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Pennsylvania Voluntary Mercury Automobile Switch Removal Guide
Pennsylvania Department of Environmental Protection
December 2005 i

Pennsylvania Voluntary Mercury Automobile Switch Removal Guide
December 2005
I. Program Overview. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1
What is the purpose of this manual? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1
What is a mercury switch? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1
What is the Voluntary Mercury Automobile Switch Removal Program? . . . . . . . . 1
Why should mercury switches be removed? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2
Methyl Mercury in Sport Fish: Information for Fish Consumers. . . . . . . . . . . . . . . 2
What are the requirements for participation in the mercury switch removal program? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3
What are the costs of the mercury switch program? . . . . . . . . . . . . . . . . . . . . . . . . . 3
What are the costs to participating automobile recyclers? . . . . . . . . . . . . . . . . . . . . 3
What are the “steps” of the mercury switch removal program? . . . . . . . . . . . . . . . . 3
How will the mercury recyclers determine the number of switches/weight equivalency? . . . . . . . . . .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4
II. Removing Light Assemblies From Vehicles. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4
How are the light assemblies removed from the vehicles? . . . . . . . . . . . . . . . . . . . . 4
Is there a way to tell which vehicle makes and models contain mercury switches? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4
Why isn’t there a comprehensive list of the vehicles that contain mercury switches? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4
III. Removing Mercury Switches From Light Assemblies . . . . . . . . . . . . . . . . . . . . . . . . . . . 5
How are the mercury switches removed from the light assembly? . . . . . . . . . . . . . 5
How should glass switches be handled? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5
IV. Requirements For Universal Waste Handlers . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5
What are the waste requirements for program participants? 5
What are the specific waste management standards for handling mercurycontaining devices (mercury switches)? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6
What are the labeling and storage requirements for mercury switches? . . . . . . . . . . 6
What are the treatment and disposal prohibitions? . . . . . . . . . . . . . . . . . . . . . . . . . . 6
V. Shipping. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7
How is mercury waste shipped? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7
VI. Cleaning Up A Mercury Spill . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8
How can an accidental mercury spill be safely cleaned up? . . . . . . . . . . . . . . . . . . 8
VII. Mercury Safety . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9
What are important things to keep in mind when cleaning up a mercury spill? . . . . 9
What are the first aid measures for mercury spills? . . . . . . . . . . . . . . . . . . . . . . . . . 10
Appendices
Appendix A: Photos of typical light assemblies containing mercury switches . . . . . . . . . 11
Appendix B: How To Determine Your Universal Waste Category . . . . . . . . . . . . . . . . . . 17
Appendix C: Photo of Properly Labeled Storage Container. . . . . . . . . . . . . . . . . . . . . . . . 18
Appendix D: Mercury Automobile Switch Shipping Guidelines. . . . . . . . . . . . . . . . . . . . 19
Appendix E: Switch Recovery / Reimbursement Form . . . . . . . . . . . . . . . . . . . . . . . . . . . 20
Appendix F: Photo of Shipping Box with FedEx Label. . . . . . . . . . . . . . . . . . . . . . . . . . . 21
Appendix G: Photo of Mercury Spill Kit . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 22
Appendix H: Mercury Switch Removal Program Contact Information. . . . . . . . . . . . . . . 23
Appendix I: DEP Regional Contact Information. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 24 ii

