removing mercury switches from vehicles · scrap.3 this shredded scrap is used primarily to produce...

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Removing Mercury Switches from Vehicles

A Pollution Prevention Opportunity for States

August 2005

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REMOVING MERCURY SWITCHES FROM VEHICLES

Background

Methylmercury is a persistent, toxiccontaminant that bioaccumulates in thetissues of fish. Relatively low concentrations

of mercury in fish pose serious health risks to peopleand wildlife that consume them. Anthropogenicmercury emissions enter water bodies, either directly orthrough deposition from the air and, through biologicalprocesses, transform into methylmercury, which entersthe aquatic food chain.

The population at the highest risk of mercury-related developmentalproblems is children of women who consumed large amounts of fishand seafood during pregnancy. The National Research Council’s July2000 report estimated that each year about 60,000 children could beborn in this country with permanent, irreversible neurologicalproblems due to mercury exposure. As a result, 45 States and theFood and Drug Administration have adopted public healthadvisories related to fish consumption throughout the country due tomercury contamination.

Pure mercury is a liquid metal that volatizes readily. It hastraditionally been used in making products like thermometers,switches, and some light bulbs. (It is sometimes referred to asquicksilver.) Breaking mercury products and spilling mercury, aswell as the improper treatment and disposal of products such asvehicle switches, and wastes containing mercury, can also release itinto the environment.1

Removing Mercury Switches from Vehicles

A Pollution Prevention Opportunity for States

Mercury in Vehicles—The Problem

Prior to complete phase out at the end ofmodel year 2003, domestic automobilemanufacturers (Ford, GM, Chrysler) installedmercury-containing switches in vehicles forconvenience lighting in the trunk, hood andother interior lighted areas, in anti-lockbraking systems (ABS), and in other systemssuch as ride control. Other automobilemanufacturers never used mercury in similarapplications (Honda, Toyota), or stoppedusing it by the end of model year 1997(Subaru) or earlier. Today, vehicles containingan estimated 150 million mercury conveniencelight and ABS switches (representing around150 tons of mercury) remain on the roadalthough this “snapshot” number is falling asthe remaining vehicles with mercury switchesare retired.2 This is a snapshot in time.

Unless there are programs in place to collectthe mercury switches before these vehicles arecrushed, shredded and recycled, mercury canbe released into the air, soil and water duringcrushing, shredding or more importantlyfrom subsequent smelting of the steel hulks inelectric arc furnaces (EAFs). It is estimatedthat between 10-to-12 million vehicles withmercury switches are annually shredded intoscrap.3 This shredded scrap is used primarilyto produce steel in EAFs, and is used to alimited extent in iron and steel foundries.Steel scrap is also used in integrated steelmills but to a smaller extent.4

Automakers are not able to provide precisefigures on the number of switches in existingor scrapped cars because the switches wereinstalled as options in many cases, and theydid not track the installations. However,reasonable estimates of mercury switches in

salvaged vehicles can be derived for aparticular state by first estimating the numberof cars taken out of service annually in thatstate. To derive the number of switches, aconservative estimate of one switch per twoscrapped cars is consistent with the lower endof recent state estimates.

New Federal Regulations On the Horizon—New Challenges for States

US EPA estimates that EAF mercury airemissions are 10 tons per year, making themthe 4th largest source in the United States5.US EPA is writing a Clean Air Act area sourcerule for EAF hazardous air pollutants,including mercury, and hopes to propose it inlate 2005. End-of-stack controls are unlikelybecause of technical issues and US EPAauthority is limited to steel mills (i.e. US EPAcannot impose requirements on upstreamsuppliers, such as dismantlers).

The area source rule is expected to include“work practice” requirements for mercurysource control (pollution prevention), such asmercury feed restrictions already imposed oniron and steel foundries. These “workpractices” may include recognizing scrapgenerated in states with applicable statutes orvoluntary programs that in some systematic,documented way reduce the amount ofmercury in vehicle and other scrap—examples include statutorily mandatedcollection and recycling programs in Maine,New Jersey, and Arkansas, and the voluntaryprograms in Wisconsin, and Colorado. Itshould be noted that it is not yet clear whichexisting programs US EPA would considersufficient for this purpose—it may dependupon the program’s effectiveness.

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States without such programs will need todevelop or amend programs to make themstringent enough to satisfy the rules’requirements so that the scrap from their state’svehicle shredders and dismantlers can continueto be sold for steel production.

Looking For Solutions

Existing Vehicle Recycling Infrastructure

Dismantlers, those handling whole,uncrushed end of life vehicles (ELVs), are inthe best and last position to recover mercuryswitches. However, they generally do notremove mercury switches since there is nomarket for them and there are added costs todo so (locating and removing switches cancost between $1.00 to $5.00 per conveniencelight switch depending on labor, disposal,record keeping, regulatory requirements, etc.).ABS switch removal requires more effortbecause of where they are located, so thelabor cost of ABS switch removal is higher.There are approximately 14,000 vehicledismantlers in the US. However, only a fewStates can identify their dismantlers sincemany are small operations that may not besubject to or may operate outside ofenvironmental permitting or vehicle de-titlingrequirements. The largest dismantler tradeassociation, the national AutomotiveRecyclers Association (ARA), includes, by itsown estimate, only about 30% of alldismantlers. There are also state, regional,and local associations of dismantlers.Dismantlers are also known as salvage yards,and they sell parts from vehicles as well asthe steel hulks. Dismantlers may crushvehicles on site or chose to sell to a mobile orstationary crushing firm for furtherprocessing.

Scrap Processors are a group of businessesthat handle crushed or whole (uncrushed)vehicles. While most accept only crushedvehicles, those handling whole vehicles aresimilar to dismantlers—in the best and lastposition to recover mercury switches. Theprimary national trade association for scrapprocessors is the Institute of Scrap RecyclingIndustries, (ISRI). ISRI has nearly all scrapprocessors operating vehicle shredders andmany of those that pre-process the ELVs asmembers.

Partnership for Mercury Free Vehicles. Thecoalition of dismantlers (ARA), scrapprocessors and shredders (Institute of ScrapRecycling Industries), steelmakers (AmericanIron and Steel Institute, Steel ManufacturersAssociation), environmental groups(Environmental Defense, Great Lakes United,Ecology Center, etc.), are working together toestablish effective mercury switch andrecovery programs that include outreach andeducation, financial incentives fordismantlers, and automaker responsibility.6

Other States

States (23 to date), US EPA, and Canada havetaken steps to address this problem usingeither existing authorities or new legislativeapproaches. Table-1 summarizes the range ofState approaches for removing mercuryswitches from vehicles as of June 2005.(Appendix A provides abstracts and web sitelinks to more information about state programs.Appendix B summarizes the 2005 laws.)

