Product Stewardship and Mercury Automobile Switches

1
Product Stewardship and Mercury Automobile
Switches

• Peggy Harris
• CA Department of Toxic Substances Control

2
Summary

• History of the Mercury Switch Issue
• Overview of National Recovery Program
• Implementation Progress and Needs
• Lessons Learned and Next Steps

3
Many Years of State NGO Action

• CA Mercury Switch Regulation
• MN Study (92), MI Mercury P2 Task Force (95)
  Auto Cos agreed to eliminate as soon as
  feasible
• Voluntary States and Mandatory Switch Recovery
  Programs
• Vermont Mercury Labeling Law
• Maine Mercury in Vehicles Report, and

4
State Legislative Successes

• Maine Law Established
• - Producer responsibility for switch collection
• - Incentive payments to encourage recovery
• 11 States Would go on to Enact Laws with Required
  Incentive Payments
• - 2 states, taxpayer funded
• - 2 states, incentives only if capture goals not
  met
• 3 States, Non-mandated Incentive Programs
• - Other states, voluntary-only (or legislation
  only)

5
National Vehicle Mercury Switch Recovery Program
(NVMSRP)

• Signed on August 18, 2006
• - Facilitated by U.S. EPA
• - Parties include vehicle manufacturers, steel
  manufacturers, vehicle dismantlers, vehicle
  shredders, states (ECOS), and the environmental
  community

6
Key Features of the NVMSRP

• Automakers provide educational material,
  collection containers, shipping, recycling of the
  switches, and tracking/reporting
• Steelmakers implement supply chain mechanisms to
  promote participation in the program
• 4 Million fund established for early incentive
  reward of 1 per switch for the first 3 years of
  program
• - For states without existing cash incentive
  mechanism
• 80 mercury recovery goal established, with
  performance metrics and regular progress
  reporting
• Sunsets in 2017 (90 switches retired)

7
Implementation

• Nationwide implementation over first year
• - Estimated completion by Sept. 2007
• Parties work collaboratively with state agency on
  state implementation plans
• - Discuss any unique rules/regulations/definitio
  ns
• - Discuss how to identify recyclers within the
  state
• - Send introductory letter, followed up by
  delivery of collection materials (buckets)

8
End of Life Vehicle Solutions

• Created by the automotive industry to promote the
  industrys environmental efforts in
  recyclability, education and outreach, and the
  proper management of substances of concern

9
Teams

• Funding-Funding decisions made by stakeholders
  other than those providing the fund
• Measurement-Retirement rates and estimate of
  switches left in circulation
• Recognitions-National recognition program
• Communications-communicate success

10
Followup to Signing of MOU

• Parties meet subsequent to MOU to evaluate
  success

11
Peggy HarrisCA Department of Toxic
Substances Control(916) 324-7663pharris_at_dtsc.c
a.gov