Pennsylvania Voluntary Mercury Automobile Switch Removal Guide
December 2005
What is the purpose of this manual?
This manual will provide general guidance to automotive recyclers on how to locate, safely remove, and manage the mercury switches found in vehicle hood and trunk convenience light assemblies. The manual details the process of how to safely remove the switch and the proper procedure to follow to obtain the cash incentive offered as part of this voluntary switch removal program. Removing and recycling the light assemblies and mercury switches can be done using the steps laid out in this booklet.
What is a mercury switch?
A mercury switch, found frequently in the convenience light assemblies in vehicle hoods and trunks, is a small bullet-shaped capsule that is usually made of steel or glass and contains elemental mercury.
The mercury enables the switch to complete or break an electrical circuit that turns the hood or trunk convenience lights on or off. Hood and trunk mercury-containing convenience light switches account for about 87 per cent of the total mercury contained in model year 1999 and older vehicles. The picture below shows a typical mercury automobile switch.
Source: California Environmental Protection Agency, Department of Toxic Substances Control, from
Pollution Probe, 2000
What is the Voluntary Mercury Automobile Switch Removal Program?
On November 9, 2004, the Pennsylvania Department of Environmental Protection (DEP) announced the creation of the Pennsylvania Mercury Automobile Switch Removal Program. This announcement occurred in conjunction with the formal signing ceremony for the Memorandum of Understanding that was developed by the Mercury Automobile Switch Workgroup (Workgroup). The Workgroup is composed of AERC Recycling Solutions and Bethlehem Apparatus Company, Inc. (mercury recyclers), the Pennsylvania Automotive Recycling Trade Society (PARTS), the Clean Air Council
(CAC), the Institute of Scrap Recycling Industries (ISRI), the Steel Recycling Institute (SRI) and DEP.
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Pennsylvania Voluntary Mercury Automobile Switch Removal Guide December 2005
The Workgroup developed a program that encourages the removal of mercury switches from automobiles in a safe, effective and relatively easy manner.
The Mercury Automobile Switch Removal Program is a voluntary two-year program that encourages the removal of mercury-containing switches from “end of life” vehicles. An incentive will be paid for the switches that are removed by registered participants. DEP has entered into this program pursuant to
Section 4(22) of the Air Pollution Control Act (35 P.S. 4001 et seq.) which authorizes DEP to develop and conduct demonstration programs relating to air pollution control, and Section 104(2) of the Solid
Waste Management Act (35 P.S. 6018.104) which authorizes DEP to cooperate with appropriate private organizations to initiate, conduct, and support demonstration projects pertaining to solid waste management systems. The mercury-containing switches that are removed and recycled under this program will be managed under the Federal and Pennsylvania Universal Waste Regulations in accordance with 40 CFR Part 273 and 25 Pa. Code Chapter 266b respectively.
Why should mercury switches be removed?
Mercury-containing switches were installed in automobiles for convenience lighting in the trunk, hood and other interior lighted areas, and in anti-lock braking systems (ABS) prior to a complete phase out in model year 2003. Approximately 200 tons of mercury are used in automobile switches on the road in the United States today. Approximately 10 tons of mercury are in automobiles being recycled each year. Within 10 to 15 years most of the automobiles containing these mercury switches will have been recycled. The majority of the mercury from automobile switches enters the environment when the crushed automobiles with switches still intact are melted as scrap in the steel and iron making processes and the mercury is emitted to the air. Eventually, the elemental mercury ends up in
Pennsylvania waterways and is converted by bacteria into its more toxic form—methylmercury.
Methylmercury is a persistent, toxic contaminant that bioaccumulates in fish tissue. High concentrations of methylmercury in fish pose serious health risks to people and wildlife that consume them.
Studies indicate that approximately one gram of mercury, the amount in a single mercury switch, enters a 20-acre lake each year through atmospheric deposition. This small amount, over time, can contaminate the fish in that lake. Therefore, as each automobile that contains mercury switches is recycled, the potential for further contamination of Pennsylvania’s waterways greatly increases.
METHYLMERCURY IN SPORT FISH: INFORMATION FOR FISH CONSUMERS
Methylmercury is a form of mercury that is found in most freshwater and saltwater fish largely because of man-made emissions. In every waterway in Pennsylvania, methylmercury has been found in some types of fish at concentrations that may be harmful to human health. In 2001
Pennsylvania began issuing statewide advisories cautioning people not to eat more than half a pound of fish caught in Pennsylvania’s waters per week (approximately one meal). This advisory was issued because of the high content of mercury in fish. In these advisories, women of childbearing age and children are encouraged to be especially careful about following the advice because of the greater sensitivity of fetuses and children to methylmercury. To view the advisory, visit www.dep.state.pa.us
and type in the Keyword “fish advisory.”
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Pennsylvania Voluntary Mercury Automobile Switch Removal Guide December 2005
What are the requirements for participation in the mercury switch removal program?
Any business located in Pennsylvania that meets the following requirements may participate. For determination or additional program information, please contact Mike Berk of PARTS at (717) 763-
1777.
Participation Requirements :

Participants must be located in Pennsylvania.

