Recycling - Yes! / Toxic Waste - No!

Recycling saves energy and natural resources, but it is essential that the process of resource recovery not leave a toxic hotspot for the next generation to clean up. Efforts to recover everything that can be used or recycled deserve full support, but automobile manufacturers must adopt clean production strategies that eliminate all toxics from cars.

Automobile Recycling

Nationally, the United States scraps ten million cars each year. These automobiles, along with 20 million consumer applicances, are shredded and valuable ferrous metals (steel) are recovered and recycled into new products.¹ The non-ferrous residue that remains is termed "auto shredder residue" (ASR) and commonly referred to as "auto fluff". Each year in the United States, auto shredders are left with approximately five million tons of "fluff".²

Is Fluff a Hazardous Waste?

Many hazardous chemicals are used in the manufacturing and maintenance of automobiles. A review of ASR auto fluff by the Ecology Center in Michigan (www.ecocenter.org) found several toxic contaminants in fluff.³ Studies by the German EPA and the U.S. EPA report that auto fluff contains mercury, lead, cadmium, chromium, arsenic, polyvinyl chloride, and PCBs. The state of California considers auto fluff a hazardous waste requiring special disposal.⁴

Landfill Tests of Auto Fluff Allow Hazardous Waste Dumping

The U.S. Environmental Protection Agency's landfill test for hazardous wastes is inadequate and does not protect public health. The EPA test for hazardous waste is called the Toxic Characteristic Leaching Procedure (TCLP). Of the hundreds of hazardous chemicals in industrial use, the TCLP looks for only 43 to determine if the waste is toxic.⁵ So in most states toxic auto fluff can legally be dumped at local solid waste landfills.⁶

The Problem with Mercury in Cars

American automakers use mercury switches in convenience lighting and anti-lock brake systems. Few of these switches are removed before the automobile scrapping process begins. The result is huge amounts of mercury released to the environment at different stages of the recycling process. Most of the release occurs at electric arc furnace operations but some find its way into the fluff. Once it is landfilled, mercury in fluff can leach out with rainwater, be released with contaminated landfill gas, or be dispersed in a landfill fire.⁷ Scrapped vehicles represent a major waste stream in the United States. But American automakers continue to use mercury switches 10 years after European companies switched.⁸ The United States should follow the example of successful European companies.

Fluff Fires?

An EPA study of emissions from fires at ASR landfills and stockpiles, prompted by a 38 day fire at a Shredded Products fire in Montvale, VA, noted: "A number of these stockpiles have caught fire, resulting in the emission of numerous air pollutants." This study concluded that, "substantial quantities of air pollutants are emitted." and "cadmium, copper, lead and zinc were found in significant quantities".⁹

We recommend the following steps to protect human health:

1. Remove all toxics from automobiles and appliances before shredding.

2. Put the responsibility for these materials on the manufacturers. If the waste is hazardous, require long-term management in a permitted hazardous waste facility.

3. Expand the test for hazardous waste to cover all of the toxics, not just a few. Landfill only that material that is truly inert.

4. Require adequate bonding for any future treatment. As research on toxics in the environment develops, additional actions to treat ASR waste may be necessary. Future owners of any landfill site should have access to the resources required to protect public health and the environment.

5. Choose safe alternatives. Toxics in products don't just happen - they are manufactured. Clean production and extended producer responsibility will shift the burden for all toxics back to the manufacturer for long-term solutions.

Auto fluff should be assumed hazardous until it is proven harmless.

Footnotes:

¹ EPA Office of Solid Waste letter from Sylvia K. Lowrance to the Japanese Office of Marine Pollution Control & Waste Management, March 5, 1993.

² Argonne Labs bulk separation of ASR project licensed to Salyp N.V. of Belgium, http://www.es.anl.gov/Process Engineering/Technologies/Documents/3-ASR_2003.PDF

³ The Ecology Center, www.mcats.org/holcim.html

⁴ Mercury in Cars, www.cleancarcampaign.org/pdf/toxicsinvehicles_mercury.pdf

⁵Blue Ridge Environmental Defense League TCLP fact sheet, www.bredl.org/solidwaste/TCLP_hazwaste.html

⁶WMI Testing Guidance, www.highacreslandfill.com/Testing Requirements.html

⁷Mercury in Cars, www.cleancarcampaign.org/pdf/toxicsinvehicles_mercury.pdf

⁸Mercury in Cars, www.cleancarcampaign.org/pdf/toxicsinvehicles_mercury.pdf

⁹ EPA Abstract "Characterization of Emissions from the Simulated open-burning of Non-Metallic Automobile Shredder Residue", prepared by Jeffrey V. Ryan and Christopher C. Lutes, Acurex Environmental Corporation.