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Product Stewardship and Mercury Automobile Switches
Peggy HarrisCA 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, 2006
- 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. 2007
• 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
