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December 28, 2012
PCB exclusion possible for auto plastics

Recycling of plastic recovered from shredded automobiles could potentially result in a million or more tons of plastic rescued from disposal and used in place of virgin plastic material.  However, plastics recovered from automobile shredder residue (ASR) may contain polychlorinated biphenyls (PCBs), which raises legality issues under the Toxic Substances Control Act (TSCA).  TSCA generally prohibits the manufacture, processing, distribution in commerce, and use of PCBs.  But recent communications between the EPA and the Institute of Scrap Recycling Industries, Inc. (ISRI) have raised the possibility that most plastics from shredded automobiles could be listed by the Agency as an excluded PCB product, which would not be subject to the TSCA prohibitions, thereby opening the door to recycling opportunities.

No unreasonable risk

According to the EPA, in a February 2011 letter, the ISRI requested confirmation that recycling plastics recovered from ASR presented no unreasonable risk.  The ISRI stated that resolving regulatory uncertainty in this area could lead to investments and further development in innovative methods to separate plastics from ASR aggregate, which would produce broad environmental benefits and increase global competitiveness. 

The ISRI also presented the EPA with a set of voluntary procedures that recycling facilities could use to prevent the introduction of regulated PCBs into recycled plastics recovered from shredder residue generated by metal recycling facilities.  The voluntary procedures include development and implementation of a materials management system through (1) documented source control programs aimed at preventing the introduction of PCBs regulated for disposal into the shredder feedstock materials that contribute to any shredder residue from which plastics will be recovered for recycling, and (2) documented output control programs for facilities processing/producing/recycling plastics from shredder residue.

50 ppm threshold

In a Federal Register notice requesting public comment on listing plastics recovered from ASR as an excluded PCB product, the Agency notes that it is directed by the Pollution Prevention Act of 1990 to generally prefer recycling to disposal of materials within the waste management hierarchy. 


Applying this general preference to the ISRI inquiry, the Agency notes that the ISRI voluntary procedures could form the basis for assurances that plastics recovered from ASR aggregate do not exceed the 50 part per million (ppm) PCB concentration, the threshold that generally qualifies a product as an excluded PCB product.  The Agency states:
 “EPA believes that, for shredders and their suppliers that follow the Voluntary Procedures document, it is appropriate to generally treat the feedstock as consisting of excluded PCB products unless there is information specifically indicating that the feedstock does not qualify.  If shredders and suppliers do not follow the voluntary procedures, they will need to be able to otherwise demonstrate that the feedstock and residue meet the exclusion.  Clearly, if the feedstock materials or residue contain PCBs at concentrations = 50 ppm, the materials cannot qualify as excluded PCB products.”

Data uncertainty

The EPA notes that it has not developed independent estimates of the magnitude or timing of economic and environmental benefits that may result from following through on ISRI’s proposed action.  ISRI’s documents also rely on  assumptions supported by limited data on plastic volumes, recoverability, environmental impacts, and market prices, says the EPA, which is therefore requesting public comment on these and related issues. 

EPA’s notice and request for public comment were published in the December 12, 2012, FR.

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