The EPA's Mercurial Madness

Guest Post by Willis Eschenbach

In the process of writing my piece about Lisa Jackson and the EPA, I got to reading about the EPA passing new mercury regulations. Their regulations are supposed to save the lives of some 11,000 people per year. So I figured I should learn something about mercury. It turned out to be quite surprising … here was my first surprise:

Figure 1. Natural and anthropogenic sources of atmospheric mercury emissions. About 7,500 tonnes of mercury are emitted into the atmosphere each year. Named countries show anthropogenic (human caused) emissions for that country.

My first surprise was that far and away the largest emitter of atmospheric mercury is the ocean. The ocean? I’d never have guessed that. Other huge emitters are various lightly vegetated land areas. In addition, forests, volcanoes, and geothermal vents are significant emitters … which is the reason for my new religious crusade:

So … what are the anthropogenic sources of mercury emissions, and how much of those are emitted from North America? Figure 2 shows those values:

Figure 2. North American emissions versus the rest of the world.

As you can see, North America is not doing well at all in the mercury emission sweepstakes. The rest of the world is busting our chops, easily out-emitting us in all categories. We’ve fallen way, way behind, the Chinese are kicking our emissionary fundament-als. Not only that, but the residence time for mercury in the atmosphere is about a year, so they get our mercury … but we also get theirs …

Now, the “stationary combustion” figures are what the EPA is targeting with their new restrictions. Those are mostly the coal-fired power plants. So let’s see how much of the global emissions are caused by US power plants:

Figure 3. US power plant mercury emissions, and emissions from all other sources.

As you can see, the US power plants emit less than 1% of the global mercury emissions. Even if the EPA could get rid of every US coal plant, it will not make a measurable difference in the atmospheric mercury.

Now, here comes the fun part. The new EPA regulations will not cut out all the mercury from US power plants. We’re already pretty efficient at removing mercury, and each additional reduction comes with more difficulty.

So let’s assume that the EPA regs will cut out 25 tonnes of mercury per year. This is supposed to save 11,000 lives every year. So that means if we could wave a magical wand and cut out all of the mercury, 100 percent of it, we should expect to save about 11,000 times 7500/25 = 11,000 times 300 = 3,300,000 lives saved every year … and if you believe that three million people die every year from mercury poisoning, you too could get a job with the EPA.

That’s the thing about facts. As Homer Simpson says,

Facts are meaningless. You could use facts to prove anything that’s even remotely true!


All data from N. Pirrone et al., Global mercury emissions to the atmosphere from anthropogenic and natural sources, Atmospheric Chemistry and Physics, 2010 

For further reading, see Willie Soon’s excellent analysis of the EPA “science” on which they have based their mercury findings.

[UPDATE] To better illustrate the total natural and anthropogenic mercury emissions, here is a different version of the same data shown in Figure 1.

Natural sources account for about 70% of the world’s total mercury emissions.



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Owen in Ga

The EPA doesn’t need all that sciencey stuff…they have Gaia. Faith always trumps that hard thinking stuff.

Someone might think that ,really, the environment has nothing to do with these regulations.
It’s about power, money and power.


The regs cover…mercury, arsenic, acid gas, nickel, selenium and cyanides, not just mercury.
You cannot ‘assume’ 25 tonnes of mercury equates to 11,000 deaths prevented….I cannot find the amount the EPA expects the regs to remove from the environment, maybe you have some numbers………..

If you get a second, you should mention that compact fluorescent lights (CFL’s) contain about 4 milligrams (mg) of mercury. If we assume one broken bulb per household at 114,235,996 households in the US, that is 0.46 tonnes of mercury per year or 0.71% of the US total. If the EPA is successful in cutting emissions by 25 tonnes, this percentage increases to 1.2%. Hence CFL’s will then contribute as much of the US mercury as the US contributes to overall mercury. We should ban them.
Note that vaccines are something the UN wants to ban.
These guys:
(hope that cut and paste of the link worked!)

Bob W in NC

OK. So – I’m curious…the EPA wants to decrease mercury entering the environment, right? But, in the next year or so, we’ll all be having to use CFL bulbs, at about 5 mg mercury each.
Has anyone calculated how much mercury these will spill into the environment as they are thrown away? I know they are supposed to be recycled, but doubt seriously how effective that will be.
At 20 of these things per household, that’s 100 mg. Multiply that by the number of households in the US or North America, and how many tonnes are estimated?


Mercury is a genuine and serious pollutant. If EPA would confine itself to controlling genuine and serious pollutants like this, I wouldn’t have any problem with them.
It’s the other nonsense about carbon and biodiversity that makes them dangerous and requires the agency to be abolished. (After a bureaucracy tastes blood, there’s no way to take it back to sanity.)


