• Recycling for Good: ISRI Member Provides Food for Local Families

    Aug 13, 2020

    By Nidhi Turakhia 

    ISRI members, and the recycling industry as a whole, have always shown ways to step up and help their communities during times of need. Throughout the Coronavirus pandemic a number of companies have reached out to support their neighbors. 


    One such company is Allied Alloys. The Houston-based company is located in one of the areas of Texas hardest hit by the Coronavirus. Harris County has the most COVID-19 positive cases in the state. There was a shortage of produce, and canned and package foods in the grocery store. With the local food supply low, Allied Alloys turned to one of its international connections for a solution. 

    The family-run business looked to a nonprofit in India that they are personally involved in that conducts food drives in remote villages. Allied Alloys thought it would be a great idea to replicate in the Houston area to help provide food for families and organized a community-wide contactless food drive. 

    The company purposely provided items that were packed with nutrients and longer shelf lives. Furthermore, it was all vegetarian. The community was already facing existing health issues and there was fear the pandemic would make things worse, so healthy food was a priority. 

    Employees worked to load 300 cars with 35 pounds of food. Their contributions made a lasting impact on their community. One lady called the company after the event, crying she was so thankful. She said it was the first time in years she was able to make a pasta dish for her kids.  

    Have any creative ideas your company has done to help its local company? Please share your stories with Rachel Bookman at ISRI. 

  • Guidance for Safeguarding Against Cargo Theft

    Jun 12, 2020
    According to the National Insurance Crime Bureau (NICB), nationwide losses to cargo theft range from $15 - $30 billion a year and the latest FBI statistics suggest less than 20% of merchandise is recovered. ISRI members are not immune to this crime and in today’s tight business climate, caution must be taken. 

    Extra steps to safeguard loads can be difficult for longstanding members used to conducting business with a handshake, phone call, or email. Unfortunately, this is the world we live in. The guidance offered below is meant to safeguard against two types of cargo theft related to domestic shipping by truck; straight cargo theft and strategic cargo theft.

    Straight cargo theft is defined as the physical theft of, or from, loads while in transit. This can occur when trailers are left unattended at truck stops, parking lots, or roadside rests areas, to name a few. Hijacking could also be considered straight cargo theft.

    Strategic cargo theft involves deception and fraud. Using today’s technology, sophisticated thieves can create forgeries of order forms and other documents used by legitimate companies. What might appear to be letterhead from a longstanding customer could in fact be fake and involve fraudulent carriers used to ship goods to unintended locations without any intention of payment. Phishing email scams or computer viruses can be used to intercept legitimate orders and alter shipping instructions.

    Best Practices 

    1. Consider vetting employees with background checks, especially drivers and those with access to shipping logistics and other sensitive information.
      1. Contract carriers should also be vetted by checking references, safety records, and training.
      2. Confirm driver and truck identification information. Pay extra attention to any last minute changes or driver substitutions.
    2. Provide training for company drivers on theft and hijacking prevention.
      1. Secure sensitive information such as travel routes and schedules.
      2. Resources such as insurance companies recommend drivers should avoid stopping within the first 200 miles in the event they were tracked from the member’s yard.
      3. Ensure drivers park in secure lighted areas and lock unattended vehicles.
    3. Confirm orders from buyers or brokers by calling known numbers prior to shipping. Even when dealing with longstanding customers, reach out to a known contact. Double check numbers found on letterhead or order forms.
    4. GPS tracking devices, vehicle immobilizers, container seals and locks, and cameras can help deter theft or track cargo should a theft occur.
    5. Maintaining cyber security is a must in order to prevent intrusion into company computers. Review information the company website makes available to the general public. Financial records and other sensitive information should be password protected.

    Below are excellent resources for more information on safeguarding against cargo theft and current theft trends. These sites can also offer assistance in the event of a theft.





    Brady Mills is director of law enforcement outreach for ISRI.

  • EPA Launches Campaign Supporting Recyclers

    May 26, 2020

    “Right now, there is a critical need for raw materials in the manufacturing supply chain, especially paper and cardboard,” said EPA Administrator Andrew Wheeler in a press release. “Business closures and limited operations means less recycled material for American manufactures, and we all must do our part to recycle more and recycle right to fill this immediate need.”

    The three videos produced by the EPA showcase how essential recycling is and the important role our industry plays in the economy. This public outreach effort will help Americans rediscover recycling in a new way, and increase the supply of quality material during a critical time of need. It is something that everyone can do to make a difference.

    Behind the scenes, ISRI worked with the EPA and other stakeholders on some of the key messages outlined:

    • Recyclable materials provide valuable feedstock to American manufacturers;
    • Recycling is an essential part of our daily lives, and is playing an important role during the Coronavirus pandemic;
    • Individuals should follow their local guidelines to ensure proper recycling; and
    • PPE such as masks and gloves should be disposed and not recycled.

    The series includes a video, “COVID-19” in which Secretary Wheeler calls on all Americans to recycle more and recycle right. “Right now there is a critical need for all raw materials in the manufacturing supply chain, especially paper and cardboard,” Wheeler says. He goes on to say that proper recycling will ensure the manufacturing supply chain will remain open and essential goods will be delivered.

    Another video, “Recycling During the Health Crisis” highlights the critical role recycling is playing during COVID-19. It encourages people to recycle correctly so material is available to manufacture goods for frontline workers and to produce the packaging needed for deliveries.

    The third video, “Don’t Recycling PPE,” emphasizes the need to recycling right, which includes properly disposing of PPE in the trash. Items such as masks and gloves are not recyclable.

    These strong messages delivered by the EPA are evidence of just how essential our industry is to our current health crisis and beyond. It is a testament to each and every recycling worker and the contribution they make to their communities and the broader economy.

    Please share these videos on your social media networks, websites, and other ways of outreach. Sharing these messages far and wide will demonstrate the power of recyclers!

  • Mourning the Loss of Jerry Simms

    Jan 18, 2020

    DSC_0301-smIt is with much sadness and grief that I share with you that former ISRI Chair Jerry Simms passed away last Friday morning. As many of you know, Jerry had been suffering from Parkinson's disease, and unfortunately his health deteriorated significantly over the last month. According to Terry, his wife, Jerry is in a better place now, out of pain, but missed by so many.

    Jerry was a great friend and colleague to many of us, chairing ISRI from 2012 to 2014. It was during his tenure as Chair that ISRI reinvigorated our state program, expanded ISRI's resources to fight metals theft, successfully prevented EPA from going down the path of regulating scrap as hazardous waste, and obtained EPA's authorization to recycle plastics from shredder fluff. 