States with existing programs as well as thoseconsidering new legislation are all targetingtheir efforts on having dismantlers and scrapprocessors remove mercury-containing devices

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from end of life vehicles. They differ is in suchareas as:

n Who pays for the program (e.g., automak-ers, steel mills, grants from US EPA, etc.).

n How comprehensive the program is in terms of membership and record-keeping, and data collection.

n Whether switch removal is mandatory.

n Whether someone provides in-kind or directcash financial incentives (e.g., bounties) todismantlers to remove the devices.

n Whether they include ABS switches.

Unlike some other environmental issues,there is virtual agreement among all partiesthat mercury switch removal at vehicle end oflife is warranted to reduce mercury releases.The issues that have created the mostcontroversy are who should finance theprograms, and who should absorb the costs ofswitch removal and subsequent management.

Some states have enacted legislation requiringthe automakers to create or finance parts or theentire program, including a financial incentiveto the dismantlers.

n Arguments for taking this approachinclude imposing costs on those entitieswho installed the switches despite theavailability of non-mercury alternativesused by other manufacturers at the time,and the limited funds available at stateagencies or elsewhere to fund this non-federally supported initiative.

n Arguments against this approach include areluctance to penalize automakers for usingmercury switches that were legal at thetime, and an acknowledgement that

steelmakers should contribute at least inpart because they benefit economicallyfrom not installing mercury stack controls ifthe switches are removed prior to smelting.

A separate but related issue is whetherproviding a financial incentive to dismantlers,sometimes called a bounty, is a necessary anddesirable element of the program. States havetaken different approaches based uponwhether as an equity matter they seek torelieve salvage yards from some of the switchremoval costs, and whether states believe afinancial incentive is needed because of thechallenges associated with a voluntary orenforcement-based approach for the salvageyard sector. In some cases, states have startedwithout an incentive to test the results, buthave indicated they may move to an incentiveif the results do not meet expectations.

The decision on whether to include ABSswitches depends upon balancingconsiderations of the higher time and expenseassociated with ABS switch removal versusthe estimated 10-15% of the mercury invehicles attributed to ABS systems.

Switch removal programs also generally havethree common program components:

n Program administration to manage theprogram and evaluate its effectiveness

n Outreach to the dismantler communitywithin their state

n A system that ensures safe handling,storage and proper management of theremoved mercury devices

Wisconsin and New York have incorporatedrequirements in storm water permits for autodismantlers.

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Table 1 — Summary of State Approaches

State Use Existing Program Authorities Special Legislation12

Arkansas Enacted Legislation — “Mercury Switch Removal Act 2005”Signed March 7, 2005

California Outreach, Pilot Program, Regulation Proposed Legislation: AB 1240— ”Mercury Switch Removal Act of 2005”This bill is currently a two year bill and is on inactive status.

Colorado Voluntary ELV Removal Program

Connecticut Compliance Assistance Proposed Legislation: SB 1187 — Outreach Program “An Act Concerning Mercury Switches

and Devices In Motor Vehicles”

Florida Compliance Assistance Pilot

Illinois Research ”Report to the Governor Proposed Legislation: HB 1628—and Legislature on Reducing and ”Mercury Free Vehicle Act of 2005”Recycling Mercury Switch Thermostats and Vehicle Components”

Indiana Compliance Assistance and Inspections Project

Louisiana Proposed Legislation: HB 600—

Maine Enacted Legislation—Maine law on mercury components in motor vehicles, 38 MRSA §1665-

Enacted Legislation “An Act To Amend the Law on Mercury-added Products” Signed May 20, 2005

Massachusetts Proposed Legislation: H1293 “Mercury Free Vehicle Act of 2005”

Proposed Legislation: H1296—”An Act To Eliminate The Emission Of Mercury From Vehicles”

Michigan Voluntary ELV Removal Program Partnership

Minnesota Pilot Program Partnership Enacted Legislation 1995 requiring “good faitheffort” to remove switches prior to crushing.[Minn. Stat. 116.92 subd. 4(c)]

(continued on page 6)

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Table 1 — Summary of State Approaches (continued from page 5)

State Use Existing Program Authorities Special Legislation12

New Jersey Enacted Legislation — P.L. 2005, c.54 “Mercury Free Vehicle Act of 2005” Signed March 24, 2005

New York Pilot Collection Program Proposed Legislation: A03336 and S 04256—”Mercury-free Vehicle Act of 2005”

North Carolina Proposed Legislation: SB 1014 and HB 1136 —“Mercury Switch Removal Act of 2005”

Ohio Research “Mercury Contamination from Metal Scrap Processing Facilities — A Study by Ohio EPA”

Oregon Pilot Project Partnership OR DEQ Interim Policy Directive For Managing Mercury Switched (Issued in 2002)

Pennsylvania Voluntary ELV Removal Proposed Legislation: SB 524 — Program Partnership “Mercury-Free Motor Vehicle Act”

Rhode Island Outreach Factsheets Enacted: 2005—H 5911 SUBSTITUTE A AS AMENDED — “Mercury Reduction and Education Act.”

South Carolina Proposed Legislation: H709 and H3922—”Mercury Switch Removal Act of 2005”

Texas Enacted Legislation: HB 2793 — “Removal of Convenience Switches”

Vermont Outreach Proposed Legislation: S. 0084—”Comprehensive Management of Exposure to Mercury”

Virginia Partnership Pilot

Washington Proposed Legislation: HB 1731 “An Act Relating to the Removal of Mercury-addedComponents in Motor Vehicles; amending RCW 70.95M.010 and 70.95M.080.”

Proposed Legislation: ESB 5710—An Act Relating to the Removal of Mercury-addedComponents in Motor Vehicles; adding a new chapter to Title 70 RCW; and prescribing penalties.”

Wisconsin Voluntary Partnership

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Existing Vehicle Recycling Infrastructure— A Source and A Solution7

The vehicle-recycling infrastructure currentlyin place in the United States (and Canada) isshown in Figure 1. Approximately 94 percentof End of Life Vehicles (ELVs) enter thissystem, where parts are recovered for their re-use value and the ferrous and non-ferrousmetals are recovered and re-used in theproduction of steel and other products.

Dismantling

ELVs enter the recycling infrastructure via avehicle dismantling facility which sells parts,and/or a “scrap yard,” which makes moneysolely on the value of the steel. (A scrapprocessor may take in whole vehicles or

vehicles that have gone through salvageyards.) Once vehicle dismantlers remove allthe parts with significant resale value from anend-of-life vehicle, the remaining hulk isprepared for crushing and/or shredding.

n The United States has an estimated 14,000dismantlers, 20 percent of which useadvanced technologies and target latemodel vehicles. The remaining dismantlersconduct more traditional auto salvageoperations.

n High-value parts dismantlers tend to behigh-volume operations that quicklyprocess ELVs. This type of dismantler eithersends the ELV hulks on to a shredder or toa scrap yard for further preparation prior toshredding.