Thank you Willis for a well presented article. Those of us who live in States in the USA already knew how little mercury is emitted. Hopefully, more will know and understand this now.


Silly, really that they’ll reduce power plant emissions but required to use them in our homes where, if broken, we’ll get a lung full of it. Praying for Obama to loose so that this extremist Jackson gets canned.


It’s pretty obvious that the current Administration is anti-military… but that doesn’t stop them from adopting military tactics. What I see them doing is employing a classical pincer movement whereby coal fired energy production is being attacked from multiple directions with CO2/global warming being the primary thrust (at least for now) and the other flank being attacked through their efforts concerning mercury pollution (for now). I’m sure that they have other things waiting in the wings…

Reblogged this on Climate Ponderings and commented:
Willis Eschenbach on Mercury poisoned EPA regs.

Raymond Kuntz

Also see:
Volcano ‘Pollution’ Solves Mercury Mystery @

kadaka (KD Knoebel)

If the moderators will allow it, I’ll recycle most of a comment I made last December when I also found out how shockingly low the US power plant emissions were.
Now compare that to this April 07, 2011 newspaper account of a growing Hg contamination issue:

Demand for CFL bulbs is growing as government mandates for energy-efficient lighting take effect, yet only about 2% of residential consumers and one-third of businesses recycle the new bulbs, according to the Assn. of Lighting and Mercury Recyclers.
As a result, U.S. landfills are releasing more than 4 tons of mercury annually into the atmosphere and storm water runoff, according to a study in the Journal of the Air and Waste Management Assn.
A San Francisco hardware store owner is all too familiar with the bulb issue.
“They’re promoting them and giving them away, but there’s nowhere to drop them off,” said Tom Tognetti, co-owner of Fredricksen’s Hardware.

I continually find this issue obfuscated by claims that the energy savings lead to reduced demand on coal-fired electric plants yielding less Hg emissions at those plants. To wit:

CFL bulbs actually have fewer mercury concerns than incandescent lights, according to the California Energy Commission. Although the older bulbs contain no mercury, they’re often powered by coal-fired electricity plants, which release mercury as a pollutant. The result is about 40% less mercury emissions per bulb with CFLs, according to Environmental Protection Agency figures.

Some claims are even more extreme:

Generating power is the number one contributor of mercury in the environment. CFLs save up to 70% of lighting energy, which means that power plants can produce 70% less power, which means 70% less mercury in the atmosphere.

Strangely enough, this claim does not factor in the Hg emissions from any coal-fired energy sources for the energy used in manufacturing and recycling CFL’s, let alone the Hg emissions from obtaining the Hg and manufacturing process releases. The 70% can be figured by a Nov 2010 EPA document (fine print says it’s a “living document” subject to change):
Which makes an amazing claim:

Most mercury vapor inside fluorescent light bulbs becomes bound to the inside of the light bulb as it is used. EPA estimates that the rest of the mercury within a CFL – about 11 percent – is released into air or water when it is sent to a landfill, assuming the light bulb is broken.

This allows them to significantly downgrade their estimate of Hg released. And they are also not mentioning the Hg emissions related to manufacturing, and recycling including recovering the Hg from the toxic glass, if possible. Since the EPA thinks 89% of the Hg will stay forever bound to the glass in a landfill, it must take a lot of energy to liberate the Hg when recycling. Looks like there may be even more Hg released by recycling than just chucking them into a landfill.
So the EPA wants to regulate out of existence the coal-fired power plants that release only a relatively tiny bit of worldwide Hg emissions. But they want us to use CFL’s while being less than precise about the Hg emissions involved. And if you’re really worried about those coal-fired power plant emissions, ask yourself this: Which gives you a more severe exposure to Hg, those plant emissions spread out across the map, or a single CFL broken in your house? With EPA recommendations of ventilating a room for several hours with outdoor air after breaking a CFL, the answer should be obvious.


They should really be renamed the EPR, the Environmental Protection Racket


These people made up their minds a long time ago that they do not like the use of cheap energy be it coal, oil, or nuclear. If they can’t use mercury as the excuse, they will invent a reason to ban cheap energy even if they have to demonize plant food to do it. Cheap energy means prosperity, prosperity means an expanding human population, and having to share this planet with an ever increasing hoard of human “infestation” is the last thing they want.

Nick in Vancouver

Clearly the EPA needs to ban China, oh wait we’ve “outsourced” all our manufacturing there what will we do? “only take what you need to survive” – Spaceballs the movie – ahead of its time in so many ways The inspiration for the whole environmental movement..

