulfill the regulation's requirements. On January 18, 2012, EPA
issued a new rule (pdf) (11 pp, 198 kb) About PDF that updated references to three ASTM standards to
allow the use of mercury-free thermometers in certain field and laboratory applications relevant to
petroleum refining, power generation, and polychlorinated biphenyl (PCB) waste disposal
(www.gpo.gov/fdsys/pkg/FR-2012-01-18/pdf/2012-712.pdf).
In 2006 EPA initiated its own internal effort to replace mercury-containing non-fever thermometers. EPA
has now replaced the majority of mercury-containing non-fever thermometers in Agency labs
throughout the country. Since initiating the program, EPA labs removed and safely disposed of
approximately 2,000 mercury-containing non-fever thermometers. To learn more about the EPA's
initiative to phase-out the use of mercury-containing non-fever thermometers in industrial and
laboratory settings, visit our website (www.epa.gov/hg/thermometer.htm).
Other federal agencies have also taken steps to reduce their use of mercury-containing non-fever
thermometers. For example, the National Institutes of Health (NIH) established a Campaign for a
Mercury Free NIH (http://orf.od.nih.gov/environmentalprotection/mercuryfree/Pages/NIH-Mercury-
Hazard-Reduction-Campaign.aspx); and, through a 2008 policy
(http://oma.od.nih.gov/manualchapters/intramural/3033/index.html), created mandatory restrictions
on procurement, use, and disposal of mercury. The U.S. Department of State has language in its
Domestic Design Guidelines and Buildings Standards requiring that all thermostats be pneumatic
(mercury-free).
Case studies regarding other government efforts to transition to mercury-free non-fever thermometers
are available on the website of the Northeast Waste Management Officials' Association (NEWMOA).
These case studies include mercury assessments completed by a shipyard (pdf) (5 pp, 126 kb) About PDF
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(www.newmoa.org/publications/mercstudies/PortsmouthStudyl.pdf), an air force base (pdf) (5 pp, 175
kb) About PDF (www.newmoa.org/publications/mercstudies/HanscomStudy.pdf), and an environmental
laboratory (pdf) (4 pp, no kb) About PDF
(www.newmoa.org/publications/mercstudies/EPALabStudyl.pdf).
C. Costs to Clean up Mercury Spills
There are significant costs when cleaning up mercury spills. Spills tend to be more costly when the
mercury is widely scattered or located on porous surfaces (New York Dept. of Health, 2009). Few studies
have systematically assessed the cost of cleaning up mercury spills in different settings, but case studies
indicate that small mercury spills typically cost approximately $1,000; for larger spills, usually in
industrial or organizational settings, the cost can be more than $5,000 (Lowell Center for Sustainable
Production, 2003; U.S. EPA Region 9, 2002).
In addition to the direct costs of cleaning up a spill and disposing of mercury-containing waste, there
may be other costs associated with mercury spills. For example, Kaiser Permanente suggests that for
every dollar spent on a direct mercury spill response, $1.75 is incurred in costs associated with training,
fines, and treatment of exposure (Galligan et al., 2003).
As mentioned earlier, health and environmental costs may also be associated with mercury spills. While
few people may immediately become ill after a spill, mercury exposure can have lasting health effects
(Knoblauch, 2009). Mercury vapor levels are often higher in confined rooms with mercury spills even
after spill remediation, which can result in detrimental outcomes to human health and the environment
(Lowell Center for Sustainable Production, 2003). In addition, a spill is more dangerous when mercury
thermometers break in ovens or in incubators because mercury evaporates readily at high
temperatures, which creates high mercury concentrations.
Get information on preventing and cleaning up mercury releases and spills
(www.epa.gov/mercury/spills).
II. Where Mercury-Containing Non-Fever Thermometers May Be Found
Government agencies are encouraged to begin the process of phasing out mercury-containing non-fever
thermometers by surveying their facilities to assess where and how many of the devices still exist. While
most thermometers are found in laboratories, agencies may also find mercury-containing thermometers
in other facilities. In laboratories, mercury-containing non-fever thermometers may be used in
autoclaves, flash point equipment, incubators, ovens, refrigerators, and other devices, as well as for
calibrating other thermometers (both mercury-containing and mercury-free). HVAC/R systems can have
mercury-containing non-fever thermometers in multiple locations, including along steam and chill lines.
