California Withdraws Emergency Regulation That Would Cause Metal Shredders to Become Managers of Hazardous Waste
In September, ARA worked with industry stakeholders such as the State of California Auto Dismantlers Association (SCADA), LKQ Corporation, and CA Metal Recyclers Coalition to provide comments on a California Department of Toxic Substances Control (DTSC) proposed emergency regulation that would negatively affect the ability for metal shredders to operate in the state of California. The proposed emergency regulation was set to make two changes to existing California regulations, including redefining how California regulators defined the term “scrap metal” by aligning the state’s definition of scrap metal with that of the U.S. Environmental Protection Agency. The second change would have caused California’s metal shredders to be classified as managers of hazardous waste.
ARA’s comments opposing the changes are available on the ARA website and clarified to the DTSC that “motor vehicles, motor vehicle parts and components are not waste material and in no way should be classified as hazardous waste.” Additionally, ARA explained that should metal shredders be classified as hazardous waste managers, California’s entire recycling industry will be potentially disrupted. The proposed regulations have been withdrawn but had the DTSC’s emergency regulation been implemented, it would have increased costs to metal shredders in their disposal of metal shredding residue and subsequently the value of vehicle hulks sold to shredders by automotive recyclers. The proposed regulation could have impacted automotive recyclers’ operations and processing of vehicles. It is expected that the DTSC will try and implement the same rule through a formal rulemaking process and ARA will continue to monitor this important issue.
Don’t Miss Out on New Totaled Treasure!
We are launching new episodes every week on ARA’s YouTube Channel, Totaled Treasure, and we don’t want you to miss out on all the fun and finds! Join the email list to stay up to date, it's fun and pretty easy. Join Totaled Treasure here: https://totaledtreasure.com/subscribe.
Totaled Treasure tells the story of the journey and experiences of ARA’s Vince Edivan and film producer Aaron Stone as they travel the country, visiting professional auto recycling facilities and searching through the vehicles to see what they can find. At each stop, Vince and Aaron introduce a new recycler, their team, their story, and often their family to the viewers. It’s just one of the great ways we at the ARA are working to spread the word about our incredible industry.
Through storytelling, and a healthy dose of laughs, Totaled Treasure takes the viewer on a journey to have fun, find cool stuff, and learn about the people, places, and incredible value of the automotive recycling industry. So spread the word!
WELCOME NEW AND RETURNING MEMBERS
Ace Iron and Metal
Allied Auto Wrecking
AllPro Auto Parts
ATC Auto Salvage, LLC
Brevard Capital Group, Inc.
Erie Vo-Vo, Inc.
European Metal Recycling (EMR)
Graveyard Pick N Pull
Helman Auto Parts
Jackson Auto Salvage
KBI: Kinsbursky Brothers Intl.
Matt's Used Auto Parts
Peak Auto Auctions
Prestige Auto & Metal Recycling
Ready To Start Auto Parts, LLC
(India Affiliate Chapter)
San Diego County Auto Recyclers Assn. (SDCARA)
Vallett Auto Group, LLC
Wilken and Sons, Inc.
YS Catalytic Recycling
ARA’s Education and Advocacy Campaign is Working to Protect the Interest of Members and Their Use of EPA-Compliant Used OEM Catalytic Converters as Replacement Parts
Since its inception in 1943, the Automotive Recyclers Association (ARA) has represented professional automotive recyclers who provide motor vehicle owners with the ability to choose ROE – Recycled Original Equipment® motor vehicle replacement parts.
ARA is guided by a foundational principle to protect automotive recyclers’ ability to sell vehicle repair parts that are safe for reuse. Therefore, ARA takes every effort to encourage, promote, and expand the opportunities for professional automotive recyclers to provide safe and effective automotive replacement parts for vehicle repairs. The need to protect the automotive recycler’s ability to sell legitimately acquired vehicle parts is becoming ever more important today with catalytic converters, EV batteries, and other new emerging technologies.
The most recent example of ARA’s work protecting the interest of its members has been to combat efforts to eliminate the ability for its members to sell used OEM catalytic converters as replacement parts. Over the past year, ARA has been tracking 48 pieces of legislation dealing with catalytic converter theft in 23 states. Parties have repeatedly and incorrectly claimed that federal law prohibits any used OEM catalytic converter to be used as a replacement part. While four states place some restrictions on the use of EPA-Compliant Used OEM Catalytic Converters as replacement parts, most states solely rely on EPA guidance.
ARA conducted a thorough review of federal and state laws and has begun an education and advocacy campaign in the states to show that the U.S. Environmental Protection Agency (EPA) has a longstanding policy endorsing the use of EPA-Compliant Used OEM Catalytic Converters as replacement parts. Furthermore, the EPA recognizes the economic and environmental value in providing vehicle owners with the ability to purchase EPA-Compliant Used OEM Catalytic Converters as a “less expensive” means of affecting repairs. It is important to note however, that while the EPA endorses the use of EPA-Compliant Used OEM Catalytic Converters as replacement parts, their 1986 policy places requirements designed to ensure that the used OEM catalytic converter being resold is a properly functioning unit and EPA compliant.
Today, automotive recyclers most commonly sell detached catalytic converters for their Platinum Group Metal content due to the high price of precious metals. At this moment in time, it is often easier and quicker for automotive recyclers to benefit from the high prices of rhodium, palladium, and platinum and the convenience associated with selling processed catalytic converters directly to processors. However, the commodity price of a detached catalytic converter is directly tied to the manufacture of catalytic converters since globally 80% of the rhodium, 74% of the palladium, and 40% of the total platinum are consumed by the auto catalyst industry.
As vehicle manufacturers are actively committing to replace internal combustion engine vehicles with zero emission and electric vehicles that do not have catalytic converters, the demand for the precious metals contained in catalytic converters and their market price will fall dramatically.
