TransRec
Transfer of Recycling Car Technologies
LEONARDO DA VINCI Transfer of innovation
Deliverable PO2
Report on the about initial investigations of the ALCVET project
outcomes
Originated from the WP2
WP leader: ASTRA
Deliverable PO2: Report on the about initial investigations of the ALCVET project outcomes
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Change log
Version
Date
Change
0.1
10.03.2014
Document created
0.2
26.03.2014
Document updated
0.3
15.04.2014
Document updated
This document is the property of the TransRec Consortium. This document may not be copied,
reproduced, or modified in the whole or in the part for any purpose without written permission from the
TransRec Consortium.
Deliverable PO2: Report on the about initial investigations of the ALCVET project outcomes
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Content
Abbreviations ........................................................................................................................................... 4
1
Introduction ...................................................................................................................................... 5
2
Analysis of the ALCVET training program from the view of applied training methods ...................... 7
3
4
5
2.1
Main training methods used ..................................................................................................... 7
2.2
Pedagogic approach – principles used for the ALCVET target groups..................................... 7
2.3
Student support system for the learners – mentors, tutors, teachers ....................................... 8
Analysis of the ALCVET training program from the technical point of view .................................... 10
3.1
Delivery of the training – organisation of the course .............................................................. 10
3.2
IT platform used in ALCVET................................................................................................... 13
Analysis of the ALCVET training program from the SMEs’ point of view P3 .................................. 17
4.1
General Observations about the ALCVET training module .................................................... 17
4.2
Specific Observations about the chapters in ALCVET training module .................................. 19
SUMMARY OF THE REGULATION ON CONTROLLING THE END-OF-LIFE VEHICLES ........... 23
5.1
CHAPTER 1: Objectives, Scope, Grounds, Definitions and General Principles ..................... 23
5.2
CHAPTER 2: Duties, Authorities and Liabilities ..................................................................... 25
5.3
CHAPTER 3: Prohibition of the Use of Hazardous Substances in Vehicles and Labeling ..... 26
5.4
CHAPTER 4: Collection of End of Life Vehicles, Using Unregistering and Disposing Vehicle
Forms (Article 12, 13) ........................................................................................................................ 26
5.5
CHAPTER 5: Processing Facilities with Normative Considerations and Environmental Permits
and Licenses...................................................................................................................................... 26
5.6
CHAPTER 6: Reuse-Recycle and Reuse-Recycle Ratio and Type of Approval .................... 27
5.7
CHAPTER 7: Miscellaneous and Final Provisions ................................................................. 28
5.8
STATISTICS ABOUT VEHICLE RECYCLING ....................................................................... 30
Deliverable PO2: Report on the about initial investigations of the ALCVET project outcomes
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Abbreviations
LdV programme
Leonardo da Vinci
SME
Small and medium enterpises
WP
Working package
ALCVET
Advanced eLearning Content for VET
TOU
Turgut Özal University
PIAP
Przemysłowy Instytut Automatyki i Pomiarów
TRANSREC
Transfer of Recycling Car Technologies
PO
Project Outcome
EU
European Union
FTF
Face to face
LCMS
Learning Content Management System
ELV
End of Life
TSA
Temporary Storage Area
Deliverable PO2: Report on the about initial investigations of the ALCVET project outcomes
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1 Introduction
This document is the Deliverable PO2 of the transfer of innovation project TransRec „Transfer of
Recycling Car Technologies“ which is being implemented within the Leonardo da Vinci programme.
The aim of the TransRec project is to provide a cost-effective, comprehensive training system for SMEs
in recycling domain covering 2 topics:
-
general recycling technologies
-
car recycling technologies
The objective is to provide unified training content for the following 3 target groups:
-
Managers in SMEs
-
Technical Employees in SMEs
-
Teachers/Trainers in vocational education organisations
The TransRec project is based on the ALCVET project
The process of transferring innovative training content will be based on the following procedure:
-
The needs and requirements of targeted users, already identified and analysed in the previous
projects will be checked for validity, updated and extended with new ones for planned content
extension (general recycling topics, local specifics etc) and for new regions/countries.
-
The innovative content from the previous projects will be analysed and updated to meet the
requirements, and the methodology for transfer (based on ontology) will be identified
-
The courses will be adapted to the approach for organisation of training in the new recycling
areas, countries/regions and cultures (first for Turkey).
