Below are several questions frequently asked by automotive recyclers regarding environmental compliance issues. Click on the link to select a topic area or simply scroll down through the list of questions. 

General Compliance Topics
Enforcement Issues
Managing Hazardous Waste
Water Quality Issues
Specific Topics of Interest to Auto Recyclers

General Compliance Topics

I noticed that there are both federal and state regulations that impact my business. Which regulations do I need to follow?
The short answer is both. The U.S. Environmental Protection Agency (EPA) is the regulatory body that writes federal regulations to implement the laws made by Congress. In addition, each state has its own environmental regulatory agency that writes, implements and enforces state laws. In many cases, EPA will turn over to the states the power to interpret and enforce certain federal laws. These state agencies may make the federal requirements more demanding, but generally cannot make them less so. In addition to adhering to the rules that apply to your particular state, there also are instances when counties and townships develop their own laws. This website seeks to provide the federal and state requirements, but you should inquire whether any county or local regulations also may apply.

What is the ECAR Tour?
The ECAR Tour, which is the centerpiece of the ECAR Center, is a user-friendly, interactive tool that allows users to quickly access the environmental requirements that apply to more than 20 specific activities associated with auto recycling, such as the handling of used oil or management procedures for waste tires. ECARcenter.org includes a state-by-state listing of such requirements for each state.  

How can I get more compliance assistance information beyond this site?
There are numerous resources to help automotive recyclers stay in compliance with federal and state environmental laws. The Automotive Recyclers Association (ARA) is the national trade association representing the professional automotive recycling industry and is the first place to research more compliance assistance information. Beyond ARA, there are more than 30 ARA state affiliate chapters, as well as several industry consultants and educational programs. The federal EPA and the state environmental agencies maintain comprehensive websites that are easily navigated for more information. 

Enforcement Issues

What will happen if my company is found to not be in compliance with federal or state regulations?
There is little doubt that the federal and state environmental agencies are focusing their attention to automotive recycling facilities and salvage yards. Rightly or wrongly, they have targeted the industry for increased enforcement in the coming years. This site, which is a partnership between the Automotive Recyclers Association (ARA), the National Center for Manufacturing Sciences and EPA, is designed to provide information to help auto recyclers comply with environmental regulations. Users of the site will in no way be at greater risk for enforcement, but non-users may lack important information that would otherwise keep them out of trouble. 

I try to follow the state and federal rules, but it's frustrating when I see other companies that don't. What should I do?
ECAR Center is an environmental compliance assistance website, as opposed to an enforcement website. The mission of the site is to provide automotive recyclers throughout the country with useful and up-to-date information that will better equip them to comply with federal and state environmental rules. EPA does not monitor who visits the website. If you know of auto dismantlers that could benefit from the information in this site, please encourage them to visit the website. The industry has suffered from a poor stigma even though its contributions to society are immeasurable. Every dismantler should strive for 100 percent compliance with all laws and regulations. EPA is fining and jailing those that intentionally ignore their responsibilities.

Managing Hazardous Waste

What does RCRA stand for and how does it regulate my business?
RCRA, or the Resource Conservation and Recovery Act, is the law under which EPA regulates all solid and hazardous waste. RCRA's goals are to: protect the environment from the hazards of waste disposal; conserve energy and natural resources by recycling and recovery; reduce or eliminate waste; and clean up waste which may have spilled, leaked, or been improperly disposed. Congress created RCRA to serve as a "cradle to grave" regulation of hazardous waste. As an auto recycler, there are many requirements that you must follow under the RCRA umbrella. For more information, visit the ECAR Center's RCRA/Hazardous Waste Resource Locator.

What is a waste manifest?
A waste manifest or manifest system is a set of forms, reports, and procedures designed to seamlessly track hazardous waste from the time it leaves the generator facility where it was produced, until it reaches the off-site waste management facility that will store, treat, or dispose of the hazardous waste. The system allows the waste generator to verify that its waste has been properly delivered, and that no waste has been lost or unaccounted for in the process. In other words, a manifest tracks and documents hazardous wastes from the cradle to the grave. Many recyclers are waste generators even though they didn't actually manufacture the waste. However, at the point at which a product ceases to be used for its intended purpose, more or less, it can become a waste. Mercury from mercury switches is one example.

How do hazardous wastes need to be handled differently than regular solid wastes?
The hazardous waste regulations vary slightly by state. However, if you are managing the waste as hazardous, here are some of the general rules: 
  -You can only store the waste for a limited time on your site before sending it to an approved hazardous waste facility. (The time limit will depend on how much hazardous waste you generate.)
  -You have to use a licensed waste hauler to transport the waste off your site. 
  -You have to keep a record (called a "shipping manifest") of the shipment for a specified  period of time.
For more information, visit the ECAR RCRA/Hazardous Waste Resource Locator.

Where can I find a list of materials that are considered hazardous wastes?
As an auto recycler, your business is almost certainly subject to hazardous waste regulations. "Hazardous waste" is a legal term that describes certain toxic, ignitable, corrosive, or reactive wastes generated in manufacturing, industrial, or other processes. EPA has prepared a simple guidance document to explain hazardous wastes and help you determine whether you generate hazardous wastes and are subject to regulation. Your company is responsible for handling correctly all hazardous waste. The hazardous waste regulations also can be found in Title 40 of the Code of Federal Regulations (CFR) Part 261-299.

