Fact Sheet - Mercury Switch Management Guidance for Vehicle Dismantlers
Why is mercury a problem in end-of-life vehicles?
Mercury auto switches were used to control convenience lighting and anti-lock brake systems (ABS) in many vehicles manufactured prior to model year 2003. The National Vehicle Mercury Switch Recovery Program (NVMSRP) estimates that 67 million of these switches are available for recovery nationwide.
Mercury is a toxin that affects the nervous system and the brain. It is particularly damaging to a developing fetus and young child. If switches are not removed prior to crushing or shredding a vehicle or before the steel melting process, the mercury may be emitted into the air where it eventually enters rivers and lakes and contaminates fish and wildlife. Eating mercury-contaminated fish is the primary route of exposure for most people and has resulted in the issuance of health warnings about fish consumption for New York State residents.
Are mercury switches prohibited in New York State?
New York State Environmental Conservation Law (ECL) Article 27, Title 21, Mercury-added Consumer Products, Section 27-2107(7) states: "On or after January first, two thousand eight, no person shall sell, offer for sale or distribute any mercury switch or mercury relay individually or as a product component" Cost effective, non-mercury replacement switches exist which use a ball bearing in place of liquid mercury to trigger the electrical connection.
Who must remove mercury-added equipment from vehicles?
Mercury switches and mercury-containing ABS modules must be removed from end-of-life vehicles by vehicle dismantlers or vehicle shredders prior to crushing or shredding according to New York State Environmental Conservation Law (ECL) Article 27, Title 23, Vehicle Dismantling Facilities, Section 27-2303(5).
Which motor vehicles contain mercury?
All vehicles did not contain mercury switches. In general, convenience lighting in domestic cars manufactured before model year 2003 and foreign cars manufactured before model year 1992 should be inspected for mercury switches and mercury-containing ABS modules.
Mercury light switches are often found in the car's hood and trunk convenience lighting. The light assembly contains a small steel canister or "pellet" that contains liquid mercury. For some assemblies, it is easier to leave the pellet in place and discard the entire assembly into a leakproof recycling container. A mercury-containing ABS module should be completely removed without prying it open to remove the pellet.
The End of Life Vehicle Solutions Corporation (ELVS) has an excellent website that lists specific makes and models of various vehicles containing mercury switches.
How do I recycle or dispose of mercury switches and mercury-containing ABS modules?
- Automobile manufacturers established the NVMSRP to facilitate collecting and recycling mercury switches and mercury-containing ABS modules. In support of the NVMSRP, ELVS provides vehicle dismantlers with free collection buckets (1 or 3 ½ gallon) and free services to manage these automotive switches once they are removed from the vehicles. These services cover all transportation and final disposal costs of any collected switches.
- If you wish to participate in the NVMSRP, you must register with ELVS. You may register by going online at www.elvsolutions.org or by calling (877) 225-ELVS (3587). ELVS will send you a collection bucket, a list of vehicles that have the potential to contain mercury switches, removal instructions for mercury-containing ABS assemblies, a removal brochure, a removing/recycling DVD, and detailed shipping instructions for the switches.
- Mercury switches that have been removed intact (complete convenience lighting tilt switch assembly or a mercury-containing ABS assembly) and mercury "pellets" that are encased in metal and removed from switch units should be managed as "Universal Waste". "Universal Waste" is hazardous waste that can be managed with reduced regulation but with on-site requirements to meet. The following storage and shipping steps must be followed:
- Use the bucket label that ELVS provides to identify the bucket's content as "Universal Waste - Mercury-Containing Equipment";
- Store the bucket in a separate area for "Universal Waste" at your facility;
- Store switches and/or assemblies in the bucket with the lid securely fastened until you have collected enough for shipment to Environmental Quality Company (EQ), the reclamation facility that ELVS has contracted with;
- "Universal Waste" can be stored for up to one year from initial placement in a container at your facility. You must document the date on which you start to collect and store switches in each bucket. This is done by noting the date on the bucket label when you start collecting and storing the switches in that bucket.
- When the bucket is full (3 ½ gallon bucket holds 450 pellets or 130 assemblies) or prior to the one year storage limitation, visit United Parcel Service (UPS) on the web at www.ups.com to order a shipping label and to arrange for a pick-up of the container. If you do not have access to the web, you may contact EQ at 1-800-839-3975 to arrange UPS pick-up. Shipping instructions and contact information are provided in all buckets sent to program participants.
