Mercury Rising

A tiny automotive switch containing roughly a gram of mercury is creating the possibility of big headaches for the scrap industry, its suppliers, and its consumers.

Like the mercury in a thermometer slowly rising on a summer day, the issue of mercury in scrapped automobiles has been heating up lately.
   At present, the problems caused by automotive mercury are mostly affecting auto dismantlers and scrap consumers. Some industry observers see the trouble spreading, however, with scrap processors—and shredder operators in particular—at some risk of contaminating their products, equipment, or plants. Such contamination could, in turn, lead to added costs, lost markets, and even Superfund problems.
   Ironically, the largest part of the problem is a switch about the size of a dime that contains, on average, a gram of mercury, a toxic metal that’s liquid at room temperature. The switches are used mostly to turn on convenience lights in a car’s trunk or hood. They are also found in antilock brake systems (ABSs), which are somewhat larger devices containing roughly 3 grams of mercury. Other vehicle components—such as navigational lights, certain headlights, and the new in-vehicle entertainment systems—also contain mercury. Still, most of the recent attention has focused on the more widely used trunk and hood switches. Various sources suggest that roughly 35 to 40 percent of vehicles either have mercury switches now or have had them in the recent past.
   So how big a mess can these little switches create?
   This January, the Clean Car Campaign—a coalition of environmental groups—released the report Toxics in Vehicles: Mercury that warned: “The North American vehicle fleet may now contain as many as 250 million switches that, if not removed and properly managed, could release as much as 200 metric tons of mercury into the environment, causing harm to human health and wildlife.”

Air, Water, and Emissions
To put those 250 million possible switches into perspective, consider this: A single gram of mercury from a single automotive switch could con-taminate a lake roughly 20 acres in size, making the fish in that lake unhealthy to eat, warns Tom Corbett, an environmental chemist in the Buffalo office of the New York State Department of Environmental Conservation.
   Corbett should know. More than 20 bodies of water in his state—including Lake Champlain, the Susquehanna River, and five reservoirs supplying water to New York City—have mercury-related problems, notes the office of New York’s attorney general. The water is usually contaminated through airborne mercury emissions. While this airborne contamination of water is an especially large problem for states surrounding the Great Lakes, it’s certainly not limited to that region. Across the United States, 41 states have issued more than 2,200 warnings against eating mercury-contaminated fish, reports the New York attorney general’s office.
   The sources of these airborne mercury emissions are well-documented, Corbett says, and can, in part, be traced to electric-arc furnaces (EAFs) that melt scrap containing mercury switches.
   Indeed, Toxics in Vehicles: Mercury lists EAFs as the fourth-largest source of mercury emissions in the United States at an estimated 15.6 mt a year behind coal-fired utility boilers (47.2 mt), municipal waste combustors (26.9 mt), and commercial/industrial boilers (25.8 mt). Mercury from automobiles “is likely the single largest contributing source” to the EAF emissions, the report concludes.
   Notably, the New Jersey Department of Environmental Protection cites iron and steel production as the state’s “largest mercury emission category,” higher even than emissions from coal combustion or municipal solid waste incineration. 
   The U.S. EPA is beginning to look into automotive mercury as well, and at least one EPA official has noted that “use of contaminated steel scrap could be the largest U.S. source of mercury without existing or planned regulation.”
   Clearly, the issue has caught the attention of state governments, with most of this attention focused on scrap consumers and auto dismantlers. Minnesota, for instance, passed a law several years ago requiring car crushers to first make a “good faith effort” to remove mercury switches prior to flattening the vehicle, notes John Gilkenson, principal planner in Minnesota’s office of environmental assistance.
   Rhode Island tried to include a similar provision this year in an omnibus mercury bill. Though ReMA supported the overall bill, the switch-removal provision could have created “significant liability problems for owners and operators of shredders,” notes Tracy Mattson, ISRI’s director of environmental compliance. Thanks, in part, to efforts by ReMA and its members, the final bill did not contain that provision, but legislative concerns over mercury are only growing. All told, more than 40 bills restricting mercury usage in general—not necessarily in automotive applications—have been considered by various state legislatures this year.
   For scrap processors, all this attention to mercury poses numerous challenges as well as certain opportunities, industry observers note.
   The issue can be broken down into three main parts—getting mercury out of new cars being built today (and keeping it out of future models), getting it out of existing vehicles already on the road, and getting it out of end-of-life vehicles (ELVs) before they are sent for recycling.