-
Optimal ways for transferring it to new socio-cultural contexts will be identified, based on local
training providers experiences and end-user requirements,
-
The TransRec system will be integrated in national / regional training systems for recycling SMEs
in the 3 partner countries/regions. An Internet based Knowledge Forum will be established to support
this transfer.
The deliverable PO2 is based mainly on the following:
-
ALCVET e-learning system
-
Ecology, law, practice and perspectives in the car recycling sector
-
ALCVET Methodology Handbook
Deliverable PO2: Report on the about initial investigations of the ALCVET project outcomes
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-
Partners‘(PIAP & ASTRA) experience and knowledge from the similar already implemented
projects
The main steps of the WP2 implementation are as follows:
-
Initial introduction of the project ALCVET by the project promoter PIAP, in the first meeting in
Turkey and then in Poland.
-
Delivery of the outcomes of ALCVET project to the partners.
-
Preparation and delivery of the presentations, different documentation and explanation of the
ALCVET project – all done by the Partner 1.
-
Sharing the experiences from the ALCVET project with other partners
-
Analysis of the content of the ALCVET project in as follows:
o Partner 0: analysis of the ALCVET training program as general and from the view of
applied training methods.
o Partner 2: analysis of the ALCVET training program as general and from the technical
point of view.
o Partner 3 analysis of the ALCVET training program as general and from the SME point
of view in order to get information whether the method/content covers the needs of
SMEs.
The deliverable P02 was prepared within the WP2 of the TransRec project. Together with the other
TransRec project products (questionnaires & survey results developed and prepared within WP3),
deliverable P02 will serve as the main inputs for the further TransRec project WPs.
The PO2 consists of the following parts;
-
Analysis of the ALCVET training program as general and from the view of applied training
methods
-
Analysis of the ALCVET training program as general and from the technical point of view.
-
Analysis of the ALCVET training program as general and from the SMEs’ point of view
WP2 and its main deliverable P02 is closely connected to the WP3. While the P02 gives the overview
what is available – what kind of products the ALCVET project has offered for the transfer, the WP3
products will provide the information what is required from the main target groups.
Deliverable PO2: Report on the about initial investigations of the ALCVET project outcomes
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2 Analysis of the ALCVET training program from the view
of applied training methods
2.1 Main training methods used
For the purpose of the project, the ALCVET partners have contacted more than 500 SMEs and
analyzed the situation in this sector in EU and found out that a clear need to achieve the declared
objectives regarding environmental protection is application of advanced continuous trainings of the
SME staff.
During these interviews, it is observed that more than 90% of companies in recycling industry are SMEs,
needing an urgent support for competency improvement.
However, the characteristics of the sector and target groups have imposed a great challenge for the
design of appropriate training methods. Namely, the cross-regional character and high variety of the
sector with many specific areas (often low number of SMEs in one region in a specific area) and a need
for cost-effective training solutions imposed the requirement to provide solutions comprehensive enough
to be useful for general recycler and for different specific areas (paper recycling, end-of-life vehicles –
ELV- recycling etc.) and for different countries.
As a result, the project has aimed to provide a cost-effective, comprehensive training system for SMEs
in recycling domain covering 3 topics:
-
- general recycling technologies,
-
- process improvements (PI) and supporting ICT systems,
-
- new business forms and SME networking
The objective was to provide unified training content applicable in different EU countries and regions
and in different recycling areas (i.e. for the whole recycling sector) for defined target groups.
2.2 Pedagogic approach – principles used for the ALCVET target
groups
From the pedagogical point of view, the project has emphasized a great focus on specific socio-cultural
aspects and linguistic context among the partnering countries. Target groups are carefully defined and
Deliverable PO2: Report on the about initial investigations of the ALCVET project outcomes
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appropriate training tools designed for each. The characteristics of each group from the training
methods point of view are as follows:
Less Qualified Workers: Less qualified workers, whose are a majority in recycling SMEs, need both
initial and continuous training on general recycling and further on specific topics depending on recycling
area. The challenging problem is to provide eLearning solution which is appropriate for less ICT
experienced employees.
