VACC ADRD commentary on EPA Victoria Draft Dismantling Guidelines
Members of the VACC Automotive Dismantling and Recyclers Division (ADRD) are advised that your ADRD Executive Committee are currently in the final phase of collaboration with EPA Victoria with regards to the industry roll out of the EPA Victoria Dismantling Guidelines. The ADRD Committee are to be thanked for their time and expertise. A great example of a genuine, membership based industry body working towards an industry lead solution.
You can read the ADRD commentary on the EPA Guidelines by visiting the VACC webpage www.vacc.com.au .
It is important to note that the ADRD Commentary has been complied using data and the industry expertise of members of the ADRD Executive Committee.
What is the purpose of the EPA Vic, Dismantling Industry Guidelines?
The intended purpose of the guidelines is to provide clear guidance on practical measures that can be taken to prevent or minimise risk of harm to human health and the environment while being able to maintain a profitable legitimate business as a result of auto recycling operations.
The ADRD input into the guidelines focuses on the practicalities of industry being able and willing to adapt the guidelines and further separate the legitimate dismantling industry from the illegitimate and illegal operations that so riddle the dismantling industry. This will be an important step on the VACC ADRD journey towards Government mandated implementation of a National End of life Vehicle Policy.
Importantly the ADRD Commentary makes a key recommendation that EPA legislate that any statutory written-off vehicle or End of life Vehicle is defined under the EPA Act as a prescribed waste product and to be handled by approved registered contractors in the future.
What sectors will the Guidelines be relevant to?
If you are an operator of a business involved in all forms of ‘vehicle’ parts recycling and metal recycling i.e. cars, trucks, motorcycles, farm machinery and other industrial vehicles except boats, then these guidelines will be relevant to you. Some examples of businesses that should refer to this guide include:
- Full service auto recyclers who dismantle, catalogue and warehouse parts
- Self serve auto parts recyclers
- Shredder operations who take end of life vehicles (ELVs) directly from public or trade for crushing and shredding.
- Scrap metal dealers that handle ELVs.
- Exporters who dismantle ELVs for parts and scrap metal markets outside Australia
- Support services for the auto recycling industry (waste oil collectors, waste removers etc.).
EPA and VACC advise that the guidelines should assist you to identify controls to prevent or minimise, so far as reasonably practicable, risk of harm to human health and the environment from your operations.
To improve health, safety, environmental outcomes and reduce the incidence of stolen motor vehicle, Regulators must understand that End of Life Vehicles must be processed and dismantled in appropriately licenced, equipped, trained, transparent facilities and not in unlicensed, obscured, poorly trained and equipped facilities. It is a Regulator responsibility to monitor the market sector for contraventions of their respective Acts and Regulations and to ensure issues of non-compliance are addressed as and when they are identified to ensure the bulk of ELVs are processed in the best recycling operations and not the worst operations.
Next steps
EPA Victoria has asked for a representation of VACC members to meet with EPA Vic and other stakeholders at a specially convened meeting on 18 June 2018. VACC requests that members from a cross section of the membership make themselves available to attend this meeting where the guidelines will be subject to final industry scrutiny. It is important that as many ADRD members attend this meeting as possible.
Please call me at VACC if you can send a representative (s) on the 18 June. The time and venue will be confirmed when known.