ECAR Fact Sheet for Rhode Island
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, 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. 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

The Rhode Island Department of Environmental Management (DEM) has prepared a guidance document to help auto recyclers manage mercury-containing devices, lamps and thermostats. Much of the information is included in the fact sheet below. You can access the DEM's Universal Waste Rule fact sheet under "Other Relevant Resources."

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 the State of Rhode Island, mercury-containing devices (including switches), lamps and thermostats are considered a "universal waste," which is a special EPA designation that the DEM 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. What this means is if a waste has at least one hazardous waste characteristic, it must be managed as a universal waste if it is not managed as a hazardous waste.

For example, the rule extends the amount of time that you can accumulate universal wastes on-site by up to a year or more. It also allows you to transport such wastes with a common carrier, instead of a hazardous waste transporter, and no longer requires you to prepare a manifest.

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. A SQHUW is not required to notify DEM and EPA of its universal waste handling activities, and is not required to keep records of shipments of universal waste.
• 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. A LQHUW must submit written notification of universal waste management to DEM and obtain an EPA identification number prior to accumulating these amounts. Note that if the entity already has an EPA identification number, this notification is not required. A LQHUW must also keep a record of each shipment of universal waste to and from the facility

Mercury-containing devices are any electrical product or component which contains elemental mercury that is necessary for its operation and is housed within an outer metal, glass, or plastic casing. These devices include, but are not limited to thermometers, barometers, electric switches, electric relays, thermocouples, manometers, and sphygmomanometers. You must manage universal waste mercury-containing devices in the following manner:

• In way that prevents releases of any waste or component of universal waste to the environment;
• You must contain any universal waste mercury-containing device that shows evidence of leakage, spillage, or damage that could cause leakage under reasonably foreseeable conditions in a container. The container must be closed, structurally sound, compatible with the contents of the mercury-containing devices, and must lack evidence of leakage, spillage, or damage that could cause leakage under reasonably foreseeable conditions.

You may:

• Mix different types of universal waste mercury-containing devices, or universal waste mercury-containing devices and universal waste thermostats in one container; or
• Remove mercury-containing ampoules from universal waste mercury-containing devices provided that you comply with the requirements listed in the "thermostats" section.

Mercury-containing lamps are lamps in which mercury is purposely introduced by the manufacturer for the operation of the lamp. They include, but are not limited to, fluorescent lamps, neon lamps, high intensity discharge (HID) lamps (including mercury vapor, metal halide and high pressure sodium lamps). You must manage universal waste mercury-containing lamps in a way that prevents releases of any universal waste or component of a universal waste to the environment, as follows:

• You must contain any universal waste mercury-containing lamp that shows evidence of leakage, spillage, or damage that could cause leakage under reasonable foreseeable conditions in a container. The container must be closed, structurally sound, compatible with the contents of the mercury-containing lamps, and must lack evidence of leakage, spillage, or damage that could cause leakage under reasonably foreseeable conditions.
• You must contain unbroken mercury-containing lamps in packaging that will minimize breakage during normal handling conditions.
• You must contain mercury-containing lamps in packaging that will minimize releases of lamp fragments and residues.

Mercury-Containing Thermostats can contain as much as three grams of liquid mercury and are found in commercial, industrial, and community buildings. You must manage mercury-containing thermostats in the following manner:

• In a way that prevents releases of universal waste or component of universal waste to the environment.
• You must contain any universal waste thermostat that shows evidence of leakage, spillage, or damage that could cause leakage under reasonably foreseeable conditions in a container. The container must be closed, structurally sound, compatible with the contents of the thermostat, and must lack evidence of leakage, spillage, or damage that could cause leakage under reasonably foreseeable conditions.
• You may remove mercury-containing ampoules from universal waste thermostats provided that you:
  • Remove the ampoules in a manner designed to prevent breakage of the ampoules;
  • Removes ampoules only over or in a containment device (e.g., tray or pan sufficient to collect and contain any mercury released from an ampoule in case of breakage);
  • Ensure that a mercury clean-up system is readily available to immediately transfer any mercury resulting from spills or leaks from broken ampoules from the containment device to a container that meets universal waste requirements;
  • Immediately transfer any mercury resulting from spills or leaks from broken ampoules from the containment device to a container that meets the universal waste requirements
  • Ensure that the area in which ampoules are removed is well ventilated and monitored to ensure compliance with applicable OSHA exposure levels for mercury;
  • Ensure that employees removing ampoules are thoroughly familiar with proper waste mercury handling and emergency procedures, including transfer of mercury from containment devices to appropriate containers;
  • Store removed ampoules in closed, non-leaking containers that are in good condition;
  • Pack removed ampoules in the container with packing materials adequate to prevent breakage during storage, handling, and transportation.