Fixing the Future
On the first part, limited progress has been made since the issue of mercury switches first arose in the early 1990s, sources indicate. For instance, the Alliance of Automobile Manufacturers (AAM)—the car industry’s trade group—says the number of mercury switches used in automobiles has declined “significantly” over the past five years.
   Jeff Gearhart from the Ecology Center (Ann Arbor, Mich.), a co-author of Toxics in Vehicles: Mercury, notes that the use of mercury switches for convenience lighting has decreased by as much as 84 percent since 1996. Moreover, various international automakers—such as Toyota and BMW—no longer sell cars with mercury switches, while U.S. manufacturers say they plan to eliminate the switches from most if not all new vehicles within the next year or so (though it’s not clear if that refers to model years or calendar years, one source explains). 
   Some groups counter, however, that U.S. automakers—who still used approximately 4 million mercury switches in 2000—have broken numerous promises to reduce mercury usage by certain dates, still haven’t done all that they promised, and have actually increased certain usages of mercury.
   Also, while carmakers say they are poised to phase out mercury in ABS applications in the next few years, their ABS mercury usage remained fairly constant from 1996 to 2000, Gearhart notes. 
   Plus, the use of mercury in applications such as high-intensity discharge lamps, navigational displays, and entertainment systems appears to be increasing, environmental groups note, with the auto manufacturers indicating that they have no immediate plans to curtail the use of mercury in these situations. In fact, while these applications to date have mainly been in high-end vehicles, the carmakers seem ready to add them to more mainstream models as well, notes ISRI’s Mattson.

The Existing Problem
On the second point—removing switches from existing vehicles—pilot projects have been conducted or are under way to prove the feasibility of this approach. New York, for instance, is currently collecting switches from sources such as taxi companies and even the state environmental agency’s own fleet of vehicles, notes Tom Corbett. The project also involves public vehicle inspection stations and commercial service companies such as muffler and oil-change shops.
   Likewise, the attorneys general from 26 states and U.S. territories—ranging from major population centers such as New York, New Jersey, Illinois, and California to locations as distant and sparsely inhabited as the Northern Mariana Islands in the western Pacific Ocean—joined together this July to ask Ford Motor Co. to remove mercury light switches from the hoods and trunks of millions of Ford vehicles currently being recalled because of defective tires.
   The Clean Car Campaign and 31 other environmental groups recently sent a similar letter to Ford, General Motors Corp., and DaimlerChrysler, urging that mercury switches be replaced whenever vehicles are recalled or serviced.
   While the automotive companies have provided some educational assistance for mercury programs, they don’t seem interested in helping remove mercury switches from vehicles still on the road, environmental groups note. AAM is on record against the idea, arguing that removing switches from existing cars at the industry’s expense “makes neither environmental nor economic sense.” Instead, automakers say it would be “smarter” to remove mercury switches “at the end-of-life of the vehicle, along with other environmentally harmful substances such as gasoline, engine oil, and transmission fluid.”

