NHTSA Lays Down The Rules
Just one year ago, the CARS program (aka Cash for Clunkers) was making headlines as a piece of proposed legislation. Now, the U.S. government-sponsored vehicle retirement program is over for consumers, but in full swing for auto recyclers. The CARS program took nearly 700,000 vehicles off the road. For many auto recyclers count down has begun for hundreds of vehicles that await the crusher. The vehicle must be crushed within 270 days after receipt from the dealer at the disposal facility (aka auto recycler).
The NHTSA (National Highway Transportation Safety Administration) held an informational webinar on March 3, 2010 to help auto recyclers understand the legally mandated procedures.
There are three primary responsibilities for a CARS program disposal facility. It must report twice to the National Motor Vehicle Title Information System (NMVTIS); once within seven days of receiving the vehicle (report as scrap), and again within seven days of crushing the vehicle (report as crush). The facility must remove all environmental hazards as is consistent with End of Life Vehicle Solutions (ELVS). And it must crush or shred the vehicle on site.
Many of the 120 webinar participants questioned the last requirement. Original CARS program rules focused on the prohibited sale of a vehicle's engine block or drivetrain as a whole (the transmission, drive shaft and rear end can be sold separately). The engine and drivetrain, and whatever else was not pulled, had to be crushed within 90 days (now 270 days after an extension passed January 2010). From the beginning, auto recyclers questioned what exactly constituted crushing the vehicle and if that included just the engine and drivetrain.
NHTSA webinar presenters informed auto recyclers that along with the engine block and drivetrain, the vehicle's chassis must also be crushed. NHTSA officials emphasized parts can be removed from a CARS program vehicle, but a "vehicle" still needs to be crushed. There must be something left for the crusher and that something should be identifiable with a VIN. The rule-of-thumb, according to NHTSA presenters: "If you can unbolt it, you can take it off."
NHTSA expressed the vehicle needs to be crushed flat, not stacked or crushed with forks. Auto recyclers may keep recovered parts stored and shelved without time limit restrictions.
CARS program vehicles need to be crushed on-site with a stationary or mobile crusher. No part of the vehicle may be sent out for crush, even to a sister location. NHTSA officials stressed this point as important, specifically for record keeping. Officials said each engine must track back to its vehicle. To do this, an engine needs to stay with the vehicle until it is crushed and records be maintained to show both were crushed. The agency also suggested keeping records for at least five years.
Diligent and precise recordkeeping will keep auto recyclers from heavy fines, $15,000 for each NMVTIS non-compliance mistake. NHTSA officials stressed the importance of the reporting form: all numbers filled in accurately, use of legal business name vs. dba, and original, non-altered forms.
|TIP: The Disposal Facility Certification Form is available as an editable PDF.|
With 500 - 5,000 vehicles to process, you'll want to avoid redundant entry of your business information.