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 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.