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Final Report: Pollution Prevention Planning in Respect to Mercury Releases from Mercury Switches in End-Of-Life Vehicles Processed by Steel Mills
Pollution Prevention Planning is a process by which organizations can improve their environmental performance by strategically planning to reduce or eliminate pollution before it is created.
Last Updated: May 2013
The Pollution Prevention (P2) Planning Notice, when published in 2007 required P2 plans to be fully implemented by December 2011. All companies subject to the P2 Notice have submitted a declaration confirming their P2 plans have been implemented.
Two progress reports were previously published in February and June 2010 based on information reported within interim reports. This final report summarizes results of this P2 Notice for 2008-2011.
The implementation of this P2 Planning Notice has resulted in the successful development of a national vehicle mercury switch recovery program (hereafter called "the Program") whereby the previous regional "Switch Out" Program has been expanded and now operates in all Canadian provinces and territories. From 2008 to 2011, the Program has collected a total of 320,586 switches.
A P2 Planning Notice targeting vehicle manufacturers and steel mills was published on December 29, 2007, requiring the preparation and implementation of a pollution prevention plan for the management of mercury switches from end-of-life vehicles. The risk management objective of the Notice was to reduce the release of mercury to the environment through participation by vehicle manufacturers and steel mills in a mercury switch management program in Canada. The factors to consider included:
- Participation in the program by each vehicle manufacturers for 15 years after the last model year in which mercury switches were installed in vehicles manufactured by that vehicle manufacturer, and by steel mills until December 31, 2017;
- Development of annual targets for the number of mercury switches to be collected and for the capture rate, in consideration of an ultimate goal of achieving an annual capture rate of 90% within the first four years of participation;
- Development and distribution of educational resource material for vehicle recyclers and dismantlers that specifies the location of mercury switches in vehicles and explains removal and management of mercury switches; and
- Development and implementation of a purchasing policy by steel mills requiring that the steel purchased from end-of-life vehicles be mercury-free.
Summary of Results
The risk management objective of reducing releases of mercury to the environment through participation by vehicle manufacturers and steel mills in a national mercury switch management program in Canada has been achieved. The annual targets and capture rates of mercury switches set by the vehicle manufacturers have been achieved for the most part. However, the ultimate goal of achieving a capture rate of 90% within the first four years of the Program, as listed in the Notice, has not been achieved, as reported in the Declarations of Implementation.
Since 2008, vehicle manufacturers and steel mills subject to the P2 Planning Notice have worked together to establish and implement a National Mercury Switch Recovery Program. This national Program builds on the regional Switch Out initiative whichoperated mainly in Ontario and Quebec, and has been expanded to a national program which is managed by Summerhill Impact (formerly The Clean Air Foundation). The Program is successful as mercury switches from end-of-life vehicles are being collected and properly managed nationally. Further, the recovered mercury switches are being recycled and retorted such that the releases of mercury to the environment have been reduced.
Under the P2 Planning Notice, vehicle manufacturers and steel mills were required to indicate the anticipated number of switches to be collected annually through the national Program as well as corresponding capture rates (number of mercury switches annually managed and expressed as a percentage of the estimated total number of accessible mercury switches in end-of-life vehicles). The targeted companies reported that a 70% capture rate was expected to be reached within the first five years of the Program for a total amount of 505,000 switches to be collected between 2008 and 2012. The companies also reported that an anticipated additional 609,000 switches would be collected between 2013 and 2017.
In parallel with the national Program, the steel mill Evraz Inc. NA Canada has been operating the Evraz Mercury Recovery Program. This independent program collects mercury switches from end of life vehicles, but also white goods and electronics.
It should be noted that prior to the Notice being issued in 2008, estimates of the number of switches available for collection annually were based on forecasts from the 2004 Clean Air Foundation model. This model, although the best available information for estimating the mercury switch numbers at that time, had associated uncertainties, particularly with respect to the accuracy of vehicle scrappage rates and decay rates were questionable, and erroneous assumptions of the steady influx of new vehicles were made. Since the corresponding capture rates reported under the P2 Notice were also estimated, they too were influenced by the same uncertainties and challenges.
