– In response to the U.S. Environmental Protection Agency’s (EPA) notice on Evaluation of
the Institute of Scrap Recycling Industries (ISRI) submitted comments
identifying federal regulations that have negatively impeded the
The EPA’s call for public comment was in response to the Trump
Administration’s Executive Order “Enforcing the Regulatory Reform
regulatory burdens have long added to the cost of doing business for
the recycling industry,” said Robin Wiener, president of ISRI. “As the
Voice of the Recycling Industry, ISRI advocates at all level of
governments to relieve our members of red tape that hurts operational
efficiencies and limit growth opportunities. In consultation
with ISRI members we have made a number of key recommendations to EPA to
reform current regulations and remove barriers for recyclers.”
ISRI pointed to the following regulations in need of repeal, replacement, or modification:
- Subtitles C & D of the Resource Conservation and Recovery Act (RCRA): Modification
to distinguish scrap commodities destined for recycling from waste destined for disposal.
- The Federal Multi-Sector General Permit developed pursuant to the Clean Water Act:
to account better for the unique characteristics of stormwater and to
align benchmark monitoring better with the performance potential of
control measures and wet-weather
- The refrigerant management regulations of the Clean Air Act: Revision
to require removal of refrigerant from appliances and vehicles prior to delivery for recycling.
- The Chemical Data Reporting regulations pursuant to the Toxic Substances Control
Act: Revision to eliminate the current reporting requirement for scrap metal imported for recycling.
- Elimination of Regulator Conflicts: A
request that EPA’s Office of Policy exert great influence on the program
offices to communicate among themselves during rulemaking about
potential regulatory conflicts or difficulties across regulations for
which they have responsibility.
The Institute of Scrap Recycling Industries, Inc. (ISRI)
is the "Voice of the Recycling Industry™." ISRI represents more than
1,300 companies in 21 chapters in the U.S. and 35 countries that
process, broker, and consume scrap commodities, including metals, paper,
plastics, glass, rubber, electronics, and textiles.
With headquarters in Washington, DC, the Institute provides education,
advocacy, safety and compliance training, and promotes public awareness
of the vital role recycling plays in the U.S. economy, global trade, the
environment and sustainable development.
Generating nearly $117 billion annually in U.S. economic activity, the
scrap recycling industry provides nearly half a million Americans with