Mercury

ECAR Fact Sheet for New York
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

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. For more information see ARA Governmental Affairs NVMSRP.

One of the NVMSRP goals was to maximize switch collection nationally.

A $4 million fund was established that was used to reward dismantlers/recyclers in the participating states on a first-come, first-serve basis over a 3-year period for their efforts.

The NVMSRP voluntary incentive fund was depleted as of July 2009. All other aspects of the switch collection program will continue. You are strongly encouraged to continue removing switches and the program will continue to accept these switches at no cost to participants.

End of Life Vehicle Solutions (ELVS) will carry out the program responsibilities for the vehicle manufacturers. Click here for more information.

Because of its potential to pose long-lasting health 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.

Most auto recyclers fall into the category of Conditionally Exempt Small Quantity Generators (CESQGs) of hazardous waste. CESQGs may accumulate and store mercury switches at their facilities for an unlimited period of time. This extended storage period for CESQGs allows facilities that remove lighting assemblies and anti-lock brake sensors containing mercury to collect sufficient quantities to make switch recycling feasible. It also allows time for yards to dismantle the lighting assemblies that contain mercury, enabling low cost recycling of the switches. More information is available on the Department of Environmental Conservation (DEC) web site.

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

New York Conservation Rules and Regulations on Hazardous Waste Management (NYCRR 373)

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.
Does your operation qualify as a Conditionally Exempt Small Quantity Generator (CESQG)?
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 general information on tank and bulk storage programs, contact the Bulk Storage Hotline at 518-402-9549.
NYS Spill Hotline (1-800-457-7362).

Related ECAR fact sheets

Hazardous Wastes

Other Related Resources

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