Health clinics, including dental facilities, may have such thermometers in sterilizers or refrigeration
units. Food-related facilities may have mercury-containing non-fever thermometers in refrigerators,
freezers, ovens, pressure cookers, and other equipment. Finally, mercury-containing non-fever
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thermometers are often used in tank farms to check the accuracy of temperature devices inside liquid
storage tanks.
EPA developed a sample table for surveying, tracking, and phasing out mercury-containing non-fever
thermometers. A template based on this sample table is included in the appendix. Other agencies may
find this useful for their own programs.
III. Examples of Mercury-Free Non-Fever Thermometers
Accurate and reliable alternatives to mercury-containing thermometers are available for most uses. In
this section, seven categories of such alternatives are described. The General Services Administration
(GSA) procurement website offers most types of mercury-free thermometers (www.gsaadvantage.gov/).
Note: Listing a product or website in this guide does not signify EPA's endorsement of the product or
website. Accuracies listed below may vary based on the application.
A. Resistance Temperature Detectors (RTDs)
A properly chosen RTD can be used to replace almost all mercury-containing non-fever thermometers.
The electrical resistance of the platinum or other metal rises as the temperature rises. The readout
converts the measured resistance to indicated temperature using either a standard curve or a
calibration function for the particular materials used in the probe. For high-vibration applications within
the temperature range of -100 °C to 150 °C (-148 °F to 302 °F), RTDs with platinum film deposited on a
ceramic chip work well (Strouse et al., 2010). For applications requiring broader temperature ranges or
less uncertainty, NIST recommends wire-wound RTDs. In both cases, the sensor is typically mounted in a
metal sheath (Strouse et al., 2010).
Temperature range:
RTD: -200 °C to 850 °C (-328 °F to 1562 °F)
Source: http://www.omega.com/rtd.html
Accuracy:
RTD: Grade A Tolerance = ±[0.13 +0.0017 * 111 ] °C
Grade B tolerance = ±[0.25 +0.0042 * |t | ] °C
Where: |t| is the absolute value of the RTD's temperature in °C.
Source: http://www.temperatures.com/sensors/csensors/resistance-temperature-detectors-
tds/4/
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B. Standard Platinum Resistance Thermometers (SPRTs)
A special class of highly accurate RTDs (see above), SPRTs utilize reference grade platinum wire and can
cost many thousands of dollars. While not very durable, their utility over a wide temperature range and
excellent accuracy can make them an important category of mercury-free thermometers for certain uses
(Iman).
Temperature range:
SPRT: -259 °C to 962 °C (-434 °F to 1763 °F)
Source: (Li, 1996)
Accuracy:
SPRT: 0.001 °C(± 0.002 °F)
Source: (Li, 1996)
C. Thermistors
Thermistors work well in the range of -20 °C to 100 °C (-4 °F to 212 °F). Thermistors' probes consist of
ceramic material, in contrast to the metallic probes found in RTDs. Most stable when sealed with a glass
coating, thermistors are best suited for uses with a low risk of mechanical shock (Strouse et al., 2010).
The electrical resistance of the blend of metal oxides in these devices decreases as the temperature
increases (Strouse et al., 2010).
Temperature range:
-40 °C to 150 °C (-40 °F to 302 °F)
Source: http://www.efunda.com/designstandards/sensors/thermistors/thermistors intro.cfm
Accuracy:
±0.1°C(±0.18°F)or
± 0.02 °C(± 0.036 °F)
Source: http://www.omega.com/prodinfo/thermistor.html
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D. Thermocouples
Thermocouple temperature sensors are the preferred option for applications involving mechanical
shock and vibration. These devices measure the electric potential between two dissimilar metals, which
varies with temperature. The International Society for Automation (ISA) Thermocouple Types E, J, K, N
and T contain base-metals and can be used to measure temperatures up to approximately 1000 °C (1832
°F). Types S, R, and B contain noble-metals and can be used to measure temperatures up to
approximately 2000 °C (3632 °F). The table below provides temperature range and accuracy information
for a variety of thermocouples.
Table 1.
