Are You Prepared for Potentially Hazardous Materials?

By Kenneth Cohen

Kenneth Cohen is chairman of ISRI’s Education and Training Committee and vice-president and general manager of Cohen Brothers Inc., Middletown, Ohio.

Increased public concern about the existence of potentially hazardous materials in our environment has placed scrap processors in a precarious position. We must strive to comply with recently strengthened environmental regulation and make use of new findings about potential hazards without winding up out of business in the process.

Tougher questions must be asked today before bringing a load of scrap over the scale. Are any potentially hazardous items included? If so, should you take them into your plant? If you do, what guidelines must you follow to ensure safe working conditions? What role are government agencies playing in monitoring these conditions and your operations?

The list of questions is endless, and no clear-cut answers exist. However, knowing what items may pose problems is a start.

Unfortunately, the potentially-hazardous-materials list also seems endless. The list shown here, which should not be considered complete, was developed by the Processing and Equipment Committee of the Institute of Scrap Recycling Industries (ISRI). Its purpose was not to pinpoint materials that processors should avoid, but rather to alert processors to potential hazards inherent in handling certain materials.

Decisions about purchasing and processing are best left for individuals to make on a case-by-case basis.

The hazards noted are not specific and may vary depending on state regulations. For example, heavy metals other than lead, such as chromium and arsenic, can be found in many of the listed items but are not noted since only the most obvious hazards are mentioned. However, the heavy metal threat is there and must be considered. Other substances, such as oil, are prevalent, and awareness of their presence is essential.

Remember that the listing of a material does not necessarily mean it should no longer be purchased or that it is always hazardous. Inclusion simply means that, if the material is considered for regular purchase, close scrutiny and proper management of the material are necessary.

Now That You Know, What Can You Do?

Once you can identify the potentially hazardous materials, how can you protect your facility, employees, and customers while maintaining proper business relationships with suppliers? You can begin with training for your scale men, truck drivers, and operations personnel. Many firms are showing ReMA's video "Identifying Potentially Hazardous Materials" to their employees as well as to their scrap suppliers and sources. This video is available to all ReMA members. ReMA also has available for its members "Suggested Operating Practices" sheets covering materials such as drums, underground storage and chemical tanks, and waste oil. Information on radiation and aluminum lithium alloy is forthcoming.

To further protect your business, take these steps:

Write a letter to your suppliers listing the materials you will no longer buy, or the conditions under which you will purchase them. Where appropriate, request Material Safety Data Sheets for the acceptable items. ReMA has developed a suggested letter to send.

Meet with your suppliers and suggest that they not use materials that could generate hazardous wastes or cause other environmental problems. Make them aware that hazardous substances present in their material could make them liable for future on- and off-site cleanups.

Insist on receiving a warranty and indemnification from each vendor providing you material. This procedure is intended to provide maximum protection to the scrap purchaser. However, the value of this certification is only as great as the financial strength of the company or individual providing it. Make sure you know your suppliers.

Refuse to accept any material that you believe poses too great a risk. If you don't know what it is, what it was, or what it contained, don't take it. In this atmosphere, the deal you didn't make could be the best deal of all.

Know your obligations to the Occupational Safety and Health Administration, the Environmental Protection Agency, and other government agencies. Liability is not just a corporate responsibility; it can "pierce the corporate veil" and affect you personally.

Identifying and properly handling potentially hazardous materials are two of your biggest responsibilities. When the health of an employee, the contamination of property, and the destruction of a relationship with a valued customer are at stake, the risks are real and substantial.

If you recognize and make sound decisions about these materials, you not only will protect your business interests, but you will help guarantee the future strength and viability of the scrap processing and recycling industry.

Potentially Hazardous Materials and Their Potential Problems (based on federal law)

Gas tanks (explosions; lead from gasoline residue and terneplate)

Batteries (lead, acid, or nickel-cadmium residues)

Closed containers (explosions; chemical residues)

Tanks (explosions; chemical residues)

Testing and lab equipment, hospital equipment, vials and bottles (radioactivity; chemical residues; medical and human wastes)

Gauges and measuring devices (radioactivity)

Compressed gas cylinders; oxygen bottles (explosions; hazardous gases)

Turnings (oil or chemical residues)

Drums, barrels, and other “empty” containers (whole or cut up) (chemical residues)

Wire/cable (insulated or coated) (asbestos; lead; or chemical residues)

Pipe (asbestos; lead; other coatings or internal chemical residues)

Transformers and capacitors (large and small) (PCBs; oil)

Paint or paint thinner cans and buckets (explosions; lead; cadmium or solvents)

Metallic sludges; drosses (chemical residues)

Motor blocks (oils; solvents; chemical residues)

Demolition scrap; lighting fixtures (radioactivity; asbestos; lead; PCBs)

White goods, appliances (PCBs; cadmium; asbestos)

Military/government scrap (explosions; chemical residues)

Slag and pit scrap (chemical residues)

Aircraft material (aluminum/lithium explosions; chemical residues)

Auto or rail brakes/drums (asbestos)

Waste oil (“free-flowing”; PCB residues)

Leaded scrap (lead)

Painted, coated, or plated scrap (cadmium; lead; zinc)