As someone who has been deeply involved in the state regulatory process for many years, and who has experienced the outcomes of this process both good and bad, I was concerned about a recent push by the Department of Toxic Substances Control (DTSC) to adopt “emergency” regulations that would impose “hazardous waste” rules on the state’s metal-recycling plants – rules that have the potential to shut down a vibrant recycling industry.
Though the initial push for these changes was withdrawn, DTSC is now moving forward again to file different emergency regulations where no emergency exists, and channels for input are quite limited.
The lack of emergency is apparent on the face of DTSC’s new public notice of their filing. Given DTSC’s persistence in proceeding down a path that deprives all interested stakeholders an opportunity to take part in this important matter of public policy, it’s crucial to explain why these regulatory changes affecting metal recycling are neither necessary nor workable.
These metal-recycling facilities are not a public nuisance or health threat. All are located in ports or other areas zoned for industrial activity.
California is still the largest manufacturing state in the country, and the durable-goods manufacturing sector in particular depends on a free flow of recycled scrap metal to make the consumer products — vehicles, appliances, fixtures, metal furniture, food and beverage cans — we all need and buy.
In fact, we are the largest user of recycled goods. Regulations that interfere with a reliable and affordable supply of scrap metal will be challenging for manufacturing, and our recycling policies should always be considered with utmost scrutiny regarding their impacts and necessity.
California produces vast quantities of scrap metal every single day, millions of tons per year – including more than 1.5 million cars and other vehicles (trucks, trailers, buses, railcars, etc.), used refrigerators and other household appliances, and myriad other metal-containing items that have outlived their original purpose
For more than 50 years, the metal-recycling industry has safely and efficiently processed the overwhelming majority of this scrap metal, sending it to steel mills and smelters for use as raw material in the production of new products. This valuable material contributes to lower costs of steel products, saves huge amounts of energy, and is better for the environment.
Read more: Scrap metal recyclers a key to manufacturing economy