ECAR Fact Sheet for Tennessee
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.

Certain 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.

In Tennessee, hazardous waste regulations govern the storage and regulation of mercury. Under Tennessee's Universal Waste regulations, only mercury-containing lamps are exempt from hazardous waste requirements. Also, the state has its own standards for crushing universal waste lamps on-site.

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.

Crushing Universal Waste Lamps. Both Small and Large Quantity Handlers of Universal Waste are permitted to crush universal waste lamps to reduce storage volume, and must meet the following conditions:

• Any air exhausted from the crushing unit must pass through a well-maintained high-efficiency particulate air filter designed to minimize loss of mercury or other hazardous constituents to the atmosphere.
• Detailed records must be kept for review for at least three years. The records must include the technology employed for crushing, including any certification or testing data provided by the manufacturer of the crushing unit.
• You must immediately transfer any material recovered from a spill or leak to a container that meets the state's generator accumulation rule and has available equipment necessary to comply with this requirement.
• You must ensure that the area in which the lamps are crushed is well ventilated and monitored to ensure compliance with applicable Occupational Safety and Health Administration (OSHA) exposure levels for mercury or other hazardous constituents.
• You must ensure that employees who crush lamps are thoroughly familiar with proper handling of mercury and other hazardous constituents and emergency procedures, including transfer of mercury or other hazardous constituents from containment devices to appropriate containers.
• The crushed lamps are stored in closed, non-leaking containers that are in good condition (e.g., no severe rusting, apparent structural defects, or deterioration) and are suitable to prevent releases during storage, handling, and transportation.

Permit-By-Rule. If you have a crusher system used explicitly for the crushing of universal waste lamps to achieve volume reduction, you are considered to have a hazardous waste permit, if you comply with all applicable universal waste standards and state notification requirements. You are not allowed to dispose of, dilute or treat universal waste, except by crushing for volume reduction in accordance with the state law and universal waste requirements

Accumulation Time. Crushed lamps cannot be accumulated for more than one year from the date the universal waste is generated or received.

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

Tennessee's Hazardous Waste Management Requirements

Tennessee's Universal Waste Management Requirements

Tennessee Permit-By-Rule Standards (on-site volume reduction of mercury-containing lamps)

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.

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

1. For more information, contact the Tennessee Division of Solid and Hazardous Waste Management at 615-532-0780.
2. To report a spill or leak, call the Tennessee State Emergency Operations Center 24-hour hotline at 800-262-3300, or the National Response Center at 800-424-8802.
3. To report an environmental incident or complaint, contact the nearest regional office.

Related ECAR fact sheets

1. Hazardous Wastes

Other Related Resources

1. Tennessee - Mercury Clean Up Fact Sheet
2. Tennessee - Permitted Hazardous Waste Transporters
3. Mercury Switch Removal Procedure from Vehicle Hood and Trunk Lights (Vermont document).

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