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 (“shredders”). 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 regulated 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 residue.

A. Source Control Procedures for Shredder Facilities and Their Suppliers. 

Documented source control procedures will be implemented by shredder facilities to prevent the 

introduction of materials containing > 50 ppm PCBs (including, but not limited 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 accept 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 Compacted

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.

• Employee 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 prohibition 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 

shredder 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 additional 

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 supplied 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 that 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 

identified, 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 requirements. 

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 materials 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 materials containing > 50 ppm PCBs.
• Visual Inspections. 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 acceptance, 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 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.

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

identified, 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 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 using 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 control 

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 trigger 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 ppm (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 from 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 the date of their creation.

B. Output Control Procedures. 

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 applicable 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 provisions 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 oral 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. Maintain 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 any 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 and 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 to 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. 

• 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 receiving 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 information 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 Pennsylvania 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 recurrence of the event.