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.