    Jerry received ISRI's Lifetime Achievement award last year for his decades of dedication and leadership within the industry. It was Jerry who inspired and led ISRI's efforts to reform Superfund that resulted in passage of the Superfund Recycling Equity Act (SREA) in 1999. His letter to the ISRI leadership in the early 90s, calling for the rallying of ISRI members at the grassroots level and the leveraging of their political power to effect change that spurred ISRI's efforts on this critical issue. And along with the leadership of Mark Reiter, who we also tragically lost this past week, Jerry helped mobilize the industry and build the political structure that remains today at ISRI. According to Jerry, "when working in concert, ISRI and our members can achieve any successes we need in the battles that confront us, be they legislative, regulatory, or public perception."

    I can't think of any stronger advocate for ISRI and the recycling industry than Jerry. He showed us the power one person can have, bringing together an entire industry to fight for a cause. His dedication to ISRI and recycling was endless. Most importantly, Jerry was an incredibly special person who I feel incredibly lucky to have been able to work so closely with and become friends with. He will be missed by so many within and outside ISRI and the recycling industry.

    A tribute page has been set up on ISRI's website for members to leave messages and memories.

    In lieu of flowers, people can honor and remember Jerry through donations to either the Michael J Fox Foundation or the Colorado-based Davis Phinney Foundation for Parkinson's.

    Thank you,

  • Mourning a Loss in the ISRI Family

    Jan 16, 2020
    markreiterIt is with much sadness and grief that I share with you that Mark Reiter, ISRI's employee of nearly 30 years and current vice president of government relations, passed away on Wednesday, January 15, 2020. Mark always said that when he joined ISRI, he thought he would stay for a few years and then move on to something else. But he fell in love with the industry and the members, and he literally never left.

    Having had the pleasure and honor of working beside Mark for his entire ISRI career, I can honestly say that doing right for the membership was always at the top of his mind, and doing it with integrity was always his first priority. Mark absolutely loved working for the recycling industry and was dedicated to advancing the interests of each and every member. What he loved most was using his experience and expertise to help empower individual members to feel comfortable meeting with their local, state, and national representatives. Mark helped create ISRI's original grassroots advocacy network. He would tell members that "when meeting with your elected representatives, always remember that you are not a Democrat, you are not a Republican, you are an ISRI-ite!" In other words, if you want to do what is best for the industry, you have to put ISRI above party politics.

    While Mark accomplished many things in his years at ISRI, he was most proud of the work he did alongside that grassroots network to lobby for the passage of the Superfund Recycling Equity Act (SREA) in 1999. SREA saved the industry hundreds of millions of dollars and created the precedent for recognizing recyclers as distinct from disposal or waste operations. He truly made a difference for the industry.

    Politics and the political process defined Mark. He was fond of recalling that he started in politics at age 10, working on sound trucks for various candidates in his hometown of the Bronx, N.Y. In the years that followed, Mark worked for New York Mayor John Lindsay; he moved to Washington, D.C., to work for Rep. Bella Abzug (D-N.Y.); he spent 10 years at the U.S. Environmental Protection Agency; then he returned to Capitol Hill as a senior staff member on the Senate Environment and Public Works Committee. In 1992 he left government and joined ISRI as manager of legislative and international affairs. As Mark once said, "Being connected to politics keeps my engine going."

    Mark was also a wonderful and dear friend to me and many others on staff, throughout the membership, and here in Washington. He will be missed.

    Funeral arrangements are still pending. We will set up a tribute page on ISRI's website which will be updated with details once they become available.

    Robin Wiener

  • ISRI's Upcoming America Recycles Week Activities

    Nov 08, 2019

    To celebrate America Recycles Day, the Institute of Scrap Recycling Industries (ISRI) is taking part in a number of key initiatives throughout next week focused on the current state of our industry and its future, particularly as it relates to driving market demand for valuable scrap commodities, including the ISRI Design for Recycling® initiative. I encourage you to join us, and other industry and business leaders to celebrate the thriving U.S. recycling industry.

    Over the course of the last year, ISRI worked closely with the U.S. Environmental Protection Agency (EPA) and other industry stakeholders on challenges and opportunities facing the industry. The work that was accomplished will be discussed in-depth at three main events:

    4th Annual State of Recycling Caucus Briefing: Designing for the Recycling Economy Wednesday, November 13, 2019
    1:00 – 3:00 pm
    Energy & Commerce Committee Room, Rayburn 2322
    Moderated by ISRI President Robin Wiener and hosted by Recycling Caucus Co-Chairs: Energy & Commerce Chairman Frank Pallone, Jr. and Rep. John Shimkus. Panelists will include: David Tulauskas, Chief Sustainability Officer, Nestle Waters; Joe Heilman, LyondellBasell; Mark Ohleyer, Vice President, Sales & Marketing, Clearwater Paper Corporation; Erica Logan, Regulatory Senior Principal Engineer, North America Environmental Affairs & Producer Responsibility, Dell Computer Corporation; and Adam Gendell, Associate Director, Sustainable Packaging Coalition Green/Blue
    The event is free and open to the public.

    America Recycles Innovation Fair
    Thursday, November 14, 2019
    1:00 – 6:00 pm
    Ronald Reagan Building Pavilion Room

    Hosted by the EPA in partnership with ISRI and other organizations, the Innovation Fair is designed to showcase recycling innovators that practice design for recycling and/or develop technologies to improve recycling rates. The Fair will feature displays from ISRI, along with ISRI Design for Recycling® Award winners Nestlé Waters North America and Samsung, as well as more than 35 other innovators.
    The event is free and open to the public. Registration in advance is requested.

    2019 America Recycles Summit
    Friday, November 15, 2019
    10:00 am – 1:00 pm
    Industry stakeholders, including ISRI, will discuss accomplishments since last year’s America Recycles Day Summit in which ISRI and industry stakeholders signed the America Recycles Day Pledge. EPA Administrator Andrew Wheeler will preside over this year’s summit, which will feature reports from the working groups on education & outreach, infrastructure, market development and measurement on their accomplishments towards a revitalized recycling sector in the United States. 
    The event is free and open to the public. Registration in advance is requested. You can watch the event’s livestream at www.epa.gov/live.

    We are looking forward to a very successful week in promoting the many economic and environmental benefits of our industry. We hope that you can join us at these events.

  • Breaking the Glass (Recycling) Ceiling

    Oct 23, 2019
    The health of the environment is important, and a significant part of making our world safer involves making our world green. For many people, recycling is an easy way to help the environment, and that begins with placing plastic, paper, and glass into their respective curbside bins.

    Glass, in particular, can be endlessly recycled with no loss of purity, and recycling it saves raw materials, reduces the demand for energy, and helps cut CO2 emissions. Just consider these recycling statistics:

    • One ton of carbon dioxide is reduced for every six tons of recycled container glass used in the manufacturing process.
    • Recycled glass is substituted for up to 95% of raw materials.
    • Energy costs drop about 2–3% for every 10% cullet used in the manufacturing process.

