ECAR Fact Sheet for Vermont
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.

However, since mercury thermostats, lamps, and mercury-containing devices, including switches, 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 components, 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 Vermont Department of Environmental Conservation (VT DEC) has prepared guidance documents to help auto recyclers manage mercury. Much of the information is included in the fact sheet below or you can access the guidance for mercury under 'Other Relevant Resources.'

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 Vermont, mercury thermostats, lamps, and mercury-containing devices, including switches, are considered a "universal waste," which is a special EPA designation that the Vermont Department of Environmental Conservation (VT DEC) has implemented. 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 thermostats, lamps and mercury-containing devices 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 thermostats, lamps and mercury-containing devices, including 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 according to the universal waste regulations.

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.

• Containers holding universal waste mercury-containing devices must be labeled or marked clearly with one of the following phrases: "Universal Waste-Mercury Device(s)," or "Waste Mercury Device(s)," or "Used Mercury Device(s)."
• Containers holding universal waste thermostats must be labeled or marked clearly with one of the following phrases: "Universal Waste-Mercury Thermostat(s)," or "Waste Mercury Thermostat(s)," or "Used Mercury Thermostat(s)."
• Containers holding universal waste lamps must be labeled or marked clearly with one of the following phrases: "Universal Waste-Lamp(s)," or "Waste Lamp(s)," or "Used Lamp(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.

Crushing Mercury Lamps and Switches. Do not intentionally crush mercury-containing lamps and switches.

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.

Vermont's Universal Waste Management Standards

Vermont's Mercury Management Rules

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. 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.
2. 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.
3. If the facility is a LQHUW, they are required to have an EPA Identification Number. Verify that the facility has an EPA Identification Number.
4. 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.
• Properly label storage containers.
• 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 Vermont Department of Environmental Conservation, Waste Management Division at 802-241-3888.
2. To report a spill or leak, call the Vermont Division of Waste Management at 802-241-3888 (weekdays), the 24-hour spill reporting hotline at 800-641-5005, or the National Response Center at 800-424-8802.
3. To report an environmental incident or complaint, call 802-241-3820, or contact the nearest regional enforcement officer.

Related ECAR fact sheets

1. Hazardous Wastes

Other Related Resources

1. Vermont - Mercury Switch Removal Procedure from Vehicle Hood and Trunk Lights
2. Vermont - Mercury Switch and Relay Fact Sheet
3. Vermont - Waste Mercury-Added Devices: Handling and Disposal Guidelines
4. Vermont - Fluorescent Lamps: Handling and Disposal Guidelines
5. Vermont - Clean Up Instructions for Small Mercury Spills
6. Vermont EAD - Auto Salvage Yard Environmental Resource Center
7. Vermont - List of Permitted Hazardous Waste Transporters
8. Vermont - List of all Permitted Transporters
   

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