Properties of ISA Type Thermocouples
ISA Type
E
J
K
N
T
B
R
S
Temperature
Range °C
(contin-
uous)
0 to +800
0 to +750
Oto
+1100
Oto
+1100
-185 to
+300
+200 to
+1700
Oto
+1600
0 to 1600
(short-
term)
-40 to
+900
-180 to
+800
-180 to
+1300
-270 to
+1300
-250 to
+400
Oto
+1820
-50 to
+1700
-50 to
+1750
Accuracy Class One
±1.5 between -40 °C and 375 °C ±0.004xT
between 375 °C and 800 °C
±1.5 between -40 °C and 375 °C ±0.004xT
between 375 °C and 750 °C
±1.5 between -40 °C and 375 °C ±0.004xT
between 375 °C and 1000 °C
±1.5 between -40 °C and 375 °C ±0.004xT
between 375 °C and 1000 °C
±0.5 between -40 °C and 125 °C ±0.004xT
between 125 °C and 350 °C
Not Available
±1.0 between 0 °C and 1100 °C ±[1 +
0.003x(T - 1100)] between 1100 °C and
1600 °C
±1.0 between 0 °C and 1100 °C ±[1 +
0.003x(T - 1100)] between 1100 °C and
1600 °C
Accuracy Class Two
±2.5 between -40 °C and 333 °C ±0.0075x1
between 333 °C and 900 °C
±2.5 between -40 °C and 333 °C ±0.0075x1
between 333 °C and 750 °C
±2.5 between -40 °C and 333 °C ±0.0075x1
between 333 °C and 1200 °C
±2.5 between -40 °C and 333 °C ±0.0075x1
between 333 °C and 1200 °C
±1.0 between -40 °C and 133 °C ±0.0075x1
between 133 °C and 350 °C
±0.0025x1 between 600 °C and 1700 °C
±1.5 between 0 °C and 600 °C ±0.0025x1
between 600 °C and 1600 °C
±1.5 between 0 °C and 600 °C ±0.0025x1
between 600 °C and 1600 °C
Note: The accuracy classes are differentiated by their tolerances, which also vary by thermocouple type and
temperature range. T represents temperature in degrees C.
ISA Type Thermocouple Materials:
E Chromel & Constantan (Ni-Cr & Cu-Ni)
J Iron & Constantan (Fe & Cu-Ni)
K Chromel &Alumel (Ni-Cr & Ni-AI)
N Nicrosil-Nisil (Nickel-Chromium-Silicon/Nickel-Silicon)
T Copper & Constantan (Cu & Cu-Ni)
B 70% Platinum/30% Rhodium & 94% Platinum/6% Rhodium
R Platinum & 87% Platinum/13% Rhodium (Pt & Pt-Rh)
S Platinum & 90% Platinum/10% Rhodium (Pt & Pt-Rh)
Source:
http://thermalfluidscentral.org/encyclopedia/index.php/Temperature measurements and instrumentation
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E. Organic-Liquid-in-Glass Thermometers
Organic-liquid-in-glass thermometers work well within the temperature range of -100 °C to 100 °C (-148
°F to 212 °F) and when an uncertainty of 0.5 °C (1 °F) is acceptable. Comprised of a glass bulb and
cylinder, these simple thermometers contain a liquid such as alcohol or pentane. As the temperature
within the bulb increases, the liquid expands along the cylinder. The following table compares
temperature range and accuracy information for mercury and organic-liquid-in-glass substitutes.
Table 2.