    However, not all glass is the same, so separating it correctly in the recycling process can be a challenge. Here, we’ll explore the glass recycling and sorting process and provide techniques to improve it.

    Common Contaminants in Glass

    Glass used in bottles and containers is called soda glass. This type of glass is recycled in a closed-loop system (meaning that it’s recycled back into soda glass), which saves raw materials needed to create new glass.

    The environmental benefits of glass recycling are particularly advantageous because, unlike plastic, glass can be reused and recycled indefinitely, provided it contains no contaminants such as non-glass materials and unrecyclable glass ceramic material.

    Unrecyclable glass materials such as ceramics, crystal, and clay are increasingly common in a variety of products, including garden pots, cookware, manufactured goods, and smartphones. These materials can even contain contaminants—including lead—that are harmful to our health.

    Even if no harmful contaminants are present in the unrecyclable glass ceramic, most have different chemistries and a higher melting point than regular soda glass. This can potentially cause damage to the glass furnace and cutting systems, as well as create impurities in new glass material.

    Glass bottles with impurities also have a greater risk of shattering when being used or transported. This can lead to potential product safety and manufacturing issues further down the supply chain.

    As more new glass containers are made with recycled glass, it’s especially important to separate contaminated waste from the recyclable glass in a fast, affordable, and reliable manner.

    But, how? To answer this question, let’s explore the modern recycling process to understand how to make glass sorting more practical and efficient. 

    Glass recycling process
    Glass Recycling Process

    Sorting Through the Modern Recycling Process

    In modern single-stream recycling, all the recyclable material gets dumped on a conveyor, where it undergoes a multistep separation process. Facilities use multiple screening and separation techniques to sort out various contaminants based on their physical characteristics.

    For example, magnetic sorting is used to filter out ferrous alloys. Plastics, papers, and non-ferrous alloys can be sorted out via a combination of density sorting techniques (e.g. vibrating screens) and optical screening.

    At the end of the process, the remaining glass material is crushed into small pieces called cullet. However, certain types of unrecyclable materials, such as glass ceramics, crystal, and clay garden pots, may still be present in the cullet and will need to be sorted out. The cullet then moves on to the reclaiming facility where this unrecyclable glass is removed.

    Historically, glass recyclers used magnetic or visual/infrared sorting on certain types of glass materials. But, there are some drawbacks to these methods. For example, certain ceramic glasses (like transparent cookware) and recyclable glass have very similar physical and optical properties. As a result, they are distinguished only by their chemical composition.

    So, how do we efficiently separate safe, recyclable glass from unsafe materials? The answer is X-ray fluorescence (XRF). 

    Glass Cullet Stream
    Glass cullet stream
    What is X-Ray Fluorescence?

    Simply put, XRF is a spectroscopy technique that can be used to determine the material chemistry of a sample. It utilizes the physical phenomenon of photoelectric absorption and emission, whereby bombarding a material with energetic X-rays leads to the generation of secondary fluorescent X-rays.

    These secondary X-rays will have energy that is characteristic of the elements that produce them. Using a specialized detector, it’s possible to capture and measure these fluorescent X-rays and measure their energy, thus generating a spectra that can be mathematically analyzed to determine composition.

    One of the key advantages of utilizing XRF technology over other spectroscopy techniques is that it’s completely nondestructive. It can also be used to test material “as is” — with little to no sample preparation.

    What is Handheld XRF?

    Historically, XRF testing has been done on large benchtop and laboratory systems and required careful sample preparation. These days, the same kind of analysis can be accomplished rapidly using handheld XRF technology, such as Olympus Vanta™ analyzers.

    Handheld XRF uses the exact same technique as the large benchtop systems, which is possible because it uses a low energy and compact X-ray tube source. These portable XRF analyzers are already used regularly in a variety of industries, including scrap metal recycling, mineral/metal mining, and material QA/QC.

    In recent years, handheld XRF devices have also been deployed in other kinds of recycling and material recovery operations, such as the recovery of precious metals from automotive catalysts and consumer electronics.

    The Advantages of Using XRF for Glass Material Processing

    Because of its ability to directly measure composition, XRF offers a distinct advantage over other techniques to sort out non-recyclable glasses and ceramics from normal soda glass.

    For example, a handheld XRF analyzer can recognize ceramic identifiers, such as zinc, titanium, and lead in fragments of material as small as 1 mm (0.04 in.) diameter in as little as one to three seconds with a single trigger pull. Once identified, these materials can then be manually removed from the safe, recyclable glass.

    Beyond its analytical capabilities, handheld XRF technology is designed to work in industrial environments. It also offers several other features that can help ensure productivity and speed in a material processing facility.

    Wireless and cloud connected instruments can ensure that data collected from the XRF analyzer is uploaded automatically to process control systems after each test. It also enables facility managers to monitor instrument usage and performance remotely, as well as customize instrument configuration for each operator or task.

    Sorting Glass Cullet with High-Speed, In-Line XRF Systems

    While handheld XRF analyzers will more than suffice for small batches of cullet, a large glass recycling plant can process more than 20 tons of cullet per hour. This makes manual separation of the identified unrecyclable glass impractical. Fortunately, the XRF technique can also be scaled to high-speed, in-line systems.

    For instance, Olympus’ X-STREAM in-line X-ray fluorescence analyzer uses automated, high-volume technology to rapidly and accurately sort glass cullet. In fact, this system can process as much as 28 tons of glass cullet per hour. It also uses multiple detector arrays so that even small fragments can be reliably separated.


    The X-STREAM in-line system sorts glass cullet as it passes under the arrays and separates contaminated fragments from safe glass using a blast of air. With the contaminated glass separated from the recyclable glass, the endless cycle of glass recycling can safely continue.

    Dillon McDowell is an applications scientist, analytical instruments for Olympus, an ISRI member.

  • ISRI Continues Leadership Positions on Key REMADE Committees

    Oct 03, 2019

    ISRI continues to play an integral in the many different aspects of industry innovation and research development. Its involvement and selection to leadership roles in the REMADE Institute is a clear indication of the important role ISRI plays in both the industry’s current landscape, and its future.

    The Reducing EMbodied-Energy And Decreasing Emissions (REMADE) Institute is a public-private partnership in the Manufacturing USA® network with members from academia, industry, non-profit sector, and national laboratories. With up to $70 million in Department of Energy funds over 5 years matched by the private sector, REMADE is tasked with advancing manufacturing through research and development into technologies aimed at “addressing knowledge gaps that will eliminate and/or mitigate the technical and economic barriers that prevent greater material recycling, recovery, remanufacturing and reuse.”

    For the last several years ISRI has played a key role offering industry expertise, and serving as a conduit between ISRI members and REMADE. ISRI President Robin Wiener serves on REMADE’s Strategic Advisory Committee as Affiliate representative and vice chair. In her role, she advises on the organization’s Strategic Investment Plan, membership, IP management, and manufacturing issues.

