Voluntary Procedures for Recycling Plastics from Shredder Residue

The Institute of Scrap Recycling Industries (ISRI), in consultation with EPA, has developed a set of voluntary procedures related to separating and recycling plastic materials from shredder residue (“residue”) generated by metals recycling facilities (“shr edders”). Where the entities involved in a plastic recycling stream are all following the applicable portions of these procedures, verified as directed below by a qualified, independent third party, these procedures can prevent the introduction of PCBs reg ulated for disposal into the recycled plastics. These procedures include development and implementation of a documented materials management system by using: (1) documented source control programs aimed at preventing the introduction of PCBs regulated

for disposal into the shredder feedstock materials that contribute to any shredder residue from which plastics will be recovered for recycling; and (2) documented output control programs for facilities processing/producing/recycling plastics from shredder res idue.

A. Source Control Procedures for Shredder Facilities and Their Suppliers

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Documented source control procedures will be implemented by shredder facilities to prevent the introduction of materials containing > 50 ppm PCBs (including, but not limite d to, small capacitors and light ballasts containing > 50 ppm PCBs and non

- liquid materials containing > 50 ppm PCBs (e.g., PCB

- containing caulk) to any shredder residue from which plastics will be recovered for recycling. As noted below, shredders will ac cept compacted feedstock materials from suppliers only if the supplier also implements documented source control procedures as described below. A shredder’s procedures will include provisions for:

Feedstock: Not Baled, Logged or Otherwise Comparably Comp acted Shredder facilities accepting feedstock that is not baled, logged or otherwise comparably compacted will:

• Post Signage . Post signage at the accepting facility describing the prohibition against accepting any materials containing > 50 ppm PCBs.

• Empl oyee Training . Ensure all employees involved in receiving, inspecting or movement of feedstock materials prior to shredding operations are trained to be aware of, identify, and, for designated employees, remove prohibited items and materials. All employees responsible for any of these procedures will be trained and made aware of such responsibilities, with refresher training provided annually.

• Informational Materials . Provide handouts at the entrance to the accepting facility or the scale describing the pr ohibition against accepting any materials containing > 50 ppm PCBs to suppliers of feedstock that is not baled, logged or otherwise comparably compacted.• Conditions for Accepting Materials . Only accept scrap that can be effectively inspected at the

shred der facility without using additional equipment to pry apart or disassemble (e.g., crushed, baled, logged or otherwise comparably compacted material that cannot be visually inspected will not be accepted under these provisions). Shredders may also use addi tional measures to ensure that materials that may contain > 50 ppm PCBs are not in the feedstock,

such as:

o The shredder facility has an established program or policies to provide incentives (e.g., “bounties”) for suppliers to identify and remove from supp lied materials any articles or other materials that may contain > 50 ppm PCBs.

OR

o The shredder facility requires the suppliers to provide a certification for each delivery that they are aware of the prohibition and that the materials they supply do not

contain PCBs at concentrations > 50 ppm. Suppliers that make multiple deliveries in

a year may provide a contractual certification with first delivery in a calendar year that covers all of the subsequent deliveries for that calendar year.

• Visual Inspection . Have properly trained individual conduct visual inspections of all loads of

scrap t hat is not baled, logged or otherwise comparably compacted brought into the facility before acceptance for articles or other materials that may contain > 50 ppm PCBs.

• Prohibited Items . If any articles or other materials that may contain > 50 ppm PCBs are

i dentified, then the facility will either reject the load that included such articles or materials, or, separate such prohibited articles or other materials from the load and properly manage and dispose of them in accordance with all applicable regulatory r equirements.

Feedstock: Baled, Logged or Otherwise Comparably Compacted Shredder facilities accepting feedstock from all suppliers of baled, logged or otherwise comparably compacted feedstock that cannot be effectively inspected without being pried apart
will:

• Post Signage . Post signage at the accepting facility describing the prohibition against accepting any materials containing > 50 ppm PCBs.

• Employee Training . Ensure all employees involved in receiving, inspecting or movement of

feedstock mater ials prior to shredding operations will be trained to be aware of, identify, and, for designated employees, remove prohibited items and materials. All employees responsible for any of these procedures will be trained and made aware of such responsibilities , with refresher training provided annually.

• Informational Materials . Provide awareness or educational materials to suppliers of these feedstock materials regarding the potential presence of PCBs in various materials and the prohibition against such materi als containing > 50 ppm PCBs.• Visual Inspection s . Conduct periodic visual inspections, by a trained individual, of compacted scrap from all suppliers brought into the facility for articles or other materials that may contain > 50 ppm PCBs before acceptan ce, unless:

o The shredder facility has an established program or policies to provide incentives (e.g., “bounties”) for suppliers to identify and remove from supplied materials any articles or other materials that may contain > 50 ppm PCBs.

OR

o The shredd er facility requires the suppliers to provide a certification for each delivery that they are aware of the prohibition and that the materials they supply do not

contain PCBs at concentrations > 50 ppm. Suppliers that make multiple deliveries in

a year may provide a contractual certification with first delivery in a calendar year that covers all of the subsequent deliveries for that calendar year.

• Prohibited Items . If any articles or other materials that may contain > 50 ppm PCBs are identified, then the fac ility will either reject the load that included such articles or materials, or separate such prohibited articles or other materials from the load and properly manage and dispose of them in accordance with all applicable regulatory requirements.