Some automotive recyclers have come to the realization that in specific applications they are able to sell used catalytic converters as EPA-Compliant Used OEM Catalytic Converters for substantially more money than they would if the catalytic converter had been sold only for its precious metals. Furthermore, as the scrap metal value for the precious metals contained within catalytic converters declines, the economic value of selling catalytic converters for repairs will increase.
As a part of ARA’s commitment to work alongside law enforcement to fight catalytic converter and automotive theft, ARA was appointed to the International Association of Auto Theft Investigators’ (IAATI) Auto Theft Prevention Authority Sub Committee on Catalytic Converter Theft Prevention. ARA is the only party representing the automotive recycling industry on this Committee.
As the premiere national law enforcement organization focused on automotive theft and automotive related crimes, IAATI has produced a white paper on catalytic converter theft, a policy document, and model
legislation. In IAATI’s policy document and model legislation, IAATI recognizes the legal right and important need to be able to sell EPA-Compliant Used OEM Catalytic Converters as replacement parts (when not prohibited by state law). IAATI is also spearheading efforts to combat catalytic converter theft by coordinating a response from multiple segments of the automotive industry.
IAATI’s policy document includes six policy points for effective catalytic converter legislation:
1) Identify with certainty the person selling the catalytic converter;
2) Identify with certainty the vehicle from which the catalytic converter was removed;
3) Require a traceable payment and prohibit cash transactions;
4) Require records of catalytic converter transactions be maintained and made accessible to law enforcement upon request;
5) The penalty for not meeting the above requirements needs to be a sufficient deterrent.
6) The Environmental Protection Agency (or an equivalent official entity with appropriate jurisdiction) governs what specific catalytic converters can be sold in the market. If requirements 1 – 4 above are satisfied, theft is not considered an issue.
ARA is also interested in promoting other efforts for expanding opportunities for the sale of EPA-compliant catalytic converters by its members. As the situation continues to develop, ARA will keep its membership informed.
Join an ARA Volunteer Committee in 2022!
Are you looking for ways to further your interest in industry issues beyond the day-to-day operations? Do you want to become more involved in your Association and stay up-to-date on all that ARA is working on? We are looking for YOU!
Volunteering on one of ARA’s many committees is a great way to make your voice heard. Contact firstname.lastname@example.org for more information.
• Annual Convention Educational
• Programming Committee
• Certification Committee
• Government Affairs Committee
• Awareness Committee
• Interchange Committee
• Scholarship Foundation
• Automotive Recycling Training Institute – Coming in 2022!
ARA Government Affairs Committee (GAC) chair Slater Shroyer, Shroyer’s Auto Parts, recently sat down with ARA to explain the importance of the Government Affairs Committee and why he is involved. Slater explained that, “there is only one way to have your voice heard when it comes to the laws regulating our industry, and that is to get a seat at the table. Volunteering on the Government Affairs Committee is the best way to get that seat and we are always looking for people willing to contribute to those efforts. Member input is crucial as laws enacted at the federal, state or local level can have a direct and immediate impact on your business. As my friend and predecessor Norman Wright is fond of saying, ‘If you’re not at the table, you’re probably going to end up on the menu.’”
If the GAC is of interest, this upcoming year ARA anticipates seeing many issues that will impact automotive recyclers at the federal level and in state legislatures. Some of these issues include COVID-19 relief, right to repair, data access to motor vehicles, catalytic converter anti-theft initiatives, and OEM repair restrictions.
ARA’s Certification Committee chair, Shannon Nordstrom, VP/GM Nordstrom’s Automotive Inc., says about volunteering in ARA in general, “When I first started going to ARA conventions and meeting people, I had a desire to learn more. I heard about committees and asked, ‘How do I get involved?’ and found out how easy it was. I found myself gaining so much knowledge and met folks that have ended up being mentors and friends for life as we helped improve our great industry! Now, it would be hard to give back, as much as I gained, and I am proud to say together we have had an impact on many things!”
ARA Represents the Industry
ARA leadership and staff attended several industry meetings in the early fall, including the CIECA Connex Conference in Charlotte, North Carolina in September. ARA member Jeff Schroder, CEO of Car-Part.com, currently serves as Chair of CIECA and was a conference speaker. ARA affiliates in Arizona and New England also met for association events.
New ARA Virtual Facility Tour Series Launches
ARA University (arauniversity.org/facility-tours/) now hosts the newest installment of Virtual Facility Tours featuring ARA Member Nordstrom’s Automotive in Garrettson, South Dakota. Hosted by ARA Past President Jonathan Morrow and VP of Nordstrom’s, Shannon Nordstrom, they walk you through the entire operation. Get a glimpse into how one of the industry’s most progressive automotive recycling facility operates and how ARA’s Certification Program has been integral to Nordstrom’s success.
ARA’s Certified Automotive Recycler (CAR) program helps Nordstrom’s Automotive to be one of the premiere auto recycling facilities in the world. See how you can utilize this program to help your business operate safely, efficiently, and at the highest level possible.
Episode 1: Bidding, Purchasing, Grading, Inventory – See how the Nordstrom’s team conducts bidding, purchasing, grading, and inventorying of the vehicles they process.
Episode 2: Depolluting & Dismantling – See how the Nordstrom’s team depollutes and dismantles the vehicles that they process. They’ve designed an incredible system that ensures safety and efficiency.
Episode 3: Production Hub – See how the Nordstrom’s team checks and ensures the quality of the parts throughout the process and how certain tools are used to ensure the customer consistently gets the best quality part.
Episode 4: Shipping & Sales – See how the Nordstrom’s team streamlined the sales and shipping processes, how to save money on shipping, as well as techniques for sales and relationship building.