End of Life Vehicle

Foundries • Steel Mills(Electric Arc Furnace

and Integrated)

Recycling MarketsParts and Materials

Non-FerrousScrap Markets

Non-Ferrous Scrap

Ferrous Scrap ASR

Landfills

Salvage yard or scrap processor, the most efficient place to remove switches

Figure 1

Existing Vehicle Recycling Infrastructure

Dismantling Crushing Shredding

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n The vast majority of automotivedismantlers are low volume low tech-nology operations that store the ELV towait for a good metal price to sell theremoved parts. Many of the low volume,low technology operations are small andmay not be subject to environmentalregulation.

The most effective and efficientremoval of mercury switches occurs atthe auto dismantler/recycler or thescrap-processing yard prior to crushingfor shipment and shredding.8

Crushing

Mobile and stationary crushers are used tocrush vehicles at auto or scrap recyclingfacilities prior to shredding. Crushers arerarely or never located at EAFs. The hulk isusually crushed or flattened for volumereduction before shipment to the shredder.While some components are removed prior tocrushing, significant quantities of plastics(trim, cabling, etc.), glass and other non-recycled materials and contaminants remainin the vehicle. Shredded vehicle hulksprovide a consistent affordable raw materialfor steel mills. Once a vehicle is crushed, themercury switch (if not removed) may becomeinaccessible.

Shredding

Vehicles are typically crushed before shreddingbut don’t have to be for ease of transport,handling, and efficiency. Vehicles may beshredded at freestanding shredders orshredders located at EAFs (rare). Theshredding process separates the materials intothree fractions: ferrous, nonferrous, and autoshredder residue (ASR). ASR includeslightweight materials such as foam, textiles,plastics, glass, metal fines that are notrecovered, residual fluids, and dirt. Theshredder uses hammermills to break down thehulk into fist-sized chunks. The ferrous metalsare then recovered by magnetic separation.Nonferrous metals are recovered using othertechnologies such as eddy current separators.The shredder produces a high quality steelscrap product, which is sent to integrated andEAF steel mills and to iron and steel foundries,although, EAFs are the predominantnationwide consumer.

Though some states have made progressin recovering mercury switches, thebulk of the mercury switches remainwith the shredded steel product. Themercury is contained in small steel‘bullets’ which are readily attracted by amagnet in most switches.9

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Electric Arc Furnaces or Mini Mills (EAF)

EAFs use electrical energy to melt and refinescrap to make steel products. During melting,elements in the scrap — such as phosphorus,silicon, manganese, carbon, and other materials— are oxidized. Other documented byproductsof the EAF process include metal dusts, andgaseous byproducts, including an estimated 10tons of mercury air emissions.10

Today there are about 100 EAF Mini Millsoperating in the United States. The U.S. steelproduction from these mills for that year was approximately 45 million metric tons (50 million short tons). Approximately 37 percent of all domestic ferrous scrapprocessed by the steel industry is suppliedfrom the automotive recycling sector, whichalso processes discarded appliances and other industrial scrap steel.11 (See figure 2 forStates with EAF Mills.)

WA

OR

CA

ID

MT

NV

UT

AZ

HI

State Has One or More Electric Arc Furnace Facilities

Figure 2Location of Some Electric Arc Furnaces in the United States*

June 2005

*Based on data provided by Steel Manufacturers Association, QSC Members, and US EPA

CO

WY

NM

TX

OK

KS

NE

SD

ND

MNWI

IL

MO

AR

LA

MSAL

NC

VA

MI

NY

PA

DE

NH

ME

TN

KY

WV

IA

SC

NJ

GA

FL

IN OHMDDC

CT

MA

RI

VT

AK

Removing Switches from Vehicles— Cost Effective and Easy To Do

Most of the mercury in vehicles is found inconvenience light switches. Vehicle trunk andhood light switches can contain mercury. Amercury switch is probably being used if thelight goes on when the hood is partway up, orif the bulb housing is deliberately mounted atan angle to the hood, Most cars containingmercury switches are American makes andmodels. The second most significant use ofmercury is in ABS sensors, which are typicallyin four-wheel drive vehicles. Other much lessimportant uses (less than 1% historically) areswitches to activate airbags, some seat beltsystems and automatically adjustingsuspension systems. Some agriculturalequipment, military vehicles, mass transitvehicles, and fire hook and ladder equipmentalso contain mercury switches.

n A Michigan study found on average, it takes48 seconds to remove a convenience lightswitch assembly and 95 seconds total toremove the pellet in addition to theassembly.14 The study timed this activityfrom the point at which the switch waslocated and exclusive of recordkeeping andassociated activities.

n New Jersey estimates it takes less than 1 minute to remove a mercury conveniencelighting switch from an end of life vehicle.15

n The 1.3 million vehicles registered in Maineat the beginning of 2001 contained almost2300 pounds of mercury in switches alone.16

n Since the inception of the voluntaryMichigan Mercury Switch Sweep recoveryprogram a total of 12,028 switches.17

n Minnesota has recovered over 46,000 vehicleswitches since its programs began in 2001.18

How Dismantlers Remove Switches

Mercury switches are removed before thevehicle is junked or crushed. This is generallydone at the same time as removal of vehiclefluids, batteries, refrigerants and non-deployed airbags. There are four basic stepsdismantlers follow:

1. Cut the power supply wire attached to thebase of the switch assembly.

2. Remove any fasteners in order to separatethe entire assembly from the vehicle.

3. Carefully remove the mercury switch fromthe assembly. If the switch cannot easily beremoved, put the entire assembly in thecollection container. Removing the switchfrom the assembly will save storage spaceand may also save on disposal costs.

4. If the switch or the assembly looks damagedor corroded, place the switch or entireassembly in a separate plastic container, likea yogurt tub with a tight fitting lid, toprevent leakage.13

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Auto recycler removes mercury switchfrom under the car hood

State Actions and Approaches

ARKANSAS

Enacted Legislation—The “Mercury SwitchRemoval Act of 2005” establishes a programthat requires mercury switches to be removedfrom end of life vehicles before they arecrushed, or flattened, and shredded.Automobile manufacturers are required to takeresponsibility—including financial—for the saferemoval of mercury-containing light switchesfrom end-of-life vehicles, prior to beingshredded and recycled into new products.Signed into law on March 7, 2005.

http://www.arkleg.state.ar.us/ftproot/bills/2005/ public/SB323.pdf andhttp://www.americanrecycler.com/0405mercury.shtml

CALIFORNIA

Outreach, Pilots, and Regulation—Developedvariety of materials (including trainingmanuals, fact sheets, a Best ManagementPractices (BMP) document, modelrecordkeeping forms, and accumulationlabels) to assist auto dismantlers and repairfacilities to identify, locate, remove, andproperly manage mercury switches invehicles. California is also currentlyconducting a pilot program in collaborationwith the State of California Auto Dismantlers’Association (SCADA) to assist the associa-

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Appendix APrograms for Reducing and RecyclingMercury Containing Vehicle Devices

Abstracts and Web Site Links as of June 2, 2005

tion’s member dismantlers in complying with the State’s mercury switch removalrequirement. In 2003, adopted regulationswhich required, effective January 1, 2005, thatrequire removal of mercury convenience lightswitches from the trunks and hoods of end-of-life vehicles prior to crushing, bailing,shearing or shredding the vehicle.http://www.dtsc.ca.gov/LawsRegulationsPolicies/Mercury/Oeara_regs_mercfinaltext.pdf andhttp://www.dtsc.ca.gov/HazardousWaste/Mercury/index.html