ASTM Organic Liquid-ln-Glass Thermometers
ASTM Mercury
Thermometers
5C/5F
12C/12F
18C / 18F
22C/22F
56C/56F
58C/58F
59C/59F
62C/62F
63C/63F
64C / 64F
65C/65F
66C/66F
67C/67F
91C
116C
117C
120C
130C / 130F
ASTM Organic
Thermometers*
S5C/S5F
S12C/S12F
S18C/S18F
S22C/S22F
S56C/S56F
S58C/S58F
S59C/S59F
S62C/S62F
S63C/S63F
S64C/S64F
S65C/S65F
S66C/S66F
S67C/S67F
S91C
S116C
S117C
S120C
S130C/S130F
Temperature Range
-38 to 50 °C (-35 to +120 °F)
-20 to 102 °C (-5 to 215°F)
34 to 42 °C (94 to 108 °F)
95 to 103 °C (204 to 218 °F)
19 to 35 °C (66 to 95 °F)
-34 to 49 °C (-30 to 120°F)
-18to82°C(Otol80°F)
-38 to 2 °C (-36 to + 35 °F)
-8to32°C(18to89°F)
22 to 55 °C (77 to 131 °F)
50 to 80 °C (122 to 176 °F)
75 to 105 °C (167 to 221 °F)
95 to 155 °C (203 to 311 °F)
20 to 50 °C
18.9 to 25.1 °C
23.9 to 30.1 °C
38.6 to 41.4 °C
-7 to 105 °C (20 to 220 °F)
Scale Error, Max**
0.5°C(1°F)
0.15 °C (0.25 °F)
0.1°C(0.2°F)
0.1°C(0.2°F)
0.10°C(0.20°F)
0.3°C(0.5°F)
0.3 °C (0.5 °F)
0.1°C(0.2°F)
0.1°C(0.2°F)
0.1°C(0.2°F)
0.1°C(0.2°F)
0.1°C(0.2°F)
0.2 °C (0.5 °F)
0.1°C(0.2°F)
0.1°C(0.2°F)
0.1°C(0.2°F)
0.1°C(0.2°F)
0.5°C(1°F)
*The S's preceding the thermometer numbers in this column denote the use of mercury-free organic
liquid.
**Scale error is a measure of accuracy and tolerance.
Sources: ASTM Designation El-07: Standard Specification for ASTM Liquid-in-Glass Thermometers.
ASTM Designation E2251-11: Standard Specification for Liquid-in-Glass ASTM Thermometers
with Low Hazardous Precision Liquid.
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F. Dial Thermometers and Bimetallic Thermometers
Dial thermometers have a wide range of uses. They feature a dial pointer attached to a temperature
detector or sensor. The temperature sensor may be a metal strip with two different metals bound
together in a helical structure, with each metal expanding and contracting at unequal rates
corresponding to changes in temperature. This results in the metal strip curling and moving the pointer
to varying temperatures. In addition, dial thermometers with fluid-filled temperature sensors are
manufactured with liquids (such as proprietary organic liquids)/ gases (such as nitrogen) or vapors (such
as glycerine, silicone, or glycerine/water) as actuation materials. These actuation materials expand and
contract with changes in temperature and revolve the dial pointer, similar to the way in which bimetallic
strips work.
Temperature range:
-73 °Cto 538 °C (-100 °F to +1000 °F)
Source: http://www.reotemp.com/pdf/card.0310.pdf
Accuracy:
± 1.0% of the device's full temperature scale, typically
Source: http://www.reotemp.com/bimetal dial-thermometers.html
G. Infrared Thermometers
Infrared thermometers detect radiance and can be used to measure high temperatures in applications
such as the processing and handling of asphalt. As the technology improves, these devices may become
useful for other purposes.
Temperature Range:
-60 °C to 860 °C (-76 °F to 1580 °F)
Source: http://www.omega.com/manuals/manualpdf/M4424.pdf
Extended range:
Extended range infrared thermometers are also available, but generally more expensive.
550 °C to 3300 °C (1022 °F to 5972 °F)
Source: http://lumasenseinc.com/EN/products/infrared-thermometers-and-switches/series-
140/pyrometer-impac-is-140-pb.html
Accuracy:
±1.0 "C (± 1.8 °F)
Source: http://www.omega.com/manuals/manualpdf/M4424.pdf
0.3% of measured value in °C for < 1500 °C (2732 °F)
0.5% of measured value in °C for > 1500 °C (2732 °F)
Mercury is sometimes used as the actuating liquid in dial thermometers; therefore, when seeking to use dial thermometers as
non-mercury alternatives, users should exercise care in avoiding mercury-filled dial thermometers.
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H.
Source:
http://lumasenseinc.com/uploads/Products/lmpac/pdf/Datasheets/Pyrometer/Series 140/IS14
0 IGA140 PB Datasheet.pdf
Comparison of Accuracies for Platinum Resistance Thermometers, Thermistors, and
Base-Metal Thermocouples
Figure 1 summarizes typical manufacturing tolerances or accuracies for a variety of mercury-free
thermometers in units of degrees Celsius. Low tolerance correlates to high accuracy. Calibrated
thermistors have the lowest tolerance and the highest accuracy, but their temperature range is smaller
than those of platinum resistance thermometers and thermocouples.
