Fact Sheet for Maine
Best Management Practices
Related ECAR Fact Sheets
Other Relevant Resources
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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 Switch Removal Program
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
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.
Participant/Related Documents/Participating Auto
Mercury Switch Removal Information
vehicle mercury switch recovery law prevents the ELVS
program from operating in the state. Maine has unique
requirements for the collection and recycling of switches
that are incompatible with the ELVS nationwide model.
Mercury in Maine's environment is
a problem, particularly for infants and young children. The National
Academy of Sciences says that over 60,000 children born each year
may suffer learning disabilities and other problems because of their
mothers' exposure to small amounts of mercury. In the case of motor
vehicles, mercury is released when scrapped vehicles are shredded
and smelted to make recycled steel.
The Maine Department of Environmental
Protection (ME DEP) estimates that motor vehicles in Maine currently
contain about 1,500 pounds of mercury in convenience light and ABS
switches. Most of this mercury eventually will be released to the
air unless these switches are removed before the vehicles are crushed.
This is why the Maine Legislature
created a program to get these switches out before vehicles are flattened for recycling.
Under the program, auto dismantlers and automakers share responsibility.
Your role as a dismantler or salvage yard operator is to remove
the switches and store them for recycling. Automakers will recycle
the switches and pay you $1 per switch
to help offset your removal costs.
Mercury switches do not need to be
handled in accordance with the requirements described in this document
if the waste is being handled under a ME DEP-sanctioned takeback
program. The Automobile Manufacturers take back mercury switches
from motor vehicles when they are dismantled. There are two separate
programs, one for passenger vehicles including pickup trucks and
one for medium and heavy-duty trucks:
Vehicle Program. Automakers have hired Wesco to operate
consolidation facilities in Bangor and Portland. Dismantlers of
passenger cars and pick up trucks can take their mercury switches
to one of these two Wesco locations along with their log sheets
and receive a $1 bounty per switch.
and Heavy Truck Program. The Truck Manufacturers Association
on behalf of their members operates the truck program. The White
& Bradstreet facility in Augusta serves as the consolidation
facility for this program. Dismantlers of medium and heavy-duty
trucks can take their mercury switches along with their log sheets
to the White & Bradstreet facility and receive a $1 bounty per
ME DEP has prepared guidance documents to help auto recyclers manage
mercury-containing switches and devices. Much of that information
is included in the fact sheet below. You can access the links to
the guidance documents under "Other Relevant Resources."
the State of Maine, mercury switches and other mercury-containing
devices and lamps are considered a "universal waste."
These universal waste regulations are designed to encourage recycling
of certain specific wastes. These rules are less demanding than
the hazardous waste rules.
Types of Universal Waste. Universal waste include the following
- Motor vehicle
mercury switches, including hood and truck light switches and
devices including mercury thermometers, sphygmomanometers,
non-motor vehicle mercury switches.
lamps containing mercury or lead, including fluorescent,
intensity discharge, neon, mercury vapor, high-pressure sodium,
and metal halide bulbs.
thermostats including temperature control devices, which
of Universal Waste Generators. There are two types of universal waste generators in Maine:
- A large universal waste generator (LUWG) generates or accumulates
more than 200 items of universal waste or 4,000 motor vehicle
switches at any one time or in any given month.
small universal waste generator (SUWG) generates and accumulates
on site, 200 or less universal waste items or 4,000 or less
motor vehicle switches at a time or in any given month.
Accumulation Facilities: There are three types
of central accumulation facilities, including:
- Facilities where a generator consolidates it's own universal
wastes from the generators' various facilities.