Proposed Legislation—AB 1240—“Mercury Switch Removal Act of 2005.” Would require every manufacturer of vehicles sold in thestate, individually or as part of a group ofmanufacturers, in consultation with theDepartment of Toxic Substances Control(Department), develop and submit a mercuryswitch removal plan to the Department forreview and approval on or before July 1, 2006.The plan will provide for the financing of theremoval, collection, and recovery system formercury switches. These costs are to be borneby the manufacturers of vehicles sold in thestate, and the manufacturers will develop amethod that ensures the prompt payment tovehicle recyclers, scrap recycling facilities,and the department, for costs associated withmercury switch removal and disposal.http://www.leginfo.ca.gov/cgi-bin/postquery?bill_number=ab_1240&sess=CUR&house=B&author=levine

Enacted Legislation—Senate Bill (SB) 633, theMercury Reduction Act of 2001, required theDepartment of Toxic Substances Control totake certain actions to promote the removaland proper management of conveniencelighting switches from vehicles: 1) providetechnical assistance to businesses thatdismantle or crush vehicles on the saferemoval and proper disposal of mercury lightswitches, including information on makesand models that contain such switches andcompanies that recycle them; 2) encouragerepair shops to offer replacement andrecycling of mercury light switches; 3) informthe public how they can have mercury lightswitches replaced and recycled.

COLORADO

Voluntary ELV Removal Program—Participants in the program remove switchesfrom ELVs, properly store and dispose ofcollected switches, maintain records andprovide program input. With money fromSupplemental Environmental Projects (SEPs)the Colorado Department of Public Health andEnvironment (CDPHE) provides training,technical support, and basic equipment toparticipants and provides resources to supporta program administrator. The programadministrator collects switches, complies withapplicable regulations, ships switches todisposal/recycling site, pays cost of transportand disposal/recycling, records number ofswitches received, reports to CDPHE and auto-motive recyclers. Participants in the programare receiving some enforcement amnesty andare also eligible to receive Cross MediaCompliance Assistance (CMCA). Automobilemanufacturers are not financially responsible forthe removal and collection of the switches.

http://www.cdphe.state.co.us/hm/mercury/switch.asp

CONNECTICUT

Compliance Assistance Outreach—Communicates about the issue in their AutoRecycling Industry Compliance Guide andthrough a fact sheet that describes bestmanagement practices for locating andremoving switches in vehicles.http://www.dep.state.ct.us/enf/autorecyclingguide.pdf

Proposed Legislation—SB 1187— Wouldprohibit the sale of motor vehicles containingmercury switches and headlamps andestablish a program to recover such switchesand headlamps when motor vehicles arerecycled. Auto manufacturers would developa program to remove mercury switches andmercury-containing headlamps from ELVs.Costs born by auto manufacturers- incentive,transport, recycling— Min $1.00 per switch.Would also require the phase-out mercurycontaining switches and headlamps byJanuary 1, 2007. Dealers establish voluntaryswitch removal/ replacement for vehicles incommerce.http://www.cga.ct.gov/2005/tob/s/2005SB-01187-R00-SB.htm

FLORIDA

Compliance Assistance Pilot—Provides freeenvironmental training to salvage yardsoperators. An environmental compliancemanual is provided to all participating yards,and those that have verifiable compliancewith the requirements of the manual getcertified as “Florida Green Yards.” Mercuryswitches are one of the waste streams targetedunder this program. The compliance manual

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has information on the proper removal andmanagement of mercury switches.http://www.dep.state.fl.us/waste/categories/hazardous/pages/autocert.htm

ILLINOIS

Research—In February 2005, the IllinoisEnvironmental Protection Agency issued aReport to Governor and Legislature on Reducingand Recycling Mercury Switch Thermostats andVehicle Components. This report presentsrecommendations for improving efforts toreduce and recycle mercury components thatare found in thermostats and motor vehicles. It recommends a statewide program be createdto collect and manage mercury-containingswitches when a vehicle reaches the end of itsuseful life. The framework for a mercuryswitch removal and management program caninclude the following components:

n Establish a goal that over 90 percent ofreasonably accessible mercury switcheswill be removed from end-of-life vehicles.Operate the program for 10 years andensure the collected switches are safelymanaged.

n Establish a mutually agreed-to systemamong automakers, steel mills andshredders to fund the costs associated withremoval and management of mercuryswitches from end-of-life vehicles,including educational outreach andcompliance. Provide a monetary incentivefor auto recyclers/ dismantlers and othersto remove and return the switches forcollection to foster widespread andeffective participation in the program.

n Create educational materials (e.g., guidancemanual and instructional video) and

deliver training workshops around thestate to provide information on theenvironmental benefits and appropriateprocedures for removing and managingmercury switches from end-of-life vehicles.(IEPA/OPP/04-026)

Proposed Legislation—HB 1628 is known asthe “Mercury-Free Vehicle Act”. Twoamendments have been offered. One concernsthe removal of mercury switches, while theother would prohibit the use of mercury-containing products in new vehicles.

http://www.ilga.gov/legislation/BillStatus.asp?DocNum=1628&GAID=8&DocTypeID=HB&LegID=16423&SessionID=50&GA=94

INDIANA

Compliance Assistance and Inspections—This long-term project takes a comprehensive,integrated approach to the auto salvage facilitysector in Indiana. The project includes acompliance assistance manual that addressesmercury switch disposal and provides linkswhere citizens may obtain more information.Workshops and inspections are also includedin the project.

http://www.in.gov/idem/autosalvage/

LOUISIANA

Proposed Legislation—HB 600 “MercurySwitch Removal Act” states that manufacturersof vehicles sold within this state, individuallyor as part of a group, shall develop, inconsultation with the Louisiana Department ofEnvironmental Quality, a mercuryminimization plan and submit the mercuryminimization plan to the secretary for reviewand approval. A mercury minimization planmust provide for the financing of the removal,

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collection, and recovery system for mercuryswitches installed in vehicles manufactured bythe manufacturer and its predecessors andaffiliates. These costs shall be borne by themanufacturers of vehicles sold in the state,ensuring that additional financial burdens arenot placed on automobile dealers or businessesdealing with end-of-life vehicles. Themanufacturers shall develop a method thatensures the prompt payment to vehiclerecyclers, scrap recycling facilities, and thedepartment for costs associated with mercuryswitch removal and disposal.http://www.legis.state.la.us/billdata/stream document.asp?did=296675http://www.legis.state.la.us/

