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Guide for Appliance Recyclers June 2004 If a package contains more than one pound of mercury, it must be transported in compliance with U.S. Department of Transportation (DOT) hazardous materials regulations (HMR), which are found in Title 49 Code of Federal Regulations (CFR) Parts 171 — 180. Even if it contains less than one pound of mercury, a package of mercury switches that is shipped by air or water must comply with HMR. In many states, discarded mercury switches are not universal wastes and may instead be fully regulated as hazardous wastes. In most or all of these states, mercury switches produced by generators of less than 100 kilograms (220 pounds) of hazardous waste per calendar month are exempt from the uniform hazardous waste manifest requirement. Consequently, these generators' discarded mercury switches are also exempt from DOT's requirements for transporting hazardous wastes. Provided they are not transported by air and are placed in packages that do not exceed one pound of mercury, these generators' switches are also exempt from HMR. In states where they are not universal waste, discarded mercury switches produced by generators of more than 220 pounds per month of hazardous waste must be shipped with a uniform hazardous waste manifest. If managed as hazardous waste, however, the mercury switches must be transported by a hazardous waste transporter who has: (a) a valid registration with DTSC, (b) must use the uniform hazardous waste manifest, and (c) must deliver the mercury switches to a permitted hazardous waste facility. • Who will take removed mercury switches? Mercury switches must ultimately go to an authorized "destination facility"where the mercury is recovered from the switches and recycled. The mercury switches that you collect may be transported directly to a destination facility or to a universal waste handler who consolidates the switches before sending them to a recycler. Handlers of universal waste mercury switches may use their current hazardous waste hauler to transport the switches, or they may self-transport the switches. Alternatively, mercury switches may be transported by a commercial carrier that accepts universal waste, as long as the mercury switches are handled as such. Such carriers should be contacted first to determine what their policies are for transporting universal waste. Vendors should be contacted directly to obtain specific guidance about their services and costs. Appendix E lists some of the mercury switch handling and transporting facilities that serve California. Destination facilities that recover and recycle mercury switches and serve California are listed in Appendix F. Do I need to keep records of mercury switches that I send off site for recycling? Yes. If mercury switches are handled as universal waste, a record such as a log, invoice, bill of lading, or other shipping document should be kept for at least three years from the time the mercury switches leave the facility. This record should include the • 26