![]() Substances that could be confused as scrap metal but are not scrap metal, according to the Lexology article RCRA Guidance: February 24th U.S. EPA informs that powders caused by the demolition or revision of scrap metal only meet the definition of scrap metal in 40 CFR 261.1 (c)(6) if the powder has agglomerated to create other types of scrap metal such as small bits or pieces of metal parts. Pictured above: metal shavings from typical machining processesĪ City and County of San Francisco Department of Public Health publication entitled Hazardous Waste Frequently Asked Questions says that metal workings, cuttings, shavings, or grindings with a diameter of more than 100 microns (about the diameter of a human hair) are considered to be scrap metal and are not hazardous waste. ![]() In accordance to 1.6(a)(3)(B), scrap metal, as defined in 0.10, is exempted from regulation under State law when recycled.” Pursuant to section 66260.10 of Title 22 of the California Code of Regulations (22 CCR), scrap metal means, “manufactured, solid metal objects and products all sorts of metal workings such as cuttings, trimmings, stampings, grindings, and shavings and or solid metal residues created from metal productions. The Scrap Metal Recycling article describes how California defines scrap metal differently than does the Environmental Protection Agency (EPA). DTSC points out that it is important to follow federal law, but it is also important to follow state law-especially in California where it is more stringent. Under state regulations, the hazardous waste control law is more demanding and has a larger scope than the federal. Not all wastes that contain metal are considered scrap metal. ![]() Scrap metal is to be recycled in order to recover its metal content or metal pieces that are generated from machining operations. Under federal law scrap metal is the byproduct of metal that has become worn out and is always a solid waste when it is discarded however, it is excused from regulation as a hazardous waste when recycled. State DefinitionsĪn article released by the California Department of Toxic Substances Control (DTSC) entitled Scrap Metal Recycling addresses the disparity between the federal and California state definitions of scrap metal. In the Zendesk article What is a Scrap Metal and What is its Regulatory Status When Reclaimed?, the author describes scrap metal as “a product made of metal that has become worn out or is off-specification and is recycled to recover its metal content, or metal pieces generated from machining operations and recycled to recover their metal content.” However, the way federal law defines scrap metal typically differs from state law definitions. Scrap metal can include wire, rods, bars, sheets, radiators, cars etc. Scrap metal is defined in section 261.1 (c)(6) of Title 40 of the Code of Federal Regulations (40 CFR) as smaller bits and pieces of larger metal parts or metal pieces that are attached to soldering or bolts and can be recycled according to 40 CFR §261.2(c)(6). Further, once such a determination is made, it can then be confusing deciphering how the material must be properly managed. Is it scrap metal? Is it a hazardous waste? Is it both? This article explores the federal and California state regulations guiding the proper management of these materials.ĭiscerning whether a material is considered to be scrap metal under federal and/or state regulations can be difficult. ![]()
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