Hazardous Waste Management for Scrap Metal Recyclers

Scrap metal originates from end-of-life-products, structures, construction and demolition debris, or out-of-specification metal products that are recycled to recover their metal content. Scrap metal can be sourced from discarded appliances, vehicles, electronic waste (e-waste), metal pieces generated from machining operations, and other metal-containing wastes. Scrap metal is not subject to management as hazardous waste in California if it meets the regulatory definition and is recycled. Regardless of whether it is being recycled, scrap metal should be managed in a way that does not cause a release of its hazardous constituents to air, soil, or surface water.

Appliances

Discarded appliances are valuable sources of scrap metal. However, appliances contain materials that can harm public health and the environment if they are not removed and properly managed before recycling. These materials are called materials that require special handling (MRSH). Once they are removed from appliances, they are hazardous waste.

California law requires that facilities and individuals who remove MRSH from discarded major appliances be certified by DTSC under the Certified Appliance Recyclers (CAR) Program by demonstrating the ability to properly remove and manage MRSH in accordance with all applicable California Hazardous Waste Control Law (HWCL). Please note, individuals who hold a Section 608 Technician Certification and do not remove any MRSH besides refrigerants do not need to be CAR certified.

Helpful Information (Fact Sheets):

Vehicles

Vehicles are valuable sources of scrap metal. Auto dismantlers must be licensed by the California Department of Motor Vehicles (DMV) to conduct their business and DTSC regulates the hazardous waste that is removed from scrap vehicles. Some specific wastes including MRSH and/or hazardous wastes often found in vehicles include:

Motor vehicle fluids
Management of Spent Lead-Acid Batteries
Mercury switches
Undeployed airbags containing sodium azide and/or perchlorate
Lead weight wheels
Managing Used Oil Filters for Generators
Used oil filters

Additional Guidance:

Hazardous Waste Requirements

Scrap metal recycling facilities may generate wastes that are considered hazardous during the recycling process. A “generator” is any person, by site, whose act or process produces hazardous waste or whose act first causes a hazardous waste to become subject to regulation. The following factsheets are resources for generators of hazardous waste:

For information on Hazardous Waste ID Numbers, visit DTSC’s Hazardous Waste ID Numbers webpage. For information on reporting and recordkeeping, visit DTSC’s Reporting-Recordkeeping Standards webpage.

Universal Waste

Scrap metal recyclers may transport, handle and recycle certain universal wastes in a manner that differs from the requirements for most hazardous wastes. To discourage improper disposal in landfills, state laws and regulations identify the hazardous wastes that can be managed as universal wastes and provides rules for handling and recycling them. Universal wastes must be sent to a universal waste handler to be managed under the universal waste handler standards. If these wastes are not managed as universal waste, they must be managed as fully regulated hazardous waste. Although not an exhaustive list, the following fact sheets and web pages address some universal wastes:

Electronic Waste (E-Waste)

Electronic hazardous waste (e-waste) is a type of universal waste. E-waste refers to a discarded electronic device or cathode ray tube (CRT) device that is managed as a universal waste. E-waste frequently contains hazardous materials, such as lead and mercury, and is produced by households, businesses, governments, and industries.

Generators are responsible for determining if their e-waste is hazardous. Please see the Recycling and Treatment of E-Waste fact sheet for specific requirements that scrap recycling facilities must follow if they accept certain e-waste for recycling. Additionally, CalRecycle coordinates with DTSC to implement portions of the Electronic Waste Recycling Act of 2003, which established a funding system for the collection and recycling of certain electronic devices.

Additional Metal Wastes

Scrap metal recyclers may encounter or handle metal waste that has special management considerations. For assistance in determining if a material classifies as scrap metal, please contact your local Certified Unified Program Agency (CUPA) or DTSC for assistance.

Although not an exhaustive list, the following fact sheet and web pages address some of these wastes:

For additional information, please visit DTSC’s Additional Resources for Scrap Metal Recyclers webpage and DTSC’s Scrap Metal Recycling Regulatory Oversight webpage.

*Disclaimer
This web page is intended to be guidance only and it does not supersede or implement laws or regulations. The information in this advisory is intended solely as guidance and as educational reference material and should not be considered enforceable or regulatory in nature. Reference in this web site to any specific commercial products, processes, or services, or the use of any trade, firm, or corporation name is for the information and convenience of the public, and does not constitute endorsement, recommendation, or favoring by the State of California, or its employees or agents.

Managing Hazardous Waste