Mercury

ECAR Fact Sheet for Indiana
Mercury

Regulations
Self-Audit Checklist
Best Management Practices
Contacts
Related ECAR Fact Sheets
Other Relevant Resources

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The following fact sheet was prepared by the ECAR Center staff. Once prepared, each ECAR Center fact sheet undergoes a review process with the applicable state environmental agency(ies). You can check on the status of the review process here. Please read the disclaimer on the status page. While we have tried to present a summary of the essential information on this topic, you should be aware that other items, such as local regulations, may apply to you.

What You Need to Know

National Mercury Switch Removal Program

In late 2006, the Automotive Recyclers Association (ARA) became a partner in the National Vehicle Mercury Switch Recovery Program (NVMSRP) which is designed to remove mercury convenience light switches from scrap vehicles before the vehicles are flattened, shredded, and melted to make new steel. For more information see ARA Governmental Affairs NVMSRP.

One of the NVMSRP goals was to maximize switch collection nationally.

A $4 million fund was established that was used to reward dismantlers/recyclers in the participating states on a first-come, first-serve basis over a 3-year period for their efforts.

The NVMSRP voluntary incentive fund was depleted as of July 2009. All other aspects of the switch collection program will continue. You are strongly encouraged to continue removing switches and the program will continue to accept these switches at no cost to participants.

End of Life Vehicle Solutions (ELVS) will carry out the program responsibilities for the vehicle manufacturers. Click here for more information.

Mercury can be found throughout vehicles, primarily in anti-lock brake switches, navigational displays, hood/trunk lighting and as a vapor in High Intensity Discharge lamps. Mercury switches account for more than 99% of mercury use in vehicles.

Mercury is a highly toxic substance. The amount of mercury in one vehicle mercury switch (approximately one gram) can contaminate a 20-acre lake to the point where the fish should not be eaten.

Some cars may contain no mercury components, while others may contain several. Removal of mercury switches from vehicles before crushing is an important part of managing your hazardous wastes. This fact sheet will give you a list of components to watch out for, as well as specific instructions on what to do with them.

The Indiana Department of Environmental Management (IDEM) has prepared a guidance document to help auto recyclers manage mercury. Much of that information is included in the fact sheet below. You can access the link to IDEM’s Compliance Manual for Auto Salvage Facilities under Other Relevant Resources.

Regulations

In the State of Indiana, hazardous waste regulations govern the storage and regulation of mercury components. It is recommended that you recycle mercury components because they contain liquid mercury.

There are various sources of mercury in automobiles, including:

Light switches (e.g., tilt switches used on underhood and truck lighting)
Anti-lock braking systems
Active ride control or ride leveling sensors
High intensity discharge systems (headlights, tail lamps)
Virtual image instrument panel

Mercury switches should be removed and recycled prior to storage, disposal or crushing of the vehicle. Unusable parts that are removed from vehicles and contain mercury cannot be disposed of in landfills or incinerated. They must be managed as hazardous waste. (See the ECAR Hazardous Waste Fact Sheet.) The hazardous waste rules cover storage, transportation, recordkeeping, and reporting. Depending on how much hazardous waste you generate, you may need to obtain an EPA hazardous waste number. For a complete review of these requirements see the RCRA Hazardous Waste Plain Language Guide.

Mercury Switch and Lamp Storage. Always store mercury switches and lamps in a secured, covered location, that is designed to contain leaks and temperature extremes. Keep mercury switches and lamps away from open flames or other ignitable sources. Do not stack switches and lamps since they may crack and leak hazardous components, thereby incurring a potential expensive cleanup. Keep mercury switches and lamps off the ground to prevent them from coming in contact with water, which may result in contaminated runoff into creeks and streams. Do not store mercury switches and lamps around inside floor drains or outside storm drains.

Response to Releases. Should your mercury-containing lamps or switches leak onto the ground, you must immediately contain all releases and determine whether any material resulting from the release is hazardous waste. If so, you must manage the hazardous waste in compliance with all applicable laws.

You can minimize its chances of having spills/releases by removing anything that might be released from the vehicle during crushing activities prior to the vehicle being crushed. Crushing should only be done in areas where spillage or releases can be contained and prevented from coming into contact with the soil.

Crushing Mercury Lamps and Switches. Although you are not required to remove mercury switches from vehicles upon arrival or prior to crushing activities, it is highly recommended that you do so, to avoid any releases to the environment that must be contained and remediated. Removal of the switches will help to ensure that the switch does not break and release mercury to the environment.

Links to the Regulations. Use the following links to view the regulations pertaining to mercury.

Indiana Hazardous Waste Regulations (Article 3)

Federal EPA Standards Applicable to Generators of Hazardous Waste

Self-Audit Checklist

When an inspector comes to your facility, there are certain things he or she checks to see if you are in compliance with environmental regulations. It makes good sense for you to perform a “self-audit” and catch and correct problems before they result in penalties. Also, there are some compliance incentives associated with self-audits (see Audit Policy Page).

Use the following list to audit your mercury management program.

Have all mercury switches been removed? Check to make sure that all components that may contain mercury have been removed and recycled prior to storing, disposal or crushing of the vehicle.

Have mercury switches and lamps been stored safely? They should be stored in a secured, covered location, that is designed to contain leaks and temperature extremes.

Are you prepared to handle mercury spills? You can minimize its chances of having spills/releases by removing anything that might be released from the vehicle during crushing activities prior to the vehicle being crushed. Should your mercury-containing lamps or switches leak onto the ground, you must immediately contain all releases and determine whether any material resulting from the release is hazardous waste.

Best Management Practices (BMPs)

Most regulations tell you what you have to do to be in compliance, but they don’t explain how to do it. That’s where “best management practices” come into play. BMPs are proven methods that help you to get into compliance and stay there.

The following BMPs are recommended for management and disposal of vehicle parts containing mercury:

All employees who handle or manage mercury-added products should be informed of proper handling and emergency procedures for these products and for mercury.
Remove all mercury switches from the vehicle as soon as possible.
Be careful not to break or puncture the mercury container during removal.
If a mercury-containing device breaks, at a minimum, the device, the released mercury and cleanup debris should be analyzed to determine whether it is a hazardous waste.
Store mercury switches in a leak-proof, closed container. Store in a way that will prevent the capsules from breaking.
Be able to demonstrate that you have not had the devices stored for more than one year. This can be done by keeping a log, shipping papers, or by labeling storage containers with the accumulation start date.
Recycle mercury switches with a licensed metals recycler that reclaims mercury.

Contacts

For more information, contact the Indiana Department of Environmental Management (IDEM) at 800-451-6027 or 317-232-8603.
Report spills and environmental emergencies immediately to IDEM by telephone at 1-888-233-7745.
Submit a pollution complaint online through the IDEM Pollution Complaints Clearinghouse.

Related ECAR fact sheets

Hazardous Wastes

Other Related Resources

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