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ECAR
Fact Sheet for New Hampshire
Regulations BACK to VIRTUAL TOUR 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. There are various sources of mercury in automobiles, including:
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:
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:
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 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.
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:
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