Participants must pre-register with PARTS and receive an acceptance letter.

Participants must obtain program information and safety equipment from DEP. This equipment includes safety goggles, latex gloves, mercury spill kits, and plastic dismantling tray and storage containers.
What are the costs of the mercury switch program?
DEP has allocated $350,000 over the next two years to pay program costs that include training workshops, shipping containers and safety equipment (mercury spill kits, safety goggles, latex gloves, and plastic containment tub, etc). This funding includes a cash incentive paid to participants by
PARTS through a grant from DEP for removing the mercury switches. The mercury recyclers are paying for the shipping and mercury recycling costs. If participation is greater than anticipated, DEP will explore additional funding opportunities for continuation of the program. However, program payments are made subject to the availability of funding.
What are the costs to participating automobile recyclers?
The cost to the participants is the amount of time that it takes to remove the switches beyond what the incentive pays for. The removal time will decrease as program participants become more experienced and efficient at removing the switches.
What are the “steps” of the mercury switch removal program? (Continue reading manual for details of the program.)

Complete registration application.

Obtain program information and supplies.

Receive acceptance letter and safety equipment.

Remove switches in the manner described by DEP and store in properly labeled containers.
(Switches must be removed from the switch assembly.)

Call one of the two mercury recyclers when approximately 450 switches have been accumulated or within one year from the time you began accumulating the switches, whichever comes first. (Shipping containers will hold up to 450 switches.)

Receive shipping materials and Switch Recovery/Reimbursement form from mercury recyclers.

Complete Section 1 of the Switch Recovery/Reimbursement form and return along with the switches to the mercury recycler that sent you the shipping materials and form.

The Switch Recovery/Reimbursement form will be returned to you with Section 2 completed and the number of switches/weight equivalency noted.

Sign and date Section 3 of the Switch Recovery/Reimbursement form to indicate agreement with the mercury recyclers.
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Pennsylvania Voluntary Mercury Automobile Switch Removal Guide December 2005

Mail completed Switch Recovery/Reimbursement form to PARTS for reimbursement. (All
Sections must be completed for reimbursement.)

Continue collecting mercury switches.
How will the mercury recyclers determine the number of switches/weight equivalency?
This is an important issue to program participants because it will determine the reimbursement for the switches that are shipped. When the switches are shipped to the mercury recycler, the mercury recycler will weigh the shipment. Each switch weighs approximately 3.0 grams. A switch equivalency will be determined by dividing the weight of the shipment by 3. Although the equivalency will not exactly match the number of switches that are turned in, it should be close. Counting the number of switches by the mercury recyclers would substantially increase the cost—and decrease the efficiency—of the program.
How are light assemblies removed from the vehicles?
Locate the small light assembly beneath the vehicle trunk or hood. (Refer to Appendix A for examples of common light assemblies that contain mercury switches.)

Always put on the goggles and gloves provided by DEP.

Locate the light in the trunk and/or in the hood.

Find and follow the wiring to the light assembly.

Disconnect the power supply that is attached to the base of the light assembly, if a battery is still connected.

Disconnect any additional wiring attached to the light assembly.

Remove the entire light assembly from the vehicle.

Place the entire light assembly in a properly labeled thick, plastic bucket that has a tight-fitting lid for temporary storage until the mercury switches can be removed from the light assemblies.

Repeat these steps for all mercury-containing light assemblies in the vehicle.

Assume that a light assembly contains a mercury switch if there is any doubt.
Is there a way to tell which vehicle makes and models contain mercury switches?
The suggested general rule of thumb is:

Most American cars prior to 2003 contain mercury switches (Chrysler not after 1998)

Foreign cars prior to 1995 may contain mercury switches (Honda & Toyota few models)

Keep in mind: if a car typically does not contain a mercury switch as a standard feature, mercury switches may have been added as an after-market option or as a replacement.
Why isn’t there a comprehensive list of the vehicles that contain mercury switches?
So far, complete, comprehensive lists are generally inaccurate. Other states have found that using a list is more time-consuming than using the general rule of thumb enumerated above.
NOTE : Some of the mercury switches are inaccessible because of damage to the car. DO NOT try to remove the assemblies if the car is too damaged.
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Pennsylvania Voluntary Mercury Automobile Switch Removal Guide December 2005
How are the mercury switches removed from the light assemblies?