- Licensed solid waste transfer
stations or town recycling centers where generators may
their universal waste if agreed to by the host municipality.
where less than 200 universal waste items are collected
a generator's site for whom the facility provides a service
function. Examples of this third category can be electrical
contractors, cleaning companies or sign service companies.
you handle more than 5000 kg of universal waste, you must have an
EPA identification number. If you handle less than 5000 kg of universal
waste, you do not need an EPA ID Number but you must notify the
ME DEP on a document called the "waste notification form." With
the exception of motor vehicle mercury switches, for the types of
waste currently classified as a universal waste, it is unlikely
that a Central Accumulation Facility will exceed 5,000 kg (approximately
11,000 pounds) of universal waste.
owners or operators of any central accumulation or consolidation
facility and transporters of mercury waste must comply with the
requirements for the storage of mercury waste, as summarized below:
- The mercury waste must be stored in a secured area, which
can be locked when not in use. The waste cannot be exposed
all mercury waste in containers. The containers must not
evidence of leakage, spillage or damage that could cause leakage
under reasonably foreseeable conditions. The containers
be closed, structurally sound and compatible with the waste.
container must be labeled with the date you first put the
waste in it (accumulation start date), and the date the container
becomes full, if you wish to store mercury wastes for more
cannot store mercury waste for more than 365 days from the
the waste is first placed in the container. However, there
is an exception, which allows additional storage time where
is needed to fill a container of waste no larger than the following
container sizes and the container is shipped no more than
days from the date the container is filled:
A container designed for no more than 190 lamps
Thermostats: A container no larger than 30 gallons
Devices: A container no larger than 55 gallons
Vehicle Mercury Switches: A container no larger than
- Motor vehicle mercury switches must be shipped off at least
every three years from when waste is first placed in the container
regardless of whether the 5-gallon container is filled.
waste must be packed in containers with packing materials
to prevent breakage during storage, handling and transportation.
mercury waste containers must be sealed securely
around box openings. Any waste containers must immediately
if incidental breakage occurs.
of mercury waste must not be stacked more than 5 feet high.
This prevents crushing of items stored in boxes in the lower
waste storage areas must be inspected weekly and the inspection
documented in a written inspection log. The log must include
the name of the inspector, date of the inspection, condition
of all waste containers, description of any problem noted during
the inspection and action taken to fix it, and the number
type of universal waste on site.
Universal Waste Generators are
not required to meet the above weekly inspection requirements
except for keeping track of the number and type of universal
waste items on site. However, it is recommended that an inspection
be conducted whenever waste is added to the universal
area to reduce the potential for contamination or exposure
to universal waste.
waste containers must be stored to facilitate inspection
the container. The inspector shall be able to determine the
accumulation start date, container full date, and the container's
that accumulate more than 200 items of universal waste or
than 4,000 motor vehicle mercury switches at any one time or
in any given month, must notify the ME CEP of the handling
universal waste and must obtain either an EPA or a State Identification
and Marking. Universal waste storage areas
must be designated by a clearly marked sign, which states "Universal
Hazardous Waste Storage," or the type of waste being stored there:
"Waste Lamp Storage", "Waste Mercury Device Storage",
"Waste Mercury Thermostat Storage", or "Waste Motor Vehicle
Training Requirements. You must train all employees and
contractors who handle or have responsibility for managing mercury
waste on proper handling and emergency procedures. Documentation
of the training must be maintained at the facility for a minimum
of three years from the date the facility first receives or ships
universal waste, or for the length of employment, whichever is longer.
This documentation must include the name of the employee or contractor
receiving the training, the date of the training, and the information
covered during the training.
to Releases. All releases of waste and residues resulting from
spills or leaks of mercury waste must immediately be contained and
transferred into a container that meets the requirements of the
state's hazardous waste management rules. Incidental breakage of
ten or fewer lamps or CRTs may still be handled as universal waste.
Spills resulting from other than incidental breakage must be handled as hazardous waste. The total amount of broken lamps and CRTs in storage may exceed ten items
provided no breakage event exceeds the incidental limits. Incidental
breakage should however be a rare occasion. If frequent breakage
is occurring, the generator, facility and transporter should review
their handling procedures and packing materials to ensure that they
are adequate for the job.
Report spills/discharges of universal
wastes to the ME DEP's spill hotline at 800-452-4664. All spills/discharges
from batteries, mercury-containing thermostats, mercury devices
and motor vehicle mercury switches must be reported immediately.
Transporting Mercury Waste. Only a licensed hazardous waste
transporter or a common carrier, a mercury waste generator transporting
his or her own mercury waste, an owner or operator of a central
accumulation facility, or an owner or operator of a consolidation
facility may transport mercury waste.
