ECAR Fact Sheet for Connecticut
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 is released into the environment when mercury switches are not removed prior to compacting or shredding vehicles. Mercury is highly toxic to humans and the environment. It accumulates in the tissues of fish and other organisms in mercury-containing water and may be carried up the food chain to humans.

Vehicle trunk and hood light switches can contain mercury. A mercury switch is probably being used if the light goes on when the hood is partway up, or you can see that the bulb housing is deliberately mounted at an angle to the hood. Most cars containing mercury switches are American makes and models. In addition to the mercury switches in convenience lighting, some relays may contain mercury switches to activate airbags, anti-lock brakes (primarily found in four-wheel drive vehicles), some seat belt systems, and some automatically adjusting suspension systems.

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.

Certain 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.

The Connecticut Department of Environmental Protection (CT-DEP) 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 CT-DEP's Auto Recycling Guide under Other Relevant Resources.

In Connecticut, hazardous waste regulations govern the storage and regulation of mercury-containing switches. Mercury's hazardous waste code is D009.

Under Connecticut's Universal Waste regulations, only mercury-containing thermostats and lamps are exempt from hazardous waste requirements.

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.

Thermostat storage under the universal waste rule. Under state law, thermostats must be placed in a container capable of preventing leakage, spillage or damage that could cause leakage under all conditions (not just reasonably foreseeable).

Mercury-Containing Lamp Management. Lamps that are hazardous wastes can be managed as a universal waste, or under hazardous waste regulations. If the lamp is non-hazardous, it may be managed under rules similar to universal waste management rules. Containers that hold the lamps must be capable of preventing leakage, spillage or damage that could occur under all conditions (not just reasonably foreseeable).

Disposal of Universal Wastes. If you are a Conditionally Exempt Small Quantity Generator (CESQG), you cannot dispose of universal waste in municipal solid waste landfills, or nonmunicipal, nonhazardous waste disposal facilities. Universal waste must be sent to a universal waste handler or destination facility subject to the state's universal waste rules.

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

Connecticut Hazardous Waste Regulations

Connecticut Universal Waste Regulations (Section 22-a-449(c)-113)

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 hazardous waste management requirements for handling mercury? Verify that you are adhering the RCRA requirements for handling hazardous waste.
3. Are you disposing of your mercury properly? If you are a CESQG you must send your universal waste to a universal waste handler or destination facility subject to the state's universal waste rules.

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 “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.

Contacts

1. For more information, contact the Connecticut Bureau of Waste Management at 860-424-3021.
2. To report a spill or leak, immediately call the Connecticut Department of Environmental Protection, Oil and Chemical Response Division at 860-424-3338, 24 hours/day.  Should this number become unavailable for any reason, call 860-424-3333. Within 24 hours of the spill you are required to complete a written Report of Petroleum or Chemical Product Discharge.
3. To report an environmental incident or complaint, contact the nearest regional office.

Related ECAR fact sheets

1. Hazardous Wastes

Other Related Resources

1. Mercury Switch Removal Procedure from Vehicle Hood and Trunk Lights (Vermont document).
2. Connecticut Auto Recycling Guide

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