Note that if the ampoule is removed, you must determine whether or not any spilled mercury, clean-up residues, or remaining solid waste exhibit a characteristic of hazardous waste and must manage it as such if it does.

Prohibitions. Both large and small quantity handlers of universal waste must not dispose of a universal waste in the regular solid waste stream, dilute or treat universal waste, or intentionally break or crush universal waste.

Accumulation Time Periods. Both small and large quantity handlers of universal waste may accumulate universal waste for no longer than one year from the date the universal waste is generated or received from others. But, you may accumulate universal waste for longer periods of time, provided that such storage is solely for the purpose of accumulation to facilitate proper recovery, treatment or disposal, and you can prove this purpose. If you accumulate waste, you must demonstrate accumulation time by:

• Placing the universal waste in a container and marking or labeling the container with the earliest date that any universal waste in the container became a waste or was received;
• Marking or labeling the individual item of universal waste with the date it became a waste or was received;
• Maintaining an inventory system on-site that identifies the date the universal waste being accumulated became a waste or was received;
• Maintaining an inventory system on-site that identifies the earliest date that any universal waste in a group of universal waste items or a group of containers of universal waste became a waste or was received;
• Placing the universal waste in a specific accumulation area and identifying the earliest date that any universal waste in the area became a waste or was received; or
• Any other method which clearly demonstrates the length of time that the universal waste has been accumulated from the date it becomes a waste or is received.

Labeling and Marking. Small and large quantity handlers of universal waste must label each universal waste item or each container of universal waste items with the words "Universal Waste" and the identity of the waste, e.g. "Waste Thermostats." You must also satisfy US DOT packaging, labeling, marking, placarding, and shipping paper requirements for any universal waste that is a US DOT hazardous material prior to offsite shipment,

Response to Releases. Should your mercury-containing devices, lamps or thermostats leak or spill, or if there is unintentional breakage of significant numbers of universal waste items, you must manage the released material as hazardous waste if it has hazardous waste characteristics.

Transportation.You are allowed to self transport universal waste, but there are specific requirements for transporters. If you use a transporter, they must be properly licensed to remove your waste.

Employee Training. You must train employees on proper waste handling and emergency procedures.

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

Rhode Island's 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.

1. Are you properly managing your mercury-containing universal wastes? You must manage your wastes in way that prevents releases of any waste or component of universal waste to the environment. You must also contain any universal waste mercury-containing device that shows evidence of leakage, spillage, or damage that could cause leakage under reasonably foreseeable conditions in a container.
2. Are you properly disposing of your mercury-containing universal wastes? Do not dispose of a universal waste in the regular solid waste stream, dilute or treat it, or intentionally break or crush it.
3. Are you complying with required accumulation times for mercury-containing universal wastes? Do not accumulate universal waste for more than one year from the date the universal waste is generated or received from others, unless you can prove that such storage is solely for the purpose of accumulation to facilitate proper recovery, treatment or disposal.
4. Are you properly labeling your mercury-containing universal wastes? You must label each universal waste item or each container of universal waste items with the words "Universal Waste" and the identity of the waste, e.g. "Waste Thermostats."

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 must be trained on proper waste handling and emergency procedures.

• Remove all mercury switches from the vehicle as soon as possible.
• Be careful not to break or puncture the mercury container during removal.
• Label each universal waste item or each container of universal waste items with the words "Universal Waste" and the identity of the waste, e.g. "Waste Thermostats."
• Do not dispose of a universal waste in the regular solid waste stream, dilute or treat universal waste, or intentionally break or crush universal waste.
• Be able to demonstrate that you have not had the devices stored for more than one year.
• Recycle mercury switches with a licensed metals recycler that reclaims mercury.

Contacts

1. For more information, contact the Rhode Island DEM, Office of Technical and Customer Assistance at 401-222-6822.
2. To report a spill or leak, immediately call the DEM at 401-222-1360 or, if after hours, call the
   24-hour emergency number at 401-222-3070.
3. To report an environmental incident or complaint, contact the DEM Offices.

Related ECAR fact sheets

1. Hazardous Wastes

Other Related Resources

1. Rhode Island Universal Waste Fact Sheet
2. Rhode Island - Permitted Hazardous Waste Transporter List
3. Mercury Switch Removal Procedure from Vehicle Hood and Trunk Lights (Vermont document).

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