    ISRI Chief Scientist David Wagger was just re-elected to the position of Affiliate representative on the Technical Advisory Committee. In his role, David will continue to advise on the organization’s technical roadmap and technology priorities.


  • New York Chapter President Represents ISRI at New York Lunch with U.S. EPA Administrator Andrew Wheeler

    Sep 27, 2019

    On Monday September 23, ISRI’s New York Chapter President Leonard Formato, Jr. represented ISRI at a very intimate luncheon of ten guests featuring United States Environmental Protection Agency (EPA) Administrator Andrew Wheeler. In addition to Lenny Formato of Empire Metal Trading in Brooklyn, NY, were representatives of the chemical, agricultural, and oil industries, as well as some of the nations’ largest corporations.

    The lunch was sponsored by the United States Council for International Business (USCIB) of which ISRI is a member. The discussion addressed American innovation and initiatives to tackle global environmental challenges. Also discussed were opportunities for public/private partnerships to advance U.S. competitiveness through investment in environmental infrastructure and cleaner technologies. 

    Administrator Wheeler advised the guests that EPA is aware of the challenges facing the recycling industry today. Subsequent to the meeting, Formato was able to spend a few minutes with Mr. Wheeler.

    “On behalf  of ISRI and its 1,300 plus members, I thanked the Administrator  for coming to speak at ISRI’s July Board meeting, and for recognizing the challenges facing our industry today. I found the luncheon to be very informative and productive. The opportunity to have lunch with Administrator Wheeler and a small group of major industry executives and discuss environmental issues facing all of our industries was unique for me. I got to experience a small slice of what our Association’s staff does for us – to whom they are exposed and the kind of discussions they have.”

    If you are a Chapter President or a leader of the industry in other capacities, and would like to participate in similar types of meetings that may occur near your business and for which ISRI has been invited to participate, please let us know. ISRI staff will look out for those opportunities in your backyards and try to get you a seat at the table. Contact Mark Reiter for further details.
  • President Trump Visits Pratt Industries' New 100% Recycled Paper Mill

    Sep 23, 2019

    Recognizing the important role paper recycling plays in American manufacturing, U.S. President Donald Trump on Sunday toured Pratt Industries’ containerboard mill in Wapakoneta, Ohio.  The event was broadcast live on at least one national cable channel. Pratt Industries, is a member of the Institute of Scrap Recycling Industries (ISRI), and the Paper Stock Industries (PSI) Chapter. 


    Accompanying the President during the tour, and during the press conference was Australian Prime Minister Scott Morrison, and company owner Anthony Pratt. The President explicitly stated that not one tree is used in the manufacture of Pratt's paper at their 100% recycled paper mills. 

    The Ohio facility, Pratt Industries' fifth 100% recycled paper mill in the U.S., is scheduled to open in October, and will consume 425,000 tons of mixed paper and old corrugated containers as feedstock. It represents the largest factory pledged and built during President Trump’s first term.

    In 2017, Anthony Pratt vowed to invest $2 billion in the U.S. over the next decade and create 5,000 high-paying jobs. In addition to the plant in Wapakoneta, Pratt has also built factories in Valparaiso, Indiana; Lewisburg, Ohio; and Beloit, Wisconsin. Combined, these investments have totaled over $1 billion, and are an example of the continued growth of paper recycling in the U.S. Overall, Pratt Industries employs 9,000 Americans.

    "Over the past 18 months the paper recycling markets in North America have been quite challenging due to the tumultuous export markets," stated Robin Wiener, president of ISRI. "Due to investments by ISRI members such as Pratt's, in this new paper mill, there will be a new domestic market in the Midwest for nearly 1 billion pounds of recycled paper each year."

    The U.S. paper recycling industry as a whole provides a nearly $34 billion economic impact in the U.S. It is directly and indirectly responsible for 154,000 American jobs.

  • One Recycler’s Tips for Handling Batteries

    Jun 19, 2019

    Recently an ISRI member visited a large battery recycling facility and was given a tour by the facility EHS manager. The facility handles large quantities of lithium and other types of batteries monthly, and he wanted to share some takeaways from that visit along with some proactive measures that his company is taking to minimize risks to employees, equipment, and the facilities. Here is the member’s take on that visit:

    First of all, the recycling facility had a very sophisticated fire detection and suppression systems that may not be achievable for smaller handlers, but there are several things that I feel we can all do to minimize our risks:

    • For hot or smoking batteries, bright red labeled buckets are located around our facility that contain Cell Block EX, which is a Class D fire extinguishing media
    • Bags of Cell Block EX are located in and near our battery storage area that can be quickly torn open and dumped into smoking gaylord boxes or barrels. It may not extinguish a fire, but it will certainly slow it down until the fire department can get there and take further action if needed. The battery recycler swears by this stuff and they have it everywhere around their facility.
    • Minimize storage time and storage quantities to keep lithium battery inventories as low as possible. Doing this is an additional expense to the company, but one that we feel is worth the cost. We investigated keeping inventory in a shipping container away from the facility, but we feel that heat build-up in the warmer months may create or cause additional hazards
    • Evaluate battery storage areas with your insurance company and fire alarm company for their suggestions. Also, we are looking into thermal imaging monitoring for quicker hot spot detection vs. heat and smoke sensors.
    • Solid steel shelving is being added to our storage racks to minimize upward fire spread. We are also painting shelf surfaces with truck bed liner so they are non-conductive.
    • We are running a water line to our e-scrap shredder with a gate valve next to the E-Stop so we can quickly shut down and flood the shredder chamber in the event of an emergency. Please let us know if anyone has better ideas out there for this one?
    • And we are always improving employee awareness and training programs in regards to battery safety.

    These batteries scare us, and there are enough horror stories out there that we think we’re doing the right thing by moving quickly with these proactive solutions and preventative actions.

    The hope is that some of this info helps you in keeping your employees and facilities safer. Please let us know if you have any other ideas or solutions that you’ve implemented at your facilities.

    Another great resource for safety information on lithium batteries is the Battery Council.

    Tony Smith is the director of safety outreach for ISRI.

  • Autocatalyst Recycling Outlook for 2019

    Feb 25, 2019

    by Becky Berube

    Looking back is always easier than looking forward. And last year was a good year for autocatalyst recycling. And for 2019 the outlook remains positive.

    Autocatalystimage22The strong demand for autocatalyst, increased vehicle recycling, and a short supply continues to push the Palladium price higher. Lower demand from the decrease of consumption of diesel vehicles in Europe combined with an increase of secondary supply from recycling continues to hold the Platinum price down. Stricter emission standards will increase Rhodium loadings, but that metal will still be in surplus.