• Additional Conditions for Accepting Compacted Materials from Suppliers Using Mechanical Methods of Compacting, Baling or Logging . Only accept compacted feedstock (baled, logged or otherwise comparably compacted material that cannot be visually inspected

without usin g additional equipment to pry apart or disassemble) from suppliers using mechanical methods of compacting, baling or logging that have a signed contract with the shredder facility that stipulates: (1) that the supplier implements a documented source contro l program that includes visual inspection of all material prior to compaction/baling to ensure that the materials that they supply do not contain PCBs at concentrations > 50 ppm; (2) provides clear written notice that their mechanically compacted, baled or logged feedstock materials may be used for plastics recycling, and emphasize the importance of conforming to the required documented source control program; (3) provides written notice that the presence of PCBs at > 10 ppm in the recycled plastics will tr igger an investigation to determine the source of such PCBs; and (4) requires such suppliers to provide a certification for each delivery that they are aware of the prohibition and that the materials they supply do

not contain PCBs at concentrations > 50 p pm (such suppliers that make multiple deliveries in a year may provide a contractual certification with first delivery in a calendar year that covers all of the subsequent deliveries for that calendar year).

Other Provisions for Documenting and Verifying Source Control Procedures

• Preventive and Corrective Action . Each facility’s documented voluntary procedures will include conducting periodic (at least annual) internal audits on the adequacy and effectiveness, including the facility’s performance, of those procedures, and promptly correcting any deficiencies that are detected.

• Records . Each facility will maintain and make available records that document the facility’s implementation of each element of the voluntary procedures described above. The facility will retain these records for a minimum of five years f rom the date of their creation.• Third Party Certification . Each shredder will have its implementation of these voluntary procedures reviewed and verified by a qualified, independent, professional third party (using the criteria set forth in this procedure) before beginning such operations and annually

thereafter. Annual third party verification will include both review of the program documentation and onsite inspection/observation of the program being implemented. Any deficiencies detected by such third party will be promptly corrected and verified by the third party evaluator. Shredders will maintain and make available records of the results of all such audits, including all deficiencies and related corrective actions, for a minimum of five years

from th e date of their creation.

B. Output Control Procedures

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Shredders Shredders following this process will only provide residue to a plastic processer/producer/recycler if the sales (or other) contract states that both parties are following all applica ble provisions of these voluntary procedures.

Plastic Recyclers Plastic processers/producers/recyclers, including shredders who recycle their own residue, will as part of their documented output control procedures:

• Contractual Provisions . Include pro visions in sales contracts for any plastics containing recycled material separated from residue expressly stating that such plastics may contain PCBs and are not suitable for use in the manufacture of toys, food or drink containers, or any products with or al applications (e.g., toothbrushes). In addition to the contract, plastic recyclers may also use material specifications, labeling, or other means that will effectively communicate this particular limitation to their customers.

• Maintaining Records . Maint ain and make available records of all sales of plastics produced with any material separated from shredder residue, including: the identity of the customer; the volume and category of the plastics sold; the applicable contract provision;

documentation of a ny supplemental methods, if used, of communicating to the customer the limitation on the plastics’ suitability; and the date of sale. These records will be maintained for a minimum of five years from the date of their creation.• Monitoring Plan . Establish and follow a documented plan for sampling and analyzing for total PCBs in the final recycled materials intended for distribution in commerce. Such plan will include the following provisions:

o Establish the number of samples that will be analyzed: For every facility, a minimum of one composite sample of each type of plastic for every 2,000 tons of plastic recovered, or a composite sample of each type every 90 days, whichever occurs first.

o Specify appropriate sample collection procedures (i.e., where, when an d how the samples will be taken and composited).

o Sample Preparation and Analysis . Plastic samples (no less than 30 g per sample) will be ground, sheared or otherwise reduced in size prior to extraction of PCBs. The extraction procedure shall be according t o EPA SW

- 846 Method 3550C. Cleanup steps should be taken to reduce the interference of phthalates in the analysis. PCB concentrations shall be measured on all samples by certified laboratories using EPA

SW

- 846 Method 8082A

– Polychlorinated Biphenyls (PCBs ) By Gas Chromatography and reported as both Total and Aroclor concentrations

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• Response to Monitoring Results . If the results of analysis for any monitoring sample indicate the presence of > 10 ppm total PCBs, the facility will, within 30 days of receivin g such data, send those results (including a copy of laboratory data) to EPA at: Director, National Program Chemicals Division, Environmental Protection Agency, 1200 Pennsylvania Avenue, N.W., Washington, DC 20460

- 0001. All submissions that contain informa tion claimed as Confidential Business Information (CBI) must clearly be marked as such. CBI must be

mailed or hand

- delivered to: Document Control Office (7407M), Office of Pollution Prevention and Toxics (OPPT), Environmental Protection Agency, 1200 Pennsy lvania Ave., N.W., Washington, DC 20460

- 0001. To arrange deliveries, contact the Document Control Office at (202) 564

- 8930. In addition to notifying EPA, the facility will notify all shredders which contributed plastic feedstock processed in that sampling period. Upon obtaining such data, both the shredder and the plastic recycler will review their operations and practices to determine if the cause of such results can be identified, and improve their operations and practices as appropriate to prevent recurr ence of the event.