Nick in Vancouver

Some person in a previous thread remarked that a plastic shopping bag full of old CFLs inadvertantly “dropped” in your local legislative building contains enough mercury to trigger an evacuation of the building and a full HAZMAT response. Democracy at work.
Our newish Conservative government, here in Canada, has shelved the phase out of incandescants even though they have all been pulled from our local stores (????). Ive got a closet stuffed with em and as the old softee Charlton Heston remarked they’ll have to – gently and slowly – pry my incandescents from my cold dead hands. If you check out Charltons’ quote he aims it at Mr. Gore – wow that guy is into everything – but was referring to another environmental hazard.

Yep, another example of “because we can measure it we must use that to model the world into our vision of how it should be.” The usual dogma, from the usual demigods, selling another false theology. I’m not sure what is worst the false theologies of the present and past or these new ones.

Actually, I think mercury is a serious problem with modern civilization. Whether or not the measures intended to control it are or are not likely to be effective, mercury is a very bad molecule to be carrying around in your body. However, the problem isn’t elemental mercury — you could drink a cup full of liquid mercury and suffer very little in the way of side effects (and people used to do just this back when they were searching for medicines, read Stephenson’s “Quicksilver” in the Baroque Cycle) — it is mercury compounds, in particular (IIRC) methyl mercury and mercuric cyanide. Mercury vapor isn’t good for you, but it is unusual to build up a vapor concentration that is dangerous — it needs spilled mercury in a closed warm room sitting a long time with little circulation to get an equilibrium vapor pressure with potential toxicity — even releasing the mercury vapor in a fluorescent bulb only makes the air around it moderately toxic for a few minutes.
Methyl mercury is a very bad actor — produced by bacteria, toxic enough to kill you if a single drop gets on your skin, and the cyanic variants are just as bad. Mercury has a rather long half life in the body, concentrating in fatty tissue in things like the liver. It acts among other ways as an oxidant, damaging cellular DNA. The body doesn’t like heavy metals, and mercury probably beats out lead as being a heavy metal it doesn’t like. You can read about mercury objectively here:
One of the problems with mercury is that it does not remain uniformly diluted at harmless concentrations. Once aerosolized from e.g. the burning of coal, it falls as rain into waterways, is transformed by bacteria into methyl mercury and related organic forms, is eaten by the things that eat the bacteria and starts making its way up the food chain, concentrating as it goes. In particular, it concentrates in top of the food chain fish. As a fisherman, I totally appreciate that because nearly any large fish I fish for has measurable concentration of mercury in its flesh.
This too isn’t uniform. In Eastern NC they used to make paper. Paper mills used liquid mercury to electrolyze salt into chlorine to bleach the paper. One mill in particular went out of business — they just went bankrupt and the owners walked away, leaving the whole thing to moulder including the mercury pits. Forty years passed, and the mercury vats corroded through, and tons of mercury literally poured out onto the swampy ground. When this was finally discovered — we’re talking rural and stuck out on a back road where nobody ever went but occasional deer hunters — the ground near the plant was so saturated that mercury would ooze up out of the mud when investigators walked towards the buildings.
Mercury in contact with ground = active source of methyl mercury operating over years, with the methyl mercury leaching into groundwater and down into the nearby (IIRC) Neuse River and thence down to the NC sounds and the sea. Predators like catfish and bass taken near the plant were horribly toxic and probably did kill a lot of people (decades later) with cancer and various linked diseases and disorders — it doesn’t act quickly but it acts; elevated levels of mercury were evident in fish sampled all the way down to and out in the ocean. It took years and lots of state money to clean it up (because the original owners were all dead and the heirs didn’t even know they had a problem and had no money anyway).
Another place where the problem is evident is the Great Lakes. Visit Michigan’s DNR website and look over it’s recommendations on eating fish taken from the Great Lakes — no more than one meal of fish a month (and none for pregnant women) because the fish are so damn toxic with cumulated mercury and PCBs. Certain fish (e.g. catfish) they suggest not eating at all. Certain places (e.g. Saginaw Bay) those of us who sometimes fished there knew better than to keep fish — Saginaw is surrounded by industries and has a far higher concentration of mercury and PCBs than the average, even for the Great Lakes. They are trying to clean them up, but it takes decades of regulation and elimination of new sources to drop the concentrations to where things get better, and it will probably be 2100 before fish taken there are anything close to safe to eat in quantity.
Mercury will, given enough time, flush out even of the oceans — methyl mercury from the mercury we are ADDING to the ocean every year will enter the food chain and eventually make its way to the bottom to build up in the rain of silt that is eventually subducted and a few hundred million years from now reforged into rock. There are doubtless natural sources — leaching out of mercury ores (cinnabar) in rivers and the like — but we (humans) are by far the biggest source of mercury, and we do not distribute that mercury at all evenly and the biosphere concentrates that which we do produce. The mercury vapor given off by the ocean is probably harmless. The biologically active mercury in the oceans is definitely not harmless. The mercury we produce eventually becomes biologically active and increases the concentration of non-harmless mercury to actively dangerous levels, generally in specific spatial locations but also in particular species that appear particularly susceptible (e.g. swordfish) in the ocean.
Mercury, in addition to be a teratogen (causing birth defects), toxin (poisonous enough to kill you directly), carcinogen (as a DNA-damaging oxidative agent readily taken up and stored in tissue), has a pronounced CNS effect — it crosses the blood brain barrier and causes damage to nervous tissue. It is mad as a hatter to oppose reasonable efforts to reduce the levels of mercury in the environment, or try to claim that the mercury that is there is harmless and that we didn’t put a lot of it there right where it is most dangerous. Dissenters are invited to take their pregnant wives and visit sunny Michigan for a Saginaw Fish Fry.
Well, no, I suppose I’m kidding — it really isn’t funny, and I wouldn’t wish birth defects on anyone for the sin of disagreeing or being wrong about something, but there really is a rather large amount of science and experience behind this and sometimes even the overdemonized EPA gets things right. Indeed, overall I rather think it is a good thing, because we made a bloody mess out of our waterways and air quality before it came along, and a lot of what it does anyone with common sense would want done. Don’t throw the many babies it provides out with the bathwater of misdirected efforts treating CO_2 as a “pollutant”.
Mercury is many things, but one thing it isn’t is equivalent to CO_2 in toxicity or long term capacity to cause harm.


