ECAR
Fact Sheet for Nebraska
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. State
Mercury Switch Removal Information |
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.
Regulations
In
Nebraska, hazardous waste regulations govern the storage and
regulation of mercury-containing devices. Only mercury-containing
thermostats and spent lamps are exempt from hazardous waste requirements.
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.
Nebraska's Hazardous
Waste Management Requirements
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.
- Has
the facility made a size determination (SQHUW vs. LQHUW)? Review
records and current inventory to verify the size determination
was correct.
- If
the facility is a LQHUW, they are required to have an EPA Identification
Number.
Verify that the facility has an EPA Identification Number.
- Have
you followed the universal waste management requirements for
handling mercury? Verify that you are
adhering the federal and state requirements for handling universal
wastes.
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.
- Label storage containers with required language.
- 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 Nebraska Department
of Environmental Quality (NDEQ) Waste Management Program at 402-471-2186.
- To report a spill or leak, call the NDEQ spill hotline
at 402-471-2186, or 402-471-4545 (weeknights, weekends and holidays).
- To report an environmental incident or complaint, contact
the nearest NDEQ
Regional Office.
Related
ECAR Fact Sheets
- Hazardous Wastes
Other
Related Resources
- Mercury
Switch Removal Procedure from Vehicle Hood and Trunk Lights
(Vermont document).
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