    The demand for new automobile catalyst climbed to record levels last year amidst a shortage of palladium (Pd), a surplus of platinum (Pt), and an increasing supply of rhodium (Rh). You can see from Figure 1 that palladium makes up most of the precious metals contained in autocatalyst or catalytic converters.

    This is good news for palladium since palladium loadings have been increasing, mostly in the U.S. market, in autocatalyst since the 1990s. At that time the palladium technology was less advanced and the fuels less clean, which means more palladium was added than platinum removed. At the same time, palladium was historically less than half the price of platinum.

    Johnson Matthey in its PGM Market Report dated February 13, 2019, states that the secondary supply of palladium grew by 10 percent in 2018, after having a 20 percent gain in 2017. This is due to the increase in vehicle recycling once the scrap steel price bounced back from its lows during 2015 – 2016.

    And considering “dieselgate,” Germany’s car emissions fraud scandal, there have been stricter vehicle testing procedures and tighter emission limits on heavy duty vehicles. This contributes to higher demand for autocatalyst and use of Platinum Group Metals (PGMs), namely, Pt, Pd, and Rh.

    Autocatalyst Image

    Even with the decreased use of platinum in three-way catalyst over the past 20 years, and the reduction of diesel catalyst production which uses more platinum, a small rise in increased demand for platinum will come from fuel cell technology in automotive applications and stationary power generation over the next several years. See Figure 2.

     As emission standards tighten in most countries, rhodium loadings will also increase. Still this metal is expected to continue to be in surplus.

    Recently, I asked Philip Newman, the Director of Metals Focus (@metalsfocus), a London-based independent precious metals consultancy group to comment on the outlook for platinum and palladium in 2019. Here is what Philip had to say.

    Platinum has fallen to a record discount to gold of $526. That said, Metals Focus still expects platinum prices to eventually firm this year, especially towards end-2019. However, this is premised on our view of a stronger gold price. In other words, platinum will continue to face headwinds of unsupportive supply and demand.

    In trying to gauge professional investor sentiment in recent weeks, the absence of up-to-date CFTC data has led us to review Nymex open interest. Having fallen for much of January, open interest has since risen through to mid-February. In our view, subdued weak institutional sentiment towards platinum indicates that the rise in open interest represents an increase in gross short positions.

    Palladium has continued to strengthen this year, achieving a new record high of $1,439 on January 17. Key to this is the ongoing physical deficit in the palladium market, which this year is expected by Metals Focus to reach 1Moz.

    Autocatalyst Image

    Looking ahead, we believe palladium prices will continue rise this year. Even so, palladium’s record high prices increase the risk of near-term profit taking, although any downturn in the palladium price should be short-lived.

    In summary, 2018 was a great year for both vehicle and autocatalyst recycling. At this time, 2019 looks to be more of the same. This is why we, at United Catalyst Corporation, believe that recyclers can get the most from their converters with the scientific process of selling converters on assay. For questions  about selling converters on assay or copies of this article or previous articles in this series, email me or go to unitedcatalystcorporation.com.

    BeckyBerube2Becky Berube serves the recycling community as United Catalyst Corporation President, she writes a monthly educational column for the industry, serves as co-chair of the ARA Annual Convention Educational Programming Committee, is on the administrative team for the ARA Peer Mentoring Program, and is an Executive Committee member of the IPMI. She can be reached at 864-834-2003 or by email at berube@unitedcatalystcorporation.com.

  • Protection of a Valued USPS Asset: Everyone Can Save Postal Dollars

    Dec 18, 2018
    By Postal Inspector Claudia Angel 

     Among the types of equipment used are: plastic and wood pallets, plastic tray and tubs, canvas and plastic hampers, general purpose carts, and bulk mail containers to move the mail. In the past 10 years, the Postal Service purchased $1 billion of new postal MTE to replenish inventory and ensure that both our business and our customers can function effectively. Protecting all postal equipment is a balancing act affected by many external and internal sources.

    Although rare, we have encountered situations at times where businesses and/or individuals kept excess amounts of postal equipment, and on occasion, have sold them to other businesses including recyclers. It is important that this equipment is returned to the Postal Service as the replacement costs add up quickly. The U.S. Postal Inspection Service is the federal law enforcement arm of the Postal Service, charged with securing the mail and postal assets. The Inspection Service is requesting your assistance in the recovery of postal equipment.

    Title 18, U.S. Code, Section 1707, states it is illegal to misuse postal-owned equipment. Violation of this statute is punishable with up to three years imprisonment with fines.

    Criminal investigations conducted by the Inspection Service have revealed improper use with large quantities of postal equipment destroyed or recycled. As a result, the Postal Service is losing millions of dollars yearly in replacement costs.

    The Postal Service does not sell postal equipment, and postal employees do not have the authority to do so, regardless of its condition. Damaged equipment is only disposed of through a limited number of certified recyclers. It is illegal to sell or recycle postal equipment. If a company is in possession of postal equipment which it is not actively being used in conducting business with the Postal Service, it may be interpreted that the company is in illegal possession of postal MTE. 

    The Inspection Service has been directed by the Chief Postal Inspector to conduct reviews at mailer and recycling facilities nationwide in order to recover postal MTE not actively being used in conducting business with the Postal Service and to educate the general public on how to identify the postal equipment and have it returned to the Postal Service. If you should encounter postal equipment at your business which is not being used in conjunction with doing business with the Postal Service, or if you are aware of a situation of postal equipment being improperly used, please contact our Mail Transportation Equipment Recovery Hotline at 866-330-3404; upon doing so, you will be contacted by a Postal Service representative who will arrange to have the postal MTE returned to the possession of the Postal Service.

    Postal Inspector Claudia Angel currently serves as Program Manager at the U.S. Postal Inspection Service National Headquarters in Washington, DC. Inspector Angel oversees the Cybercrime Digital Product Security program in evaluating and recommending security controls, prevention, monitoring, detection and reporting for new/modified digital products developed or supported by the U.S. Postal Service. 

    Angel was appointed to the position of United States Postal Inspector for the United States Postal Inspection Service in August 2001 where she was assigned to the San Juan Field Office of the Newark Division and dedicated the first 10 years of her career conducting investigations throughout Puerto Rico and the U.S. Virgin Islands.

  • Training with Local Fire Department a Winning Partnership

    Jun 21, 2018

    By Peter Van Houten 

    Over the past year the Portland Fire Department and Bob’s Metals Inc. have partnered in creating hands-on emergency response training opportunities with simulated rescue situations created by the Bob’s Metals yard staff.

    BobsMetalsThese experiences have included crash scenarios of multiple sized vehicles, enabling the fire department opportunities to test out and train on new cutting and lifting equipment to gain access to the ‘crash victim.’ The Portland Fire Department has an exceptional training facility, at Station 2, but one of the benefits in working with Bob’s Metals is dealing with the unknown. Part of the excitement is enabling our yard staff to create the scenario, and they seek to make it difficult.

