In response to the U.S. Environmental Protection Agency's (EPA) notice on Evaluation of Existing Regulations, the Institute of Scrap Recycling Industries (ISRI) submitted comments identifying federal regulations that have negatively impeded the recycling industry. The EPA's call for public comment was in response to the Trump Administration's Executive Order "Enforcing the Regulatory Reform Agenda."
"Unnecessary regulatory burdens have long added to the cost of doing business for the recycling industry," said Robin Wiener, president of ISRI. "As the Voice of the Recycling Industry, ISRI advocates at all level of governments to relieve our members of red tape that hurts operational efficiencies and limit growth opportunities. In consultation with ISRI members we have made a number of key recommendations to EPA to reform current regulations and remove barriers for recyclers."
ISRI pointed to the following regulations in need of repeal, replacement, or modification:
- Subtitles C & D of the Resource Conservation and Recovery Act (RCRA): Modification to distinguish scrap commodities destined for recycling from waste destined for disposal.
- The Federal Multi-Sector General Permit developed pursuant to the Clean Water Act: Revision to account better for the unique characteristics of stormwater and to align benchmark monitoring better with the performance potential of control measures and wet-weather conditions.
- The refrigerant management regulations of the Clean Air Act: Revision to require removal of refrigerant from appliances and vehicles prior to delivery for recycling.
- The Chemical Data Reporting regulations pursuant to the Toxic Substances Control Act: Revision to eliminate the current reporting requirement for scrap metal imported for recycling.
- Elimination of Regulator Conflicts: A request that EPA's Office of Policy exert great influence on the program offices to communicate among themselves during rulemaking about potential regulatory conflicts or difficulties across regulations for which they have responsibility.
The full text of ISRI's comments, including detailed background information and explanations for each recommendation is available.
