View Entire PIM

checkMaintain Organization-Wide Mercury-Free Policies

All PIM content was independently developed and reviewed to be vendor-, product-, and service provider-neutral.


Most facilities have phased out mercury-containing devices due to mercury’s serious environmental and health impacts, but it is still found some office fixtures, medical supplies and equipment, electronics, and cleaning products.  A policy will help with its ultimate elimination and reduce the risks of having such a dangerous chemical in your facility.  Other policies must also be maintained, for example, maintaining an inventory of and tagging all remaining mercury-containing switches, guages and other devices.  Also maintaining a mercury spill policy.

  • Project Talking Points

    • Mercury is a potent neurotoxin that can harm the brain, spinal cord, kidneys, and liver. It has been used throughout healthcare in a variety of products and equipment including thermometers, sphygmomanometers, dental amalgam, laboratory chemicals, and preservatives such as thimerosal, cleaning agents, and various electronic devices such as fluorescent bulbs/lamps and computer equipment.
    • Fluorescent bulbs contain mercury.  Nonetheless, because of their energy efficiency, and therefore the reduced reliance on coal-fired powered plants (which contribute to mercury pollution), they are deamed beneficial over other lighting.  BUT care must be taken to prevent breakage, and when a broken bulb does occur, mercury spill clean-up processes must be followed. 
    • Mercury containing devices like fluorescent bulbs must be managed as hazardous or universal wastes.
    • Cumulative usage, spills, breakages, and disposal of these products continues to make the healthcare sector a significant contributor of mercury pollution in the environment.
    • Elimination of mercury is relatively easy because of the many safe, cost-effective, non-mercury alternatives that exist for nearly all uses of mercury in healthcare.
    • This overview from Health Care Without Harm provides comprehensive information and supporting materials surrounding issues with mercury use in healthcare, toxicity to human health, and the impacts on the environment.
  • Triple Bottom Line Benefits

    Cost savings – Establishing a policy and becoming mercury-free allows healthcare facilities to avoid the costs of storing and disposing of hazardous wastes, and the costs of meeting mercury emission regulation standards. Many local wastewater treatment plants are identifying hospitals as industrial pollution sources. As a result, strict wastewater mercury concentration limits are being imposed. In this case, eliminating or reducing mercury will not only lower the cost of compliance, but it will also allow facilities to avoid the costs of fines and possible legal battles in instances of non-compliance. In addition, mercury elimination or reduction can eliminate the costs incurred by expensive spill cleanups and the costs associated with personnel training on the proper identification and use of this widely distributed hazardous substance.

    Environmental benefits – Instituting a stringent policy to eliminate mercury will result in reducing the amount of mercury in waste streams and therefore in water and the food chain. It also ensures and provides documentation that your hospital is complying with regulatory standards.

    Health and safety benefits - being mercury-free protects patients, staff and the environment. Hospitals’ mission statements often include the goal of assessing and improving community health. As significant users of products containing mercury, hospitals have an opportunity to play a key role in protecting public health and the environment by minimizing their use of these products. When hospitals reduce their use of mercury they are positively influencing community health by eliminating a known health hazard. They also set a higher standard for other businesses in the community.

    CQO Perspective - Given the lower relative costs of mercury free products, an organization cannot afford to ignore the benefits of eliminating mercury.  Patient outcomes are no longer threatened, quality of product is guaranteed by going with mercury free alternatives, and cost differential is most often beneficial to the facility especially once disposal is complete.


  • Purchasing Considerations

    Mandate mercury-free contract language such as the following in purchasing RFP language; service contracts; lease contracts, etc.:

    “XYZ is committed to elimination of mercury utilized in its operations, and desires to avoid the acquisition of products that contain mercury whenever feasible alternatives exist that do not compromise patient care. Supplier shall represent and warrant in the purchase agreement and with the submission of this Proposal that the products proposed to be furnished under any Agreement do not contain mercury, except as identified and listed in an exhibit to this Proposal. Supplier shall specify the amount of mercury contained in any products listed in this exhibit and indicate in the Proposal if a feasible mercury-free alternative is available.”

    Include mercury in the list of “materials of concern” banning is purchase in all contract specifications.

