News, Trends & Reports from the Automotive Recyclers Association

Mar 1, 2023 | Industry

Establishing & Communicating ARA’s EV Battery Recycling Protocols

Cirba Solutions

I was recently asked to make a presentation to a group of electronic recycling contacts from state agencies in the upper Midwest (EPA Regions 5 and 7). As technology has developed,

they have been the ones that get the questions on end-of-life EV traction and hybrid batteries. They had some questions about how the auto recycling industry works, what happens with EV batteries and how our industry is engaged on the issue of EV batteries.  

I introduced them to the auto recycling industry and the work that auto recyclers have done for over a century to assure sustainable, carbon negative business practices that benefit not only consumers but the communities our industry serves.

I presented our high voltage vehicle dismantling protocol to point out that we first must be able to safely handle high voltage vehicles, the batteries and other high energy components in the vehicles. I explained that we have spent a lot of time developing training and resources for our members and the auto recycling industry and make it easily accessible on our training platform.

I also explained that we are working closely with many agencies and companies, including the manufacturers of the vehicles and batteries to assure that we have the latest information and resources available to handle, process and safely sell high voltage batteries and components into the proper and highest value marketplace available.

–Sandy Blalock, Executive Director

ARA’s Work on EV Batteries Continues as Association Presents to EPA

Electric battery vehicle policy has been a growing area of importance for ARA, as has reaching out to battery stakeholders to educate them about the automotive recycling industry’s critical role.  

Some of the agencies ARA has engaged with are the U.S. Department of Energy, the U.S. Environmental Protection Agency, the U.S. Department of Transportation, and the California Environmental Protection Agency. Throughout ARA’s work with government regulatory agencies, ARA has advocated for an end-of-life EV battery market that gives automotive recyclers the widest available opportunity to put EV batteries to their highest and best use while also receiving the highest and best value for their EV batteries.

Most recently, ARA Executive Director Sandy Blalock presented to a large group of EPA administrators in early January.

ARA has also developed educational and training resources that ARA has developed for its members and their employees over the past several years. For the most up-to-date resources, please visit ARA University (www.arauniversity.org).

Automotive Recyclers Association Updates Strategic Plan

The Automotive Recyclers Association (ARA) announced an update to the Association's Strategic Plan representing a direction that will guide current and future work. The plan was adopted by the ARA Board of Directors on March 8, 2023.

“2020 has been a game changer,” said ARA President, Shan Lathem. “During these challenging times and given the unprecedented impact that a global pandemic is having on all businesses and industries, the direction outlined in this Strategic Plan will help ARA continue to move forward. A lot of planning and strategic thought went into this document, designed to promote the professional automotive recyclers and their businesses for many years to come.”

ARA’s Strategic Plan is grounded in the Association’s mission to advance the automotive recycling industry and promote its beneficial effects on society. The Strategic Plan identifies four strategic initiatives that are the means through which ARA plans to translate its vision into practice. The strategic initiatives focus on strategic partnerships and branding, data, advocacy, and education/certification/compliance. Each of the four strategic initiatives outlines a series of objectives which describe how ARA plans to commit its resources and how future success will be measured.

“This plan is a representation of ARA as the eyes, ears and voice of the professional automotive recycling industry,” said ARA Executive Director, Sandy Blalock. “With the direction and guidance the Strategic Plan provides, and the support of our ARA volunteer leaders and members, I am confident that ARA is well equipped to meet any challenge that comes our way.”

ARA’s Interchange Committee Announces New Peer Interchange Program

For the past several months, the Association’s Interchange Committee has been working with the inventory management systems to identify the best method for capturing recycler-to-recycler part interchangeability information that doesn’t necessarily meet the criteria for traditional interchange information. For example, part modification or fitment information based on recyclers experiences.

A new Subcommittee has been established to collect and verify this type of peer feedback. The goal is to help recyclers make more sales outside of what is provided by interchange. Once information has been reviewed and verified, Checkmate and Hollander have agreed to incorporate this user feedback into their systems. Car-Part has also agreed to put this user feedback information on their website. More information will be forthcoming as this process rolls out and your volunteer leaders are excited about the value that this could bring to ARA member businesses.

To submit your interchange information, please send the following information to: ARAPI@a-r-a.org.

1. Interchange Numbers

2. User Notes (Please provide a description of what changes need to be made for this part to become interchangeable)

3. Your Contact Info

4. Photos (not required but greatly appreciated)

5. OEM Part Number (not required but greatly appreciated)

ARA State Legislative Update Calls Resume

Now that state legislatures have started convening for the 2023 legislative sessions, ARA has resumed its regular state legislative update calls hosted on Monday afternoons. The calls are open to all ARA members with an interest in state and national advocacy efforts on behalf of the recycled parts industry. The calls are an opportunity to share information, discuss strategy and resources with other automotive recyclers across the country and are provided as a member benefit.

As of early February, ARA was already tracking 92 pieces of legislation across 32 states. Issue areas include:

• 43 Catalytic Converter Bills

• 7 Titling/Branding Bills

• 7 Environmental Bills

• 5 Battery Bills

• 3 OEM Repair Procedure Bills

• 3 Odometer Disclosure Bills

• 2 Counterfeit Airbag Bills

• 1 Vehicle Telematics Bill

For more information, please contact Jessica Andrews (jessica@a-r-a.org) or Emil Nusbaum (emil@a-r-a.org).

Call for Presentations – Submit Your Session Idea for ARA’s 80th Annual Convention

The ARA Annual Convention Educational Programming Committee is now soliciting presentations for the 80th Annual Convention and Exposition, which will be held October 12-14 at the Sheraton Kansas City at Crown Center in Kansas City, Missouri.