Put on safety goggles and gloves provided for you by DEP.

Use a hand tool to remove the latch, clip, or snap that holds the light assembly together.

Look for the small bullet-shaped mercury switch when the light assembly is open.

ALWAYS DISMANTLE THE MERCURY SWITCH FROM THE LIGHT ASSEMBLY
OVER THE PLASTIC TRAY PROVIDED BY DEP. THIS WILL CONTAIN THE
MERCURY IF THERE IS A LEAK OR SPILL.

Use a small, flathead screwdriver, or other tool, to remove the mercury switch.

Place removed mercury switches in a plastic bag and store in the properly labeled sealable shipping container for temporary storage.
**Note: These are just the recommended procedures based on prior experience. There may be other tools or methods that work better. However, please do not compromise health and safety.
Follow the safety instructions to ensure proper storage and shipping of the mercury switches.
Glass Switches : Old Volvos, Audis, Mercedes, and other European vehicles prior to model year 1993 may have glass mercury switches; take extra care when removing these assemblies.
How should glass switches be handled?

Place the glass switches in a separate plastic bag.

Place the bag containing the glass switch(es) in the other plastic bag with the metal switches.

Place both bags in the shipping container. Ensure that enough room is left to accommodate the larger sized glass switch(es) without breaking them. Seal the container.
NOTE : Some vehicles may have a ball bearing switch instead of a mercury switch. They often look similar to the mercury switch. The way to tell them apart is that the ball bearing switch rattles when shaken.
DO NOT include ball bearing switches with mercury switches.
What are the waste requirements for program participants?
Participants in this voluntary program must follow Pennsylvania’s Universal Waste Regulations. For a more complete understanding of how these regulations apply to your facility, please consult the
Pennsylvania Universal Waste Regulations at 25 Pa. Code Chapter 266b and 40 CFR Part 273
(incorporated by Reference), and the Pennsylvania Hazardous Waste Regulation Compliance Guide:
“Requirements for Managing Universal Wastes.”
Most, if not all, program participants will qualify as small quantity handlers of universal waste
(SQHUW), not a large quantity handler. Therefore, this program guidance is set up for the SQHUW.
(Refer to Appendix B for a more detailed discussion of the category to which you belong.)
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Pennsylvania Voluntary Mercury Automobile Switch Removal Guide December 2005
What are the specific waste management standards for handling mercury-containing devices
(mercury switches)?
The following requirements are common sense waste management standards designed to prevent the release of mercury to the environment. The primary waste management activity associated with mercury automobile switches will be removing the mercury switch from the light assembly. If a mercury switch shows evidence of leakage or damage that could cause leakage while still in the light assembly, you must place the entire assembly in a closed, structurally sound container. The removal of mercury switches is allowed under 25 Pa. Code 266b.11, provided you comply with the following requirements:

Remove mercury switches in a manner designed to prevent breakage;

Remove mercury switches on, in or over a containment device ( plastic tray provided )

Ensure that a mercury clean-up system is in place to transfer any spilled mercury to an appropriate container ( spill kit provided );

Ensure that the work area is well-ventilated and monitored to ensure compliance with applicable OSHA exposure levels for mercury;

Train employees in proper waste-handling and emergency procedures;

Store removed mercury switches in closed, non-leaking containers that are in good condition
(shipping containers provided) ; and

Pack removed mercury switches in a container with packing materials adequate to prevent breakage during storage, handling and transportation ( packing materials provided ).
What are the labeling and storage requirements for mercury switches?
There are several things to keep in mind when labeling and storing mercury switches and preparing them for shipping and for eventual recycling:

Ensure that all containers that are used for storage of mercury switches are properly labeled. This includes the container holding the lighting assemblies with the mercury switch intact, as well as the container that holds the removed mercury switches.

Check that the label is marked with one of three phrases provided in the regulations ( labels provided
). We recommend using the phrase, “Universal Waste—Mercury-Containing
Device(s).” (Refer to Appendix C for photo of properly labeled storage container.)

