ECAR Fact Sheet for Colorado
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

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:

• Small Quantity Handler of Universal Wastes (SQHUW) - accumulates less than 11,000 lbs. (5,000 kg) of universal waste at any time during a calendar year.
• Large Quantity Handler of Universal Wastes (LQHUW) - accumulates 11,000 lbs. or more (5,000 kg) of universal waste at any time during the calendar year, which would require the site to have an EPA Identification Number.

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:

• Avoid skin contact. Wear neoprene glove when removing switch.
• Wear safety glasses.
• Process over or in a container in case of breakage.
• Limit processing of glass ampoules or 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:

• Have people not involved with cleanup leave area.
• Turn off heat and any air circulation systems.
• Isolate the area and ventilate the room to outdoors.
• Contain the spill and use a spill kit to clean up the contact area.
• Check around spill area with flashlight (small beads may not be seen without a flashlight).
• Suction up free mercury with eyedropper or adhesive tape (never vacuum).
• Store collected mercury, along with any contact materials (i.e. clothing, gloves, wipes, cloths, etc.) in a sturdy, sealed, airtight plastic container outside of building separate from stored switches.
• Continue to ventilate area for a few hours after the spill, if possible.
• Dispose of collected mercury and contact materials at next removed switch disposal event (do not dispose of in trash).
• Wash the contact area with (trisodium phosphate) detergent solution and rinse with water.

Crushing Mercury Lamps. SQHUWs and LQHUWs are allowed to crush lamps under the following conditions:

• Lamps are to be crushed in a completely enclosed system that prevents the release of any waste or component into the environment
• Develop and implement a written procedure detailing how to safely crush the waste lamps. This must include the type of equipment to be used, the operation and maintenance of the unit, the segregation of incompatible waste, proper waste management practices, and waste characterization.
• A spill cleanup kit is readily available to immediately clean up spills or leaks that may occur during lamp crushing operations.
• The crushed lamp is to be immediately transferred to a container that meets state and federal requirements.
• The area in which the lamps are crushed is to be well ventilated and monitored, and comply with OSHA exposure levels for mercury.
• Employees are to be thoroughly familiar with the procedure for crushing waste lamps, and proper handling and emergency procedures.

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

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.

1. 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.
2. Have you followed the proper procedures when handling mercury and removing switches? Avoid skin contact. Wear neoprene glove when removing switch. Wear safety glasses. Process over or in a container in case of breakage. Limit processing of glass ampoules or switches.
3. Are you disposing of your mercury properly? 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.

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. Cut the power supply wire attached to the base of the light fixture. Remove any fasteners in order to separate the entire fixture from the vehicle. Carefully remove the mercury switch from the fixture. If the switch cannot easily be removed, put the entire fixture in the collection container. Removing the switch from the fixture will save storage space and may also save on disposal costs.
• 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. If the switch or the assembly looks damaged or corroded, place the fixture in a separate plastic container, like a yogurt tub, to prevent leakage.
• Place switches in a covered, heavy plastic labeled container with secondary containment. Do not use tin or aluminum containers because mercury may combine with these metals and leak through the seams.
• Label storage containers with "Universal Waste Mercury-containing Device(s)", "Waste Mercury-Containing Device(s)," or "Used Mercury-Containing Device(s)."
• 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.
• 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.

Contacts

1. For more information, contact the Colorado Department of Health and Environment's technical assistance line at 303-692-3320, or toll-free at 888-569-1831, if outside of the 303 area code.
2. To report a spill or leak, at minimum, call the Colorado 24-hour Emergency Spill/Release Reporting Line at 877-518-5608 and the Local Emergency Planning Committee at 303-273-1622, immediately or within 24-hours. Spill reporting requirements are complex and depend on the type of facility, the type of the spill, and the circumstances under which the spill originates. It is vital that you refer to the Reporting Chemical Spills and Releases in Colorado website for detailed spill reporting instructions.
3. To report an environmental incident or complaint, contact the nearest regional office.

Related ECAR fact sheets

1. Hazardous Wastes

2. Spill Response Fact Sheet

Other Related Resources

1. Colorado Mercury Switch Website
2. Colorado's Automotive Salvage Yard Waste Management Practices
3. Colorado Universal Waste Rule Compliance Bulletin
4. Mercury Switch Removal Procedure from Vehicle Hood and Trunk Lights (Vermont document).

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