Franklin Iron & Metal Company has developed a comprehensive environmental program to manage risks associated with environmental aspects of recycling scrap metal, demonstrating our strong commitment to our environmental responsibilities.
Some highlights of the major elements of our environmental program are as follows:
- We control what comes into our facilities. Elements of this program include communicating what we can and cannot accept to our suppliers, inspecting materials as they arrive, and responding to the discovery of unauthorized materials.
- We implement site-specific pollution prevention plans required by environmental regulations and corporate policies to further prevent pollution. Examples include Storm Water Pollution Prevention Plans, Spill Prevention Control and Countermeasure Plans, Waste Water Discharge Plans, and Engineered Barrier Maintenance Plans.
- We implement structural and management controls for recyclable materials deemed environmentally significant.
- We obtain required environmental permits, registration, and licenses pertaining to our operations.
- We continue to implement strategies and explore opportunities to conserve energy, fuel, and oil used in our operations.
- We properly manage byproducts and wastes generated from our operations and we continually explore ways to improve recovery and increase reuse and recycling opportunities.
- We perform environmental training to facility personnel through ongoing education.
- We perform SREA compliance evaluations of significant consumers to whom we ship scrap metal to ensure they are in compliance with substantive provisions of environmental compliance.
- To continually improve our environmental programs, we review the environmental aspects of our scrap metal recycling operations annually and develop new environmental programs and initiatives as emergent issues arise.
Protecting Our Suppliers
What is the Superfund Recycling Equity Act?
On November 29, 1999, President Clinton signed into law the Superfund Recycling Equity Act (SREA). SREA serves to correct the unintended consequence of the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) that discourage recycling of metals due to the potential environmental and legal costs of a cleanup. SREA clarifies that recycling is not disposal, and shipping of material to be recycled is not arranging for disposal. SREA no longer holds companies who sell scrap for recycling responsible for the cleanup of contaminated site when the site’s owners or operator has caused the contamination.
In order to be afforded relief from liability, a recycler must be able to demonstrate:
- The recyclable materials meet a commercial specification grade.
- A market exists for the recyclable material.
- A substantial portion of the recyclable material is made available as feedstock for the manufacture of a new saleable product.
- The recyclable material could have been a replacement for virgin raw material.
- The person exercised “reasonable care” to determine that the accepting facility was in compliance with substantive federal, state or local environmental laws or regulations.