USA – According to the US Institute of Scrap Recycling Industries (ISRI), a proposed rule on the Definition of Solid Waste (DSW) of its country’s environment ministry (EPA) would significantly increase regulation of scrap recycling – and equate scrap recycling with hazardous waste recycling for the first time ever in federal law – even though the origin of the proposed DSW rule had nothing to do with the industry or the scrap materials that ISRI members recycle.
Specifically, EPA’s proposal would impose unnecessary, burdensome administrative and operational requirements on facilities by requiring recyclers of scrap metal – and perhaps other commodities in the future – to demonstrate with written documentation that the recycling of scrap metal, circuit boards, spent lead-acid batteries and perhaps other scrap materials satisfies proposed new ‘legitimacy’ criteria, the body contends.
ISRI is asking its members to prepare written documentation to demonstrate legitimacy, based on the current drafting of the proposed rule, potentially on a per-transaction basis and to notify their EPA regional office initially upon the recycling of certain scrap commodities, and then periodically thereafter.
According to ISRI, there is little doubt that this proposed rule, if adopted in its current form, has the potential to bring the scrap recycling industry to a grinding halt. ISRI President Robin Wiener states in a letter to members: ‘EPA did not consider the industry in developing the proposed rule, but justifies applying the legitimacy criteria to scrap recycling using a questionable study linking scrap recycling with significant environmental damage. ISRI is fighting EPA aggressively on this issue, using all the resources we have.’
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