Regarding your continuing story (July 21 issue of Tire Business) about the new Waste Tire Hauler Manifest System in California, I find it a little suspicious that only now are we hearing from this group of retreaders who are seeking some relief from what they're calling an unwieldy tire policy.
Each of them has been asked to participate in the process that has led up to this system. Harvey Brodsky, managing director of the Tire Retread Information Bureau (TRIB), also has been asked to participate in this process and now that the process has evolved in a way that makes each stakeholder responsible for their part in it, he wants a voice in the process.
I have consistently opposed the California Integrated Waste Management Board's interpretation of a waste tire that includes tires that continue to have value, and I have been successful in getting a modification of that definition for the storage of used tires. I believe additional changes could be made with a stronger, focused approach through legislation.
For the past several years, every generator of used or waste tires including casings was subject to severe fines of up to $10,000 for allowing those tires to be moved from their stores or retread plants by unregistered haulers including their own vehicles.
The registered hauler of used/waste tires was required to complete a three-part manifest, and each party was to keep a copy of that manifest for three years.
No copy of that form was sent to the board and very seldom was an audit performed at any of the known sites, so very little enforcement took place.
In the past two years several workshop sessions were held throughout the state where suggestions from stakeholders were consolidated. That resulted in the separation of the three-part form into three parts. The generator completes a form which identifies him, the number of tires moved, the type of tires moved and the vehicle on which the tires are moved, along with a reference to the hauler's numbered log of that transaction.
The hauler lists that manifest number on his log as well as the number of a similar manifest completed by the destination site. Each of these forms is a prepaid mailer that is folded and mailed to the waste board. A copy is kept by the hauler and each of the stakeholders.
The concept is that the waste board will scrutinize these forms by the numbers on each form and seek explanations for missing information or forms.
Administrative penalties remain the same as they have been for the past several years at $5,000 to $10,000 per incident and from six months to one year in jail. The $25,000 fine mentioned in your article is the potential for criminal penalties if fraud or conspiracy is involved. Vehicle code violations are involved if the hauler is cited by law enforcement.
If anything has changed, it is that the generator is no longer liable for the end-use of the tires when they use a registered hauler and complete the appropriate manifest form. Until now the generator could be held liable for tires that did not arrive at a legally permitted site-similar to the ``Superfund'' problems of hazardous materials fame.
I would like to participate in any legislation that would address the way the board sees tires of value being part of their waste tire mandate.
The original 1989 legislation referred to a waste tire as being a tire that could no longer be used for its originally intended purpose.
We all know it does not include reusable, repairable, regroovable and recappable tires. The board was allowed to make the changes that resulted in all tires being waste tires because they had very few dealers objecting to their changes. Now is the time to take control of this process and focus on appropriate legislation.
Carl E. Atkinson Jr.
Waste Tire Management
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I recently sent portions of this letter to Harvey Brodsky, managing director of the Tire Retread Information Bureau, to be included in his presentation to the California Integrated Waste Management Board concerning its new Waste Tire Manifest System.
That system has unilaterally placed the tire recycler (retreader) right in the middle of the bureaucracy's project to account for the disposition of used tires in the state of California.
The recycler/retreader has, to this point, provided the only solid method for the control of scrap tires. He has always had to account for the disposition-either by recycling, or legally scrapping the used tires. It is his business. If he fails to properly account for the used tires, he loses his customers and his business.
Retreading tires is a narrow margin business with tremendous operating cost in gathering, disposing and returning retreaded tires to the customer. The internal paperwork needed to track the tire through the process is already onerous. This is a grassroots business with the vast majority of the clerical recording done in the field by personnel who are loading the tires. Now we must add to this the state manifests, which are a duplication of the field work already necessary to process tires for retreading.
Financially, as an aside, our current estimate is that we will spend on average in basic wage one-half man day per day (without fringes and taxes) of nearly $1,600 per month just to administer and reconcile the paperwork generated from the new system.
Additionally, our customer-whose initial contact with this program is through us, the retreader-now relates to us as the one who identified them to the state by getting them their Tire Producer Identification Number (TPID), which anyone who produces waste tires must have.
The tire retreader is the good guy. He saves tires from the scrap heap to retread. He recycles these tires two, three, four times. Yet he is being put in the middle of a political and administrative mess. The state is, by implication, driving the tire user to make a decision not to retread because it is too complicated.
The retreader-who now patrols, ramrods and administrates the state program on his terms while functioning in his business-is now faced with another ``stone in his wheels.'' He cannot absorb this additional burden and defend his position. He has had this dropped on his doorstep!
What must be done: The state must be more communicative with the user, through ads, seminars and meetings with trucking associations. They must be prepared to work with the retreader. He must be provided with some sort of summary reporting that would allow him to operate his business and satisfy the state requirements.
He should be held accountable but not responsible for the problems of scrap tires.
The real problem is with the user who does not now and will not comply with the new system. The communication must be with the tire user, not with the recycler who is already complying with the waste tire program by accounting for every scrap tire.
Delray Tire and Retreading Corp.
Yes, corrosion's a big problem with Michelins
In response to Harold E. Fouty's letter to the editor (July 7 issue of Tire Business) about Michelin tires and the corrosion problem, I agree wholeheartedly.
We have almost exclusively seen this problem with Michelin tires or rims that have had Michelins on them.
I think the response you published from Michelin North America Inc. was very one-sided.
I am sure they do not want to admit there is a problem. I think this corrosion is caused by the very thin layer of rubber over the bead wires and a chemical reaction that occurs with the aluminum wheel.
I have been in the tire business for 35 years and have seen this condition a lot lately. I'm sure we are not the only tire dealers that have this problem.
Michelin's statement about salt on winter roads and salt air doesn't make sense. If that were true, all rims would corrode-no matter whose tires were on them.
County Tire Co.