ISRI Adopts New Positions on Mercury Switch Program and Vehicle Seller Licensing
The Institute of Scrap Recycling Industries (ISRI) recently adopted a new policy position on the National Vehicle Mercury Switch Recovery Program (NVMSRP) in addition to a new position on vehicle seller licensing.
NVMSRP was created by a 2006 Memorandum of Understanding (MOU) that will expire at the end of 2017. The MOU currently provides that auto manufacturers fund the End of Life Vehicle Solutions Corporation (ELVS), which supplies recyclers with buckets to collect mercury switches and covers the cost of shipping the buckets and recycling the mercury, as well as providing indemnification for participants once the switches are packaged and shipped.
ISRI’s newly adopted position stated that the recycling industry “supports a continuation of the National Vehicle Mercury Switch Recovery Program through the end of 2021, conditioned upon the following sections of the 2006 Memorandum of Understanding (MOU) remaining essentially unchanged:
The transportation, acceptance, recycling, and liability language regarding the End of Life Vehicle Solutions Corporation (ELVS) under Section V.1.C, subsections 3 through 6; and
Language regarding the responsibilities of ISRI and participating vehicle crushers, scrap processing facilities, brokers, and vehicle dismantlers, as well as their interactions with other parties.”
In addition, the ISRI Board also ratified a new policy on the “appropriate regulation, registration, permitting, or licensing of sellers of vehicles for scrap or parts only.” While scrap metal processors often purchase vehicles in a mechanically crushed or flattened condition, many vehicles are purchased in whole form. Those whole vehicle sellers that are in the business of removing parts or scrap metals from these cars for re-selling the parts are typically regulated as dismantlers or scrap metal processors.
The new policy stated that the recycling industry “supports reporting of whole vehicles sold for scrap or for parts in accordance with state and federal laws, and opposes overreaching or duplicative regulations, registrations, permitting or licensing requirements placed on the sellers of whole vehicles that are sold only for scrap or for parts, if the vehicles are sold to properly licensed, registered, or permitted (as regulated or required by state law) scrap metal processors or automotive dismantlers.”