Management Staff: Management of recycling SMEs need a highly efficient continuous training in order
to be able to react quickly to the market conditions change, new organisation forms and new business
opportunities. Thus the whole spectrum of the ALCVET courses will be offered to them in an eLearning
form specifically adapted to their working conditions (lack of time-short eLearning lessons for flexible
use). The courses related to general topics will be organised also for management from business areas
closely cooperating with recycling. This will offer the advantages of organising learning groups and
transnational virtual study circles, particularly important for an increase of networking among these
organisations.
Technical Staff: Technical staff of SMEs has to be continuously educated on the latest technological
developments. The ALCVET courses related to PI, new technologies and ICT systems introduction will
be offered to them. In addition to the general aspects the area specific courses will be organised.
Trainers and Consultants: Trainers and consultants belonging to different kinds of training providing
organisations, educating SME staff on business topics and needing a highly efficient delivery of up to
date content. Another important part of this group are consultants coaching SME on PI (experts from
RTD and consultancy companies).
2.3 Student support system for the learners – mentors, tutors,
teachers
All existing courses are brought to the same learning technology level and included in an advanced and
comprehensive eLearning system enabling easy and efficient combination of the content for different
courses for different target groups in different recycling areas.
The needs and requirements of targeted users, already identified and analysed in the previous projects
are checked for validity, updated and extended with new ones for planned content extension (general
Deliverable PO2: Report on the about initial investigations of the ALCVET project outcomes
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recycling topics, local specifics etc) and for new regions/countries. The innovative content from the
previous projects is analysed and updated to meet the requirements and the methodology for transfer.
The courses are adapted to the approach for organisation of training in the new recycling areas,
countries/regions and cultures. Optimal ways for course transfer to new socio-cultural contexts are
identified, based on local training providers’ experiences and end-user requirements. The ALCVET
system is integrated into national/regional training systems for recycling SMEs in the partner countries.
Deliverable PO2: Report on the about initial investigations of the ALCVET project outcomes
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3 Analysis of the ALCVET training program from the
technical point of view
3.1 Delivery of the training – organisation of the course
Project ALCVET was focused on 4 different target groups. These groups were different in their main
characteristics such as: will to study, ability, possibility and will to use ICT as a support for their study (elearning), and levels of learning skills. All of these were into account before the ALCVET course was
executed. In order to achieve the course education goals, the following guidelines for the delivery of the
course for single target groups were prepared while the delivery of the ALCVET training had the same
blocks for each target group. These are:
-
Face to face (FTF) sessions
o Introductory FTF session
o Intermediate FTF session
o Closing FTF session
-
Independent study on line with or without the tutor support
The single parts can be described as follows:
-
Introductory FTF session: The first 4 hour FTF introductory session was focused on the following
topics:
o ALCVET project overview in order to spread the information about the course origin
o Course aims – short explanation of the course educational aims in order to explain
what they will gain by the course studying in both professional and study skills fields.
The short Power point presentation about the course aims can be prepared and later
placed in the Moodle.
o Course structure – this should be explained to prospective participants in details. The
division of the course into modules and chapters introduced by the tutor or teacher.
Tutor also should explain how chapters are divided into parts and how to use the
glossary as a support tool during the study. The tests and tasks of the course should
also be demonstrated,
Deliverable PO2: Report on the about initial investigations of the ALCVET project outcomes
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o Study support – during this session we should inform course participants what kind of
support we provide for them. Usually we should give them the contacts to their tutors
and mentors (if there are mentor in the course). We also should explain that beside the
human support there are support tools built in the Moodle.
o Moodle – this LMS should be introduced as the support tool suitable for the on line
course delivery. At the first session each participants should be given his/her login and
password. The tutor should go through complete process of logging in, studying on line,
using the glossary, working with tests as well as the navigation and use of
communication tolls provided by ALCVET Moodle should be demonstrated and explain.
o ALCVET study guide – in order to give participants a support for the independent study
the printed study guide is useful. Everything which explained during the introductory
FTF session should be recorded and printed in this guide. The example of such a guide
developed by the Slovak partner of the ALCVET project is annexed to this material.
-
Intermediate session: this should be at least four our session focused on the discussion with
participants and sharing the experience with study in the course. The main emphasis should be put by
the tutor on encouraging and supporting of the course participants. In the course we recommend to
have at least one intermediate session for those groups which are not used to independent study and
might be discouraged by the lack of personal contact with tutors or student fellows. Such session
should be organized shortly after the first third of the course is finished (according to the research
done this the time when the majority of e-learning students give up the study). If you plan to have two
or more intermediate sessions then plan them evenly during the course timetable in order to give the
regular FTF support to the e-learning course participants. However, we do not recommend more than
one FTF session monthly.
