For the last five years, Call2Recycle has worked closely with industry trade organizations and the federal government to minimize safety risks in transporting used batteries and increase the ease with which generators of used batteries can have them recycled. During this period, the U.S. Department of Transportation (USDOT) has promoted regulation to further safety and has audited the Call2Recycle program to assess compliance.
Call2Recycle recently submitted comments in response to the USDOT’s Pipeline and Hazardous Materials Safety Administration’s (PHMSA) Advanced Notification of Proposed Rulemaking (ANPRM) on hazardous materials in reverse logistics, which would affect the transport of used batteries for recycling. As part of the USDOT’s retrospective plan to review existing rules, this ANPRM titled “Hazardous Materials: Reverse Logistics” will identify possible ways to reduce the regulatory burden on retail outlets that ship consumer products containing hazardous materials in the “reverse logistics’’ supply chain.
Given the potential impact on Call2Recycle’s program and its significant collection network, especially retailers, Call2Recycle’s greatest concern is that the regulatory language to define reverse logistics will place additional training requirements on its program participants, likely store personnel. This requirement would significantly harm battery recycling efforts and ultimately the environment.
While Call2Recycle supports the USDOT’s efforts to improve transportation safety, it believes that there are sufficient regulations in place to do this.
For a copy of Call2Recycle’s comments, please click here.