    This past scenario included a Honda that had lodged itself underneath a full-size garbage truck, requiring the response team to assess gaining access to the injured driver by stabilizing/lifting the garbage truck and cutting away the doors and roof of the Honda. Overall feedback from the fire department is that they like the ‘surprise’ element of the scenario, making them analyze the situation to best utilize their skills and tools to perform.

    BobsMetals“I am very appreciative of the support that Bob’s Metals has provided station 8. As an officer, it is important for me to conduct routine drills, especially with operations that we do not perform very often, i.e. vehicle stabilization, extrication, and lifting. Furthermore, I feel it important to keep Truck 8 in our district instead of going to the other side of the city...the north end resources can be quickly depleted, so staying in district allows us to cut and run from a drill if need be.” – Lt. Justin De Ruyter

    Working together these scenarios not only provide the Fire Department with a more realistic training situation, but increases the awareness of employees to our own emergency plans and working relationships with emergency personnel. A win-win example in community partnership.

    Peter Van Houten is general manager of ISRI member Bob’s Metals, Inc.

  • Century Club to Have Its Day at ISRI2018

    Mar 12, 2018

    -By Manny Bodner and Barry Hunter

    Anyone who has a combined age and years of active participation in ISRI and/or its predecessor organizations, Institute of Scrap Iron and Steel, National Association of Recycling Industries, and/or Paper Stock Institute that meets or exceeds 100 years, whether or not you are still working, is encouraged to join this prestigious group.

    ISRI’s Century Club is intended to provide members with a means to maintain the industry relationships and friendships developed over the years, as well as the opportunity to contribute knowledge and expertise to the ever-growing and ever-changing scrap recycling industry.

    With the complete support of ISRI leadership, our first official meeting of ISRI’s Century Club will occur during ISRI2018, on April 17. Dubbed “Century Club Day at ISRI2018”, members will begin the day by teaming up with ISRI’s Young Executives group for a light-hearted and fun session during which the Century Club and Young Execs will discuss the industry and its many changes over the years. Next, Century Club members will be invited to tour the ISRI2018 Exhibit Hall. The day concludes with a Century Club Member-Private reception.

    We hope all those who qualify will share in our excitement and take advantage of this opportunity to join your fellow ISRI Centenarians by embarking on this next phase of ISRI involvement – sharing fun programs, fond memories, and social events throughout the year as organized by the group.

    For more information and to apply for Century Club membership, please visit the ISRI website and complete the application.

    England has Sir Winston Churchill; the USA has FDR; the ISRI Centenarians have Barry and Manny!” – Many Bodner. Manny can be reached at (713) 248-0396.

    Barry Hunter is the catalyst behind the effort to organize the ISRI Century Club, and will continue as Co-Chair alongside Manny Bodner. Barry can be reached at (201) 259- 5075.

  • Planning for the Storm

    Sep 21, 2017

    Natural disasters are an ever-present threat, and there’s evidence to suggest they’re occurring with greater frequency and severity. Recently, Texas and its neighboring states were left devastated by the catastrophic Hurricane Harvey. Just days later, Hurricane Irma battered the Caribbean and delivered a destructive blow to South Florida.  According to NOAA National Centers for Environmental Information 2016 claimed the 2nd highest annual number of U.S. billion-dollar disasters, shortly behind 2011. Given the unprecedented amount of damage left by both Harvey and Irma, 2017 is expected to top both record-high years.                               

    If a natural disaster struck your facility, would your company and employees be prepared? Your answer to that question could determine whether your employees escape injury and whether your company survives or fails in the disaster’s wake. Natural disasters can injure a company’s employees, damage property, disrupt operations, and threaten its future viability. Though businesses can’t control natural disasters or prevent them from occurring, they can prepare for them by developing an emergency preparedness and recovery plan. Such a plan can protect human health while helping the company swiftly re-establish normal business operations.

    First Things First

    Companies have several options for drafting a plan: They can prepare their own, hire a consultant, or work with local and/or state agencies.

    For recyclers who lack such firsthand experience or need assistance developing a plan, FEMA offers the Emergency Management Guide for Business and Industry, a free, step-by-step guide to emergency planning, response, and recovery for businesses of all sizes. The guide presents information on specific disasters, such as tornadoes and earthquakes, as well as general information on preparedness. The “Ready” campaign—a joint effort of FEMA and the U.S. Department of Homeland Security—also provides information to help businesses prepare. Though these do-it-yourself resources are helpful, it is often beneficial to get outside help from third-party professionals.

    Building an Emergency Plan

    Though each recycling facility faces its own set of natural disaster risks based on its geographic location, climate, access to transportation and emergency services, and more, the process of developing any emergency preparedness plan can follow the same basic outline, experts say.

    • Assemble a team. Start by putting together a group of employees that will develop, manage, and update your company’s disaster plan. FEMA’s guide suggests having the CEO or plant manager lead the group to demonstrate management’s commitment to the plan.
    • Assess your risks. Natural disasters can take many forms, so begin by assessing which ones could affect your operations. Each type of disaster requires its own preparations and responses to mitigate or eliminate the risk. After identifying potential or likely disasters, assess the impact each could have on the company, including your supply chain or customers.

    Part of risk assessment is considering your plant’s physical structures and layout. If employees have to seek shelter at the facility—such as during a tornado—are there areas on site to shelter them?

    Risk assessment also means identifying essential business functions. Determine how long your company could withstand an interruption and what it would need to re-open. Additionally, identify an alternative, temporary location from which your company could operate after a disaster. Be sure to review your company’s insurance policies as well, to ascertain which losses will be covered.

    • Form a plan. After you identify your company’s risks, develop a plan to address them. Procedures should spell out how your staff will respond before, during, and after a disaster. Basic plan features should include procedures for warning employees and visitors of any impending danger; providing escape routes, if necessary; protecting vital records and assets; and getting the company running as soon as possible—even if it’s from a temporary location.

      A thorough plan should identify more than one evacuation route in case the initial one is blocked, designate meeting areas for employees, and have a system to account for every individual at the facility, including visitors, when the disaster occurred. Your plan also should have information about community evacuation routes, facility shutdown procedures, and plans for assisting employees who might need transportation, the FEMA guide says.
    • Communicate effectively. Communication—before, during, and after a disaster strikes—is a key component of any emergency preparedness plan. Your plan should designate one or more people who are responsible for informing employees about potential dangers as well as those who will contact customers and vendors after an event. Identify whom you would need to contact internally and externally during a crisis, and keep their contact information up to date. Don’t expect to be able to use traditional communication methods such as land-based telephone lines or cell phones, experts say. Companywide text message alerts and check-ins—which require less bandwidth than voice transmissions—are a smart alternative.

