ECAR Fact Sheet for Hawaii
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, a silver-colored liquid metal, is extremely toxic to the nervous system and may impair the way we see, hear, walk and talk. When spilled, mercury can evaporate at room temperature and the breathable vapors cannot be seen, smelled or tasted. In the environment, mercury can be converted into a form that is especially toxic and can build up in fish tissue and fish eaters. Because of its potential to pose long-lasting health and environmental risks, mercury has become a high-profile toxic waste.  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.

Regulations

In Hawaii, hazardous waste regulations govern the storage and regulation of mercury-containing devices. Under Hawaii’s Universal Waste regulations, only fluorescent 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.

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

Hawaii’s Hazardous Waste Management Requirement (unofficial online version)

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.

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.

Contacts

1. For more information, contact the Hawaii Department of Health (DOH), Solid and Hazardous Waste Branch, Hazardous at (808) 586-4226.
2. To report a spill or leak, or to report an environmental incident or complaint, call the Hawaii Department of Health Office of Hazard Evaluation and Emergency Response 24-hour hotline at
   808-247-2191, or 808-586-4249 during regular office hours.

Related ECAR fact sheets

1. Hazardous Wastes

Other Related Resources

1. Mercury Switch Removal Procedure from Vehicle Hood and Trunk Lights (Vermont document).
2. Directory of Environmental Businesses in Hawaii, 2000
3. Hawaii Recycling Industry Guide

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