-
Closing session: 4 hour closing session is focused on the short time evaluation of the course. The
short time evaluation should be carried out at least by the two means: ALCVET feedback
questionnaires and brainstorming or facilitated discussion which should be recorded in written. The
closing session is place and time for participants to express their impressions and experience with the
e-learning course.
-
Independent on line study: this a time when students use the main advantages of the e-learning
course but at the same time all risks connected with this kind of course delivery usually occur. During
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this stage the tutors and mentors (if there are any, because we can deliver the course also without
any human support) play the main role. The tutors should send their responses in time and also
should encourage the course participants by any available means. The study materials can be
delivered to students in the various modes/forms or their combination according to the participants’
requirements: on line, on CD ROM, and/or printed.
For the single target groups of the ALCVET project the following types of the ALCVET course delivery
were recommended in the ALCVET Methodology handbook:
-
Managers of recycling SMEs On line course with 2 face to face (FTF) sessions is the most
suitable choice for this advanced target group which usually is too busy and according to our findings
prefers flexibility in study place and time. The course delivery is divided into 3 main parts:
o 4 hour introductory FTF session,
o independent on line study with the tutor support, and
o 4 hour closing FTF session
o Study materials are delivered on line and on CD ROM
o Study guide is delivered in printed form during the introductory session and on line
placed in the Moodle. The login and passwords are given to participants during the
introductory session.
-
Technical staff of recycling SMEs: Blended on line course with 3 FTF sessions:
o 4 hour FTF introductory session
o 2 hour FTF session after the first three lessons, which will be focused on the discussion
with tutors and fellow students on problems and experience
o 4 hour FTF closing session
o Study materials are delivered on line and on CD ROM
o Study guide is delivered in printed form during the introductory session and on line
placed in the Moodle. The login and passwords are given to participants during the
introductory session.
-
Consultants & Trainers: Fully on line course with 1 FTF session - 4 hour closing session. Study
materials are delivered only on line. The study guide is delivered also on line placed in the Moodle.
The login and passwords are delivered by e-mail.
-
Less qualified people: Blended course with at least 3 FTF sessions
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o 4 hour FTF introductory session
o 2 hour FTF session after the first three lessons, which will be focused on the discussion
with tutors and fellow students on problems and experience
o 4 hour FTF closing session
o Study materials are delivered on line, on CD ROM or printed
o Study guide is delivered in printed form during the introductory session and on line
placed in the Moodle. The login and passwords are given to participants during the
introductory session.
3.2 IT platform used in ALCVET
3.2.1
ALCVET system structure
The ICT part of the system comprises the functionalities as presented below:
-
Generic Content Development/Design Tools and/or Solution (Moodle) Specific Content
Development/Design Tools, in which Learning objects (lessons or parts of lessons) was created
-
Learning Content Management System which enables the Lesson/Course author to create
eLearning Modules - Lessons/Courses
-
Learning Management System, which allows for course organisation, execution and
administration, comprising the functionalities to enable interaction of all eLearning process
participants
The ALCVET system components is composed according Picture 1
Deliverable PO2: Report on the about initial investigations of the ALCVET project outcomes
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Instructor
(on-line
mentoring)
Author
Content
Development
(eLearning Objects)
LCMS
eLearning
modules
LMS
Learner
Administrator
Picture 1 System Concept as given in the ALCVET Handbook
-
Content Development/Design Tools
The selected SW tool Moodle allows for application of a number of generic content development/design
tools for authoring learning content - creation of Learning Objects, which can be exported to several
standard formats (SCORM 1.2, IMS or core HTML).
-
Learning Objects and Learning Modules - Lessons
The learning objects and learning bundles were the base of the ALCVET system aiming to support
collaborative learning and knowledge sharing among SME employees and SMEs according to their
needs. Learning Objects are defined as units of instructionally sound content centred on a learning
objective or outcome intended to teach a focused concept. The sets of Learning objects - collected
about a common theme are Learning Modules - Lessons. The ALCVET Lessons are divided in three
groups dealing with General Recycling topics, ICT supported process improvement, and New business
forms centred on SME networking.