Table 1 summarizes the annual anticipated and actual number of switches collected annually by the national Switch Out Program between 2008 and 2011. Actual capture rates, as well as those estimated in 2008 as reported in the P2 interim progress reports, are also provided. The number of switches captured through the Evraz Program is provided in Table 2. Table 3 provides the total number of mercury switches reported under the P2 notice (covering both programs).
|Year||Anticipated number of switches captured by the Switch Out Program1||Anticipated capture rate of the Switch Out Program1||Actual number of switches captured by the Switch Out Program||Actual capture rate reported by the Switch Out Program|
1 - Switch Out refers to the National Mercury Switch Recovery Program
|Year||Actual number of switches|
|Year||Actual number of switches|
In order to obtain more accurate numbers of mercury switches available for recovery and management, the Canadian Vehicle Manufacturers’ Association (CVMA) undertook a more thorough analysis in summer 2010, using data from a mercury switch model published by the U.S. End of Life Vehicle Solutions (ELVS), which was adjusted for Canada, and from Statistics Canada’s Canadian Vehicle Survey which presents actual vehicle population breakdowns. The analysis indicated that there are far fewer switches available for collection than originally estimated and therefore recovery of the forecasted 505,000 switches within the first 5 years of the program would not be reached based on the anticipated numbers provided in 2008 under the P2 Planning Notice. Data gaps included knowledge of the number of switches per vehicle, mortality rates of vehicles and process rates of recyclers, and details of the end-of-life process of vehicles (dismantling, shredding, flattening, etc). The forecast based on the new analysis indicates that the mercury switch inventory is declining much faster than anticipated. As part of the ongoing efforts under the Notice, the switch inventory is reviewed and evaluated on an ongoing basis.
Figure 1: Numbers of mercury switches captured since 2008
It is expected that the number of switches collected will continue to decrease gradually each year, through the end of the Program. This downward trend was already apparent between 2009 and 2011 (Figure 1). The forecast based on Statistics Canada through the Canadian Vehicle Survey information indicates that it is highly likely that the on-road switch inventory will be exhausted sometime between 2012 and 2016.
As required by the Notice, vehicle manufacturers have developed and continue to distribute guidance materials for vehicle recyclers and dismantlers. These educational resources include: a Switch Removal Guide, lists of vehicles that may have mercury containing switches and/or ABS sensor modules, brochures, posters, video guides, and mercury clean-up instructions. The guidance materials assist recyclers and dismantlers in removing and managing mercury switches from end-of-life vehicles and understanding the importance of their ongoing involvement. In addition, Switch Out continues to work closely with vehicle recyclers and dismantlers across Canada to maintain and enhance the effectiveness of the Program.
Figure 2: Location of convenience light mercury switches in a vehicle (Source: www.switchout.ca)
Member steel mills of the Canadian Steel Producers Association have adopted and implemented a purchasing policy requiring that all steel scrap recycled to make new steel be mercury-free. Scrap suppliers must demonstrate that they have internal procedures in place to identify, remove, track and properly dispose of all sources of mercury in the scrap.
Environment Canada will continue to monitor the Program effectiveness in the future as the Switch Out Program continues to operate and recover switches; from 2008 to 2011, the Program has collected a total of 320,586 switches which contained over 270 kg of mercury. The number of mercury switches recovered is updated regularly on the Program website.
In addition, an Advisory Committee, whose membership includes representatives from the vehicle manufacturers, steel producers, and vehicle recycling and dismantling industries continue to promote and enhance the Program. Effective engagement and outreach to vehicles recyclers and dismantlers, through innovative approaches will continue. For example, active program participants are issued a "Proud Switch Out Participant" sticker, annually. In doing so, the facility receives recognition for their efforts. Frequently, recycling facilities are also featured on the Switch Out website.
As the Program continues following the P2 Notice, efforts will continue to engage provincial or territorial organizations and governments, as well as vehicle recyclers and dismantlers not affiliated with a recycling association or who are not yet part of the program.
To obtain additional information or resources, or to join the Switch Out Program, please visit: www.switchout.ca.
Mercury Switches in Automobiles
Mercury switches are small devices that activate the convenience lights in the hoods and trunks of automobiles and some anti-lock braking systems. Mercury switches have not been used in vehicles since January 1, 2003; however, in the vehicle population there remain vehicles with legacy mercury switches in them.
Mercury: What Is It and Why Prevent Its Pollution?
Mercury is a transboundary pollutant of global concern that impacts human and environmental health.
Low levels of mercury, a neurotoxin, can cause severe health problems especially for expectant mothers and their babies. Mercury also has measurable impacts on fish and wildlife. Mercury is listed on Schedule 1 of the Canadian Environmental Protection Act, 1999 (CEPA 1999), which provides the authority for the Ministers of Environment and Health to take action.
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