Maybe the plan is to save us from the light bulbs…
….by cutting off the power


Nick in Vancouver says:
March 31, 2012 at 7:07 am
Clearly the EPA needs to ban China, oh wait we’ve “outsourced” all our manufacturing there what will we do?
No worries, Nick. I agree a top EPA priority should be a total ban of China. As to our outsourced manufacturing there, I say it goes the same way as the 40% of our electrical generation President Zero is on the way to bankrupting. When the sh*t really hits the fan, we can all riot our fannies off — that’s if disease and starvation hasn’t already taken us out.


Willis, several points.
First, mercury doesn’t cause cardiovascular issues, and EPA doesn’t (yet) claim it does. A very good study of this issue is Darius \h Mozaffarian et al. (2011), “Mercury Exposure and Risk of Cardiovascular Disease in Two U.S. Cohorts,” New England Journal of Medicine, 2011. Authors are from Harvard School of Public Health and various Boston hospitals. Conclusion section says:
“We found no evidence of any clinically relevant adverse effects of mercury exposure on coronary heart disease, stroke, or total cardiovascular disease in U.S. adults at the exposure levels seen in this study. (Funded by the National Institutes of Health.)”
Secondly, the sole adverse health effect that EPA claims to have found that they can quantify, and uses to regulate mercury, is reduction of IQ in the fetus of mothers who eat fish.
This effect, by their own admission, is so tiny as to be unmeasurable. EPA’s Regulatory Impact Analysis (RIA) is the required examination of costs and benefits of the rule. EPA’s RIA (March, 2011) says that a 90% reduction in mercury emissions from US power plants, and the subsequent reduction in the mercury that mothers ingest when they eat fish whose mercury level has declined, is a total of 511 IQ points across the entire country. See Table 1-2 on page 1-4.
On pg. 5-2, this is what they say about the valuation of a gain of 2/1000 of an IQ point per affected child:
“The average effect on individual avoided IQ loss in 2016 is 0.00209 IQ points, with total nationwide benefits estimated between $0.5 and $6.1 million.” The benefits are from aggregate estimated increases in lifetime earnings due to 511 more IQ points spread among 240,000 allegedly affected children.
The link to the RIA is here:
The third point will go to how EPA comes up with “benefits” of possibly over $100 B for a rule whose only direct benefit from mercury reduction could not be found in any child, should it exist (the 2/1000 improvement in IQ points. I will have to send it later, as I need to go someplace right now. I needed to say SOMETHING before I left!

