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October 16, 2001
Why Mercury?Mercury is a highly toxic substance that can cause serious human health and ecological effects. While it is a naturally occurring element, the extraction, concentration and use of mercury, and the improper disposal of mercury-containing products can cause serious health and ecological effects when released to the environment. Because of these and other health and environmental affects, mercury is increasingly the focus of policy initiatives that call for reductions in its deliberate use and the virtual elimination of anthropogenic discharges into the environment. Many of these initiatives have specifically targeted the use of mercury in automotive applications.
Historically, automakers have used mercury in switches for convenience lighting, antilock braking systems (ABS) and active ride control systems. In 1995 alone, 14 million mercury switches -- nearly 12 tons of mercury - were used in these applications. Despite the availability of mercury-free alternatives, voluntary efforts to phase out these uses of mercury have not been aggressively pursued by the automakers. As a result, U.S. automakers still used an estimated 4 million mercury switches in 2000. And automakers, both foreign and domestic, are introducing new automotive applications of mercury including high intensity discharge (HID) headlamps and background lighting in automotive displays -- applications that the automakers have stated that they do not plan on curtailing.
As a result of the automakers' continued decisions to use mercury in automotive applications, significant challenges have been created for the industries involved in end-of-life vehicle recycling. The potential for the contamination of the recycling infrastructure and the release of mercury to the environment is an undeniable threat caused by the automaker's disregard for the end-of-life impacts of their products.
Therefore, we believe an effective, comprehensive approach that addresses mercury and its uses is necessary. The following principles must be included in an effective, comprehensive approach for automobiles:
Principle One: Recovery, Collection, and Information
With over 210 million vehicles currently in use, containing an estimated 200 tons of mercury, a national mercury switch recovery and collection program must be established. Such a program would properly manage mercury from the existing fleet of vehicles, thereby protecting human health and the environment from the potential impacts of automotive mercury. The program should specifically target a 90% recovery rate for mercury switches, and to the greatest extent practicable, other mercury applications such as headlamps and displays. In order to utilize and expand on existing infrastructures, both in-use and end-of-life strategies should be included in the collection and recovery program. An in-use strategy recovers and collects mercury switches from the fleet of vehicles currently on the road; an end-of-life strategy would recover and collect mercury switches from retired vehicles.
Such a dual system facilitates the removal of mercury switches from automobiles thereby protecting the recycling infrastructure and the environment. The parties removing mercury from automobiles, however, should not bear the financial burdens of such a recovery and collection system. Automakers must be responsible for the design choices they make; thus they must take financial and organization responsibility for the collection and recovery of mercury from all automobiles.
The responsibility of the automakers in achieving a 90% recovery rate for mercury switches should include, but is not limited to, the following: a program that ensure the proper collection, transportation, handling and recycling/disposal of mercury-containing devices used in automobiles, disclosure of uses and locations of mercury switches as well as removal and replacement procedures; and developing a tracking mechanism to evaluate the effectiveness of the recovery/collection program. While the design of such a program should be developed by the automakers, there must also be consequences for not achieving the designated recovery rate.
Principle Two: Design for Recycling
A prospective mechanism to eliminate the use of mercury in automotive applications is absolutely essential to address the human health and environmental threats posed by releases of mercury from these devices. Design for Recycling, encourages manufacturers to design products in a way that will ensure that those products can be safely and economically recycled (using existing recycling technology and methods when the product is designed) when they reach the end of their useful lives (for which they were originally intended). As the automobile is the most-recycled product in the United States - 10 to 12 million cars are recycled each year -- this concept is vital in ensuring that vehicles are safely recycled without contributing to environmental degradation.
Thus, to stop the introduction of new sources of mercury into the end-of-life vehicle recycling infrastructure, an aggressive schedule should be implemented to phase out all automotive uses of mercury within two years. The goal of this initiative is to encourage pre-production planning for safe and efficient recycling by eliminating hazardous and non-recyclable materials from the production process. Unless the flow of hazardous and non-recyclable materials into consumer products is curtailed, society can never be fully protected by any program that only attempts to control the materials when they reach the end of their useful lives.
If an automaker is able to demonstrate that a use of mercury is essential and that no mercury-free alternatives are available that meet a specific set of criteria, a mechanism should be created to enable the automaker to apply for an exemption from the phase-out schedule. However, if the automaker is granted such an exemption, it must ensure that the component is easily removable from the vehicle, that a similar program as described above exists to recover and collect the mercury-added component, that all affected parties are notified and are aware of the source, removal instructions, and available collection programs, and that the vehicle is labeled in order to identify the component with sufficient detail so that it may be readily located for removal and to inform the purchaser, using words or symbols, that mercury is present in the product.
Principle Three: Regulatory Flexibility
In order to reduce the liability risks and handling requirements for parties involved in the recovery and collection of automotive mercury devices, mercury-added automotive components should be added to the Universal Waste Rule [40 CFR 279]. This action will encourage the recycling and proper disposal of these items and reduce the regulatory burden on businesses that are handling these materials.
Principle Four: Public Education
The automakers, in concert with the regulatory authority and the recycling community, should implement a comprehensive public education, outreach, and assistance program to ensure that affected parties are aware of and can participate in the program. This public education, outreach, and assistance program should focus on the hazards of mercury; the requirements and obligations of individuals, manufacturers, and agencies under this law; and collection efforts that individuals, institutions, and businesses can participate in to help further reduce mercury releases into the environment.
Principle Five: Government Responsibility
The federal government and state governments have an opportunity to take a leadership role in reducing the amount of mercury released to the environment from automotive applications. Thus, to ensure that government-owned vehicles are addressed by this comprehensive approach, government fleet operators should create a program to replace mercury switches in current vehicles and implement rules that require all future government fleet vehicles to be mercury-free in all applications.
email: info@cleancarcampaign.org