      After a disaster, a company spokesperson should inform the public that the facility is recovering to dispel any rumors of its closure.

    • Consider your equipment and technology needs. Emergency preparation also means protecting data and equipment as well as having the right equipment to expedite recovery. For the latter, consider backup equipment and systems such as gasoline-powered pumps to remove water, alternative power sources such as generators, and battery-powered emergency lighting, experts suggest.

      On the data side, ensure company leaders have quick access to insurance documents, and maintain off-site backup storage of critical company records, customer data, and other information.

    • Train and practice. An emergency preparedness plan won’t work, of course, unless you train employees on its features and their responsibilities. Ensure the company is ready to implement the disaster plan when a disaster strikes by practicing implementation at least once a year through full-scale drills.

    As your employees work through the drill, they should consider how to react during the first minutes, hours, days, and weeks of the event. The more companies practice their plans, the better prepared they’ll be.

    In the wake of a natural disaster, when life returns to normal, review how your company and personnel handled the crisis and the effectiveness of your plan.

    This blog post was adapted from “Weathering Any Storm,” Scrap magazine, July/August 2012, by Nicole Meir, communications intern for ISRI.

  • Plan Ahead for a Hurricane

    Sep 11, 2017

    Preparing a scrapyard for a hurricane should begin well before the winds start whipping.

    Creating, reviewing and revising an emergency response plan prior to storm season provides the optimal protection.

    In planning ahead, you can react sooner and avoid potentially disastrous oversights when a storm threatens. For example, knowing how you will secure equipment before a storm hits and communicate with employees afterward so that they know when it is safe to return will help you better protect your business and your people.

    “The time to plan is always before,” said Terry Cirone, vice president of safety for the Institute of Scrap Recycling Industries. “So, if you could be in the path of a storm get out that plan, dust it off and review it.”

    Cirone advises recycling centers to be particularly proactive in preparing their communication plans, controlling mold, and protecting their records. “It’s all about business continuity and protecting your assets.”

    Some businesses recently impacted by Hurricane Harvey failed to protect their files from water damage, she said. “If they get so flooded out or water-logged that you can’t utilize them, then that’s a problem.”

    With Hurricane Irma’s arrival imminent and additional storms looming, Cirone urged businesses to prepare early and act quickly to stay safe.

    Here are some suggested steps.

    • Review responsibilities for preparations and response with everyone, including senior management.

    • Establish processes for storm-related communication between employees and managers, such as how to announce when the business will close and re-open as well as how employees can report that they cannot make it to work. Update all related phone numbers.

    • Secure equipment or materials that could be sent flying by strong winds.

    • Shut down electrical equipment that could be exposed to flooding.

    • Remove low-lying files and other property that could be damaged by high waters.

    • Check for mold caused by flooding. Hire experts to treat affected areas like walls and carpets if needed to protect the health of your employees and customers.

    See ISRI’s Safety Tips for Hurricane and Flooding Cleanup and Recovery Work for additional information.

    The post was written by ISRI member Scrapyard Pro and originally appeared on the ScrapyardPro Blog.

  • Safety Before—and Beyond—Compliance

    Aug 16, 2017

    By Tony Smith

    Those who have been in the scrap business for decades might remember operating before the 1970 passage of the federal Occupational Safety and Health Act. The act established the Occupational Safety and Health Administration, the federal body that creates and enforces workplace safety regulations. Since then, businesses have had to ensure their operations are in compliance with OSHA regulations or the state equivalent or risk facing steep penalties.

    Long before safety was required by law, however, it was something industries tried to achieve by implementing best practices, sharing industry knowledge, and coming to consensus around voluntary standards. One such standard for crane safety, ASME B30, was first developed just over a century ago, in 1916, via the American Society of Mechanical Engineers (New York). For those who used lift equipment such as mobile cranes, overhead cranes, slings, and rigging, this signaled a new beginning in the world of safety.

    Scrap operations today are very different from what they were in 1916, of course. ASME B30 and similar standards are living documents, and the process of creating, updating, and refining them continues to this day. The stakeholders and subject matter experts that volunteer for this work come from diverse backgrounds and offer many different points of view, but they work together to reach industry consensus. ISRI Safety works with two different standards development organizations, ASME and the American National Standards Institute (Washington, DC), to ensure standards for scrap processing equipment reflect the industry’s needs and concerns.

    Right now I represent ISRI members in the standards development process for ASME B30 and a second standard, ANSI/NWRA Z245. That standard, for equipment, technology, and operations for the waste and recyclable industry, is managed by ANSI and the National Waste and Recycling Association (Washington, D.C.). I chair two subcommittees under those standards: ASME B30.25, Scrap and Material Handlers, and ANSI/NWRA Z245.7, Size Reduction Equipment. ASME B30.25, established 20 years ago, gets revised every five years; we expect to publish the newest revision in January 2018. ANSI/NWRA Z245.7 is a new standard we are developing, and we hope to publish it in the next three to five years. That, too, will have a five-year revision schedule.

    These are voluntary standards, not laws or regulations, but they offer guidance where there might not be any at the regulatory level. In many cases, OSHA does not have a regulation covering the specific safety issues related to scrap recycling equipment and processes. In other cases, the voluntary standards meet or exceed the regulatory requirements. The standards offer guidelines and best practices for equipment design and construction; equipment inspection, testing, and maintenance; and equipment operations. They focus on your real-world, day-to-day situations.

    Understanding and using the ANSI and ASME consensus standards as guidance documents for your standard operating procedures will streamline your operations and give your safety program a solid foundation. Doing so can help ensure the safe operation of your business. For more information on the consensus standards, visit www.ansi.org or www.asme.org.

    —Tony Smith is a director of safety outreach for ISRI.

  • ISRI Applauds SC for Enacting Superfund Protections for Recyclers

    May 23, 2017

    By Danielle Waterfield

    In 1999, Congress enacted limited protections for recyclers from Superfund liability in recognition that recycling is not disposal. The federal SREA law establishes that the federal government cannot impose liability for disposal of hazardous wastes on recyclers who shipped recyclable materials for recycling purposes. This law was enacted to make it clear that Congress never intended for recycling to be treated as disposal under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), commonly known as Superfund.

    Enactment of SREA protections into state law is essential to ensuring recyclers are not left with financial liability for the clean-up of hazardous waste incidents for which they had no responsibility. While the courts have upheld the validity of the SREA defense to CERCLA liability under federal law, in 2015 the Fifth Circuit U.S. Court of Appeals ruled that the defense offered by SREA does not apply to clean-up claims asserted under state law. Without similar protections explicitly written into state statute, recyclers are vulnerable to liability for clean-up of hazardous instances for which they had no part.

