There is approximately one gram of mercury in the switches found in many older model vehicles. This mercury often finds its way to wastewater and air emissions once these vehicles are dismantled and then "chopped" for scrap before being sent to steel mills. These mercury-containing switches, especially the "tilt" switches used in hoods and trunks of cars, can be removed fairly easily before the vehicle is crushed.
In 2004, the Virginia DEQ began an initiative to remove mercury switches from vehicles with a pilot project in coordination with Auto Recyclers, LLC of Winchester, Virginia. Auto Recyclers volunteered to remove the mercury switches and to assess the switch removal process. In 2006, the Virginia DEQ expanded this pilot project by partnering with the Virginia Automotive Recyclers Association to sponsor the removal of mercury-containing switches from junked cars. The DEQ negotiated with AERC Recycling Solutions in Ashland, Virginia to provide a "Switch Collection / Shipping Kit" to any salvage operator that volunteered to remove the switches during disassembly. Once full, the operator shipped the kit to AERC's facility in Pennsylvania for recycling. The success of these pilot projects led to the passage of legislation requiring the removal of mercury switches from older vehicles prior to demolition.
Mercury Switch Program Implementation
During the 2006 legislative session, Virginia adopted HB447/SB88 - Mercury switches in motor vehicles. This bill requires removal of mercury convenience switches from end-of-life motor vehicles prior to their demolition. It authorizes DEQ, through the Virginia Waste Management Board, to adopt guidelines setting standards for removal and management of mercury switches from end-of-life automobiles.
Because many end-of-life vehicles are shredded for scrap metal reclamation, the presence of mercury containing convenience light switches may contribute to mercury emissions when scrap steel is smelted for recovery. Mercury activated convenience lights are usually found in the trunks and hoods of automobiles.
In 2005, EPA added to the existing Universal Waste Rule (40 CFR Part 273) a new category for Universal Waste Mercury Containing Equipment. This rule includes mercury switches. Virginia adopted the rule, by reference, into our regulations in May, 2006. Mercury switches collected and managed for recycling/reclamation under the Universal Waste Rule are excluded from many of the requirements applicable to hazardous wastes.
DEQ has held a number of discussions with our partners for implementation of this legislation --- End of Life Vehicle Solutions (ELVS), VARA (Virginia Automotive Recyclers Association), the Department of Motor Vehicles, Virginia ’s steel recyclers and our automobile recyclers. As we continue to refine the program and develop technical outreach and training materials, information links, and other items to support implementation of this legislation, we will update this page to serve as a resource for demolishers managing mercury switches under this program.
Mercury Switch Regulations Become Effective
The Virginia Waste Board adopted the proposed Mercury Switch Regulations at their January 8, 2007 meeting. The Regulations were published in the Virginia Register on February 5, 2007 and became effective on March 21, 2007. A link to the February 5, 2007 Register is provided here. Publication and related information can be found on the Virginia Regulatory Town Hall site. The official version of the Mercury Switch Regulations, 9 VAC 20-200, is linked here.
Tracking Virginia ELVS/EQ Participants and Switch Removal Information
Click on “The Environmental Quality Company” link in the box to the upper right. This will open the ELVS/EQ Mercury Switch Recovery Program page. At the bottom of that page you will see “Collection Reporting.” To view reports on program data, select “Virginia” under the State Report and click Report. This will give you summary information about Virginia’s program. Individual participant information can be obtained by following the page instructions, our use the “List All” feature to access all Virginia program participants.