How much scrap metal do Californians generate?
California is by far the most populous state in the U.S., with more people (40 million) than either Canada or Australia, and what would be the fifth-largest economy in the world if it were its own country.
As such a large state and economic powerhouse, California industry and consumers generate vast quantities of scrap metal every single day, and millions of tons per year – including more than 1.5 million cars and other vehicles (trucks, trailers, buses, railcars, etc.) each year that have outlived their useful life.
In addition to vehicles, the salvage/scrap metal stream includes millions of tons of large and small household appliances, metal furniture, water heaters, pipes and plumbing fixtures, metal siding, chain link fencing, wire, old tools, used equipment and machinery, shipping containers, and thousands of other objects (even the steel structure of the old Bay Bridge falls into this category).
Where does this mass of metal-containing objects go?
Under California law, recyclable scrap metal items CANNOT be disposed of in landfills – and even if they could, all the landfills in California could not accommodate the huge volume of scrap metal generated in the state.
Instead, the state’s metal recycling industry safely processes the overwhelming share of this scrap metal, using a variety of safe and environmentally responsible technologies, including metal shredding and metal separation and removal techniques.
Here in California, we currently have our own capacity adequate to recycle this huge quantity of scrap metal in an environmentally friendly manner – rather than sending the material to other states or countries where there may be fewer restrictions and regulations on processing scrap metal in ways that protect the environment.
The overwhelming share (roughly 70%) of the resulting valuable scrap metal commodities are shipped overseas for use in manufacturing new metal products – thus removing millions of tons of used metal items from California and putting the metal to good use.
The scrap metal recycling industry generates more than $5 billion worth of economic activity yearly in California, resulting in major tax revenue for the state and local
Are these scrap metal materials considered a hazardous waste?
In fact, California regulations expressly state that scrap metal is NOT a hazardous waste, and instead classify it as “in-process material,” and “processed scrap metal” is also excluded from the definition of solid waste in federal law.
In addition, the process used to shred scrap metal is purely a physical, mechanical process, not involving chemicals, gases, or any other material that could be considered hazardous, toxic or poisonous.
How are metal-shredder facilities regulated, and what is the proposed change?
During the entire life of the Department of Toxic Substances Control, and its several predecessors in state government, the metal shredding and recycling process has never been designated or regulated as hazardous waste treatment.
In addition, the metal shredder facilities over the years have made huge capital investments and improvements to make the process even more environmentally friendly and minimize the potential for material to escape from the operations, with the California plants setting state-of-the-art standards for the entire industry nationwide.
Through more than 50 years of operation, there is no evidence that the metal shredding process constitutes a health risk.
Now, the Department is threatening to require metal recycling operators to seek and obtain permits as hazardous waste treatment facilities – far exceeding its authority under the law and long-standing state precedents and regulations.
For the last several years, the metal recycling industry has worked diligently in good faith to address operational concerns asserted by the Department of Toxic Substances Control, but despite repeated outreach by the industry and the submission of several alternative proposals, the Department has been non-responsive and has continued single-mindedly to pursue its own unlawful approach.
In fact, the ONLY part of the entire metal-shredding process over which the Department has oversight is the non-metallic material (shredded upholstery, cloth, carpet, rubber, glass, vinyl and plastic, etc.) left over after metals have been separated out of the material produced by the shredding process – known as “metal shredder residue.”
Most of this metal shredder residue (after being stabilized to reduce its solubility) is actually beneficially used as “alternative daily cover” at licensed landfills (which are required at the end of each day to distribute a layer of covering material over the trash deposited that day) – and highly monitored landfills have been accepting this material for more 50 years with no evidence of problems.
What would happen to the metal shredder industry under these proposed regulations?
Any operations that did remain would be stigmatized as hazardous waste facilities, not recycling plants, causing multiple problems with siting, zoning, permitting, negative public reaction, etc.
The metal recycling industry is already extensively regulated by a wide array of federal, state, regional and local authorities, including federal air and water quality laws, regional water control boards, regional air quality management districts, and local fire departments and other entities that manage and regulate land use and permitting.
If the industry is curtailed or shuts down, the plain fact is that the massive quantity of scrap metals produced every day in California will have nowhere to go.
What consequences will that have for California residents and consumers?
Californians have enthusiastically embraced recycling, because they know that recycling helps reduce pollution caused by waste, reduces the need for raw materials, preserves natural resources and reduces the energy used to mine and process native ores.
But California, which has always been a national leader in recycling, is already facing a crisis, as hundreds of recycling operations of consumer items (bottles, cans, paper, etc.) have closed down, due in part to the trade wars and foreign countries’ refusal to accept these raw materials, as documented by headlines such as “Is recycling collapsing in California?” “California faces recycling crisis after China tightens rule,” and “California counties ask governor for help with recycling industry crisis.”
Now, state government itself is about to worsen the situation by threatening to put the largest, most successful, and most viable remaining recycling operation out of business by making it uneconomical to recycle scrap metals like junk cars, used refrigerators, and the many other thousands of metal-containing products.
The most obvious and immediate consequence for the typical Californian is that these materials will begin immediately to accumulate in huge quantities, increasing urban blight and creating eyesores, and causing potential threats to health and safety by being abandoned in back alleys, yards, neighborhood streets, vacant lots – and through a geometric increase in “midnight dumping” along roadsides or in empty fields.
This will be a particularly telling problem in low-income and minority neighborhoods, which already endure more than their share of pollution.
If there is no after-market for the recycling of metal consumer products, consumers will also face the inevitable inconvenience of not being able to turn in used appliances or have them picked up by the retailer when they purchase new ones, since most of these items are sold by retailers and merchants to metal recycling facilities.
The millions of tons of metal products California metal recyclers process each year produce metal commodities that are used in new products, thereby contributing to lowering the cost of consumer items using recycled metal.
In addition, the many charitable organizations assisting children, veterans and others in California that rely on charitable donations of cars and other vehicles, even if they are not in running order, will be adversely impacted both economically and practically, because the overwhelming share of the donated vehicles are sold to metal shredder operations to produce revenue.