MAINE

Enacted Legislation—As of January 1, 2003,state law in Maine requires mercury switchesfrom convenience lighting and ABS g-sensorsas well as mercury headlamps to be removedfrom motor vehicles before they are crushedand shredded. The law also requiresautomakers to establish a collection system torecycle the mercury switches and headlamps,and pay a bounty to auto recyclers for eachswitch collected. Salvage yards must delivercollected switches to one of two sites in state.Costs born by auto manufacturers—incentive of$1.00 per switch, transport, recycling—. Thislegislation resulted from a stakeholder groupprocess and report to the Legislature.

http://janus.state.me.us/legis/ros/lom/LOM120th/5Pub651-700/Pub651-700-05.htm

Effective September 17, 2005, the bountyincreases to $4 if automakers continue requirean associated VIN; if the VIN requirement isdropped, the minimum bounty is $3 perswitch.

http://www.mainelegislature.org/legis/bills/chapters/PUBLIC148-1.asp

MASSACHUSETT

Proposed Legislation—H 1293 is known as the“Mercury Free Vehicle Act of 2005” and wouldrequire manufacturers to set up a mercuryswitch recovery program with a goal torecovering 90% of the mercury switches. Costsborn by auto manufacturers—incentive, transport,recycling—$3/switch for convenience lights and$15/switch for ABS.

Proposed Legislation—H 1296 is “An Act ToEliminate The Emission Of Mercury FromVehicles” and would require the removal ofall mercury containing components fromvehicles before they are crushed.Manufacturers would need to implementplans for the recovery of mercurycomponents from discarded vehicles,including reimbursement for the cost ofremoval of these components. http://www.mass.gov/legis/bills/house/ht01/ht01296.htm

MICHIGAN

Voluntary ELV Removal ProgramPartnership—The Michigan Department ofEnvironmental Quality and the Alliance ofAutomobile Manufacturers (Alliance) havesigned a Memorandum of Understanding thatexpires on September 30, 2006 to promote thevoluntary removal and collection of mercuryswitches from ELVs. The Michigan MercurySwitch Sweep Program project managerswork cooperatively to promote the removaland proper management of vehicle switchescontaining mercury. The Alliance contractswith a third party to operate the program.The Alliance provides funding for buckets,

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labels, spill kits, educational materials andcollection/transportation of the recoveredswitches. The Alliance has also developed a 5 minute instructional DVD that explains theprogram to dismantlers. Auto dismantlers,recyclers and crushers are not monetarilycompensated for the time it takes to removethe switches. The project includes enlistingthe help of auto shredders, the electric arcfurnace, and integrated steel manufacturers. http://www.deq.state.mi.us/documents/deq-ess-p2-mercury-switchsweepmou.pdfhttp://www.michigan.gov/deq/0,1607,7-135-3308_3323-114288—M_2005_3,00.html

MINNESOTA

Enacted Legislation—Minnesota law requiresauto recyclers, crushers and shredders to makea “good faith effort” to remove mercurylighting and ABS switches from ELVs prior tocrushing (effective 8/1/95).

Other Programs—The Minnesota PollutionControl Agency Salvage Yard Programconducted training, developed a BMPmanual, provided prepaid switch recyclingcontainers, and enforced the switch removallaw from 1995 to 2001. A six-month pilotprogram to collect both light and ABSswitches was conducted in Ramsey County in2002. A $1 bounty was given for each switchcollected. Approximately 8,700 switches werecollected from approximately 14,000 vehicles.[In legislative testimony, the auto industrycharacterized this as “100% recovery.”] Onesteel mill in the state, North Star (now GerdauAmeristeel), serves as a collection facility forswitches and since 2000 has paidparticipating dismantlers and recyclers$40/pound for switches as an incentive toremove them. The state’s Travel Management

Division has removed mercury switches fromvehicles leaving state service since November2001. Non-mercury switches are installedwhere possible. The state vehicle bidspecification has required disclosure ofmercury content in vehicles since late 2001.

Pilot Program Partnership—Automobilemanufacturers, through their tradeassociation the Alliance of AutomobileManufacturers (Alliance), have an agreementwith Minnesota Waste Wise (MWW), tooperate a two-year switch outreach,collection, transportation, and recyclingprogram. The program’s intended users aresalvage yards, scrap processors, vehiclecrushers, and other businesses that maygenerate automotive mercury switches in thecourse of their business. The agreement waseffective June 1, 2004 and the Alliance isproviding $150,000 to fund the two-yearprogram

The MWW is responsible for operation of theentire auto mercury switch outreach,collection, transportation, and recyclingprogram. MWW is responsible for makingregular program reports to the Alliance andOffice of Environmental Assistance. There areno bounties or payments to the yards, just freeand convenient recycling of whole switchassemblies, rather than pellets, to minimizethe risk of release.

NEW JERSEY

Enacted Legislation—A2482 “Mercury SwitchRemoval Act of 2005” This law establishes aprogram for the removal of mercury-containingconvenience light and anti-lock brake mercuryswitches from “end-of-life” vehicles before theyare flattened, bailed, or shredded. Automobile

15



manufacturers are financially responsible for theremoval and collection of the switches, theirtransportation to mercury retorters, and therecovery of the gram of mercury each switchcontains. Automobile Manufacturers are requiredto pay a minimum of $2/switch to dismantlers plus$0.25/switch to NJ DEP for program adminis-tration. The New Jersey bill is based on amodel developed by the Partnership forMercury Free Vehicles (PMFV). New Jersey hada stakeholder process and conducted extensiveresearch in preparation of this legislation.http://www.njleg.state.nj.us/bills/BillView.asp

NEW YORK

Pilot—The New York State Department ofEnvironmental Conservation developed avoluntary program that offers free collectioncontainers and shipping for all New Yorkauto recyclers. A portion of a U.S. EPA granthas been used to fund the program. Shippingand transportation costs were approximately$9 for 450 switches. Recycling costs were $45per pound of mercury collectedhttp://www.dec.state.ny.us/website/ppu/p2autosw.html .

Proposed Legislation—A 03336 and S 04256,The“Mercury-free Vehicle Act of 2005”; requiresautomobile manufacturers to establish andimplement plans to provide for the removal,replacement, collection and recovery ofmercury-added components from motorvehicles currently on the road or about to bescrapped. Automobile Manufacturers are requiredto pay prevailing rate based on manufacturer-dealer warranty for transport and recycling.http://assembly.state.ny.us/leg/?bn=A03336 andhttp://assembly.state.ny.us/leg/?bn=S04256

NORTH CAROLINA

Proposed Legislation—Senate Bill 1014 andHouse Bill 1136—“Mercury Switch RemovalAct”—Would require every manufacturer ofvehicles sold within North Carolina todevelop a mercury minimization plan andsubmit the plan to the Department for reviewand approval. Manufacturers of vehicleswould be allowed to develop and submit aplan either individually or as part of a groupof manufacturers. A manufacturer shall not berequired to develop or implement a mercuryminimization plan if the manufacturer demon-strates to the satisfaction of the Departmentthat there is no significant risk of a release ofmercury from any vehicle manufactured bythe manufacturer. A mercury minimizationplan must include a method to finance theremoval, collection, and recovery of mercuryswitches installed in vehicles manufactured by themanufacturer and its predecessors and affiliates.http://www.ncga.state.nc.us/Sessions/2005/Bills/House/HTML/H1136v4.htmlhttp://www.ncga.state.nc.us/sessions/2005/bills/senate/html/s1014v1.html