  • How-To

    1. Develop an inventory of mercury-containing products in your facility. Record where the mercury is, and how much is in each location.
    2. If you do not yet have a formal policy, see the resources below and use sample policies to help create yours.
    3. Talk to your hospital leadership and get a signed statement to be mercury-free/permission to draft a policy. Work with your hospital’s green team to draft your institution’s policy.
    4. Maintain a comprehensive management plan in place – you never know when a mercury device will appear. This includes:
      1. Mercury Management Policy - establish best-handling practices for all mercury-containing wastes (but first focus on phase-out of mercury-containing medical devices and facility equipment currently in use, which still commonly have high concentrations of mercury); 
      2. Mercury-free Purchasing Policy - Health Care Without Harm provides a sample purchasing policy;
      3. General Employee Education program covering mercury use and disposal issues;
      4. Spill Prevention and Education program targeted specifically toward spill prevention and response.
    5. Mercury-free is standard practice for Group Purchasing Organizations (GPOs).  Require private contract vendors to sign a mercury-free content disclosure agreement covering products you intend to purchase.
    6. Ensure building renovations and new construction design specify mercury-free devices.
  • Tools

    • Sustainable Hospitals provides technical support to the healthcare industry for selecting products that reduce occupational and environmental hazards.
    • Download an extensive list of mercury containing products and alternatives in the healthcare setting prepared by INFORM, a national non-profit educating the public about the effects of human activity on the environment and human health.

    If you have an ROI tool, calculator, or similar resources to share, please contact us or participate in the discussion below.

  • Case Studies

    Sustainable Hospitals offers several case studies of mercury reduction in hospitals.

    Eliminating mercury use in hospital laboratories: a step toward zero discharge. The Western Lake Superior Sanitary district collaborates with local hospitals to eliminate the use of mercury-containing fixatives by histopathology laboratories.

  • Regulations, Codes and Standards, Policies

    • Under certain Federal environmental statutes, such as the Clean Air Act, Clean Water Act, and Resource Conservation and Recovery Act, EPA has the responsibility to develop regulations to control some mercury emissions to air, water, or from wastes and products. In addition, states also develop regulations to address mercury emissions. The EPA provides more information on laws and regulation.
    • Many healthcare organizations including the American Academy of Pediatrics propose the Toxic Substances Control Act (TSCA) of 1976 needs a policy overhaul. TSCA provides the EPA with authority to require reporting, record-keeping and testing requirements, and restrictions relating to chemical substances and/or mixtures. Certain substances are generally excluded from TSCA, including, among others, food, drugs, cosmetics, and pesticides.
    • Understand, develop, and implement a chemicals policy that will eliminate mercury and create a mercury-free facility or healthcare system.  Practice Greenhealth provides an overview of the scientific need to develop a facility-wide chemicals policy in-house that requires chemical disclosure requirements by suppliers for an individual healthcare facility.
  • Cross References: LEED

    LEED 2009 for Healthcare, New Construction & Major Renovations, Materials and Resources, Prerequisite 2, PBT Source Reduction – Mercury.
    LEED 2009 for Healthcare, New Construction & Major Renovations, Materials and Resources, Credit 4, PBT Source Reduction—Mercury in Lamps, 1 Point.
    LEED 2009 for Existing Buildings, Operations & Maintenance, Materials and Resources , Credit 4, Sustainable Purchasing, Reduced Mercury in Lamps, 1 Point.

  • Cross References: GGHC

    GGHC, Operations Version 2.2, 2008 Revision, Chemical Management, Prerequisite 2, Chemical Management Policy and Audit, 1 Point.

  • Education Resources

    If you have any information or resources to contribute, please contact us or participate in the discussion below.

  • More Resources

  • PIM Descriptors

    Supply Chain, Waste

    Level: Beginner

    Category List:

    • Hazardous Waste
    • Policy
    • Strategic Operations
    • Universal Waste

    PIM Attributes:

    • Chemicals
    • Environmental Health and Safety
    • Waste Reduction

    Improvement Type:

    • Toxics Reduction


    • Interdepartmental
  • Interested in underwriting this PIM? Contact us to find out how!


  1. Comment, and please add information, tools, or additional resources you think should be added to the PIM.
  2. Write a case study or a PIM to contribute to the Roadmap (links are to instructions).

Home About Topics Drivers Strategies Implementation Resources Terms of Use Privacy Policy
American Hospital Association | 155 N. Wacker Drive, Suite 400 | Chicago, Illinois 60606 | (312) 422-3000
©2010-2015 by the American Hospital Association. All rights reserved.