Remember that mercury switches cannot be accumulated for longer than one (1) year from the date the first mercury-containing light assembly was removed from the vehicle.
Therefore, shipping must occur at least once per year, even if the container is not full.
Keep records of shipment to document the date the switches were shipped.

DEP recommends using a heavy plastic pail for temporary storage of mercury containing light assemblies prior to removing the bullet-shaped mercury switch.

Place the removed switches in the plastic bag and the leak-proof shipping container which are provided. The mercury recycling facilities will accept mercury switches only and will not accept the lighting assembly with switch intact.
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Pennsylvania Voluntary Mercury Automobile Switch Removal Guide
What are the treatment and disposal prohibitions?
December 2005

Treatment or disposal of mercury switches by a SQHUW is prohibited.

Delivery must be ensured to a permitted facility. Both mercury recycling facilities participating in this program are permitted to receive mercury switches.

DO NOT dispose of mercury switches in the trash.
How is mercury waste shipped?
There are two mercury recyclers located in Pennsylvania. Both recyclers have agreed to pay the program’s shipping costs and perform all mercury recycling. When the shipping container provided is almost filled, contact one of the mercury recyclers to have them send the shipping box and forms
(Refer to Appendix D for the Mercury Automobile Switch Shipping Guidelines and to Appendix E for the Switch Recovery/Reimbursement form). Select either of the two mercury recyclers listed below to ensure free shipping, recycling, and receipt of the incentive payment:
AERC Recycling Solutions
2591 Mitchell Avenue
Allentown, PA 18103
(610) 797-7608
FAX (610) 797-7696 mpark@aercrecycling.com
Important:
Bethlehem Apparatus Company, Inc.
890 Front Street
P.O. Box Y
Hellertown, PA 18055
(610) 838-7034
FAX (610) 838-6333 mail@bethapp.com

Do not fill the container with more than 450 switches (450 switches = 0.98 pound mercury). All shipments must be less than one pound of mercury . If over one pound of mercury is shipped, the shipment must then meet U.S. D.O.T. hazardous material shipping requirements and shipping will NOT be free. The U.S.D.O.T. requirements are not described in this manual. Participants that need to send more than one pound of mercury must contact the mercury recyclers, DEP, and DOT for assistance.

If you have light assemblies that cannot be disassembled, contact Bethlehem Apparatus at
(610) 838-7034 or AERC Recycling at (610) 797-7608 for shipping instructions.

Do not dispose of removed mercury switches or the intact mercury switch assemblies in the trash.

When the mercury switches are almost ready to ship, contact one of the two mercury recyclers and request shipping materials. The mercury recyclers will send a cardboard shipping container, the Switch Recovery/Reimbursement form, and another plastic container for collecting future switches.
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Pennsylvania Voluntary Mercury Automobile Switch Removal Guide December 2005

Complete Section 1 of the Switch Recovery/Reimbursement form and send to the mercury recycler with the collected switches.

Place the plastic shipping container with mercury switches in the cardboard shipping box with packing materials ( packing materials provided ).
 Fill out the supplied FedEx ground shipping label and specify “Ground Transport Only.” Check box marked “Other” and list as “Automotive Switches.”

Place the FedEx shipping label on the cardboard box. (Refer to Appendix F for photo of shipping box with FedEx label.)

After the mercury recyclers receive the switches, they will weigh the switches. Each switch weighs approximately 3.0 grams and contains approximately 1 gram of mercury. Equivalency will be determined by dividing the weight of the shipment by 3. The resulting number will be used by the mercury recyclers to fill out Section 2 of the Switch Recovery/Reimbursement form. (Although the equivalency number will not exactly match the number of switches turned in, it should be close. Counting the number of switches by the mercury recyclers would substantially increase the cost—and decrease the efficiency—of the program.)

The Switch Recovery/Reimbursement form will be returned via mail to the participant. Section
3 of the Switch Recovery/Reimbursement Form must to be completed, signed, and mailed to
PARTS for reimbursement.

