New TN Waste Requirements for Mercury Product Disposal
On April 15, 2010, the State of Tennessee passed the “Mercury Product Disposal Control Act” (Senate Bill 2403) which prohibits “covered generators” from disposing “mercury-added consumer products” as non-hazardous solid waste (i.e., trash). Effective January 1, 2011, all “covered generators” must manage waste “mercury-added consumer products” as either universal waste or hazardous waste. All waste mercury-added consumer products must be shipped for recycling, treatment, or disposal to either a universal waste destination facility or a hazardous waste management facility that has been permitted by the U.S. Environmental Protection Agency, by a state program, or foreign government. Prior to shipment offsite, these wastes must be managed in accordance with Tennessee Universal Waste or Hazardous Waste requirements (e.g., labeling, marking, closed containers, etc.)
A “covered generator” means any generator that:
- Employs ten (10) or more employees;
- Owns or maintains a building, excluding private residences, of at least three thousand (3,000) square feet;
- Owns or maintains electrical distribution systems;
- Owns or operates a business that demolishes buildings, excluding private residences; or
- Owns or operates a tanning bed salon business.
“Mercury-added consumer products” include, but are not limited to:
- Thermostats;
- Thermometers;
- Switches (whether individually or as part of another product);
- Medical or scientific instruments;
- Electrical relays and other electrical devices;
- Lamps and light bulbs; and
- Batteries other than those defined as mercury containing excluded products (defined in Senate Bill 2403).
If you have any questions or need further information, please contact Keven Arick at (901) 372-7962 or via email at karick@ensafe.com

