Rubber Expert Witnesses & EPA Proposed Rule

Rubber expert witnesses may opine on rubber consumer products, tires, and rubber piping. Here, experts at the Rubber Manufacturers Association comment on the EPA’s proposed rule on scrap tires.

The U.S. Environmental Protection Agency (EPA) has proposed a rule that would significantly harm the existing infrastructure that manages scrap tires as well as reverse two decades of environmental cleanup success, according to the Rubber Manufacturers Association (RMA).

After decades of EPA-sanctioned use as a supplemental industrial fuel, EPA is proposing now to declare whole scrap tires a solid waste. The new designation would require facilities using whole tire-derived fuel (TDF) to add costly new emission controls that would not be required to burn traditional, less efficient fuels. Instead of this option, many TDF users, likely will opt to stop using TDF in favor of more costly, less efficient and higher emitting traditional fossil fuels, including coal. This will likely result in a dramatic reduction of TDF use while driving tens of millions of scrap tires back to landfills, stockpiles and illegal dumping sites.

At the same time, EPA will still allow the use of processed scrap tires to be used as fuel only if most of the steel content is removed, which would add costs to TDF use for facilities such as cement kilns, and increase the amount of energy needed and air pollutants emitted to supply TDF to these facilities. Steel content in tires does not affect overall emissions when consumed as TDF. Instead, the steel is used as a raw material in the manufacture of cement.

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