There is absolutely no need for DTSC’s proposal to regulate scrap metal as hazardous waste. For more than 40 years, the scrap metal industry has operated safely under the existing regulatory oversight of local government. All of DTSC’s alleged concerns are already being addressed by the industry and local agencies.


A number of government entities already regulate metal shredders:

    • The Regional Water Quality Control Boards
    • CARB / Regional Air Quality Management and Air Pollution Control Districts
    • Regional and Local Fire Districts
    • Certified Unified Program Agencies
    • Cal-OSHA
    • DTSC
    • Shredder facilities are subject to either the General Industrial Stormwater Permit or have obtained individual permits to discharge to the local sanitary sewer or publicly owned treatment works or to surface waters.
    • Shredding facilities are required to develop and maintain Storm Water Pollution Prevention Plans (SWPPP) that are subject to review and enforcement by the Water Boards.
    • In addition, local municipalities and NGOs have enforcement rights under the Clean Water Act.

The regional air boards issue permits and place limits on emissions from shredder facilities including dust, VOC’s, and particulate matter.

Each community has a fire code enforced by the local fire department. Fire departments inspect scrap metal businesses and provide training

Hazardous materials are regulated by the local Unified Program Agency that provide inspections and enforcement.

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