What is a "universal waste" and how are the universal waste requirements different from other hazardous waste rules?
"Universal wastes" are certain dangerous wastes that are frequently generated, and that can be managed appropriately under less stringent regulatory requirements than those that would apply to certain other hazardous wastes. EPA and the states want to encourage recycling of these wastes so the universal waste requirements are less demanding. The designation of "universal wastes" vary from state to state. In many states, spent lead-acid batteries fall into this category, as do spent fluorescent lamps. The key differences in the management of universal wastes versus hazardous wastes are: accumulation time limits, reporting requirements, and manifest tracking. 

Water Quality Issues

What is the difference between stormwater, groundwater, and wastewater?
Stormwater is water from rainstorms and melting snow . When stormwater comes in contact with materials such as oils, gas, heavy metals, and solvents, it can become significantly contaminated. This contaminated stormwater leads to surface and groundwater contamination. Groundwater lies beneath the land surface. This water is an important natural resource and is used for many purposes, including drinking water. Half the water used in the U. S. for drinking water comes from groundwater. Groundwater may become surface water through springs or other such conveyances. Wastewater can be defined in two ways. "Sanitary wastewater" includes the water coming from lavatories/washrooms, showers, drinking fountains, etc. "Industrial wastewater" includes the water from floor drains in dismantling areas, discharges from aqueous cleaning, water from steam cleaning or equipment wash down, water used for floor cleanup in dismantling areas (e.g., mop water), or water from any other sources where it comes into contact with dismantled parts or equipment. Wastewater essentially is any water other than stormwater that comes into contact with auto recycling operations. Wastewater and stormwater are subject to different permit requirements.

Can I discharge wastewater to a body of water, such as a stream or lake?
In some states, this is permitted, but you will need a National Pollutant Discharge Elimination System (NPDES) permit. You cannot discharge hazardous wastes into any stream, lake, river, pond or wetland. If you obtain an NPDES permit, you may be required to frequently collect samples of your wastewater and have them analyzed at a laboratory. You will also have reporting and recordkeeping responsibilities. In no case can you discharge pollutants that would contribute to or cause an adverse impact on the receiving stream. In some cases, this means that you would be prohibited from discharging even very minute quantities of pollutants (in the parts per trillion range).

What is a Stormwater Pollution Prevention Plan (SWPPP) and how do I go about creating one?
To comply with federal and state stormwater requirements, and to obtain a National Pollutant Discharge Elimination System (NPDES) stormwater permit, automotive recycling facilities must prepare a Stormwater Pollution Prevention Plan (SWPPP). The plan must be updated regularly and maintained on-site. The components that must be included in your SWPPP are outlined in the ECAR Stormwater Pollution Prevention Plan Fact Sheet. 

Specific Issues of Interest to Auto Recyclers

What do I do in the event of a chemical or oil spill?
There are five basic steps in the event of spill. You must: (1) stop the release; (2) contain the released material; (3) clean up and properly manage the released material; (4) if necessary, repair or replace any leaking storage containers or tanks prior to returning them to service; and (5) if necessary, notify your state environmental regulatory agency. Nearly every state maintains a 24-hour emergency hotline, which should be utilized in the event of certain spills. Some states require that they be notified within a specific time frame, so check with your state agency before a spill occurs. The list of hazardous materials and their reporting thresholds can be found at 40 CFR Parts 110, 117, and 302.

What is an SIC Code and what would be my company's code if I operate an automotive recycling facility?
An SIC Code, or Standard Industrial Classification, is the 4-digit code that represents the economic activity of a company. Most users of ECAR Center, including salvage yard operators, auto recyclers and auto dismantlers, would fall under SIC code 5015. According to EPA's list of classifications, this code is described as "motor vehicle parts, used." Your SIC code is a particularly important factor in determining whether you need to have a stormwater permit. With rare exceptions, businesses that fall under the 5015 code are required to obtain a stormwater permit. In addition to using SIC codes to identify regulated activities, many regulations include narrative descriptions of those regulated activities. If the narrative description applies to your operations even though you may use a different SIC code, your operations most likely are regulated.

I've heard a lot in the news about mercury. What car parts contain mercury and how do I handle them?
Mercury, a highly toxic metal, is often found in hood or trunk light switches. It also can be found in anti-lock braking systems, active ride control or ride leveling sensors, high intensity discharge systems (headlights, tail lamps), and in virtual image instrument panels. Liquid mercury and mercury vapor are hazardous to both humans and the environment. Once released into the environment, mercury cannot be eliminated - it will stay in the environment forever. Removal of mercury switches from vehicles before crushing is an important part of managing your hazardous wastes. Failure to do so can be a violation of the law. See any of the state ECAR fact sheets for more information on handling mercury. 

Should I deflate a car's air bag(s) before dismantling?
No. You should remove all unused air bags before the vehicle is scrapped or sent to a shredder. These unused air bags can then be resold as recycled products. See www.airbagresources.com and ARA's Guidelines for Use of OEM Non-Deployed Airbags.

I have heard about the Automotive Recyclers Association's CAR and Gold Seal programs. How do these relate to the information contained in this site?
ARA's CAR program was created to produce a set of standards for general business practices as well as environmental and safety issues and to provide guidance for member facilities in adhering to these standards. This program is one of the cornerstones of the association as the facilities participating strive to put forward quality service and parts for the professional automotive recycling industry. The ARA Gold Seal program, available only to those ARA members who have completed CAR certification, ensures excellence in customer satisfaction through improved customer service, quality parts with accurate descriptions, reliable on-time deliveries and written product warranties. Established by ARA with an endorsement from the Automotive Service Association (ASA), the program allows recyclers to join forces to take a proactive stance to improve quality and increase customer satisfaction. While only ARA members are eligible to participate in the CAR and Gold Seal programs, ARA has designed this website to be accessible to everyone in the industry. 100 % compliance is the association's goal.