An End-of-Life Dilemma
End-of-life vehicles, of course, represent the third part of the mercury problem, and various programs have explored solutions here as well. New York, for instance, ran a pilot program that collected some 6,000 switches over a two-year period in three western counties. Under the voluntary program, the state provided auto dismantlers with a free container to put switches in, then collected the containers at no charge and shipped them to Mercury Waste Solutions Inc., which operates a secondary mercury recovery operation in Racine, Wis., Corbett explains.
   In Minnesota, steelmaker North Star Steel Inc.—the state’s largest shredder—has been collecting switches from auto dismantlers and scrap plants since 1997. Though North Star originally provided just a free outlet to suppliers for disposing of collected switches, the company enhanced its efforts last year by offering a bounty for switches of $40 a pound, notes Judd Ebersviller, North Star’s regional environmental manager. 
   The bounty increased collections by about 200 percent, he says, though he adds that even the enhanced program attracts switches from only about 15 percent of all the cars the company shreds. Likewise, the New York effort’s 6,000 switches collected just 12 pounds of mercury compared with the 200 pounds or more generated annually by scrapped automobiles in the state, Corbett says.

Regulatory Reactions
While many of the current mercury-reduction efforts are voluntary, others are driven by state regulatory action. For instance, how would you like to receive a letter from one of your consumers asking you to certify that the scrap you send them is “100-percent mercury-free”?
   That’s what happened to Camden Iron & Metal Inc. (Camden, N.J.) after one of its consumers—a pipe foundry—was required by New Jersey’s Department of Environmental Protection to adopt a mercury-management program to reduce emissions from its stacks, notes Fred Cornell, Camden’s director of environmental health and safety.
   Likewise, scrap suppliers in another state are being asked to guarantee that the material they send to one particular minimill—whose stack emissions are being monitored by state regulators—doesn’t contain more than 33 percent of materials that might contain mercury, such as cars or appliances. The minimill, which used to bale its own cars as well, has also stopped buying cars for that baler. And it was forced for nearly a year to add extra charges to each heat to compensate for reducing its use of the denser scrap from cars and appliances.
   “It’s hard to believe that [the state environmental agency] can dictate your raw material,” notes the minimill’s vice president of operations.
  To make matters more difficult, there’s no way to test for mercury in scrap. If you don’t find it before the car or appliance is crushed or shredded, the only way to determine if it was there in the first place is to melt the metal and check the emissions—at which point you already have a problem.
   While auto dismantlers are currently the major focus of laws and regulations for removing mercury switches from old vehicles, some scrap processors engage in dismantling as well as crushing or shredding. So they, like dismantlers, could end up having the whole burden dumped in their lap. That’s a prospect that worries Wendy Neu, vice president of environmental affairs in the New York City office of Hugo Neu Corp.’s wide-ranging recycling operations.
   Plus, even if you stop crushing or shredding cars today because of concern over mercury, you still might face trouble ahead because the switches corrode over time, notes Tom Corbett. So even cars left in inventory might eventually release their mercury into the environment, creating storm water problems that could reach Superfund levels of contamination, he says.
   Then there are questions about exposing your own equipment to mercury or contaminating your automotive shredder residue (ASR). States such as Minnesota already ban ASR from landfills because of mercury and other toxics, and there’s always the possibility that other states could follow suit.

