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MERCURY SWITCHES
What is a mercury switch?
"Mercury switch" or "universal waste mercury switch" is a sealed container that holds elemental mercury. Mercury switches are used for completing or breaking an electric circuit, like the convenience lights in vehicles or appliances, or for opening and closing a valve, like a flame sensor in a gas appliance. Mercury switches are relatively small and come in various shapes. Mercury switches are divided into two main types:
- "Mercury-containing motor vehicle switch" means any motor vehicle switch that contains mercury including, but not limited to, a mercury containing motor vehicle light switch. ?Mercury-containing motor vehicle light switch" means any motor vehicle switch found in the hood or trunk of a motor vehicle that contains mercury.
- "Non-automotive mercury switch" means any mercury switch other than a mercury-containing motor vehicle switch.
Is there a difference in how I dispose of these two types of switches?
There are slightly different requirements for mercury-containing motor vehicle and non-automotive switches. Both become a universal waste on the date that a handler (i.e., the person that generates, accumulates, or sends it to another handler or destination facility) removes and decides to discard a used switch from a vehicle or product. An unused switch of both types also becomes a waste on the date the handler decides to discard it.
If any existing non-automotive mercury switches are not removed from a product prior to it being discarded, the ENTIRE PRODUCT becomes a universal waste on the date the owner discards it. The requirements for vehicles are much the same except for the following distinction. Because of the difficulty of locating and removing all mercury-containing motor vehicle switches, the regulations require only that a motor vehicle from which any MERCURY-CONTAINING LIGHT SWITCHES have not been removed becomes a universal waste on the date any person decides to crush, bale, shear, or shred it.
How do I identify a mercury-containing motor vehicle switch?
Documents helpful for identifying mercury-containing motor vehicle switches are available on the Department of Toxic Substances Control website. They are:
Appendix A of the DTSC Self-training Manuals for Auto Dismantlers and Auto Repair Shops lists the vehicles that are currently known to have mercury switches in their hoods and trunks.
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What are the Best Management Practices for the motor vehicle switches?
Best Management Practices for mercury-containing motor vehicle switches are available on the Department of Toxic Substances Control website. They are:
How do I identify a non-automotive mercury switch?
Only mercury switches contained in major appliances are covered. "Major appliance" means any domestic or commercial device, including, but not limited to, a washing machine, clothes dryer, hot water heater, dehumidifier, conventional oven, microwave oven, stove, refrigerator, freezer, air-conditioner, trash compactor, and residential furnace. Major appliances are also sometimes referred to as "white goods".
What types of switches are found in these major appliances?
Two types of mercury switches may be found in major appliances.
- "Tilt", or "positional", switches measure movement. The mercury moving inside the switch responds to changes of position and will either complete or break an electrical circuit to turn an appliance (or its light) on or off.
- A "thermoelectric", or "safety valve", switch is used in flame sensors in gas-fired appliances. The expansion and contraction of mercury is used to regulate gas flow. When the pilot flame is lit the mercury is warmed and expands, and opening a diaphragm allowing gas to be supplied to the pilot light. If the pilot is not lit, the mercury cools and contracts, causing the diaphragm to close and shutting off the gas supply.
Are there other resources available to help identify these switches?
Documents helpful for identifying mercury-containing non-motor vehicle switches are available on the Department of Toxic Substances Control website. They are:
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What are the best management practices for the non-motor vehicle switches?
Best Management Practices for mercury-containing non-motor vehicle switches are available on the Department of Toxic Substances Control website. They are:
Do I have to take these items to a special recycler?
Beginning January 1, 2006, you must be a Certified Appliance Recycler to remove materials that require special handling from major appliances. Materials that require special handling are materials that when removed from a discarded appliance may not be disposed of in the garbage or at a solid waste facility. The following documents on Certified Appliance Recyclers and application forms are available on the Department of Toxic Substances Control website.