OHIO

Research—“Mercury Contamination from Metal Scrap Processing”

Facilities—A Study by Ohio EPA”—The OhioEPA initiated a study to investigate thepotential for high mercury emissions fromscrap processing facilities in Ohio. The studyreport indicates that mercury switches in carsand appliances are the main cause of mercuryemissions from these facilities and recom-mends that a voluntary program be in place toremove mercury switches before shredding.http://www.epa.state.oh.us/dapc/atu/mercpaper.pdf

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OREGON

Pilot Project—The Mercury “Switch Out”project is a cooperative effort of the OregonEnvironmental Council, AAA of Oregon andIdaho, the Northwest Automotive TradesAssociation, and the Oregon Department ofEnvironmental Quality (OR DEQ). Thisproject allows drivers to take their cars toparticipating auto repair shops to replacemercury-containing hood and trunk switchesfor free.http://www.deq.state.or.us/programs/consumercorner/mercury/mercury5.htm

http://www.oeconline.org/kidshealth/hgreductionpartnerships/view?searchterm=mercury

Policy Directive—In 2002, the OR DEQ issuedan interim policy for management of mercuryswitches. This policy allows facilities such asauto recyclers and vehicle repair facilities thatremove mercury-containing switches tomanage these switches as universal wastes. http://www.deq.state.or.us/wmc/hw/policy/2002-po-002.pdf

PENNSYLVANIA

Voluntary ELV Removal Program Partnership—The Pennsylvania Department of Environ-mental Protection (DEP), AERC RecyclingSolutions, Bethlehem Apparatus Co. Inc.,Clean Air Council, Institute of ScrapRecycling Industries, Pennsylvania Auto-motive Recycling Trade Society and SteelRecycling Institute established a partnershipprogram that invites vehicle recyclers toparticipate in Pennsylvania’s Mercury SwitchRemoval Program that encourages theremoval of mercury switches from vehicles.Program participants will remove theswitches before the mercury is released to the

environment. The DEP pays program coststhat include training workshops, shippingcontainers and safety equipment (mercuryspill kits, safety goggles, latex gloves, andplastic containment tub). It also includes anincentive payment paid to participants by theDEP for removing the mercury switches. Themercury recyclers are paying for the shippingand mercury recycling costs.http://www.dep.state.pa.us/dep/deputate/pollprev/mercury/mercuryswitch.htm

Proposed Legislation—SB 524 is known asthe “Mercury-Free Motor Vehicle Act” andrequires manufacturers to develop andimplement a plan for the removal of mercuryswitches from end-of-life vehicles. AutomobileManufacturers would be required to pay aminimum of $2/switch to dismantlers and$1/switch to DEP.

RHODE ISLAND

Outreach—The Department of EnvironmentalManagement (DEM) has developed factsheetsto enable the identification of automotivelighting assemblies that contain mercuryswitches. These fact sheets include proceduresfor replacing them with non-mercuryswitches. http://www.dem.ri.gov/programs/benviron/assist/abp2fact.htm

Enacted Legislation—2005—H 5911Substitute A As Amended—“MercuryReduction and Education Act.” Creates aprogram for the recovery of mercury switchesfrom end-of-life vehicles. Manufacturers arerequired to develop plans to capture 50% ofthe switches in 2006 and 70% in 2007 andeach year thereafter. If the capture rates arenot achieved in any calendar, the DEM shall

17



develop, issue, administer and enforceregulations compelling the manufacturers toundertake a collection program. All costs ofthe program would be borne by themanufacturers. They would be required topay vehicle recyclers or scrap metal facilities aminimum of $3/switch removed. In addition,the manufacturers would be required to pay$1/switch to the DEM as partial compensa-tion for costs of administering the program. http://www.rilin.state.ri.us/Billtext/BillText05/HouseText05/H5911Aaa.pdf

SOUTH CAROLINA

Proposed Legislation—H709 and H3922—“Mercury Switch Removal Act of 2005”—Within ninety days after the effective date ofthis chapter, every manufacturer of vehiclessold within this State, individually or as partof a group, shall develop, in consultation withthe Department of Health and EnvironmentalControl, a mercury minimization planprepared pursuant to this section and submitthe mercury minimization plan to theDirector of the Department of Health andEnvironmental Control for review andapproval pursuant to Section 44-18-150. Thesecosts must be borne by the manufacturers ofvehicles sold in the State, ensuring thatadditional financial burdens are not placed onautomobile dealers or businesses dealing withend-of-life vehicles. The manufacturers shalldevelop a method that ensures the promptpayment to vehicle recyclers, scrap recyclingfacilities, and the department for costsassociated with mercury switch removal anddisposal.http://www.scstatehouse.net/sess116_2005-2006/bills/3922.htm

TEXAS

Enacted Legislation—HB 2793—“Removal ofConvenience Switches” requires vehiclemanufacturers to develop and implement aplan to remove and recycle mercuryconvenience switches. Manufacturers arerequired to provide educational materials forthe recyclers. They are also required toprovide packaging materials, shipping,recycling, and storage or disposal for theremoved switches. Vehicle recyclers or scrapmetal recycling facilities that removeconvenience switches from eligible vehicles inaccordance with educational materialsreceived under this chapter shall be providedregulatory incentives by the commissionunder programs implemented pursuant toSection 5.755, Water Code, including on-sitetechnical assistance and compliance historyclassification adjustments. http://www.capitol.state.tx.us/

VERMONT

Outreach—Vermont conducts limitedoutreach to encourage voluntary removal andtwice a year removes switches from State-owned vehicles. (Thomas Benoit 5-25-05)

Proposed Legislation—S. 0084 is known as“Comprehensive Management of Exposure toMercury” and, among other items, requiresthe Agency of Natural Resources to conduct astudy of methods to effectively and feasiblyremove mercury-added components fromvehicles, appliances, and other equipment atsolid waste management facilities and metalsalvaging businesses. http://www.leg.state.vt.us/database/status/summary.cfm?Bill=S%2E0084&Session=2006

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VIRGINIA

Partnership Pilot—The Virginia DEQ in part-nership with the Virginia Automotive RecyclersAssociation is sponsoring and promotingremoval of mercury-containing switches fromjunked cars. AERC Recycling Solutions inAshland, Virginia provides a “SwitchCollection / Shipping Kit” to any salvageoperator that volunteers to remove the switchesduring disassembly. The kit will hold up to 450mercury switches, and when full, is shipped toAERC’s facility in Pennsylvania for recycling.http://www.deq.virginia.gov/p2/mercury/automotiveswitches.html

