ECAR Fact Sheet for Michigan
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. If 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. If these sources of mercury are not removed before the vehicle is crushed and shredded, mercury can be released to the environment.

This fact sheet will give you a list of mercury-added components found in vehicles as well as, specific instructions on how to manage them.

There are various sources of mercury in automobiles, including:

• Light switches (e.g., tilt switches used under hood and truck lighting)
• Some anti-lock braking system modules
• Active ride control or ride leveling sensors
• High intensity discharge systems (headlights, tail lamps)
• Virtual image instrument panel

Any waste containing mercury is usually regarded as hazardous waste, but the State of Michigan allows mercury-containing devices to be managed under Michigan's universal waste rule instead of the more complex hazardous waste regulations. Michigan has adapted the federal Resource Conservation and Recovery Act (RCRA) universal waste regulations to govern the storage and regulation of mercury components (See Links to Regulations below). These regulations require the recycling of mercury components because they contain liquid elemental mercury.

The current Universal Waste categories in the Michigan rules are:

• Batteries;
• Pesticides;
• Thermostats;
• Mercury switches;
• Mercury thermometers;
• Devices that contain elemental mercury;
• Electric lamps; and
• Pharmaceuticals, and Consumer electronics.

Mercury switches should be removed and recycled prior to storage, disposal or crushing of the vehicle. Use care to avoid crushing or puncturing the mercury pellet during the switch disassembly process. It is recommended that removal of the mercury pellet from the switch assembly should be performed over or in a containment vessel, that is, a trap or pan sufficient to contain any mercury released from the pellet in case of breakage. Store mercury switches in a leak-proof, re-sealable 3-5 gallon container. The container must be properly labeled according to the hazardous waste management option chosen.

In Michigan there is a statewide program in place for recovering mercury switches. The Michigan Mercury Switch/Sweep (M2S2) Program is a collaborative partnership between the Michigan Department of Environmental Quality and the Alliance of Automobile Manufacturers. When automobile dismantlers/recyclers register, they are provided with buckets, labels, a mercury spill kit, instructional video and a 'how to' brochure. When the buckets are full, the M2S2 program manager will arrange for collection and transport to one of Michigan's Groundwater Stewardship Clean Sweep Program Sites. The M2S2 program is available at no cost to the dismantler/recycler.

For more information on the program, contact Bill Stough at 616/301-1059. For a list of Clean Sweep Sites visit:

http://www.michigan.gov/mda/0,1607,7-125-2961_6860_24909---,00.html

Note: If these waste streams are not managed as universal waste, then the waste must be managed under the applicable hazardous waste regulations if the waste exhibits any hazardous waste characteristic.

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

Michigan's Natural Resources and Environmental Protection (Act 451), Part 111 regarding Hazardous Waste Management and administrative rules

40 Code of Federal Regulations, Part 273- RCRA Standards for Universal Waste Management

Identification and Listing of Hazardous Waste

Part 262 - 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 universal waste management requirements for handling mercury? Verify that you are adhering to the RCRA requirements for handling universal waste. If not, then you must follow the RCRA hazardous waste regulations.

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. A mercury spill kit should be kept on site.
• Remove all mercury switches from the vehicle as soon as possible.
• Be careful not to break or puncture the mercury pellet 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 "Universal Waste - Mercury" (with a description of the contents) and managed as a universal waste.
• Store mercury switches in a leak-proof, closed container.
• Label storage containers with "Spent Mercury-Containing Devices for Recycling" or "Universal 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.
• Retain manifests, shipping records, receipts or other appropriate documentation for a period of three years.

Contacts

1. For more information, contact DEQ's Environmental Assistance Center at 1-800-662-9278
2. For more information about the M2S2 Program contact Bill Stough at 616-301-1059. 

Related ECAR Fact Sheets

1. Hazardous Wastes
2. Batteries (also handled as a "universal waste")

Other Related Resources

1. MI Mercury Switch Information
2. Michigan Universal Waste Guidance Document
3. Mercury Switch Removal Procedure from Vehicle Hood and Trunk Lights (Vermont document)

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