Make sure that the ultimate destination of your discarded appliance is a Certified Appliance Recycler. This is a person or business certified to remove and properly manage materials that require special handling from discarded major appliances. Persons or businesses that only collect or transport appliances prior to ultimate disposal or recycling are not required to be Certified Appliance Recyclers.
Are there alternative, non-mercury, switches available?
Alternatives to mercury-containing switches are available and are currently being installed in many applications. Many foreign vehicles use mechanical or ball bearing switches that do not contain mercury. Some newer domestic vehicles no longer use mercury switches.
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How can I recycle these switches?
Recycling options differ depending on whether the mercury switches are from household use, or from business or other non-household use.
Households
Most households only generate universal waste switches if the homeowner replaces them on a vehicle or major appliance. Households may utilize the following recycling opportunities Internal for universal waste switches. It is recommended that you bring the entire universal switch rather than attempting to remove the mercury ampoule or valve yourself. If the repairs are performed by an automotive or appliance repair business, ensure that the business properly recycles the universal waste switches.
Businesses and Institutions
Subsection 66273.13(e) of Title 22 of the California Administrative Code requires that small quantity handlers of universal waste mercury switches managed them in a way that prevents releases of any universal waste or component of a universal waste to the environment. These requirements are summarized below:
- Contain any universal waste mercury switch that shows evidence of leakage, spillage, or damage that could cause leakage under reasonably foreseeable conditions, in a sealed plastic bag within a container. The container shall be closed, structurally sound, compatible with the contents of the switch, and lack evidence of leakage, spillage, or damage that could cause leakage under reasonably foreseeable conditions. The container shall contain packing materials adequate to prevent breakage of universal waste mercury switches during storage, handling, and transportation.
- Remove mercury-containing motor vehicle switches from motor vehicles, and non-automotive mercury switches from products that contain them, in accordance with the following requirements:
- Removes mercury switches in a manner designed to prevent breakage;
- Ensures that a mercury clean-up system is readily available;
- Immediately transfers any mercury resulting from spills or leaks from broken mercury switches to an airtight container that meets the requirements listed above;
- Ensures that employees removing mercury switches are thoroughly familiar with proper waste mercury handling and emergency procedures, including transfer of spilled mercury to appropriate containers;
- Accumulates removed mercury switches in closed, non-leaking containers that are in good condition;
- Packs removed mercury switches in the container with packing materials adequate to prevent breakage during storage, handling, and transportation; and
- Keeps records, on paper or electronically, of the removal of mercury switches from vehicles and household appliances for at least three years from the date of removal, which shall include, at a minimum, the following information:
- The total number of vehicles crushed, baled, sheared, or shredded;
- The total number of appliances destined for shredding;
- The total number of vehicles or appliances destined for crushing, baling, shearing, or shredding that were determined to contain one or more mercury switches;
- The number of mercury switches removed from these vehicles and appliances; and
- The number of motor vehicles from which mercury switches could not be removed due to accidental damage to the vehicle.
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Businesses and institutions may utilize the following recycling opportunities Internal for universal waste only. Universal waste switches are accepted from auto repair shops, auto dismantlers and appliance recyclers under the following conditions:
- Only Conditionally Exempt Small Quantity Universal Waste Generators (CESQUWGs) are eligible to utilize the following recycling opportunities Internal. A CESQUWG is a generator who:
- Disposes of less than 1 kilogram of RCRA acutely hazardous waste, or a combined total of 100 kilograms or less of universal and RCRA hazardous waste, in any calendar month; and
- Generates no more than 5 Cathode Ray Tube Devices in a calendar year.
- Auto dismantlers and appliance recyclers will be required to submit copies of the records required under subsection 66273.13(e) of Title 22 of the California Administrative Code. Suggested formats for these records may be found in the Mercury Switch Model Recordkeeping Forms - June 2005, document available at www.dtsc.ca.gov/HazardousWaste/Mercury. By requiring submission of this information, we can determine the success of our collection efforts and encourage compliance.
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