Product Stewardship and Mercury Automobile Switches Peggy Harris CA Department of Toxic Substances Control

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

Many Years of State – NGO Action CA Mercury Switch Regulation MN Study (’92), MI Mercury P2 Task Force (’95) – Auto Co’s agreed to eliminate “as soon as feasible” Voluntary States and Mandatory Switch Recovery Programs Vermont Mercury Labeling Law Maine Mercury in Vehicles Report, and…

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)

National Vehicle Mercury Switch Recovery Program (NVMSRP) Signed on August 18, Facilitated by U.S. EPA -Parties include: vehicle manufacturers, steel manufacturers, vehicle dismantlers, vehicle shredders, states (ECOS), and the environmental community

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)

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

End of Life Vehicle Solutions Created by the automotive industry to promote the industry’s environmental efforts in recyclability, education and outreach, and the proper management of substances of concern

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

Followup to Signing of MOU Parties meet subsequent to MOU to evaluate success

Peggy Harris CA Department of Toxic Substances Control (916)