Mercury Containing Equipment
A thermostat is a temperature control device that contains elemental mercury in an ampule attached to a bimetal sensing element and includes mercury-containing ampules that have been removed from the temperature control device. Other devices and equipment that contain elemental mercury includes the following: mercury thermometers, switches (tilt, float, fire suppression), sensors (flame), relays (displacement, wetted, contact), and manometers.
A used thermostat, mercury switch, or other device containing only elemental mercury as its hazardous waste constituent becomes a waste on the date it is discarded. An unused device becomes a waste on the date the handler decides to discard it.
The universal waste regulations do not apply to mercury that was removed from devices or ampules (e.g., mercury collected in a container). Facilities will need to manage that mercury under the hazardous waste rules that apply to their generator status.
Labeling Universal Waste Containing Mercury
Universal waste mercury-containing equipment (i.e., each device), or a container in which the equipment is contained, must be labeled, or marked clearly with “Universal Waste - Mercury-Containing Equipment”, or “Waste Mercury-Containing Equipment”, or “Used Mercury-Containing Equipment”.
A universal waste mercury-containing thermostat or container containing only universal waste mercury-containing thermostats, must be labeled, or marked clearly with “Universal Waste - Mercury Thermostat(s),” or “Waste Mercury Thermostat(s),” or “Used Mercury Thermostat(s).”