PARTS will send the incentive payment usually within 30 to 45 days.
How can an accidental mercury spill be safely cleaned up?
A spill or release occurs in the unlikely event that the mercury escapes from the metal switch. This can happen if the switch is broken or corroded and will result in about a gram of mercury being released.
1.
Bring the spill kit to the site of the spill. ( Spill kit provided
—Refer to Appendix G for photo of mercury spill kit.)
2.
Put on the gloves and goggles.
3.
Pick up any shards of glass or sharp objects. a.
Place all broken objects on a paper towel. b.
Fold the paper towel and place in disposal zip-lock bag. c.
Close the disposal bag. d.
Label the bag.
4.
Sprinkle Hg Absorb powder over the surface of the mercury.
5.
Wet powder with water.
6.
Work Hg Absorb powder into mercury with scraper to form an amalgam.
7.
Scrape the residual amalgam into dustpan and place in disposal bag.
8.
Use the mercury sponge to absorb any remaining mercury that is difficult to see after the visible mercury has been cleaned up.
9.
Wet sponge to activate Hg Absorb coating.
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Pennsylvania Voluntary Mercury Automobile Switch Removal Guide December 2005
10.
Wipe contaminated surface with coated side of sponge to amalgamate all free mercury on surface.
11.
Place sponge in disposal bag.
12.
Place remaining amalgam in disposal bag.
13.
Place disposal bag in sturdy container.
14.
Label the container.
15.
Never throw mercury-contaminated items into the trash. Contact AERC Recycling at (610)
797-7608 or Bethlehem Apparatus at (610) 838-7034 for information about how to ship the released mercury or the mercury-containing items.
Please note: Mercury spill clean-up residue cannot be handled as a universal waste, but instead must be handled as a hazardous waste. The applicable requirements of 25 Pa. Code 260a-266a, 268a and
270a must be followed. For help in determining the applicable generator requirements in the event of a spill, please contact the DEP.
What are important things to keep in mind when cleaning up a mercury spill?
Because mercury is harmful if inhaled, ingested, or touched , proper safety precautions must be followed at all times. An entire facility must be prepared to deal with unlikely spills or leaks of mercury from switches.
ALWAYS

A LWAYS use gloves and goggles

A LWAYS instruct employees on how to use the spill kit and how to handle a mercury spill.

A LWAYS use the spill kit provided by DEP.
Know where to find it and how to use it.
NEVER

N EVER pour mercury down a drain, never put it in the trash, and never put it in a fire.

N EVER use a broom to sweep up mercury. Sweeping creates even smaller beads of mercury, which will be more difficult to collect.

N EVER use a vacuum to clean up a mercury spill. Mercury readily becomes a vapor, and a vacuum will disperse mercury into the air where it can be inhaled.

A LWAYS dismantle the mercury switches from the lighting assemblies over the plastic container provided by DEP. This will contain the mercury in case of a spill or leak.

A
LWAYS try to ensure proper ventilation—e.g.: open windows, keep area below 70 °F to keep evaporation to a minimum
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Pennsylvania Voluntary Mercury Automobile Switch Removal Guide
What are the first aid measures for mercury spills?
December 2005
If a mercury spill occurs that exposes anyone to mercury, follow these procedures:

Skin contact: Wash the area with soap and water and remove any clothing that has come into contact with mercury. Place the mercury-contaminated clothing inside a sealable plastic bag.
Seek medical attention immediately. Properly dispose of the sealed bag of mercurycontaminated clothing using a hazardous waste handler at the first opportunity.

Eye contact: Flush eyes with running water for 15 minutes, then seek medical attention immediately.

Inhalation: Move the person to an area where he or she can get fresh air. Seek medical attention immediately.

