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ECAR
Fact Sheet for Colorado
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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. |
Mercury switches have traditionally been used in automobiles and appliances because of their reliability. The switches are mainly used to turn on lights in glove boxes, trunk hoods, engine hoods, and chest freezer lids. If the mercury switch is not removed prior to shredding, the mercury will be released to the environment through the ensuing processes.
However, since mercury switches and lamps are very common items, and because they can be handled as self-contained units, they have been given a special designation, called "universal wastes." By properly recycling your mercury switches, you can get something of a break from the otherwise very demanding rules that apply to most 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 Colorado Department of Public Health and Environment (CDPHE) has prepared guidance documents to help auto recyclers manage mercury switches. Much of that information is included in the fact sheet below. You can access the link to the guidance documents under Other Relevant Resources.
In the State of Colorado, mercury-containing devices are considered a "universal waste," which is a special EPA designation that the CDPHE has adopted. These universal waste regulations are designed to encourage recycling of certain specific wastes. These rules are less demanding than the hazardous waste rules.
In addition, Colorado has recently begun a mercury switch collection program. For more information, refer to the Colorado Mercury Switch link under Other Related Resources.
Mercury-containing devices are defined as "any electrical or medical product or component (excluding batteries and lamps) which contains elemental mercury that is necessary for its operation where the mercury acts as a conductor of temperature, pressure, or electricity. The mercury must be housed within an outer metal, glass, or plastic casing. To be managed under the state universal waste rule, the mercury-containing device must be a waste as well as a hazardous waste under state law.
Auto recyclers who receive, store, and send mercury-containing lamps and switches off-site for recycling are "universal waste handlers." There are two groups of handlers, based on the amount of universal waste accumulated on-site at any one time:
Once you trigger the LQHUW status you remain a LQHUW for the rest of the calendar year. However, you re-evaluate your classification at the start of each calendar year.
Mercury switches and lamps 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.
Mercury Switch and Lamp Storage. Always store mercury switches and lamps in a secured, covered location, 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.
Mercury Switch Removal. Follow these recommended procedures when removing mercury switches:
Labeling and Marking. Universal waste mercury-containing lamps/switches and containers of mercury-containing lamps/switches must be labeled or marked clearly and legibly "Universal Waste Mercury-containing Device(s)", "Waste Mercury-Containing Device(s)," or "Used Mercury-Containing Device(s)."
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. Refer to the Spill Response Fact Sheet to determine your spill response requirements. Listed below are recommended steps to take when a mercury spill occurs:
Crushing Mercury Lamps. SQHUWs and LQHUWs are allowed to crush lamps under the following conditions:
Disposal. Do not incinerate or dispose of mercury in a landfill. Use a hazardous waste contractor, ship the mercury to another universal waste handler, or ship to a disposal company.
Transportation. A transporter of universal waste is not required to get an identification number or required to obtain a hazardous waste transporter permit. A waste manifest is not required either, but a transporter must comply with all applicable US Department of Transportation (US DOT) regulations, including having the shipment properly packaged, labeled, marked, placarded, and transported with the proper shipping papers. Contact US DOT at (517) 377-1866 for more information. A transporter of universal waste is required to deliver the shipment to a universal waste handler, destination facility, or foreign destination.
Links to the Regulations. Use the following links to view the regulations pertaining to mercury.
Colorado Universal Waste Management Requirements
Federal EPA Standards Applicable to Generators of Hazardous Waste
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.
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:
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