Mercury in Vehicles
Letter in Support
of New York Mercury Legislation
April 13, 2001
Assemblyman Richard L. Brodsky
Legislative Office Building 625
Albany, NY 12247
Dear Assemblyman Brodsky,
We are writing on behalf of environmental groups that are a part of the Clean
Car Campaign to support The Comprehensive Management of Waste Mercury Act of
2001. This act is a monumental step forward in helping protect human health
from mercury exposure.
This past January, the Clean Car Campaign released two reports -- Toxics in
Vehicles: Mercury and Toxic By Design -- that document the environmental and
human health impacts associated with the mercury used in cars. Of particular
concern was the gram of mercury used in tilt switches found in hood and trunk
lighting devices as well as anti-lock braking systems. These switches, along
with other mercury-added auto parts, are not accounted for when vehicles are
disposed of and recycled. As addressed in your bill, the manufacturer mandated
collection systems, coupled with the labeling and full disclosure components,
are critical to recovering the mercury used in vehicles. We commend your foresight
to insure that manufacturers are accountable to the toxics they put in their
products, as this is an effective way to drive product design changes.
As the bill is currently written, much of the rulemaking for the collection
systems is left to the Department of Environmental Conservation. We believe
that it is critical to include some guidelines in the bill to ensure that the
collection systems are effective. For example, we advocate that a mercury auto
switch collection program achieve a 90% capture rate and include specific mechanisms
for tracking and reporting the program's success. Therefore we would like to
request that an amendment is added to the bill that includes the following items:
1) A target capture rate to be achieved by the collection system.
2) A system for tracking the program's capture rate and a mechanism to provide
that information to the agency and the public. For example, the number of switches
removed per vehicle processed and the total amount of mercury collected must
be reported on a yearly basis.
3) If the target capture rate is not achieved within any reporting period, manufacturers
must present plans that describe additional or alternative actions that will
be implemented to improve the collection system and achieve established targets.
Again, we commend your efforts to put forth a bill that will truly begin to
address the mercury problems we are faced within New York and in the end will
hopefully eliminate mercury in commerce. We look forward to working with you
and Senator Balboni on this very important bill. Sincerely,
**For more information on the Clean Car Campaign, please visit our website at
www.cleancarcampaign.org.
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