Ingestion: Seek medical attention immediately.
Contact the local poison control center or health care provider for more information.
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Pennsylvania Voluntary Mercury Automobile Switch Removal Guide
December 2005
Source: California Environmental Protection Agency, Department of Toxic Substances
Control, from New York State Department of Environmental Conservation
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Pennsylvania Voluntary Mercury Automobile Switch Removal Guide December 2005
Source: New York Department of Environmental Conservation, 2000. EPA, Region 5, 2003.
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Pennsylvania Voluntary Mercury Automobile Switch Removal Guide December 2005
Source: New York Department of Environmental Conservation, 2000. EPA, Region 5, 2003.
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Pennsylvania Voluntary Mercury Automobile Switch Removal Guide December 2005
Source: New York Department of Environmental Conservation, 2000. EPA, Region 5, 2003.
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Pennsylvania Voluntary Mercury Automobile Switch Removal Guide December 2005
Source: New York Department of Environmental Conservation, 2000. EPA, Region 5, 2003.
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Pennsylvania Voluntary Mercury Automobile Switch Removal Guide December 2005
Source: New York Department of Environmental Conservation, 2000. EPA, Region 5, 2003.
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Pennsylvania Voluntary Mercury Automobile Switch Removal Guide December 2005
Universal wastes are widely dispersed hazardous wastes that are generated in a variety of places, such as businesses and households, and often in small quantities. There are five types of materials considered to be universal waste in
Pennsylvania. These are batteries, certain pesticides, thermostats, lamps, and mercury-containing devices. In the past, these wastes were frequently mixed with other wastes and sent to municipal solid waste landfills or incinerators. To prevent this problem, the requirements in the Pennsylvania regulations (25 Pa. Code Chapter 266b) and the federal regulations (40 CFR Part 273) were streamlined to encourage the collection and recycling of these wastes.
A Universal Waste Handler is defined as someone who generates universal wastes; receives universal wastes from other waste handlers; accumulates universal waste; or sends universal wastes to another handler, a destination facility, or a foreign destination. All participating facilities will meet the definition of a Universal Waste Handler, because they will be generating, accumulating and sending universal waste to a destination facility as part of this program. The universal waste regulations specify two different size classifications for handling universal waste.
The categories are Small Quantity Handler of Universal Waste and Large Quantity handler of Universal Waste , and are defined as follows:
Small Quantity Handler of Universal Waste (SQHUW) : Someone who accumulates a total of not more than
5,000 kilograms (11,000 lbs) of one or more types of universal waste at one time (25 Pa. Code Chapter 266b,
Subchapter B and 40 CFR Part 273, Subpart B).
Large Quantity Handler of Universal Waste (LQHUW) : Someone who accumulates a total of more than 5,000 kilograms (11,000 lbs) of one or more types of universal waste at one time (25 Pa. Code Chapter 266b, Subchapter
C and 40 CFR Part 273, Subpart C).
To determine the size category of your facility, you must total up all of the universal wastes you accumulate on site.
In order to do this you must know the types and quantities of universal waste you accumulate on site. Of the five types of universal wastes recognized in Pennsylvania, only two will normally be generated in sizable quantities at automotive recycling facilities participating in the mercury switch program; mercury-containing devices (mercury switches) and car batteries. Car batteries, however, are typically handled under another section of the hazardous waste regulations (40 CFR Part 266, Subpart G) and therefore, are not considered universal waste or counted in the quantity of accumulated universal waste.
Even if a facility were to dismantle all of the cars salvaged in Pennsylvania (estimated to be 300,000 per year), the amount universal waste from this effort would only amount to 1,070 1 pounds of universal waste. This is well below the large quantity handler limits of 11,000 lbs. Therefore most, if not all, participating facilities in the mercury automobile switch removal program will be a SQHUW.
A facility would have to be collecting something other than mercury switches to exceed the quantity limits (11,000 lbs). If you have any questions about whether you are a small or large quantity handler of universal waste, please contact the DEP for assistance prior to enrolling in this voluntary program.
1 300,000 cars @ 0.54 switches/car =162,000 switches X 3 grams/switch X 454 grams/lb =1070 lbs.
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Pennsylvania Voluntary Mercury Automobile Switch Removal Guide December 2005
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Pennsylvania Voluntary Mercury Automobile Switch Removal Guide December 2005

Place no more than 450 automotive mercury switches inside the provided zip-lock plastic bag and seal the bag. 450 switches = .98 pounds of mercury.
Do not place any other materials in the bag! No elemental mercury, no switches that are broken or corroded enough to leak in transport, no wiring and no other lighting assembly parts.

Place the sealed zip-lock bag inside the provided 20-oz. hard plastic container and tightly secure the lid.

Cover all sides of the closed hard plastic container with the supplied bubble wrap and place it in the 6"x 6" x 6" corrugated cardboard box.

Close the corrugated cardboard box and secure all seams with 2" wide clear packaging tape.
 Fill out the supplied FEDEX Ground shipping label. Check the box marked “Other” and list the contents as “Automotive Switches.” The package gross weight must be less than 3.8 pounds and contain 450 switches or less to ensure the package contains less than one pound of mercury.