@ Bob W in NC :& kadaka (KD Knoebel)
I may be too cynical, but the circumstances are just too coincidental for me to ignore.
We essentially outlawed incandescent bulbs. We did this to save energy. Ok, I was against that but I understand the thought…. sort of. But, we also essentially established the CFL’s as the default bulb to replace them with. But, we did this knowing full well LEDs were right on the heels of CFL’s as being marketable with even better energy savings. We rushed the legislation to kill U.S. production and to endorse CFLs. The CFLs are simply an issue the lunatics can put in their back pocket.
Without a doubt, in a few years, there’s going to be an upwelling, a crying and gnashing of teeth because ground levels of mercury will be seen as increasing. And it will be an emergency and we’ll be prodded to do something extreme, and it will harm a successful industry in the U.S.
If WUWT is still around, we’ll show them these wonderful charts and graphs and data provided by Willis and others. And, they’ll ignore this and continue to show the rise in ground level mercury. And then we’ll lose another industry and likely a liberty or two. Next, they’ll come up with some other great idea using lead or some such for a product we don’t need but will adopt. Rinse and repeat as necessary until all forms of capitalism and liberties(yes, that’s redundant) are extinguished from this great land.
Prolly the next great scare…. after water scarcity, will be the radioactive particles of the REE found in our e-waste or some such madness.

Pamela Gray

Mercury poisoning is serious and your pie chart is misleading by making it look like a tiny anthropogenic problem. It is not. In addition global large scale efforts to reduce emissions may not affect a local source. Mercury levels are a serious LOCAL issue, tend to concentrate near population centers, and it does not take much for levels to be dangerous. Control needs to therefore be a local issue. This kind of EPA work does not make CNN headlines and apparently does not gain Miss Pinenuts’ attention.
When mercury is found it means down and dirty work, hard work. Local sources are not easily identified. And sometimes the source is not the industry near a river. For example, fish fat is the usual place to find dangerous mercury levels. But fish come and go. Where they picked up mercury is an investigative quandary. I wonder if Miss Pinenuts understands this. I seriously doubt she has any knowledge about this issue when well she should.

John F. Hultquist

The WSJ has an article by Liam Denning that says this rule applies to “new” plants. Further, he writes “Except the market got there first. Regardless of the EPA proposal, it makes no sense to build a new coal-fired plant anyway.
Then there are numbers ($ & %). The last two paragraphs are interesting. Lots of gas. Price goes down. Price of coal goes down. Gas price already low – can it go lower? All this makes the “futures” prices hard to settle on and thus, planning for new construction of electrical generation difficult.


Robert Brown says:
March 31, 2012 at 7:37 am
What you say is true, however it doesn’t bear on Willis’ point which is that the EPA is out in left field with the regulations on the power plants.
The fact that there hasn’t been a dramatic effort by the EPA to clean up known areas of contamination (with the exception of a few “Super-sites”) is one more negative point for our “Environmental Protection Agency.” They can get money to travel to talk about it, but don’t put any money in really doing it. Remediation occurs when they can point to a “guilty party,” provided that party is a private company. Federal Government Agencies, State Governments, and Municipalities get a pass – read up on the TVA, Illinois, and Huntington Beach, CA for more info. So much for protecting the environment.

Christian Bultmann

A few years ago Robert F. Kennedy Jr was here in Alberta having a fundraiser where he claimed that Alberta’s fish are too contaminated to eat with Mercury. Eluding that the Mercury contamination of the fish was caused by human activities.
The Alberta government concludes that most of the Mercury in fish likely comes from natural sources.
Greenpeace and other environmental advocacy groups funded by Kennedy insist that Mercury also enter the environment by human activities like pulp and paper processing and the oil production.
Interesting that there is no mention of the twisty lightbulbs as a source of Mercury contamination of the environment as if they would be all properly disposed off.

Robert Brown says:
” March 31, 2012 at 7:37 am
Actually, I think mercury is a serious problem with modern civilization.”
Robert, mercury poisoning is no longer a serious problem here in the US. Link me to an article that shows how many deaths of people under the age of 30 there were last year. This should be extremely easy as the EPA implies that there are tens, if not hundreds of thousands, of Americans dieing every year due to mercury poisoning. As other commentors have already clearly shown, the new EPA regs will have no effect on reducing Americans already very low Hg exposure as you are only reducing average Hg exposure by at most 1/4 of 1%. It is all pain for no gain. A cost benefit analysis should be done, which is something the EPA does NOT do. Clearly the cost far outweighs the benefits of these new regs.


How would the numbers work out if you substituted bullshit for mercury?


BTW, the environment also produces dioxins; as much as industry, for the US. Forest fires.


As a child I used to love to play with the mercury in my fathers mercury jar. It was about 5 pounds (in weight) worth. I would spill it out on the floor and eventually push the little blobs all back together with my bare hands, somehow I think this concern about mercury is a bit overblown. I turn 65 in a few months if my mercury exposure doesn’t kill me first.