Mercury wastes must be transported
to a facility authorized to handle the waste under a state program
and which is a defined universal waste facility. In addition, transporters
may only ship universal waste from:
- A generator
to a central accumulation facility, consolidation facility,
or recycling facility.
central accumulation facility to a consolidation facility or
consolidation facility to recycling facility.
must meet all of the hazardous waste management rules, including
the minimum $1,000,000 of liability insurance. Note: Small quantity
generators transporting their own universal waste and municipalities,
state and federal governments are exempt from the insurance requirement. These
rules include provisions for having a spill kit, spill response
plan, and for training drivers in the implementation of the plan.
You must comply with the following
requirements when transporting mercury waste:
- The universal
waste must be whole, intact, and unbroken and in proper packaging
that includes closed containers that are compatible with the
type and amount of waste being shipped. Packages must meet the
U.S. Department of Transportation standards.
Recyclable Hazardous Material Uniform Bill of Lading or Uniform
Hazardous Waste Manifest must accompany the waste. Copies of
these documents must be submitted to the ME DEP. Instead of
a manifest or bill of lading, a SUWG may use a log system
of tracking. This is allowed for movement of mercury from the
generator to a central accumulation facility, and from the central
accumulation facility to the consolidation facility.
Certificate of Recycling. Generators
should receive a Certificate of Recycling from the recycling facility
for each shipment of mercury waste.
You must retain the following documents and paperwork
at your facility:
logs must be kept for one year from the date of shipment or
receipt of mercury waste.
documentation must be kept for at least three years from the
date of shipment, receipt of mercury waste or length of employment
whichever is longer. Bill of lading or manifest must be kept
for at least three years from the date of shipment or receipt
of mercury waste.
of Recycling must be kept for at least three years from the
date of shipment of the mercury waste except for shipments of
ballasts or residues from mercury spill kits.
to the Regulations.
Use the following links to view the regulations pertaining to mercury.
- Mercury Switch Removal Requirement
Waste Management Requirements
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).
the following list to audit your mercury management program.
- Has the facility made a size determination (LUWG
vs. SUWG)? Review records and current inventory to
verify the size determination was correct. A large universal waste
generator (LUWG) generates or accumulates more than 200 items
of universal waste or 4,000 motor vehicle switches at any one
time or in any given month. A small universal waste generator
(SUWG) generates and accumulates on site, 200 or less universal
waste items or 4,000 or less motor vehicle switches at a time
or in any given month.
- Are you properly storing mercury waste? Mercury waste must located
in a secured area, impervious to weather, and stored in closed,
structurally sound containers. Each container must be labeled
with the date you first put the mercury waste in it and the date
the container becomes full, if you wish to store mercury wastes
for more than 365 days.
you properly labeling your mercury waste? Universal
waste storage areas must be designated by a clearly marked sign,
which states "Universal Hazardous Waste Storage," or the type
of waste being stored there: "Waste Lamp Storage", "Waste
Mercury Device Storage", "Waste Mercury Thermostat Storage",
or "Waste Motor Vehicle Switch Storage."
your employees trained to manage mercury waste?
You must train all employees and contractors who handle
or have responsibility for managing mercury waste on proper handling
and emergency procedures.
your mercury waste being picked up by approved transporters?
Only a licensed hazardous waste transporter or a common carrier, a mercury
waste generator transporting his or her own mercury waste, an
owner or operator of a central accumulation facility, or an owner
or operator of a consolidation facility may transport mercury
Management Practices (BMPs)
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.
following BMPs are recommended for management and disposal of vehicle
parts containing mercury:
All employees who handle or manage mercury-added products
must be trained on proper handling and emergency procedures for
these products and for mercury.
Remove all mercury switches from the vehicle as soon
Be careful not to break or puncture the mercury container
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
- For more information, contact the ME DEP, Office
- Immediately report spills/discharges of mercury
wastes to the ME DEP's spill hotline at
- To report an environmental incident or complaint,
contact the nearest
ECAR Fact Sheets
- Hazardous Wastes
- Maine - Auto
Dismantlers Guide to Recycling Mercury Switches and Mercury Lamps
Hazardous/Universal Waste Website
- Mercury Waste Recycling Companies
- Maine's Motor
Vehicle Recycling Website
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