WASHINGTON

Proposed Legislation—SB 5710 and HB 1731“An Act Relating to the Removal of Mercury-added Components in Motor Vehicles;amending RCW 70.95M.010 and 70.95M.080.”Vehicle manufacturers develop andimplement a system to remove, collect, andrecover mercury-added components fromend-of-life vehicles.http://www.leg.wa.gov/wsladm/billinfo1/dspBillSummary.cfm?billnumber=1731&year=2005and http://www.leg.wa.gov/wsladm/billinfo1/dspBillSummary.cfm?billnumber=5710&year=2005

WISCONSIN

Voluntary Partnership—The WisconsinDepartment of Natural Resources (WDNR),Concerned Auto Recyclers of Wisconsin, theWisconsin Institute of Scrap Recycling Indus-tries, the Storm Water Cooperative CompliancePrograms and auto and scrap recyclers haveformed a partnership to establish mercuryswitch recycling capability for end-of-life vehi-cles in Wisconsin. The WDNR worked withindustry groups to establish collection sites and

provided technical and policy guidance forremoval and safe handling of switches andprovides some supplies for the safe handling ofremoved. The partnership works cooperativelyto promote the program. A US EPA grantprovided funding through June 2005.http://www.dnr.state.wi.us/org/caer/cea/assistance/scrap/switches/index.htm

Federal Actions

U.S. EPA

In August 2004, U.S. EPA convened a group ofkey stakeholders to develop a nationalvoluntary switch removal program. Thegroup’s members included state governments,vehicle recyclers and dismantlers, shredders,auto manufacturers, environmentalorganizations, steel companies, steel recyclers,and mercury recyclers. The U.S. EPA’sobjective was to have a voluntary program inplace by January 2005. To date, the workgroupmembers have not been able to reachconsensus on how to establish or to equitablyshare costs for a voluntary program.

International Actions

CANADA

Voluntary Partnership—The Clean Air Foun-dation, which is a partnership of government,industry and non-profit organizations, workswith auto recyclers in a voluntary program tocollect mercury light switches from ELVs.Program costs include marketing materials,staff time, collection containers, transpor-tation of containers and switch disposal. Thefederal government, two provinces and autility company provided funding. http://www.pollutionprobe.org/merc/switchout.htm.

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20



ARKANSAS NEW JERSEY RHODE ISLAND TEXAS

Type of mercury switches: Conveniencelighting and ABS

Conveniencelighting and ABS

Conveniencelighting

Conveniencelighting

Switch removal is mandatory forvehicle recyclers or scrap metalrecycling facilities?

Yes, 30 days afterstate approval ofautomakersmercury minimi-zation plan

Yes, 30 days afterstate approval ofautomakersmercury minimi-zation plan

Yes No

Automakers required to submitmercury minimization plan to statefor approval?

Yes, 90 days aftereffective date oflaw

Yes, 90 days aftereffective date oflaw

Yes, bySeptember 1,2005

No

Is the capture rate that theautomakers plan must meetspecified in legislation?

Yes, 90% Yes, 90% Yes, 50% for CY 2006 and70% for CYs 2007-2017

N/A

Plan must explain how capturerate requirements are anticipatedto be met through implemen-tation of the plan?

N/A N/A Yes N/A

Plan must include proposal forstorage or disposal of theswitches?

Yes Yes Yes N/A

Plan must include proposal forpackaging and shipping switchesto authorized recycling, storage, or disposal facilities?

Yes Yes Yes N/A

Plan must provide for storage ofrecovered switches if environ-mentally appropriate recycling ordisposal technologies are notavailable?

Yes Yes No N/A

Plan must include proposal forimplementing and financing thesystem?

Yes Yes Yes N/A

Plan must not place additionalfinancial burden on automobiledealers or businesses dealing with end-of-life vehicles?

Yes No No N/A

Program must utilize, to the extentpracticable, existing infrastructure forrecycling end-of-life vehicles?

Yes Yes Yes Yes

Automakers must begin implemen-tation of plan upon state approval?

Yes, within 30days of stateapproval

Yes, within 30days of stateapproval

By January 1,2006

By January 1,2006

Appendix BMatrix of State Mercury Auto Switch

Legislation Passed in 2005*

21




Automakers must identify make,model and year of vehicles con-taining switches:

Yes, includinganticipated futureproductionmodels

Yes, includinganticipated futureproductionmodels

Contents of plannot specified inlegislation

Yes

Automakers must providedescription and location ofswitches:

Yes Yes Contents of plannot specified inlegislation

Yes

Automakers must provideestimate of number of switchesavailable, for purposes ofcomputing capture rate?

No No No Yes

Automakers to provide system tomark vehicles to be processed forshredding or crushing to indicatepresence or absence of mercuryswitches:

Yes No Contents of plannot specified inlegislation

No

Automakers to develop anddistribute educational materialsfor vehicle recyclers and scrapmetal recycling facilities:

Yes Yes Yes Yes

Must include information onsafe and environmentallysound methods for switchremoval?


Yes

Must include information onmercury hazards and properhandling of mercury?


Yes

Automakers must make availableto the public information concern-ing services to remove mercuryswitches in motor vehicles?

No No Yes No

Automakers must providetechnical assistance to vehiclerecyclers, scrap metal recyclingfacilities and state?

No No Yes No

Automakers provide financing forcosts incurred by vehicle recyclersor scrap metal recycling facilities?

Minimum of:

$5/switch tovehicle recyclersor scrap metalrecycling facilities

$1/switch to state

Minimum of:

$2/switch tovehicle recyclersor scrap metalrecycling facilities

$0.25/switch tostate

Only if capture ratenot met in any onecalendar year.

Minimum of$3/switch tovehicle recyclersor scrap metalrecycling facilities

$1/switch to state

No

Automakers to provide reimburse-ment regardless of when switcheswere removed, if vehicle recyclersor scrap recycling facilitiesmaintain records?

Yes Yes No N/A

22




Automakers pay storage containercosts?

Yes Yes Yes Yes

Automakers pay packaging costs? Yes Yes Yes Yes

Automakers pay shipping costs? Yes Yes Yes Yes

Automakers pay recycling, storageor disposal costs?

Yes Yes Yes Yes

Automakers to submit annualreports to state:

Yes Yes Yes, plus quarterly Yes

Automakers must design vehiclesand their components for recycling:

Yes No No No

Automakers to indemnify, defend,and hold harmless vehicle recyclersand scrap metal recycling facilitiesfor any liability arising from releaseof mercury from switches after thecomponents are transferred to themanufacturer or its agent orcontractor?

Yes No No No

Regulatory incentives** to vehiclerecyclers and scrap metal recyclingfacilities?

No No No Yes

Time at which vehicle recyclers orscrap metal recycling facilities mustbegin removal and proper manage-ment of removed switches afterstate approval of automakers plan:

Within 30 days Within 30 days By January 1,2006

N/A

Vehicle recycler or scrap metalrecycling facility to presumeswitch is mercury switch if themanufacturer is uncertain aboutmercury content?


No

Vehicle recyclers or scrap metalrecycling facilities exempt fromremoving switch if it is inaccessibledue to significant damage ofvehicle in area surround switch?