Curiousgeorge says:
March 31, 2012 at 8:21 am
How would the numbers work out if you substituted bullshit for mercury?
I am not sure your comment passes the sniff test…..:)


My limited understanding is that Mercury was chosen as the target pollutant because it is difficult to remove from a gas stream due to its high vapor pressure (the reason the ocean is the main global source). Other pollutants such as Arsenic can be more easily removed in scrubbers so were not chosen as the culprit. Where they cam up with the number of lives saved is a mystery.
Obama’s goal was to drive up the cost of power, but that is not a likely outcome of this EPA action. The price of power won’t be impacted since natural gas is so cheap and abundant now. The overall effect of this ban on new coal fired plants will likely have no impact on anything except the coal companies and even that will likely be temporary. China will buy up the coal we would have burned here and burn it in their plants, which likely will be less efficient at removing pollutants. Since this is only a ban on new plants (which paradoxically are much cleaner burning than the old ones that will remain), the mercury reduction will happen very gradually.
In the end, only the EPA power grab will have succeeded. Watch for the EPA to find some reason to stop the burning of natural gas in power plants, or tax the hell out of it (perhaps on some pretext of reducing fracking to save the water supply). If that happens, Obama’s goal of doubling the cost of power so that his green energy scheme can be justified will have succeeded.

Bernie McCune

Our risk adverse society continues to drive us toward idiotic solutions. I DO STRONGLY AGREE that most types of radiation and non elemental mercury (Mike’s probably fairly safe) are very dangerous at “toxic” levels. The difficulty is to discern what exactly those levels might be. I don’t believe the EPA or most of the other regulatory agencies have really gotten that figured out yet. It also well known that certain levels of radiation and mercury have therapeutic effects below these “toxic” levels. It is known as hormesis – to a degree “what doesn’t kill you makes you stronger”. Or in the case of low doses of mercury – “what kills other stuff that might kill us is good”. In the end none of us gets out of this alive.

Vince Causey

Any biologist can tell you there are two kinds of bacteria – the good kind and the bad kind. There is absolutely no doubt that there is bad Mercury – that which comes out of chimneys – and good Mercury, which comes out of the sea.
Is that so difficult to understand?

Virtually every poison has a low dose range where its effects are healthful. This is called the “hormesis effect,” or the “hormetic range.” The minuscule doses that people are getting from environmental mercury are well down in this range, meaning that minor increments to environmental mercury improve health, so that reducing it will cost lives, not save them.
To claim that current levels of mercury present a danger, the EPA first analyzes a very tiny population (perhaps non existent) that gets enough exposure to environmental mercury to present a known health risk. Since virtually all mercury exposure comes from eating fish, and since only domestic freshwater fish would be significantly affected by changes in power plant mercury emissions, they focus on native American tribesmen who subsist almost entirely on wild caught fish.
A tiny fraction of this already hypothetical population might die from mercury poisoning. That gives the EPA a starting point. Then they do what Art Robinson calls “linear extrapolation to zero,” meaning that they add up the total amount of mercury exposure and count how many lethal doses they can divide it into, and that’s how many people they assume will die!
The virtual universality of the hormesis effect proves that this is not what will actually happen. In particular, mercury is well known to follow the typical hormetic dose-response curve, where very low doses stimulate improved health. Mercury has been studied to death because of the Thimerosol scare where mercury is a component in preservatives for vaccines.
People looking for a culprit for rapidly rising autism diagnoses pointed the finger at childhood inoculations and Thimerosol, but the very small doses involved are not dangerous and to the extent that they have any effect are actually healthful. In particular, thimerosol has been found to actually reduce the risk of autism in children who are inoculated with it. For documentation, click on Edward Calabrese’s reply to this abstract:
Calabrese is the modern pioneer in documenting the virtual universality of the hormetic dose-response. See for instance:

Brian H

Hamlet’s father was killed by having mercury poured in his ear. Ban it!!