Place the supplied FEDEX Ground label on the package and send out with your daily pickup. If you do not receive a daily FEDEX GROUND pickup, call 888 777-6040 to schedule a pickup. Use Ground Transport only.
INSTRUCTIONS FOR COMPLETING SWITCH RECOVERY/REIMBURSEMENT FORM
1. Complete Section 1 of the Switch Recovery/Reimbursement form and return with the switches to the mercury recycler that sent you the shipping materials and form.
2. The Switch Recovery/Reimbursement form will be returned to you with Section 2 completed and the # of switches/weight equivalency noted.
3. Sign and date Section 3 of the Switch Recovery/Reimbursement form to indicate agreement with the mercury recyclers.
4. Mail completed Switch Recovery/Reimbursement form to PARTS for reimbursement. All sections must be completed for reimbursement.
Mail to: PARTS (Pennsylvania Automotive Recycling Trade Society)
Attention: Tina Kessel
1200 Camp Hill Bypass, Suite 101
Camp Hill, PA 17011
5. Continue collecting mercury switches.
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Pennsylvania Voluntary Mercury Automobile Switch Removal Guide
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Voluntary Mercury Automobile Switch
Removal Program
SWITCH RECOVERY/REIMBURSEMENT FORM
1. AUTOMOTIVE RECYCLER INFORMATION
Name of Business
Street Address of Business (must be street address for FedEx)
City State Zip Code
Optional: # or Weight of Switches Date of Shipment
Contact Name (Please Print) Signature of Automotive Recycler
2. TO BE COMPLETED BY MERCURY RECYCLER
Name of Recycling Facility
Weight of Switches Switch Equivalency
(Based on 3.0 grams/switch)
Discrepancies: _________________________________________________________________
_______________________________________________________________________________
Signature of Mercury Recycler Date Processed
3. AUTOMOTIVE RECYCLER VERIFICATION OF SWITCH EQUIVALENCY
I agree with the findings of the Mercury Recycler (Your signature required for reimbursement.)
Signature Date
To receive reimbursement, mail this signed and completed form to:
PARTS
Attention: Tina Kessel
1200 Camp Hill Bypass, Suite 101, Camp Hill, PA 17011
NOTE: Please make a copy of this form for your records before sending to PARTS.
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Pennsylvania Voluntary Mercury Automobile Switch Removal Guide December 2005
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Pennsylvania Voluntary Mercury Automobile Switch Removal Guide
December 2005
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Pennsylvania Voluntary Mercury Automobile Switch Removal Guide December 2005
General questions about the program:
Mike Berk
Pennsylvania Automotive Recycling Trade Society (PARTS)
1200 Camp Hill Bypass, Suite 101, Camp Hill, PA
717-763-1777 or mike@parts.org
To participate in the program (application & packet requests/information)
Tina Kessel
Pennsylvania Automotive Recycling Trade Society (PARTS)
1200 Camp Hill Bypass, Suite 101, Camp Hill, PA
717-763-1777 or mike@parts.org
Questions regarding Hazardous Waste :
Glenn Mitzel
Pennsylvania Department of Environmental Protection
400 Market Street, 14 th
Floor
Harrisburg, PA 17101
(717) 787-6239 or glmitzel@state.pa.us
Questions regarding mercury recycling and to order shipping materials:
Bethlehem Apparatus Company, Inc. AERC Recycling Solutions
890 Front Street
P.O. Box Y
Hellertown, PA 18055
2591 Mitchell Avenue
Allentown, PA 18103
(610) 797-7608
(610) 838-7034
FAX (610) 838-6333 mail@bethapp.com
FAX (610) 797-7696 mpark@aercrecycling.com
Disclaimer: This manual has been prepared to help automotive recyclers comply with the requirements that apply to hazardous waste-related activities and to aid in implementing the requirements. Nothing in this document shall affect or replace the requirements of Title 25 of the Pennsylvania Code or the Solid Waste Management Act. By participating in this program, the participant agrees that none of the sponsors of this program are responsible for any loss or injury resulting from this document.
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Pennsylvania Voluntary Mercury Automobile Switch Removal Guide
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