Two industry organizations are objecting to a proposal by the Environmental Protection Agency (EPA) that would designate scrap tires as a “solid waste.” If the regulations are adopted, manufacturers that currently utilize tire-derived fuel (TDF) – such as cement kilns and paper mills – will have to operate under the tougher standards directed at commercial incinerators.

TDF-burning facilities would fall under more stringent Section 129 emissions regulations in the Clean Air Act, which would mean revamping or replacing current combustion units. The fear is that these firms would reject using TDF in favor of more traditional fuels – thus lessening demand for old tires.

The proposed regulations “would devastate the tire-derived fuel market in the U.S., which will ripple across the entire scrap tire market infrastructure,” according to Tracey Norberg, senior vice president of the Rubber Manufacturers Association (RMA). “Worse, the proposal will drive scrap tires back to stockpiles and illegal tire dumps after two decades of success in cleaning up stockpiles and promoting safe, viable, effective markets for scrap tires.”

In documents recently submitted to the agency, the RMA is calling on the EPA to “reconsider this deeply flawed, anti-environment, anti-business and anti-common sense proposal,” Norberg notes.

The Tire Industry Association (TIA) is also raising objections. “We have too many members at every link in this recycling chain to ignore the potential problems in this rulemaking,” reports Roy Littlefield, executive vice president.

“Restricting the TDF applications will change the economic balance for all tire material and could potentially create the situation we faced in previous years, where many more tires were disposed of in landfills,” says Dick Gust, who is past-president of the TIA along with being the current president of national account sales for Liberty Tire Recycling plus the co-chair of the TIA’s Environmental Advisory Council.

“While the industry is working very hard to secure more high-end markets for tire-derived material like mulch or crumb rubber that can be used in a variety of valuable products,” Gust points out, “tire-derived fuel remains a very valuable and beneficial market for consuming the millions of tires that are generated on an annual basis. We are maturing as a viable and valuable industry that produces valued products, but we do not want to take a step backward by restricting the application for TDF.”

Scrap tire management has evolved into an “environmental success story” throughout the nation, according to the RMA’s Norberg. In 1990, more than a billion tires were stockpiled across the country while only 11 percent of the annually generated scrap tires were reused. Today, fewer than 100 million tires remain stockpiled and nearly 90 percent are reused.

About 300 million scrap tires are generated each year in the U.S. Of those, some 52 percent are used as TDF by the cement industry and at pulp and paper mills. Utilities and other industrial boilers also burn the material.

The RMA contends that “TDF has a long history as a fuel, which is recognized by EPA. The agency’s own data indicates that the combustion of TDF, whether whole or minimally processed without removal of metal beads, not only provides better fuel value than coal (12,000 to 16,000 BTUs per pound), but also results in comparable or even lower emissions than coal combustion.”

Norberg says the EPA’s proposal “turns common sense on its head and would harm the environment while causing potentially thousands of jobs to be lost in the scrap tire industry.”

More tire stockpiles would heighten increase the risk of fires and mosquito infestations, he warns.

“Unlike the controlled, extreme heat combustion when TDF is used as a fuel, a burning pile of scrap tires can cause considerable environmental harm,” says Norberg. “Such fires can burn for days or weeks. Stockpiled tires also collect rainwater,” he explains, “which then becomes an ideal breeding ground for mosquitoes that carry diseases.”

For more information, visit and www.tireindustry.org or www.rma.org.

James E. Guyette