Robert, mercury poisoning is no longer a serious problem here in the US. Link me to an article that shows how many deaths of people under the age of 30 there were last year. This should be extremely easy as the EPA implies that there are tens, if not hundreds of thousands, of Americans dieing every year due to mercury poisoning. As other commentors have already clearly shown, the new EPA regs will have no effect on reducing Americans already very low Hg exposure as you are only reducing average Hg exposure by at most 1/4 of 1%. It is all pain for no gain. A cost benefit analysis should be done, which is something the EPA does NOT do. Clearly the cost far outweighs the benefits of these new regs.
I totally agree that a cost-benefit analysis is called for, but as Pamela (?) pointed out, mercury is less of a global problem and more of a local problem. It is also a chronic problem — it doesn’t spectacularly kill people, but people who live in regions with lots of mercury tend to get all sorts of things at higher rates than the general populace. Of course toxic environments are often toxic in lots of ways, and linking it to just mercury is difficult. If you get cancer because of oxidative damage to your DNA, it isn’t really possible after the fact to attribute that damage to its true cause — radiation, mercury, lead, iron (yes, iron is toxic to the human body as well as being essential — I’m a hemachromatosis carrier and know that only too well), halogenated hydrocarbons, or just plain bad luck with nothing but oxygen, a molecule that is simultaneously essential for life and yeah, an oxidant at the cellular level that can damage DNA.
The point I’m making is that Willis’ presentation of the issue isn’t entirely fair — it is easy to point to many places and circumstances where mercury is a serious, anthropogenic, environmental hazard and where at the very least animal studies suggest that it contributes to the overall mortality and morbidity at some rate. So it isn’t silly to want to do something about mercury, and scrubbing mercury from coal is by no means a crazy place to begin, but as you point out in the end it is all about cost-benefit analysis, something that the EPA does not do and neither does anybody else in government, ever, as far as I can tell, in either party. CBA is anathema to politics, which is always about doing the right thing (going for some benefit) damn the cost or opposing the cost damn the benefit. I could wax poetic about gay marriage, the US as a “Christian” country, wars in Iraq, health care, controlling CO_2, and many, many other places where our civilization appear incapable of actually analyzing the total costs and comparing them to the reasonably expected benefits for various alternative decision pathways and using common sense to choose among them.
The problem with a CBA is that it is difficult to do a good one shooting from the hip. One actually has to do a rather large amount of research. Objectivity more or less demands that you not make up your mind about the way it is going to come out (to advance some position that you hold) ahead of time, as well. The EPA’s failure, in other words, should not become our own if we doubt its assertions.


I asked a coworker who is dealing with these new regulations what the preindusrtial levels were. Things like how much was in the soil or the ever popular fish consumption issue. Her response was noone knows.
So my next question was how does one regulate a contaminant if you do now the base line data. She just smiled.
If the EPA was required to document and justify their work with the same level of due dilegence they require of private industry, they would save money, and due more to help the environment.
But don’t let my boss see this we make lots of money on these regulations.


Doing a true CBR on the MACT act would require years. And this is actually what should be done……taking the years.
One would have to include the effect on genergal health of those who live in the northern lats as to sickness rates from prolonged exposure to lower temps in large buildings etc.
The very small amount of Hg emitted from coal at present does not appear to add a substantial amount of Hg to the atomphere/environment in comparison to all sources.
The ability of people to buy fruits and vegetables with the money not spent on higher prices as a result of higher elec rates would also have to be factored in.
So many actual questions/answers needed to make an intelligent decission, which the EPA seems not capable of anymore.

Dr. Dave

SPPI has a wealth of very good information about environmental mercury. I’ll like to just three articles while I look for the more comprehensive piece I read some time ago. There is a lot of irrefutable fact and some rather specious conjecture in the preceding comments. I wouldn’t hesitate for a moment to eat walleye, trout or salmon from Lake Michigan. A tremendous amount of commercial fishing occurs in Lake Superior, Lake Michigan and Lake Huron. That fish likely contains less mercury per kg than open ocean top predator fish like tuna or swordfish. Lake Erie is the body of water to avoid. Many of you will find this articles interesting:

polistra says on March 31, 2012 at 6:42 am
(After a bureaucracy tastes blood, there’s no way to take it back to sanity.)

I’m going to have to use that on a placard, polistra; thanks.


There is a problem with zero tolerance strategies whether with mercury, radiation, or traces of marijuana in a teenager’s backpack that got him suspended from school and possibly killed.
There are several problems that zero tolerance raises, one is: measurement; i.e. increasing ability to measure and whether there is an impact at such concentrations. Zero tolerance is derived from extrapolation of much much higher concentrations where impact can be measured.
Another problem with zero tolerance is that organism adaptation is under-appreciated. Surprising, many organisms have mechanisms to handle heavy metals, we humans are one of them. So the issue is dose; back to the “how much” story again. Surprising also, we produce cancer cells every day, quirks of damaged or mis-shapened DNA, these cells are identified and destroyed. I am not saying a little radiation is good for you, but you do get a little radiation every day whether you are out in the sun or not. We also have DNA repair systems that repair DNA that get damaged in the normal wear and tear of the cell’s work.
I do not want to imply any disrespect to Robert Brown and his excellent review of impacts of mercury and methyl-mercury. I wish to focus a bit on the fishy part. Mercury and methyl-mercury should be having its devastating biological impact on the fish before they are caught by angling enthusiasts. There is very little literature that I am aware, that has identified impacts upon the various fish (fodder fish to Coho Salmon) at levels found in the Tittabawassee River including mercury, PCPs, dioxins.
That these compounds are in the top of the food chain creatures is certain. That I would follow the guidelines of the Michigan DNR or health advisories to pregnant women and a host of other precautionary principles is also certain.
What I object to is the 11,000 number which I believe was derived from the zero-tolerance extrapolations. And here again is a scare tactic to enact a series of regulations which have a tenuous science background. Another black eye for science and the uncertainty monster.

