ECAR
Fact Sheet for Minnesota
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
***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 List
of Participating Recyclers |
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. Mercury
is not something you would want to be caught mishandling.
Any 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
Hazardous waste regulations govern
the storage and regulation of mercury components, and these regulations
require the recycling of 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.
Links to the Regulations.
Use the following links to view the regulations pertaining to mercury.
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.
- 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 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
For more information, contact
the Minnesota Pollution Control Agency (MPCA) Regional Office
closest to you:
- Northeast Region (Duluth)
218-723-4660.
- North Central Region (Brainerd)
218-828-2492.
- Northwest Region (Detroit
Lakes) 218-847-1519.
- Southwest Region (Marshall)
507-537-7146.
- Southeast Region (Rochester)
507-285-7343.
- Or contact the MPCA customer service
line at 651-297-2274.
*Report petroleum and fuel spills
of five or more gallons, and any other chemical spill (including
lead-acid batteries) which may cause pollution, to the State Duty
Officer at 651-649-5451 or 1-800-422-0798.
Related
ECAR Fact Sheets
- Hazardous
Wastes
Other
Related Resources
- Managing Mercury Switches (October 1998)
- Motor
Vehicle Salvage Facility Environmental Compliance Manual
- Mercury
Switch Removal Procedure from Vehicle Hood and Trunk Lights
(Vermont document).
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