- Vehicle dismantlers who do not participate in the free ELVS program are still required by state law to remove these switches. Switches, switch assemblies, other intact mercury-containing equipment, and mercury "pellets" must be stored in a secure heavy plastic or metal container with a tight lid. State law requires that you:
- Label your container as "Universal Waste-Mercury-Containing Equipment" and store it safely as noted above for a maximum of one year;
- Send mercury switches and other mercury-containing equipment directly to a facility that the NYS Department of Environmental Conservation has authorized to accept mercury wastes or to a facility located in another state that is authorized by that state to reclaim mercury. These recyclers usually accept various mercury wastes and they do charge a fee. Permitted hazardous waste transporters can be found in the yellow pages or by contacting DEC at (518) 402-8705.
- You may use a common carrier (such as United Parcel Service, Federal Express, or other shipping services) to transport the mercury switches provided you are transporting less than one pound of mercury. Transporting more than one pound of mercury requires United States Department of Transportation packaging, labeling, and vehicle placarding. Any one shipment must not be greater than 500 pounds.
- Mercury in most switches is encased in metal which is not susceptible to breaking and can be handled as "Universal Waste". In some Volvos made between model years 1975 and 1991, switches used for lights in engine and luggage compartments are encased in glass. Volvo also used glass-encased mercury switches for make-up mirror lights in model years 1986-1991. Glass-encased mercury switches were used in Audi engine compartment lights in model year 1992 and earlier vehicles.
- If you remove glass-encased mercury switches from the switch unit, the switch must be managed as "Hazardous Waste." You must dispose of a glass-encased mercury switch at a facility that is licensed to treat, store or dispose of hazardous waste, and you must use a licensed hazardous waste transporter for the shipment. Do not mix glass-encased mercury switches in the collection bucket with metal-encased mercury switches. If you do, the glass may break and the entire bucket of switches will be contaminated. The bucket would then have to be managed as hazardous waste.
- If the total amount of hazardous waste generated by your business is less than 220 pounds per month, mercury-containing equipment may be managed for a fee through a local household hazardous waste program. You need to contact your municipality to see if a household hazardous waste program exists in your area.
- The amount of hazardous waste your facility generates determines the specific requirements you must follow. Contact the Waste Determination & Analysis Section, Division of Environmental Remediation, NYSDEC, 625 Broadway, 12th Floor, Albany, NY 12233, Phone: (518) 402-9543.
- General mercury switch removal program information may be obtained by contacting the Bureau of Solid Waste, Reduction and Recycling, NYSDEC, 625 Broadway, 9th Floor, Albany, NY 12233-7253, Phone (518) 402-8706, email: firstname.lastname@example.org
- The Michigan Department of Environmental Quality offers a video on the removal of mercury switches in vehicles. This video may be viewed at http://www.michigan.gov/deq/0,1607,7-135-3307_29693_4175---,00.html
Do I have to declare this incentive as additional income?
ELVS will provide you with a W9 (Request for Taxpayer Identification Number and Certification) form to complete and return upon receipt of your first bucket. No payments will be made until ELVS is in receipt of the returned W9 form. Dismantlers who receive less than $600 in payments per year from ELVS do not have to declare this additional income. Dismantlers who receive more than $600 in payments per year need to declare the payments as income. ELVS will send a 1099 form (Form for Additional Income) to the dismantler at year end.
What laws apply to mercury-containing equipment in motor vehicles?
- Chapter 145 (Laws of 2004),effective July 12, 2005, requires the proper disposal of mercury-added consumer products.
- Chapter 611 (Laws of 2006) effective January 1, 2007, requires the phase-out of mercury-added components greater than 15 milligrams in motor vehicles. By calendar year 2011 (model year 2012 vehicles), no motor vehicles may contain these components except where necessary to comply with federal safety, state safety, health requirements, or for national security.
- Title 6 New York Codes of Rules and Regulations (6NYCRR) Subpart 374-3 (link leaves DEC's website) is the Standards for Universal Waste and provides for the management of the removed mercury-containing equipment.