Figure 1.
Accuracies of Platinum Resistance Thermometers (PRTs), Thermistors, and Base-Metal Thermocouples
with 0.001 to 10.000 Tolerances and -200 to +500 °C Temperatures
PRT, ASTM Class A PRT, calibrated
—Thermistor, interchangeable Thermistor, calibrated
— Base-metal thermocouple
O 10.000
t
03
8 1.000
S
0.100
8
o 0.010
8
§
0.001
-200 -100
0
100
200
300
400
500
Temperature, °C
Source: Strouse et al., 2010.
Includes allowances for sensor drift and readout uncertainties.
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IV. Purchasing Mercury-Free Non-Fever Thermometers
Using mercury-free thermometers in place of mercury-containing thermometers saves on the longer-
term costs or life cycle costs (the cost of a thermometer from purchase to disposal). Choosing to use
mercury-free thermometers also reduces the risk of exposures to mercury due to potential mercury
spills. While the purchase cost of a mercury-free thermometer can be higher, that cost does not reflect
the full life cycle cost of a mercury-containing thermometer because (1) if the thermometer were to
break, a cost would be incurred for spill clean-up, and (2) at the end of the thermometer's useful life, a
cost would be incurred to properly dispose of the mercury thermometer. Therefore, the life cycle costs,
including cleaning up mercury spills, and the training, compliance, and liability associated with
preventing or addressing those spills, as well as disposing of the mercury-containing thermometers are
likely to be more expensive in the long run. Considering these potentials costs, many organizations see a
mercury-free purchasing policy as the best economic policy (Health Care Without Harm).
Mercury-free thermometers are becoming more competitive in purchase price as market demand
increases. U.S. EPA compiled Table 3 (below) based on costs for several types of thermometers available
at www.gsaadvantage.gov.
Table 3: Cost Comparison between Mercury-Containing and Mercury-Free Thermometers
Thermometers
Mercury-in-Glass Thermometers
ASTM Certified/Calibrated
Organic Liquid-in-Glass Thermometers
ASTM Certified/Calibrated
Resistance Temperature Detectors
(RTDs) (hand-Held)
Calibration/Multitasking2
Probes
Thermistors (Hand-Held)
Calibration/Multitasking
Probes
Probe (Certified)
Thermocouples (Hand-Held)
Calibration/Multitasking2
Probes
Dial Thermometer (Bimetal/General)
Vapor/Gas Actuated
Infrared Thermometers (General
Purpose)
Calibration/Multitasking
Standard Platinum Resistance
Thermometers
Price Range
$24.35 to $34.58
$255.35 to $461.22
$7.62.00 to $86. 20
$216. 25 to $1,345.38
$50.37 to $594.08
$288.99 to $1593. 13
$11.61 to $240.99
$35. 57 to $427. 12
$921.50 to $5,545.86
$8.21 to $29.60
$986.96
$18.25 to $446.07
$186.63 to $3,387.90
$11.57 to $477.33
$1.25 to $322.01
$17.38 to $380.83
$27.68 to $1,399.89
$1,8171.49 to $7,912.80
Range not available1
Average Price
$29.47
$358.29
$46.91
$780.82
$322.23
$941.06
$136.80
$231.35
$3233.68
$18.91
$986.96
$232.16
$1787.27
$244.45
$161.53
$199.11
$713.79
$13,042.15
Available in the market for about $4,500 or more.
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Multitasking includes: Thermometer/transducer w. 4 to 20 mA output; Temperature Reference Kit;
Intrinsically Safe feature; Thermometers with multiple probes; Calorimetric Thermometer.
V. Disposing of Mercury-Containing Non-Fever Thermometers
Once your Agency decides to replace and dispose of mercury-containing non-fever thermometers, they
are hazardous waste that is regulated under federal and sometimes state laws. Under the federal
Resource Conservation and Recovery Act (RCRA), mercury-containing equipment, such as
thermometers, can be managed according to standards for hazardous waste or by an alternative set of
standards for what is known as universal waste. EPA established alternative standards to make it easier
to collect mercury-containing equipment and other universal wastes for recycling or disposal. They
require that people handling this equipment prevent releases to the environment by following specified
procedures, such as placing it in labeled, sturdy, closed containers that do not leak. The federal universal
waste regulations can be found at 40 CFR Part 273.13(c) and 273.33(c). See additional information
(www.epa.gov/epawaste/hazard/wastetypes/universal/mce.htm).
