Do metal-shredding facilities pose a threat to public health or the environment?

March 22, 2020

NO! The metal-shredding process is NOT a threat to public health. California’s major metal recycling facilities use state-of-the-art equipment and procedures to protect public health and the environment.

California’s major shredding facilities are spending millions of dollars to upgrade structures and equipment to minimize the potential for any process materials to escape the facility. These measures are ongoing and are effective in controlling off-site releases.

The California Department of Toxic Substances Control (DTSC) has never produced any scientific evidence that metal-shredding facilities pose a threat to public health or the environment.

DTSC conducted three continuous days of ambient air monitoring at three different shredding facilities. No toxic air contaminants were detected in excess of air quality standards.

California shredders have been operating safely for more than 50 years. The facilities are located in industrial and port areas, well away from schools, homes and other sensitive uses. In some cases, longtime neighbors are not even aware of their presence.

While fires can occur at metal-shredding facilities, these are not common occurrences. Rigorous fire prevention and control practices are followed by all facilities.

Shredder facilities are closely regulated by state boards and agencies, including regional air and water boards, as well as local agencies referred to as Certified Unified Program Agencies (CUPA). These agencies are charged with the responsibility of enforcing environmental regulations and inspect shredding facilities on a regular basis to ensure they are operating in compliance.

What about the large piles of scrap metal at these facilities awaiting shredding? Are they a hazard?

March 21, 2020

NO! Incoming scrap metal awaiting shredding is not a hazard. These are large pieces of metal like water heaters, household appliances and crushed cars. Incoming scrap metal is staged in paved areas and is shredded within 24-48 hours of receipt. Stockpiles are routinely monitored and protected prior to shredding.

Processed metal products are also stockpiled for shipment and do not pose a risk. These products are solid metal objects that do not leach or emit pollutants into the air.

How much scrap metal do Californians generate?

March 20, 2020

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).

How about the materials left over after the metals have been removed from the shredded scrap?

DTSC has determined that the material left over after valuable metals have been removed from the material produced by the shredder does NOT pose a risk to human health or the environment. This material is called treated metal shredder residue (MSR) and is classified by DTSC as nonhazardous waste.

The small amount of remaining metal that is contained in the treated MSR is chemically bound in the residue, greatly reducing its ability to leach into the environment.

For more than 30 years, treated MSR has been allowed by DTSC and other regulators to be used in municipal landfills as daily cover. After decades of use, no releases to groundwater have ever been detected, even in unlined landfills. Additionally, air monitoring devices placed on landfill equipment show no hazardous air emissions.

Where does this mass of metal-containing objects go?

March 19, 2020

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

What about non-metallic particles that may be released during the shredding process or when the residue is stored on site?

Light fibrous material (LFM) is basically shredded polyester fabric that is used in vehicle carpets and other fabric components. This material is very light and can become airborne and blow offsite if not properly managed. This material has been evaluated according to DTSC health risk assessment protocols and under typical exposure scenarios, does NOT pose a significant health risk, even to sensitive receptors (e.g., children).

LFM is too large to be inhaled (i.e., is “non-respirable”).

LFM also cannot be absorbed through the skin.

Someone could accidentally ingest LFM but this is very unlikely. LFM would be obvious on someone’s hands and would be brushed or washed off rather than eaten.

DTSC’s own risk assessor reached the same conclusion and stated at a community meeting that LFM does not pose a risk to local residents based on the very low potential for exposure.

While LFM is technically categorized as “hazardous” according to state regulatory thresholds, these thresholds pertain to hypothetical releases from wastes in a landfill setting and are not based on real-life risks to human health.

Major improvements have been made at shredding facilities, at a cost of millions of dollars, to minimize the potential for LFM to become airborne and blow offsite.

Are these scrap metal materials considered a hazardous waste?

March 18, 2020

NO! Scrap metal has never been classified as a hazardous waste under either federal or California law – and therefore metal recycling facilities have never been considered hazardous waste treatment facilities under either federal or state law.

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.

Are employees at these facilities subjected to greater health risks?

NO! Employees at California shredding facilities are NOT subject to greater health risks. Many employees have worked at these facilities for decades and have not suffered adverse health effects.

Periodic industrial hygiene testing is conducted (e.g., blood lead levels) and there have been no levels of any harmful chemicals detected that exceeded health-based standards. Worker safety at these California plants is the best in the world.

How are metal-shredder facilities regulated, and what is the proposed change?

March 17, 2020

The scrap metal recycling industry in California has been safely operating for 50 years and predates the establishment of the Department of Toxic Substances Control, which began in the early 1980s.

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?

March 16, 2020

In all likelihood, if the Department is allowed to regulate the metal recycling industry as hazardous waste treatment, the onerous regulations and unnecessary restrictions involved would render the industry uneconomical, and plants would shut down or move out of state.

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.

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