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Indiana Department of Environmental Management

IDEM > Compliance > Land Compliance > Auto Salvage > Auto Salvage Recyclers Environmental Self-Audit Workbook > Section G: Mercury Switches Section G: Mercury Switches

Mercury switches are found in the hood and trunk light switches of some vehicles. When cars containing these switches are crushed or when the metal is remelted, the mercury can be released into the environment and eventually make its way to the air and water. In order to help protect human health and the environment from the effects of mercury, you are required to remove mercury switches from your scrap vehicles. The information in this section will guide you through the steps necessary to accomplish this safely.

Indiana currently pays auto salvage recyclers $3 for each mercury switch and $5 for each ABS sensor. To find out how to collect your bounty, call IDEM at (800) 451-6027, ext. 2-8174 or (317) 232-8174 and see Appendix: Mercury Switch of this guide. In order to collect a bounty you must participate in the End of Life Vehicle Solutions (ELVS) program. All auto salvage yards should have received a mercury switch recycling container and additional materials from the ELVS program. If you did not receive these, please contact the ELVS program or IDEM.

Many steel mills are now required to ensure that the scrap they purchase is free of mercury switches. One steel mill in Indiana has made it a part of their scrap management plan to only buy from auto salvagers who are listed in the ELVS database as switch recyclers.

(1) Do you receive vehicles that contain mercury switches at your facility?

For a list of vehicles that contain mercury switches, visit the ELVS Solutions Web site.

If “NO”, skip to the next section H - Solid Waste.

(2) Do you remove mercury switches from vehicles at your facility?

Indiana law requires each motor vehicle recycler to remove all mercury switches from each vehicle when it is received. If you do not remove mercury switches at your facility, to be in compliance you will need to obtain an ELVS bucket, remove mercury switches from all vehicles, and submit an RTC plan form. See below for additional information.

(3) Do you use an appropriate container to store mercury switches and/or ABS G-force sensors that contain mercury switches?

An appropriate container is a container that meets the universal waste regulations for transportation (e.g., a bucket provided by ELVS.)

If you do not store mercury switches in an appropriate container such as the plastic bucket provided by ELVS, you will need to submit an RTC plan form. To be in compliance, you will need to obtain an ELVS bucket and store all mercury switches in that container (a maximum of four hundred fifty (450) switches per bucket). Place the plastic liner included with the bucket inside the bucket and place all switches in the liner. Ensure that the container is labeled with the universal waste sticker (completely filled out). After the bucket is filled, you can use the pre-paid shipping label and return the full bucket to ELVS. ELVS will then ship you a new bucket. Submit documentation of proper removal and disposal to IDEM (e.g., photos, receipts).

The ELVS bucket includes educational materials and a DVD that show you which vehicles have mercury switches and how to properly remove, store and ship them. It also contains a universal waste label that must be placed on the bucket, a plastic liner that must be placed in the bucket, and a mailing label that you must use to ship the bucket to the mercury recycler. Keep the cardboard box you received the bucket in. You will need to ship the bucket in the box.

(4) Are the containers in good condition and kept closed unless adding or removing mercury switches?

If you do not store your containers closed and maintain them in good condition, you will need to submit an RTC plan form. To be in compliance, you will need to store your containers closed and maintain the containers in good condition. Submit to IDEM documentation of proper storage (e.g., photos).

(5) Do you mark the containers as universal waste?

We recommend that you use the ELVS-supplied label; however, you can use an appropriate label for mercury switches that have the words universal waste and one of the following three (3) descriptions to describe the switches: “Mercury-Containing Equipment”, “Waste Mercury-Containing Equipment”, or “Used Mercury-Containing Equipment”.

If you do not label your containers as universal waste, you will need to submit an RTC plan form. To be in compliance, you will need to label your container (e.g., the pre-printed label provided in the ELVS bucket). Ensure that the label is completely filled out with the accumulation start date and shipper information. Submit to IDEM documentation of proper labeling (e.g., photos).

(6) Have any containers of mercury switches been accumulating on site for more than one year?

Containers shall be labeled with the accumulation start date.

If you have a container of mercury switches that has been on site for more than one year, you will need to submit an RTC plan form. Mercury switches and other universal waste may only be stored on site for a maximum of one year. Immediately send mercury off site for proper disposal (we recommend using the ELVS program which includes a shipping box, a plastic bucket, and a pre-paid shipping label). Submit to IDEM documentation of disposal and plans to ensure removal at appropriate times (e.g., shipping receipts).

(7) Do you maintain records of mercury switch removals?

Indiana law requires you to maintain records that document the number of vehicles processed at your facility, the number of vehicles that contained switches, and the total number or switches collected. You must keep those records for at least three years.

If you do not maintain records for mercury switch removal, you will need to submit an RTC plan form. To be in compliance, you will need to immediately begin maintaining records. Records should document the number of vehicles processed at your facility, the number of vehicles that contained switches, and the total number of switches collected. Submit to IDEM documentation of record keeping.

Record keeping is important to obtain the mercury switch bounty. For a copy of the claim form, visit the IDEM Forms page or Appendix: Mercury Switch of this guide.

(8) Does your facility use appropriate safety procedures and have emergency equipment available in the areas where you handle mercury switches?

These procedures and equipment can include handling mercury in a well-ventilated area, using containment devices, and having a mercury spill kit.

If you do not use appropriate safety procedures and have emergency equipment on site, you will need to submit an RTC plan form. To be in compliance, you will need to develop safety procedures for handling mercury containing devices at your facility and obtain emergency equipment capable of handling a mercury spill. Submit to IDEM documentation of compliance (e.g., a copy of your safety procedures, receipts,

and photos).

(9) Have you trained your employees on appropriate safety and emergency procedures for removing and handling mercury switches?

These procedures can include removing mercury over a containment device, having a mercury spill kit on hand, and removing mercury in a well-vented area.

If you have not trained your employees on appropriate safety and emergency procedures for removing and handling mercury switches, you will need to submit an RTC plan form. To be in compliance, you will need to train your workers on safety and emergency procedures for mercury switch handling. Submit to IDEM documentation of training (e.g., training log).

For an example of a training log, see Appendix: Mercury Switch of this guide.

Mercury is contained within the gold-colored pellet near the right end of this mercury switch housing.

ELVS bucket properly labeled with the universal waste label.

More information on the ELVS program.

Removal of mercury switches is required by Indiana law.

Improper mercury switch storage.

To obtain a bucket for mercury switches, contact ELVS using the form provided. If you have questions, call IDEM at (800) 451-6027, ext. 3-1655 or (317) 233-1655.

ELVS universal waste bucket.

Correct way to fill out a label for mercury switches.

Removal of a light containing a mercury switch.

Mercury switch bounty claim form.

Mercury spill kit.

A mercury spill kit typically includes safety glasses, disposable gloves, mercury absorbing sponges, and mercury absorbing powder. For examples of mercury kits, visit the U.S. Air Force Medical Web site (site may need you to approve the security certificate to view the page).

Auto Salvage Recyclers Workbook