ECAR Fact Sheet for New Hampshire
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 is a heavy metal that can accumulate in living tissue and cause adverse health effects. When a universal waste device is disposed of in a solid waste landfill or incinerator, the mercury can contaminate air, soil, surface water and groundwater. In New Hampshire, mercury has been detected in freshwater fish, and a statewide fish consumption advisory has been issued by the Department of Health and Human Services.

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.

The New Hampshire Department of Environmental Services (DES) has prepared guidance documents to help auto recyclers manage mercury-containing devices. Much of the information is included in the fact sheet below. You can access the DES's mercury guidance documents under Other Relevant Resources.

The Auto & Truck Recyclers Association of New Hampshire (ATRA) and Department of Environmental Services (DES) have organized a voluntary program to remove and recycle mercury switches from end-of-life vehicles before they are shredded and smelted. Under this program, ATRA members are provided with properly labeled plastic buckets, and, as they disassemble vehicles, they remove the mercury switches and store them in the buckets. Within a year, the auto recycler brings the bucket to one of eight stations throughout the state where the switches are consolidated and shipped to an approved mercury recycler. To date, over 60 buckets have been distributed and, within the first six months, over 600 switches have been collected.

Regulations

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

In the State of New Hampshire, mercury-containing devices, including mercury switches, are considered a "universal waste," which is a special EPA designation that the New Hampshire Department of Environmental Services (DES) 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.

Generator Status. Hazardous waste generators are not required to include waste mercury-containing devices and other universal wastes in their calculation of generator status in accordance with state's hazardous waste rule. Universal wastes, when recycled, are also not subject to the generator fee

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 under the federal universal waste rule, and one added type of handler under New Hampshire rule, based on the amount of universal waste accumulated on-site at any one time:

• Small Quantity Handler of Universal Wastes (SQHUW) - accumulates less than 11,000 lbs. (5,000 kg) of universal waste at any time during a calendar year.
• Large Quantity Handler of Universal Wastes (LQHUW) accumulates 11,000 lbs. or more (5,000 kg) of universal waste at any time during the calendar year, which would require the site to have an EPA Identification Number.
• New Hampshire has added another category of universal waste handler called a very large quantity handler of universal waste (VLQHUW). A VLQHUW accumulates more than or equal to 20,000 kilograms combined total of universal waste on-site at any one time.

Universal Waste Consolidation. You may collect waste mercury-containing devices from other sites or generators without a permit, provided the facility meets the handler requirements and complies with other applicable federal, state, and local regulatory requirements.

Mercury Switch and Lamp Storage. Store both intact and broken mercury-containing devices in containers that are compatible with the universal waste, in good condition, and closed at all times except when devices are being added to, or removed from, the container. If containers are stored outside, they must be covered to prevent precipitation from coming in contact with the containers.

Accumulation Time Limits. Accumulate waste mercury-containing devices for no longer than one year from the date the mercury-containing devices are generated or received from another handler. Demonstrate the length of time that the waste mercury-containing devices have been accumulated from the date the devices became waste or were received. You may do this by marking or labeling containers with the starting accumulation date, or by maintaining an inventory system on-site that identifies the earliest date devices were added to a container or received from off-site.

Labeling and Marking. Clearly label or mark each device or container of devices with any one of the following phrases: "Universal Waste--Universal waste device(s)," or "Waste Universal waste device(s)," or "Used Universal waste device(s)."

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. Listed below are recommended cleanup procedures:

• Immediately contain and clean up all releases from broken, leaking, or damaged mercury-containing devices.
• Place any broken or damaged devices and any residues resulting from breakage or damage in a secure container. The container must be closed and sealed, structurally sound and compatible with the broken devices. A plastic lined box, fiber drum or a plastic bucket with a lid that seals is recommended since some types of metal containers may be incompatible with mercury. Ensure the container is clean, because if it is contaminated with other chemicals, those substances may react with the mercury.
• Any releases that pose a threat to human health or the environment must be reported immediately to DES at 603-271-3899, or, if after hours, to the Hazmat Unit at 800-346-4009, and to the municipality in which the release occurred.
• Mercury residues from broken devices must be handled in accordance with the state hazardous waste rule. The residues may be sent to a recycling facility or a hazardous waste treatment, storage, or disposal facility authorized to accept the waste. A N.H. registered hazardous waste transporter and hazardous waste manifest must be used. Transporters who are transporting mercury residues must meet the requirements of the state's hazardous waste rules. All applicable US DOT packaging and shipping requirements for mercury residues must be met.

Transportation. Transporters are not required to obtain a N.H. hazardous waste transporter registration or use a hazardous waste manifest for waste mercury-containing devices, but must meet all applicable US DOT and NH DOS regulations. Transporters can only take waste mercury-containing devices to another handler, an authorized universal waste device recycling facility or an authorized hazardous waste facility.

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

New Hampshire Universal Waste Management Requirements

New Hampshire Hazardous Waste Management Requirements

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. Has the facility made a size determination (SQHUW vs. LQHUW vs. VLQHUW)? Review records and current inventory to verify the size determination was correct. A Small Quantity Handler of Universal Wastes (SQHUW) accumulates less than 11,000 lbs. (5,000 kg) of universal waste at any time during a calendar year. A large quantity handler of universal wastes (LQHUW) is a facility that accumulates 11,000 lbs. or more of all universal wastes at any time during the calendar year. A very large quantity handler of universal wastes (VLQHUW) is a facility that handles more than or equal to 20,000 kilograms combined total of universal waste on-site at any one time.
3. If the facility is a LQHUW, they are required to have an EPA Identification Number. Verify that the facility has an EPA Identification Number.
4. 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 "Universal Waste--Universal waste device(s)," or "Waste Universal waste device(s)," or "Used Universal waste device(s)."
• 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 recycler.

Contacts

1. For more information, contact the New Hampshire DES Waste Management Division at
   603-271-2900.
2. To report a spill or leak during business hours, call the DES at 603-271-3899. If after hours or the weekend, call the New Hampshire State Police Hazardous Material Response at 800-346-4009 (in-state), or 603-271-3636 (out-of-state).
3. To report an environmental incident or complaint, contact the nearest regional office or link to the DES Public Information Center.

Related ECAR fact sheets

1. Hazardous Wastes

Other Related Resources

1. New Hampshire - Management Requirements for Handlers and Transporters of Mercury-Containing (Universal Waste) Devices
2. New Hampshire - Management Requirements for Handlers and Transporters of Universal Waste Lamps
3. New Hampshire - Cleaning up Mercury Spills
4. New Hampshire - Recommended Mercury Spill Cleanup Procedure for Fluorescent Lamp Breakage
5. New Hampshire - List of Mercury Vendors/Recyclers
6. Mercury Switch Removal Procedure from Vehicle Hood and Trunk Lights (Vermont document).
   

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