P. Solar

Good article Willis,
one thing you don’t say is how much less Hg Europe is now emitting due to all the coal we are no longer burning since they took a frigging light bulbs away. (And how much more we are putting into the environment because of being forced to use CFLs.)
Maybe the mad hatters at EPA have not finished working out the death toll for that one yet.

Billy Liar

Can anyone explain why the fish-eating Japanese have the highest life expectancy in the world? Do their fish only contain good mercury?


Who’s the CBA candidate?
I suspect that if each department of the federal government was subjected to independent cost-benefit analysis on its operations, the results would be shocking. So much that there would be a chorus to shutter them, or at least subject them to something like that Monty Python skit with the Black Knight.

Logan in AZ

Alec Rawls says:
March 31, 2012 at 9:28 am
The classical student of hormesis is T. D. Luckey, who concentrated on low doses of radiation. I read his monograph years ago. A twenty page overview by Luckey is available at —
Luckey estimates that about 700 premature deaths per day could be prevented by a low-dose radiation supplement. Even more remarkable is the ‘accidental experiment’ in Taiwan, in which Cobalt 60 contamination of rebars used in an apartment house produced a 96% reduction in cancer — there is a five page paper published in 2004 that explains the details —
The incident was well investigated. As usual, the conclusion is that bureaucrats ignore any evidence that does not support total control by regulators, even if extensive morbidity and mortality result. The LNT theory is an analog to AGW politics in that sense. The goal is control.

Willis Eschenbach

mizimi says:
March 31, 2012 at 6:24 am

The regs cover…mercury, arsenic, acid gas, nickel, selenium and cyanides, not just mercury.
You cannot ‘assume’ 25 tonnes of mercury equates to 11,000 deaths prevented….I cannot find the amount the EPA expects the regs to remove from the environment, maybe you have some numbers………..

It’s a “back of the envelope” estimate, mizimi, not a hard figure. I estimated 25 pounds of reductions, let me see what I can find …
OK, here’s what I find. The EPA estimates the mercury emissions from power plants to be about 50 tons per year. The regulations are designed to reduce that to about 30 tonnes by 2014 and to 15 tonnes per year by 2018. So they estimate the reduction at about 35 tons, whereas I’d used 25 tons for my rough estimate …
And of course, government estimates are rarely achieved, so I’d say my numbers are reasonable.

Willis Eschenbach

Bob W in NC says:
March 31, 2012 at 6:33 am

OK. So – I’m curious…the EPA wants to decrease mercury entering the environment, right? But, in the next year or so, we’ll all be having to use CFL bulbs, at about 5 mg mercury each.
Has anyone calculated how much mercury these will spill into the environment as they are thrown away? I know they are supposed to be recycled, but doubt seriously how effective that will be.

Not a clue, although it’s certainly an issue. Let me see what numbers I can find … OK, US incandescent light bulb sales are about 40 billion units per year. Assuming a couple year lifespan, that would be about 80 billion light bulbs in the US.
Each bulb holds about 5 milligrams of mercury. So in total, enough bulbs to replace every incandescent in the US will hold about 400 tonnes of mercury … yikes! That number’s probably high, but total mercury from coal fired power plants is about 50 tonnes …

Willis Eschenbach

polistra says:
March 31, 2012 at 6:42 am

Mercury is a genuine and serious pollutant. If EPA would confine itself to controlling genuine and serious pollutants like this, I wouldn’t have any problem with them.
It’s the other nonsense about carbon and biodiversity that makes them dangerous and requires the agency to be abolished. (After a bureaucracy tastes blood, there’s no way to take it back to sanity.)

The problem is that the EPA wants to put ridiculously low levels on genuine and serious pollutants despite the existence of lots of sources for the same genuine and serious pollutants.
There are about 2,700 tonnes of mercury emitted by the ocean every year. Total natural sources are about 5,000 tonnes.
If you think cutting thirty tonnes from US power plant emissions will make the slightest difference in the face of that, the EPA has a job for you.

Neil Jones

Doesn’t that regulate energy saving light bulbs out of the home?