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Regulations 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
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 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. 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. 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. There are various sources of mercury in automobiles, including:
In the State of Massachusetts, mercury switches are considered a "universal waste," which is a special EPA designation that the Massachusetts Department of Environmental Protection (DEP) 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. Auto recyclers who receive, store, and send mercury-containing lamps and switches off-site for recycle 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. They must be managed as according to the universal waste regulations. A link to permitted mercury recovery facilities in Massachusetts is listed at the end of this document under "Other Related Resources." 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. You may mix different types of universal waste mercury-containing devices or such devices with universal waste thermostats, in one container. If you remove the mercury-containing ampoules, you must follow applicable state regulations. 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 Lamps", "Universal Waste Mercury-containing Switches", "Waste Mercury-containing Lamps" or "Used Mercury-containing Lamps". 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. Crushing Mercury Lamps and Switches. You must obtain a Class A permit if you plan to reclaim mercury/phosphor powder. Universal waste mercury-containing lamps and switches may be crushed or intentionally broken on-site to reduce their volume; however, breaking, crushing, handling, and storage must occur in a safe and controlled manner that minimize the release of mercury to the workplace and the environment and must comply with applicable laws. The procedure for breaking, crushing, handling and storing of the lamps must be documented and use a mechanical unit specifically designed for the process and incorporating the containment and filtration of process air flows to remove mercury-containing vapors and dusts. If the mercury switch or lamp is broken, it must be placed in a container that is closed, vapor tight, structurally sound, and compatible with the contents of the mercury-containing device. Also, there can be no evidence of leakage, spillage, or damage that could cause further leakage. You must show that the mercury has been recycled through proper documentation. 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. For hazardous wastes in transit, there is a five-day holding limit. Other requirements apply, such as the condition of containers, notification to local law enforcement, and having the transport vehicle ready for immediate departure. Links to the Regulations. Use the following links to view the regulations pertaining to mercury. 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:
Other Related Resources
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