Recycling Response
So far, the problems caused by mercury switches have not spread widely through the scrap industry. Only a few scrap consumers and processors have had their emissions tested by regulatory agencies, and only a handful of processors have had to deal with laws requiring them to pull switches or with consumers demanding that they change their scrap shipments to avoid mercury problems.
   Moreover, it shouldn’t come as a surprise that views about a controversial issue such as automotive mercury are, well, rather mercurial—that is, somewhat unpredictable and changeable in mood. For instance, some in the industry doubt whether the actual levels of mercury being released into the environment from scrap are high enough to pose a threat to public health. Of course, a scientific debate over parts per million may not matter if political and regulatory interest in the issue continues to build. “There’s not always a tight connection between science and the law,” one skeptic concedes.
   Another processor notes that the scrap industry’s obligations under current regulations aren’t clear when it comes to mercury—and such legal ambiguity is never comforting. “Are we not buying cars today because they have mercury?” the processor asks. “No—but the day is going to come when we’ll have to take some action.”
   So what can the industry do in response?
   Some scrap processors have taken matters into their own hands. One firm that dismantles and shreds cars has begun pulling convenience light switches from every car it brings in, even though most of them probably don’t contain mercury, company officials note. They also admit that they have no idea what they’ll eventually do with all the switches they’re pulling.
   For Camden Iron & Metal, the request for certification of mercury-free scrap from one of its consumers means, in part, passing the certification request to its own suppliers. Camden listed mercury on its exclusion list long ago, years before automotive switches became an issue, says Fred Cornell. The original reason was to keep certain types of demolition scrap—which might contain a half-cup or more of mercury—out of the firm’s scrap stream. Now, Camden is upgrading its exclusion list to specifically require certification that automotive switches have been removed, Cornell says, with the effort modeled after the company’s CFC-exclusion certification.
   For Wendy Neu, the potential problems with mercury are all too apparent—but so are the possibilities for a constructive response. “For our industry, it could be a real opportunity to align ourselves with the environmental community, to form coalitions to put the manufacturers—of automobiles or appliances—under enough pressure to eliminate unnecessary uses of mercury.”
   Manufacturers must accept the financial and organizational responsibility for removing the switches, she says, because if they don’t, who will? The auto dismantlers didn’t create the problem—why should they pay? Scrap processors didn’t cause it, nor did scrap consumers, and it certainly doesn’t seem fair to ask taxpayers to subsidize poor design decisions made by manufacturers, Neu stresses.
   In a March 2001 policy statement, ReMA said essentially the same thing. ReMA stressed that, even though auto dismantlers should be the ones to actually remove the mercury switches from end-of-life vehicles prior to sending them to scrap facilities for recycling, “the financial responsibility for ensuring the proper handling of mercury in ELVs should not fall on the dismantling and scrap recycling facilities.”
   In addition to urging automobile manufactures to design mercury out of future vehicles, ReMA stated that “automotive manufacturers must contribute financial and organizational resources to a mercury switch removal program. Such support should include providing relevant and available information identifying all historic and current uses of mercury as well as support for an effective collection program to ensure proper collection, transportation, handling and recycling/disposal of mercury-containing devices used in automobiles.”
   In addition, ReMA added its support to legislation that incorporates “equitable concepts” to reach the aforementioned goals.
   Currently, ReMA is working to bring together stakeholders of the issue, including steel mills, auto dismantlers, environmental groups, and other interested parties, says Tracy Mattson. The goal is to develop a comprehensive solution to cover the problem from designing new cars through recycling of ELVs.
   Developing such an approach will take time, though. So scrap processors may need to protect themselves now by working with their suppliers to remove mercury switches before the car hulks reach the recycling facility. Moreover, the fact that mercury is not detectable in scrap means that processors must be even more vigilant about it than with other potential threats such as radiation, sources note. 
   Where is all this leading? Optimists in the scrap industry think the problem will go away over the next 10 years or so—if car manufacturers can be persuaded or required to eliminate mercury from their vehicles.
   That’s a big if, others contend, given the auto industry’s track record so far. Instead, it seems far more likely that scrap processors will be dealing with this problem for some time and that it will probably get worse before it gets better, much like those long, hot stretches of summer when the mercury rises—and just stays there. •

Automotive Mercury Resources
For more information on mercury in automobiles, consider the following reports:
• Toxics in Vehicles: Mercury from the Clean Car Campaign, 117 N. Division, Ann Arbor, MI 48104; 734/663-2400; www.cleancarcampaign.org.
• Toxic By Design from Environmental Defense, 257 Park Avenue South, New York, NY 10010; 800/ 684-3322; www.environmentaldefense.org. 
   The first two reports were issued in January 2001 and are available online at www.cleancarcampaign. org/mercury.html. An earlier report from 1996 is also worth considering: Mercury in Automotive Systems—A White Paper from the Society of Automotive Engineers, 400 Commonwealth Drive, Warrendale, PA 15096-0001; 724/776-4841; www. sae.org.
   Plus, the Binational Toxics Strategy Mercury Workgroup (a joint effort involving U.S. EPA and Environment Canada) offers various reports and mercury-related resources at the Web site, www.epa.gov/region5/air/ mercury/mercury.html.