N/A

Vehicle recyclers and scrap metalrecycling facilities required tomaintain records on switchescollected, number of end-of-lifevehicles containing mercuryswitches, and number of end-of-lifevehicles processed for recycling?

Yes plus vehiclemake and modeland number ofswitches collectedfrom each make

Yes and VIN Contents of plannot specified inlegislation

Yes plus sendannual report toTCEQ

State must approve, disapprove,or conditionally approveautomakers switch removal plan?

Yes, within 120days of receipt oforiginal plan

Yes, within 120days of receipt oforiginal plan

Yes, timeframenot specified inlegislation

N/A

If plan is denied by state, howmany days do the automakershave to resubmit a plan?

30 days 30 days Not specified inlegislation

N/A

23




If portion of plan is approveddo the automakers have toimplement before rest of planis approved by the state?

Yes, within 30days of partialapproval

Yes, within 30days of partialapproval

Not specified inlegislation

N/A

State must review revised planwithin how many days ofreceipt?

30 days 30 days Not specified inlegislation

N/A

If the original plan is neitherapproved nor disapproved bythe state shall the plan be con-sidered conditionally approved?

Yes, 120 daysafter receipt oforiginal plan

Yes, 120 daysafter receipt oforiginal plan


N/A

State agency has authority tocomplete, on behalf of auto-makers, any portion of the mer-cury minimization plan that hasnot been approved by the state?

Yes, 240 daysafter effectivedate of legislation

Yes, 240 daysafter effectivedate of legislation


N/A

State can review the approvedplan at any time and makerecommendations to the planat any time upon finding thatthe approved plan is deficientor not accomplishing purposesof legislation?

Yes Yes No N/A

Switches must be designated asUniversal Waste by the state?

Yes Yes Yes Yes

State required to develop, issue,and administer regulations toimplement legislation?

No No Yes, if capturerate not met inany one calendaryear.

N/A

State to provide training, packag-ing, shipping, public educationand storage, disposal or recycling?

No No Yes, only ifcapture rate notmet in any onecalendar year.

No

Program End Date Not in legislation Not in legislation 2017 Does not apply tomanufacturers onor after the10thanniversary of thedate on whichthe manufacturerlast installed aconvenienceswitch in a vehi-cle sold in Texasor August 31,2015, whicheverdate occurs first.

* Created by Becky Lockart, IL EPA Office of Pollution Prevention July 2005

** Regulatory incentive means: 1) confidential technical assistance for all facility operations from the state environmental protectionagency. The state technical assistance provider cannot initiate enforcement actions and does not report to any state or federal enforce-ment personnel including those at the state environmental protection agency, the U.S. Environmental Protection Agency, or the U.S.Occupational Safety and Health Administration. 2) The state environmental protection agency may modify penalties to be paid inenforcement actions taken against the recycling facility based on facility’s participation in the voluntary switch removal program.

1 US EPA Website 2 http://www.epa.gov/mercury/about.htm

2 US EPA Staff remarks to the Quicksilver Caucus onApril 11, 2005

3 US EPA Staff remarks to the Quicksilver Caucus onApril 11, 2005

4 US EPA Website 1 (http://www.epa.gov/epaoswer/hazwaste/mercury/ntl-switch.htm)

5 ibid6 http://www.cleancarcampaign.org/

partnership.shtml7 Ecology Center, Great Lakes United, and

University of Tennessee Center for Clean Productsand Clean Technologies, Toxics in Vehicles:Mercury, Implications for Recycling and Disposal(January 2001) and US EPA Staff remarks to theQuicksilver Caucus on April 11, 2005

8 New Jersey Department of EnvironmentalProtection, “Mercury Switch Data Collection PilotProject,” March 24, 2004

9 ibid10 US EPA Staff remarks to the Quicksilver Caucus on

April 11, 200511 Ecology Center, Great Lakes United, and

University of Tennessee Center for Clean Productsand Clean Technologies, Toxics in Vehicles:Mercury, Implications for Recycling and Disposal(January 2001) and US EPA Staff remarks to theQuicksilver Caucus on April 11, 2005

12 Reflects enacted legislation and actions during the2005 legislative session

13 2004 Pit Stops Fact Sheets Connecticut Departmentof Environmental Protection, 79 Elm Street,Hartford, CT 06106-5127; Office of PollutionPrevention (860) 424-3297 ww.dep.state.ct.us/wst/p2/vehicle/abindex. htm Fact Sheet: DEP-P2-PITSTOPS-FS-005 Last Updated: August, 2004.

14 In-Service Mercury Switch Review, July 2003 –Conducted by MI DEQ

15 New Jersey Department of EnvironmentalProtection, “Mercury Switch Data Collection PilotProject,” March 24, 2004

16 http://www.maineenvironment.org/toxics/mercury%20in%20motor%20vehicles.htm

17 ibid18 John Gilkeson, MOEA, As of May 2005

24



References1. New Jersey Department of Environmental

Protection, “Mercury Switch Data Collection PilotProject,” March24, 2004

2. Ecology Center, Great Lakes United, andUniversity of Tennessee Center for CleanProducts and Clean Technologies, Toxics inVehicles: Mercury, Implications for Recycling andDisposal (January 2001)

3. U.S. Environmental Protection Agency, “MercuryStudy Report to Congress, Volume II,” December1997. US EPA MACT Rule for Iron and SteelFoundries (www.epa.gov/ttn/atw/ifoundry/ifoundrypg.html)

4. Gaither, Michelle, Final Report for King CountyWashington, “Automotive Mercury SwitchRemoval Programs,” August 2004.

5. Tom Tyler’s remarks to the Quicksilver Caucuson April 11, 2005

6. US EPA Website 1—(http://www.epa.gov/epaoswer/hazwaste/mercury/ntl-switch.htm)

7. (US EPA Website 2) http://www.epa.gov/mercury/about.htm

8. http://www.capitol.state.tx.us/cgibin/db2www/tlo/billhist/Hmatrix.d2w/report?LEG=79&SESS=R&CHAMBER=H&BILLTYPE=B&BILLSUFFIX=02793

9. (http://www.cleancarcampaign.org/pdfs/toxicsinvehicles_mercury.pdf)

10. US EPA Website 3 (http://www.epa.gov/epaoswer/hazwaste/mercury/ntl-switch.htm)

11. Report on Implementation Progress of theMinnesota Auto Mercury Switch RecoveryProgram, MN OEA, May 17, 2005

12. 2004 Pit Stops Fact Sheets ConnecticutDepartment of Environmental Protection, 79 ElmStreet, Hartford, CT 06106-5127; Office ofPollution Prevention (860) 424-3297www.dep.state.ct.us/wst/p2/vehicle/abindex.htm Fact Sheet: DEP-P2-PITSTOPS-FS-005 Last Updated: August, 2004

13. http://www.maineenvironment.org/toxics/mercury%20in%20motor%20vehicles.htm

removing mercury switches from vehicles · scrap.3 this shredded scrap is used primarily to produce...

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