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Important Update on New EPA Airbag Rule


S


ince the Environmental Protection Agency (EPA) released a rule (effective November 30, 2018) providing a condi- tional exemption for “dealerships, salvage yards and other locations” from some hazardous waste regulations allowing for a “more expedited removal of defective Takata airbag inflators,” ARA has con- tinued to research the issue for further clarification on its impact for automotive recyclers. There is a comment period on the new rule and EPA will determine if any further revisions are needed. The agency tentatively plans to publish a “final” final rule by September 2019.


While auto service centers look to benefit the most from the rule, effective November 30, 2018, automotive recyclers should be covered by an exemption that clarifies who is a “generator” of hazardous waste, i.e., the rule exempts salvage operators who removes defective airbags and sends them to a proper facility for processing. Recy- clers and “affected entities” will be allowed to send defective airbags and airbag parts to certified disposal facilities that handle hazardous waste under the Resource Con- servation and Recovery Act (RCRA). These facilities will be considered the “generator” of hazardous waste, not the recycler.


Some conditions do exist and have to be adhered to by the automotive recycler who is required to handle the airbag safety. EPA specifies:


“Conditions of exemption are mod- eled after current industry practices and are designed to ensure that the exempted airbag waste is managed safely and is appropriately destroyed and not diverted back into vehicles. The conditions for the airbag waste handler are: • Maximum 250 discarded airbag mod- ules or airbag inflators stored at the airbag handler


• Storage time limit of 180 days • Packaged and shipped in a container designed to address risk posed by inflator


• Container labeled “Airbag Waste – Do Not Reuse”


• Maintain shipping records and con- firmation of receipt for 3 years (ordi- nary business records such as bills of lading are sufficient; electronic records acceptable) The EPA has stated that it will work with states on implementing the rule because some state requirements may be more strin- gent than the federal requirements. How- ever, “EPA encourages the states to follow the federal requirements for airbag waste in order to help facilitate the airbag recall.”


I New ARA Position Statement on OEM Repair Procedures I


n light of continuing and growing concerns regarding OEM repair procedures, ARA developed a position statement on this issue to be used by all recyclers as needed. The position statement states: ARA supports that industry standards for automotive repairs should be well defined as to the process necessary to assure the vehicle is returned to pre-loss condition as closely as possible. ARA does not support repair procedures that disallow the usage of OEM


recycled parts or denies the consumer choice of what parts are used in the repair of their vehicles. To view all of ARA’s position statements, please contact the ARA office.


12 // March-April 2019


n January 2019, members of the Auto Recyclers North East (ARNE) Planning Committee held a Kick-Off Meeting at the ARANY Office in Albany, New York. ARNE is partnering with PRP-NE this year to bring even more opportunities to our attendees! This collaborative and high impact show is taking place September 26-28, 2019 in Albany, New York. Save the Date!


IRT Comes to Norfolk, UK T


he International Roundtable on Automotive Recycling (IRT) will take place in Wymondham,


Norfolk, UK on May 22-25. The 3-day conference gives the opportunity to meet with auto recyclers from all over the world to discuss issues within the global industry. Download the IRT Brochure at http://irt-autorecycling.org/ norfolk-england-2019 or contact Andy Latham at andy@salvagewire.com.


Automotive Recycling


In the Mail! You should have received your 2019 ARA Membership Directory. Please take a minute to look at your state to see who is a fellow member! Then notice who isn’t! Why not reach out to a non-


member in your region about ARA Membership? Help the ARA represent the entire industry of auto recyclers – the numbers matter!


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