ARA and the Annual Convention Educational Programming Committee aim to develop a strong, comprehensive educational program to appeal to the many aspects of the automotive recycling industry. The Committee strives to construct a rich program addressing the immediate needs of the professional automotive recycling community, as well as provide opportunities to discover and discuss upcoming trends, techniques, best practices, and issues.

Please submit your idea(s) using this form and submit to Jessica Andrews (Jessica@a-r-a.org) as soon as possible.

ARA Continues Work with CIECA

ARA has continued to work within CIECA to represent the recycled OEM parts market and ARA member businesses. As part of the Emerging Technology Committee, several new committees have been formed, including Artificial Intelligence (AI) and OEM Repair Procedures & Build Sheet Data Committees. Both have business messages that impact ROE parts ordering.

The newest committee was proposed by the Recycled Parts and Inventory Committee with the goal of advancing EV and hybrid battery recycling business messages and procedures. The new EV committee met March 1, 2023 and was chaired by ARA Past President and industry consultant Ginny Whelan, representing ARA, along with Jake Rodenroth of Lucid Motors. It will look at all data message aspects of the connected vehicles, EV technology and sustainable mobility, with a focus on safety and collision repairs that includes battery recycling standards.

EPA Publishes Enforcement Priorities Compliance Issues

Every four years, the U.S. Environmental Protection Agency (EPA) selects serious and widespread environmental problems as national initiatives to which it devotes resources where federal enforcement can make a difference. The primary objective of these initiatives is to protect human health and the environment by holding polluters accountable through enforcement and by assisting regulated entities to return to compliance.

The agency proposes continuing four of the six current national initiatives during the FY 2024-2027 cycle including retaining the emphasis on reducing significant noncompliance in the national pollutant discharge elimination system (NPDES) program. NPDES is commonly referred to as the Storm Water Program and generally administered at the state level.

Additionally, the EPA proposes addressing environmental justice concerns in all National Enforcement and Compliance Initiatives (NECIs) and to add two new NECIs on mitigating climate change and addressing PFAS pollution, for the 2024-2027 fiscal year cycle.

Stormwater Compliance

The CWA was amended in 1987 to establish a framework for regulating industrial storm water discharge under the National Pollutant Discharge Elimination System (NPDES) permit program based on their potential to contribute to storm water pollution from industrial activity.

Those industries identified by standard industrial classification (SIC) code include salvage activity. Automotive salvage activity typically uses SIC code 5015 for wholesale used automotive parts and is specifically named as Sector M by the US EPA under the industrial stormwater permit requirements.

Most states are authorized to implement the stormwater NPDES permitting program. EPA remains the permitting authority in a few states, territories, and on most land in Indian Country. See the list of state administrators at https://www.epa.gov/npdes/npdes-state-program-authority.

EPA issues all National Pollutant Discharge Elimination System (NPDES) or stormwater permits in Massachusetts, New Hampshire, New Mexico, District of Columbia, and U.S. territories (except Virgin Islands), and to certain federal facilities and on tribal lands.

Automotive salvage yards have particular concerns for adding pollutant to storm water runoff due to the sheer number of vehicles present in a yard at any given time.

Effective pollution prevention of these storm water pollutants is accomplished through choosing the most applicable Best Management Practice (BMP) as identified in the Storm Water Pollution Prevention Plan (SWPPP) developed as part of the storm water permit requirements.

In fact, the state permits are all very similar to each other and to the EPA permit rules like most other state laws authorized under a federal program.

What differs from state to state is generally the frequency of stormwater sampling, the number and type of parameters tested for in the analysis at the laboratory and the reporting of this information.

Recent US EPA inspection throughout the country have asked facilities to produce their sample data for the past three years and a copy of the Stormwater Pollution Prevention Plan (SWPPP).  The inspection goes much the same for a visit from the state agency with one notable difference, the EPA has been asking for copies of the quarterly site inspection logs as required at the federal level but only required to be done annually in some states.

Since state rules cannot be less stringent than the federal rule, automotive recyclers should all begin to conduct and log site inspections quarterly and keep the information with the SWPPP.

Sampling is another issue that has been impacted by EPA inspection in the states. The EPA prefers the pH to be field sampled using a pH meter and not the pH strips.  pH meters are inexpensive and easy to use. They are readily available through online retailers and in stores for about $15 as many pool owners use them.

Farm Industry and John Deere Set the Stage in Right to Repair Fight

On January 8, 2023, the American Farm Bureau Federation and John Deere signed a memorandum of understanding (MOU) that applies Right to Repair principles to John Deere manufactured farm equipment. The MOU is a voluntary agreement that gives farmers and independent repair facilities the ability to access software, tools, and data used in the repair of John Deere manufactured farm equipment.

John Deere meanwhile receives assurances that farmers will protect the intellectual property of the manufacturer and its copyrighted software and that modifications to farm equipment’s safety controls and emissions controls will not be modified.

It will be interesting to see how the conditions of the MOU are complied with by both farmers and John Deere and whether this agreement will make repair costs for farm equipment more affordable. While this agreement is not related to passenger vehicles, it does provide momentum for the movement and will hopefully encourage future Right to Repair initiatives for passenger vehicles.  

ARA is closely monitoring further action as the MOU is implemented as the Association has been working on Right to Repair for motor vehicle owners for many years. In Congress, ARA is working with industry groups to press for federal vehicle data access legislation introduced by Rep. Baird that would:

“(1) to protect vehicle owners’ ability to repair their vehicles with affordable repair parts at a repair shop of their choice; (2) to protect vehicle owners from original equipment manufacturers needlessly undermining a vehicle owner’s ability to fix their vehicle – thereby placing an artificial expiration on a vehicle owner’s primary method of transportation; and (3) to protect several industries that will otherwise be crippled by manufacturers’ withholding of critically important data.”  

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