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Advocacy Agenda: Regulatory Policy

agenda
The recycling industry is significantly impacted by regulatory policy made in agencies and departments across the U.S. government. Thus, ISRI is continually monitoring and commenting on any and all regulations that have the potential to hinder recycling operation. Of particular note, ISRI is aggressively advocating for:

  • Revising CAA Regulations on Appliance Recycling to Reflect Congressional Intent. ISRI continues to work with the EPA to modify the current Clean Air Act (CAA) regulations applicable to refrigerant‐containing appliances and to ensure proper enforcement. These regulations have defied the clear CAA language requiring removal of refrigerant from appliances “prior to their delivery for recycling.” This has caused confusion over what constitutes acceptable compliance and led to questionable enforcement actions, especially those “beyond the regulations.”

     

  • Maintaining Flexibility in Stormwater Permits. Through membership in the Federal Stormwater Association (FSWA), ISRI continues to work to ensure flexible Multi‐Sector General Permit (MSGP) conditions. The proposed 2020 Federal MSGP is expected to incorporate many of the recommendations by the National Academy of Science (NAS) in its 2019 report, “Improving the Next-Generation EPA Multi‐Sector General Permit for Industrial Stormwater Discharges.”

     

  • Streamlining Reporting Requirements by Recyclers into NMVTIS. ISRI fully supports the NMVTIS law as a deterrent to vehicle title/VIN fraud and believes full compliance is best achieved when reporting is convenient and at no cost to recyclers. As such, ISRI advocates for provisions allowing recyclers to comply with federal NMVTIS requirements by reporting directly to the state in conjunction with existing state requirements instead of additional separate reporting into the federal database.

     

  • Maintaining Non-Waste Regulatory Status of Recycling Facilities at State Level. ISRI continues to monitor and intercede in state legislative and regulatory activities that seek to reclassify ISRI-member recycling facilities as solid waste or hazardous waste facilities. A common state strategy has been to reclassify recycling facilities as solid waste, if not hazardous waste, facilities to impose requirements, restrictions, and/or permitting under state solid or hazardous waste regulations. Such regulations also require reporting of recycling activity for purposes of improving the state’s recycling statistics.

     

  • Oppose and combat regulatory overstepISRI objects to efforts by regulators to unfairly and improperly paint the industry as a local hazard in need of aggressive oversight to protect the public safety and health under the states’ police power. ISRI believes the legislative process is the appropriate avenue to determine appropriate regulatory oversight of the industry and will push back against abuses of the executive police power.

     

  • End the U.S. Mint’s suspension of the mutilated coin redemption program. ISRI uses Congressional inquiries to question and learn more from the Mint about the suspension and when it will end.Additionally, ISRI has offered its assistance to the Mint towards developing new testing, inspections, and acceptance standards and protocols.

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