ECAR
Fact Sheet for New Jersey
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 |
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
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 Jersey, mercury-containing devices are considered a "universal waste," which
is a special EPA designation that the New Jersey Department of Environmental
Protection (DEP) 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.
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, 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.
Once
you trigger the LQHUW status you remain a LQHUW for the rest of
the calendar year. However, you re-evaluate your classification
at the start of each calendar year.
Mercury
switches and lamps 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 according to the universal
waste regulations. A link to permitted mercury recovery facilities
in New Jersey is listed at the end of this document under “Other
Related Resources.”
Mercury Switch and Lamp Storage.Always store mercury switches and lamps in a secured, covered
location, that is designed to contain leaks and temperature extremes.
Keep mercury switches and lamps away from open flames or other ignitable
sources. Do not stack switches and lamps since they may crack and
leak hazardous components, thereby incurring a potential expensive
cleanup. Keep mercury switches and lamps off the ground to prevent
them from coming in contact with water, which may result in contaminated
runoff into creeks and streams. Do not store mercury switches and
lamps around inside floor drains or outside storm drains.
Labeling
and Marking. Universal waste mercury-containing lamps/switches
and containers of mercury-containing lamps/switches must be labeled
or marked clearly and legibly “Universal Waste Mercury-containing
Lamps”, “Universal Waste Mercury-containing Switches”, “Waste Mercury-containing
Lamps” or “Used Mercury-containing Lamps”.
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.
Crushing
Mercury Lamps and Switches.
Universal waste mercury-containing
lamps and switches may not be crushed or intentionally broken on-site.
A lamp crushing device may be used to crush mercury-containing
lamps provided the crushing is done in accordance with the requirements
for the treatment of a hazardous waste in an accumulation container,
as set forth by New Jersey law. If a lamp crushing device is used
the lamps must be managed under the Hazardous Waste Regulations
and cannot be managed under the Universal Waste Regulations. In
addition, an Air Permit may be required for the lamp crushing device
Mercury
switches may be removed from mercury-containing devices. However,
once the switch is removed, it may not be further processed. The
mercury switch must be handled in a manner that prevents the release
of the mercury from the switch.
Transportation.A transporter of universal waste is not required to get an
identification number or required to obtain a hazardous waste transporter
permit. A waste manifest is not required either, but a transporter
must comply with all applicable US Department of Transportation
(US DOT) regulations, including having the shipment properly packaged,
labeled, marked, placarded, and transported with the proper shipping
papers. Contact US DOT at (517) 377-1866 for more information.
A transporter of universal waste is required to deliver the shipment
to a universal waste handler, destination facility, or foreign destination.
Links
to the Regulations.
Use the following links to view the regulations pertaining to mercury.
New Jersey Universal
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. 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.
- 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 “Universal Waste Mercury-containing
Lamps”, “Universal Waste Mercury-containing Switches”, “Waste
Mercury-containing Lamps” or “Used Mercury-containing Lamps”.
- 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 New Jersey Division of Solid and
Hazardous Waste at
609-292-8341.
-
To report a spill or leak, or to report an environmental incident
or complaint, contact the NJDEP
24-Hour Hotline at 1-877*-WARNDEP
(1-877-927-6337).
Related
ECAR Fact Sheets
- Hazardous Wastes
Other
Related Resources
- Mercury
Switch Removal Procedure from Vehicle Hood and Trunk Lights
(Vermont document).
- Management of Spent Mercury-Containing
Lamps & Other Hazardous Waste Lamps in New Jersey
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