Scrap metal recycling is a growing industry that has found its way into numerous markets and locations. It serves a great purpose, and can be lucrative for individuals and businesses. Many metal products and components that are brought to a recycler have hazardous waste in them or can contribute to a hazardous waste stream at the recycling facility. If improperly managed, these hazardous wastes can pollute the environment and be a compliance issue for a scrap metal recycler, leading to costly cleanups and potential penalties through enforcement action. However, there are a number of steps a scrap metal recycler can take in order to ensure they protect themselves from these costs and protect the environment. Below are some regulatory terms and definitions applicable to scrap metal recyclers and descriptions of hazardous wastes along with applicable management strategies for those wastes that scrap metal recyclers can employ to ensure they are in compliance.
Many major appliances are made, at least in part, of metal, and therefore have a scrap value. Scrap metal facilities that accept and process these major appliances need to obtain a CAR certification from DTSC. The certification is required to ensure that a scrap metal recycler has knowledge of the hazardous waste streams generated from processing major appliances and handles those waste streams properly. It entails a certain degree of training for employees and allows the scrap metal recycler to legally accept and process major appliances. Major appliances include, but aren’t limited to:
- Washers and/or dryers
- Refrigerators and/or freezers
- Water and space heaters
- Furnaces and boilers
- Air conditioners and dehumidifiers
- Trash Compactors
- Ovens, stoves, and microwaves
These major appliances all contain Materials that Require Special Handling (or MRSH), which are materials that cannot be disposed of in normal garbage after removal from a major appliance. Examples include:
- Mercury, found in switches and temperature control devices
- Used oil, from compressors and transmissions
- Chlorofluorocarbons (CFCs), Hydrochlorofluorocarbons (HCFCs), and other non-CFC replacement refrigerants
- All metal-encased capacitors
- Any parts that contain encapsulated polychlorinated biphenyls (PCBs) or Diethylhexylphthlate (DEHP)
- Any other material that is regulated as hazardous waste
Other hazardous wastes generated from processing major appliances include universal waste lamps (such as fluorescent, sodium vapor, high density discharge, etc.), sodium azide canisters from unspent airbags, universal waste batteries, universal waste non-empty aerosol cans, electronic universal wastes, ballasts, contaminated absorbent material from spills of any of the above hazardous wastes, and heavy metal containing grindings, dusts, and powders from processing of metal.
All the above MRSH needs to be removed from major appliances prior to shredding, baling, or crushing of the major appliances. If the MRSH is not removed, the appliances have to be shipped to a CAR. If the MRSH has already been removed when it arrives at a CAR, the facility needs to have the individual dropping off the major appliances fill out DTSC Form 1459, unless the materials were removed by another CAR. These forms and others need to be maintained onsite and some need to be submitted monthly to DTSC and the Department of Environmental Health, Hazardous Materials Management Branch, which is the Certified Unified Program Agency (or CUPA).
There are many other requirements that apply to scrap metal recyclers, which can be found on the DTSC website. For complete verbiage from CA Health and Safety Code please see section 25211 et seq.
What happens if you’re a scrap metal recycler and you don’t accept major appliances? You still will likely generate hazardous wastes. Continue below for scrap metal recycler requirements.
DTSC CAR Forms
The forms linked below are from the California Department of Toxic Substances Control.
If you’re a scrap metal facility and you elect to not obtain certification as a CAR, and/or choose not to accept major appliances, you still may be a generator of hazardous waste. Hazardous wastes likely to be generated at your facility include used oil from individual compressors, used oil from automobile engines and parts, waste gasoline (e.g. from lawn mowers, generators, vehicles, etc.), waste diesel or antifreeze from vehicles, coatings and fine metals from wire and wire stripping, and compressed gas cylinders still containing hazardous material.
As a hazardous waste generating scrap metal recycler, all of Chapter 6.5 of California Health and Safety Code and Title 22 of the California Code of Regulations apply, including labeling, container, inspection, training, proper disposal documentation, and other requirements. See the main Hazardous Waste Generator page for resources on these requirements.