    To address this significant exposure to liability, ISRI strongly encourages recyclers to seek enactment of state equivalent protections. In South Carolina, ISRI members Barry Wolff (Charleston Steel & Metal Company) and Blake Stanley (CRC Scrap Metal Recycling, LLC) led the charge with the assistance of the South Carolina Recyclers Association and financial support of the ISRI SE Chapter. Stanley, who is president of the SC Recyclers Association and Wolff (the immediate past president), coordinated with SCRA state lobbyist Ken Kinard along with the ISRI SE Chapter leadership, which has made enactment of SREA protections a policy priority within the chapter.

    The effort this year began with a legislative reception at the state capitol sponsored by the SRCA. Recyclers from around the state joined legislators and staff for breakfast to welcome and introduce them to the industry. ISRI attended the event and assisted with preparation of educational packets that were distributed on-site. Subsequently, ISRI and SRCA leaders met afterwards with staff from the S.C. Department of Health & Environmental Control to discuss the SREA language. With the Department’s support, the legislative work began to insert simple language into state statute clarifying that SREA protections for recyclers apply to not only federal cleanup actions, but state actions as well, effective immediately.

    ISRI applauds SE Chapter president Tom Rice and the board of directors for their leadership on this very crucial issue for the recycling industry.

    Danielle Waterfield is senior director, government relations/assistant general counsel for ISRI.

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  • Dialing Down Your Superfund Risk

    Apr 07, 2017

    By Kent Kiser

    Unfortunately, most recycling companies are leaving themselves vulnerable every day to such a threat, one that could very easily bankrupt both the company and its executives. The threat is Superfund liability, which remains a real and ever-present danger. You might think your Superfund worries disappeared when Congress passed SREA Shieldthe Superfund Recycling Equity Act in 1999. SREA was a monumental victory for the industry that provides companies with a valid defense to a Superfund liability claim, but this defense is not automatic. You can only claim the exemption if you can prove you took certain affirmative actions before shipping recyclable material to a consuming facility. Those actions include conducting due diligence on the environmental compliance status of your consumers’ operations.

    The threats are not just hypothetical. In November 2011, the U.S. Environmental Protection Agency named 115 entities potentially responsible parties for Chemetco, a secondary copper smelter in Hartford, Ill., that it designated a Superfund site. In the March/April 2014 issue of Scrap, Scott Horne, then ISRI’s general counsel and vice president of government relations, noted this was the first time the EPA had named recycling companies PRPs for scrap shipments made since SREA took effect. The EPA later named another 1,400 entities Chemetco PRPs and “sent special notice letters to about 470 entities … requesting that they either agree as a group to pay for the remedial investigation and feasibility study for the site or arrange to do the work themselves with EPA oversight,” Horne wrote. At least one recycler had been named a PRP for another Superfund site, Remacor, which processed magnesium and rare earth metals. It and 18 other entities that had been named PRPs at that site signed a consent decree with the federal government in late 2012, agreeing to collectively pay $1.1 million in cleanup costs.

    SREA provides potential liability relief for those who arrange for the recycling of specific recyclable materials, which the law defines as including scrap paper, plastics, glass, textiles, rubber (other than whole tires), metal, and spent lead-acid, nickel-cadmium, and other batteries. The law does not cover anyone who owns or operates a contaminated facility or contamination caused in whole or in part by wastes from a scrap recycling facility.

    To qualify for the SREA defense, you must be able to demonstrate that your recycling company met all of the following criteria at the time of a transaction involving recyclable material as defined above.

    • The recyclable material met a commercial specification. You can demonstrate that by referencing specifications that industry trade associations publish, such as ISRI’s Scrap Specifications Circular, or other historically or widely used specifications.
    • A market existed for the recyclable material involved in the transaction. Evidence of a market can include a third-party published price (including even a negative price), more than one buyer or seller for material for which there is a documentable price, and a history of trade in the recyclable material.
    • A substantial portion of the recyclable material was made available for use as a feedstock for the manufacture of a new salable product. On this point, you need only demonstrate it is common practice for your recyclable materials to be available for use in the manufacture of a new salable product.
    • The recyclable material could have been a replacement or substitute for a virgin material, or the product to be made from the recyclable material could have been a replacement or substitute for a product made, in whole or in part, from a virgin raw material. In this case, you must be able to demonstrate the general use for the feedstock material, not that a specific unit was incorporated into a new unit. Given that some consuming facilities use recyclable material exclusively as their raw material, there are instances in which you do not need to show the recyclable material directly displaced a virgin material as the raw material feedstock.
    • For metals, the recycler did not melt the scrap metal prior to the transaction. Welding, torchcutting, sweating, and similar activities are not considered “melting” for the purposes of SREA.
    • For batteries, the recycler did not recover the valuable components of a battery and met all applicable federal regulations in effect at the time of the transaction. The liability relief applies only to those who collect, store, or transport spent batteries.
    • The recycler must demonstrate it took “reasonable care” to determine the environmental compliance status—as it applies to the recyclable material—of the facility that received the recyclable material. To qualify for the SREA defense, you must show you did not send your recyclable material to a facility you had an objectively reasonable basis to believe was not in substantive compliance with environmental laws and regulations.

    Defining Reasonable Care

    SREA determines if you took reasonable care based on several factors, with the first being the price paid in the recycling transaction. The intent is to establish whether the transaction price was reasonable based on general market conditions at the time, contractual arrangements between the buyer and seller, and the circumstances of the transaction, among other considerations.

    A second reasonable care factor is your ability to know the consuming facility’s operations regarding its handling, processing, reclamation, or other management activities related to the recyclable material. This provision acknowledges that a small company may be able to discern less information about the consuming facility’s operations than a large company.

    Reasonable care also is based on whether you made inquiries to the appropriate federal, state, or local environmental agencies regarding the consuming facility’s past and current compliance with the substantive provisions of any federal, state, or local environmental law or regulation, compliance order, or decree applicable to the direct handling, processing, reclamation, storage, or other management activities associated with the recyclable material. This provision only requires that you make reasonable inquiries to those agencies with primary responsibilities over environmental matters related to the recyclable materials involved in the transaction.

    Conducting such SREA reasonable care compliance evaluations, or due diligence, can be time-consuming and confusing, especially for recycling companies lacking in-house environmental or legal specialists. To help you with that task, ISRI developed its SREA Reasonable Care Compliance Program. The program provides comprehensive reports upon request on consuming facilities, giving you the information you need to satisfy that portion of a valid defense to a Superfund liability claim with relative ease and minimal cost.

    ISRI’s SREA Reasonable Care Compliance Program is an easy, cost-effective way for ISRI members to fulfill SREA’s requirements and, in the process, help protect your company from harm. The alternative is to continue to expose your company to potentially ruinous Superfund liability.

    Kent Kiser is publisher of Scrap and assistant vice president of industry communications for ISRI.

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