Some federal agencies have existing arrangements for managing universal wastes such as spent
batteries, fluorescent light bulbs, or other mercury or non-mercury wastes. Thermometers can be
managed along with these other universal wastes; often this means the wastes are collected by or taken
to a waste management or environmental services company. The procedures of one federal agency are
available here (http://oma.od.nih.gov/manualchapters/intramural/3033/index.html). If your Agency
does not already recycle mercury items, you can find a list of mercury recyclers at Earth911.org. Note
that if a mercury-containing device is broken and the mercury is loose, it can no longer be managed as
universal waste and must be managed under the RCRA hazardous waste regulations. Agencies that
generate hazardous wastes sometimes have existing arrangements (e.g. a contract with a waste
management provider) to comply with the RCRA regulations, and thermometers could be added to
those hazardous wastes. The RCRA requirements for generators of hazardous waste are found at 40 CFR
Part 262.
State regulations may be more stringent or broader in scope than the federal RCRA waste management
program and may vary from state to state. Agencies are encouraged to contact their state
environmental regulators for more information on requirements applicable in a particular state. Read
more about state-specific requirements
(www.epa.gov/epawaste/hazard/wastetypes/universal/statespf.htm).
13
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VI. References
eFunda. Introduction to thermocouples-overview. Retrieved from
http://www.efunda.com/designstandards/sensors/thermocouples/thmcple intro.cfm.
Galligan, C, Morose, G. & Giordani, J. (2003). An investigation of alternatives to mercury containing
products. University of Massachusetts. Retrieved from
http://www.sustainableproduction.org/downloads/An%20lnvestigation%20Hg.pdf.
Health Care Without Harm. Mercury-free medical devices: affordability. Retrieved from
http://www.noharm.org/seasia/issues/toxins/mercury/alternatives.php.
Knoblauch, J. (2009). Dangerous mercury spills still trouble schoolchildren. Scientific American, 10.
Retrieved from https://www.scientificamerican.com/article.cfm?id=mercurv-spills-trouble-
schoolchildren.
Iman, S. Why did my temperature sensor fail calibration? Fluke Corporation. Retrieved from
http://us.flukecal.com/literature/articles-and-education/temperature-calibration/papers-articles/why-
did-my-temperature-sen.
Li, Xumo. (1996). Producing the highest accuracy from SPRTs. Hart Scientific. Measurement and Control.
Retrieved from http://us.flukecal.com/categorv/literature-type/articles-and-education.
New York State Dept. of Health. (2009). Mercury spill incidents - data and resources. Retrieved from
http://www.health.nv.gov/environmental/chemicals/hsees/mercurv/mercury spill incidents.htm.
Strouse, G., Cross, D., Miller, W., & Ripple, D. (2010). User-friendly guidance on the replacement of
mercury thermometers. Environmental Protection Agency and the National Institute of Standards and
Technology. Retrieved from http://www.epa.gov/hg/pdfs/nistuserfriendlyguide.pdf
Lowell Center for Sustainable Production. (2003). Mercury spills - how much do they cost. Retrieved
from http://www.sustainablehospitals.org/PDF/IP spills cost.pdf.
U.S. EPA Region 9. (2002). Eliminating mercury in hospitals. Retrieved from
http://www.epa.gov/region9/waste/p2/proiects/hospital/mercury.pdf.
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Location
Contact
Number of
Mercury-Containing
Thermometers:
Removed
from
Service
in
[YEAR]
Present
at the
End of
[YEAR]
Detailed Information About the Remaining Mercury-
Containing Thermometers:
Brand/Manufacturer
Name and Model
Number or ASTM
Number
Quantity
Primary
Use or
Application
Is
Substitution
Possible?
(Explain)
Additional
Information:
Barriers/Limitations That Impede
the Use of Non-Mercury
Alternatives:
vt
Regulatio
S2
Method
Para mete
vt
ASTM or
Externa
Standard
01
Lack of
Alternativ
> 1
-E O
Technical/P
ical Limitati
Al
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Al
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