ECAR
Fact Sheet for Indiana
Mercury

Regulations
Self-Audit Checklist
Best Management Practices
Contacts
Related ECAR Fact Sheets
Other Relevant Resources
BACK
to VIRTUAL TOUR
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
***NEW***
National
Mercury Switch Removal Program
In
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. It is intended to be a three year
cooperative effort among auto manufacturers, steelmakers,
dismantlers, shredders, US EPA, state representatives
of the environmental community and trade associations
of certain stakeholders. For more information see ARA
Governmental Affairs — NVMSRP.
Under
this voluntary program auto recyclers agree to remove,
collect and manage the mercury switches from scrapped
vehicles. End of Life Vehicle Solutions (ELVS)
will carry out the program responsibilities for the
vehicle manufacturers. Click
here for more information.
NVMSRP Participant/Related Documents/Participating Auto Recyclers
State
Mercury Switch Removal Information NVMSRP
State Program |
Mercury can be found throughout vehicles,
primarily in anti-lock brake switches, navigational displays, hood/trunk
lighting and as a vapor in High Intensity Discharge lamps. Mercury
switches account for more than 99% of mercury use in vehicles.
Mercury is a highly toxic substance.
The amount of mercury in one vehicle mercury switch (approximately
one gram) can contaminate a 20-acre lake to the point where the
fish should not be eaten.
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. 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 Indiana Department of Environmental
Management (IDEM) 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 IDEM’s Compliance
Manual for Auto Salvage Facilities under Other Relevant Resources.
Regulations
In
the State of Indiana,
hazardous waste regulations govern the storage and regulation of
mercury components. It is recommended that you recycle mercury components
because they contain liquid mercury.
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.
Mercury
Switch and Lamp Storage. Always store mercury
switches and lamps in a secured, covered location, that is 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.
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.
You
can minimize its chances of having spills/releases by removing anything
that might be released from the vehicle during crushing activities
prior to the vehicle being crushed. Crushing should only be done
in areas where spillage or releases can be contained and prevented
from coming into contact with the soil.
Crushing
Mercury Lamps and Switches. Although
you are not required to remove mercury switches from vehicles upon
arrival or prior to crushing activities, it is highly recommended
that you do so, to avoid any releases to the environment that must
be contained and remediated. Removal of the switches will help to
ensure that the switch does not break and release mercury to the
environment.
Links
to the Regulations.
Use the following links to view the regulations pertaining to mercury.
Indiana Hazardous Waste
Regulations (Article 3)
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.
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
mercury switches and lamps been stored safely? They should be stored in a secured,
covered location, that is designed to contain leaks and temperature
extremes.
Are you prepared to handle mercury spills? You
can minimize its chances of having spills/releases by removing anything
that might be released from the vehicle during crushing activities
prior to the vehicle being crushed. 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.
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
analyzed to determine whether it is a hazardous waste.
- Store mercury switches in a leak-proof, closed container.
Store in a way that will prevent the capsules from breaking.
- 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
- For more information, contact the Indiana Department of Environmental Management
(IDEM) at 800-451-6027 or 317-232-8603.
- Report spills and environmental emergencies immediately
to IDEM by telephone at 1-888-233-7745.
- Submit
a pollution complaint online through the IDEM Pollution Complaints Clearinghouse.
Related
ECAR fact sheets
- Hazardous Wastes
Other
Related Resources
- Indiana - Mercury Webpage
- Indiana Auto Salvage
Program Website
- Indiana
Auto Salvage Compliance Manual
BACK
to VIRTUAL TOUR
|