CODE OF PRACTICE
The following description is for the general elements of the Code of Practice for Retire Your Ride. Because every automotive recycler is different, there may be some site-specific code requirements that can only be determined during a site visit. Many aspects of the Code also recognize that different regulations exist in different provinces.
Program Requirements
The Code of Practice (CoP) is based on the existing legal requirements for automotive recyclers. The only “Retire Your Ride” specific requirements are that emission related parts or the vehicle itself cannot be sold or given away for reuse.
The CoP is designed so that the average automotive recycler will be able to achieve the Code without difficulty. Over 150 automotive recyclers have been through this type of program and only the poor operations have problems meeting the requirements.
The Code was designed to help the average automotive recycler understand his/her legal requirements as it applies to their operation as well as integrate Best Practices that will help improve efficiency and profitability.
Environment vs. Profitability
There is a myth that the protection of the environment costs money and jobs. This is an old myth and in fact the opposite is true.
Clean automotive recyclers have the lowest liability with respect to soil contamination, they are more efficient, they retain good workers, they have lower accident records and above all, they are more profitable.
So use the CoP as a method to improve efficiency, reduce liability and make more money!
Environmental Impacts
There are a number of potentially hazardous materials in end-of-life vehicles that are harmful to the environment and harmful to workers. As such, automotive recyclers must:
- handle these materials properly under normal operating conditions;
- prevent large spills where possible; and,
- clean up small leaks and spills.
The hazardous materials that must be managed by automotive recyclers under normal and emergency conditions are:
- Gasoline and fuels
- Refrigerants (R12 and HFC134a)
- Oils, grease and operating fluids
- Antifreeze
- Windshield washer fluid
- Tires
- Lead and Lead Acid Batteries
General Legal Requirements
There are two legal aspects associated with hazardous materials. The first is the liability when the hazardous materials are spilled and contaminate the property. Landowners are particularly interested in this aspect because the contamination affects the value of the property. Every province has contaminated sites legislation that places the responsibility to clean up the property on the land owner. So protect your asset and prevent spills and clean them up when they occur.
The second legal aspect is when the hazardous materials leave your property under controlled or uncontrolled circumstances. Runoff during precipitation events and snow melt can transport hazardous materials to streams and sewers are regulated. If your site is located next to a fish bearing stream in a high precipitation area, then you are a “high” risk site and the control of runoff is an important concern. If your site is in a low precipitation area with no streams nearby, then your site is a “low” risk site.
Automotive recyclers must also understand that the transportation of hazardous materials on public roads to recycling or processing facilities is also regulated. Under most circumstances, transport companies must be licensed by Provincial authorities.
Because you cannot discharge the hazardous materials to the environment, regulatory authorities require the adequate removal, storage, transportation and disposal of the hazardous materials in end-of-life vehicles.
Code of Practice Check List
If you can answer “Yes” to all the 18 questions below, then you are probably in compliance with the general elements of the Code of Practice and you would be able to participate in the Retire Your Ride Program.
If you answered “No” to any of the questions, review your operations, talk to your peers and discuss how you can change your operation to meet the general elements of the Code of Practice.
Refrigerants
- does a certified or licensed mechanic or technician remove the refrigerants
from end-of-life vehicles?
- does the mechanic or technician keep a log of all end-of-life vehicles that have
been evacuated?;
- does the mechanic or technician tag or mark vehicles once the refrigerant has
been removed;
- do you give or dispose of the refrigerants to an certified or licensed business
or recycler?
- do you keep all records for a minimum of 2 years?
Fluids:
- Are all oils, antifreeze, transmission fluid, brake fluids, windshield washer fluid removed from vehicle removed before hulk is stored or crushed?
- Are the fluids stored in a safe covered location with adequate containment (i.e., secondary containment) that will catch the fluids if the storage containers fail?
- Does the transporter have a license to transport hazardous fluids issued by the Provincial government and do you keep the shipping records for a minimum of 2 years?
- Do you know the thresholds of spilled hazardous liquids that must be reported to the Provincial Emergency Program?
- Are small spills and leaks on the ground cleaned up?
Solids
- Are all lead-acid batteries and tire weights removed and stored in a dry location;
- Are sludges and contaminated solids stored in a drum as a hazardous waste?
- Does the transporter have a current Hazardous Waste Transport License to transport lead acid batteries and contaminated solids?
- Do you store the transporter’s records for 2 or more years?
- Are less than 1000 tires on site at any one time?
Mercury Switches
- Are all mercury switches removed from vehicles prior to crushing?
Emergency Preparedness
- Does your yard have a spill kit adequate to deal with the quantity of hazardous fluids on site and the risk those fluids poses to the environment?
Even it you do not want to participate in the Retire Your Ride Program, meeting the general requirements of the Code of Practice will help you prevent liabilities from leaks and spills and improve the operation of your yard.
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