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ECAR
Fact Sheet for California
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 ProgramIn 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. |
Because of its potential to pose long-lasting health risks, mercury has become a high-profile toxic waste. It's not something you would want to be caught mishandling.
Any components containing mercury must be managed as 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.
Regulations
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
A useful source of information on which vehicles can be expected to have mercury-containing devices and the approximate quantities of mercury present in each type is the Wisconsin Mercury Sourcebook: Automotive.
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. 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.
In addition to vehicle parts, a common source of mercury is fluorescent and high intensity lights. Spent lamps from businesses have been banned from solid waste incineration since 1994. Businesses generating less than 10 lamps per month may dispose of the lamps in the trash, only if the lamps are destined for a landfill and with prior approval from their landfill. If you dispose of more than 10 spent lamps per month you must arrange for disposal of the lamps in a permitted lined landfill or at permitted reclamation facility.
Links to the Regulations. Use the following links to view the regulations pertaining to mercury.
Identification and Listing of Hazardous Waste
Part 262 - Standards Applicable to Generators of Hazardous Waste
California Code of Regulations, Sections 22 and 27
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 you followed the hazardous waste management requirements for handling mercury? Verify that you are adhering the RCRA requirements for handling 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 sealed in a plastic bag and transferred to a closed compatible container labeled "Hazardous Waste" (with a description of the contents) and managed as a hazardous waste.
- Store mercury switches in a leak-proof, closed container. Store in a way that will prevent the capsules from breaking.
- Label storage containers with "Spent Mercury-Containing Devices for Recycling" or "Waste/Used Mercury Devices. "
- 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.
The following BMPs are recommended for management and disposal of fluorescent and high intensity discharge lamps:
- Send spent lamps to a recycling facility rather than a disposal site.
- Do not break or crush lamps (can release mercury vapor).
- Maintain records of used lamp generation and disposal/recycle.
- California Department of Toxic Substances Control: 916-323-2678.
- Public and Business Liaison Hotline: 800-728-6942.
- Office of Emergency Services Warning Center: 800-852-7550.
- Partners in the Solution Guidance Manual (Developed by the State of California Auto Demantlers Assn)
- Mercury Waste Classification and Management - Self - Training Manual for Removing Mercury Switches from Vehicles: A Guide for Auto Dismantlers
- Mercury Waste Classification and Management - Self - Training Manual for Removing Mercury Switches from Vehicles: A Guide for Auto Repair Shops
- Mercury Switch Removal Procedure from Vehicle Hood and Trunk Lights (Vermont document).
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