The ALCVET Lessons are structured in a way that each lesson includes:
o explanation of the specific thematic part - textual/graphical/multimodal
o example (practical example)
o exercises - practice - test (set of multiple-choice questions, tasks etc.)
It was estimated that for each lesson an 'average student' spent between 40-60 minutes, to study
explanation and example, and to do the exercises. The total number of lessons should be maximum 15Deliverable PO2: Report on the about initial investigations of the ALCVET project outcomes
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20. This means that an 'average student' would need for the whole course maximum 20 hours + time for
training in the classroom (about 6-8 hours - to be defined). Assuming that a student will spend 2-3 hours
per day, he/she may need about 10 ± 1 working day.
According to the ALCVET solution concept, not all lessons were intended for all students/users i.e. the
lessons are specifically adapted to the target groups identified in the project (e.g. less qualified people
should not go into details on management etc.). In addition to the lesson content adaptation, also
different examples and exercises for different target users were provided. These adaptations were
realised applying generic eLearning tools (as changes in text or graphics).
The target users as defined in the ALCVET project were: Less qualified people, Management of
recycling SMEs, Technical staff of recycling SMEs, Consultants & Trainers.
-
Learning Content Management (Functionality) System and Learning Management
(Functionality) System
The functionality of the LCMS enables composition of learning objects into the eLearning modules, as "a
multi-user environment where learning developers may create, store, reuse, manage, and deliver digital
learning content from a central object repository". This functionality and the functionality of a Learning
Management System, as "a platform to manage and administer learner training, personalized content
delivery, learner collaboration, learner tracking and assessment, web-based training administration,
database administration, and monitoring of individual and group performance, skills and achievement",
were based on the built-in functionalities of the selected Moodle platform.
As mentioned above, the content creation was done in several ways, allowing collaborative work on it,
or even involvement of the external content suppliers in order to offer a complete service. Also the level
of granularity of the learning content to be reused (between the smallest LOs and complete lessons)
was selectable according to the application conditions.
Shortly overviewed the following major functions of a Learning Management Systems were provided in
the ALCVET system:
o Learner profile manager
o Learning offering catalogue manager
o Learning planner
o Connection to delivery environment for delivery of learning offerings
Deliverable PO2: Report on the about initial investigations of the ALCVET project outcomes
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o Delivery with participation tracking
o Assessment and testing tracking
o Collaborating functions to support the learning process within a virtual classroom and
upon request asynchronously (whiteboard, e-mail, messages, forum, chat)
o Multilanguage support
o Providing user statistics for tutors and training administrators
o Right and role management
In essence, they are intended to manage the learning environment, providing a place where content can
be organized and presented to learners, learning plans can be managed, and where learning activities
and results are tracked.
3.2.2
ALCVET System Security & User Roles
ALCVET system provides four distinct user roles: Super Administrator, Administrator, Instructor, and
Learner. Each user is authenticated at login and assigned the role associated with their username.
Based on that role, they have access privileges to certain screens, functions, and information.
-
Super Administrator can create, maintain, and delete information about multiple organizations.
The Super Administrator has screens to: create and maintain multiple organizations and all system
users and to assign the content groups and content styles available to each organization
-
Administrator can create, maintain, and delete information about individual organizations, its
courses and classes, and its instructors and learners. The Administrator can: maintain information
about a single organization and its instructors and learners; create, maintain, and delete courses and
sections; batch upload learners for account creation and class assignments
-
Instructor can maintain their own personal information and maintain information about the classes
to which they are assigned. The Instructor has screens to: maintain personal password and
information; add or remove learners from classes; activate exams and create class assignments; view
the grade book for their class
-
Learners can maintain their own personal information and password; access course content and
take exams; view their grade book and personal file storage
Deliverable PO2: Report on the about initial investigations of the ALCVET project outcomes
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4 Analysis of the ALCVET training program from the
SMEs’ point of view P3
The ALCVET training module is analyzed from the SME perspective and the findings are listed in two
ways:
-
General observations
-
Specific observations about specific chapters of the training module
The outcomes of the analysis will be used in the adaptation phase. Therefore, the ALCVET training
module is analyzed from a critical perspective and only the findings/observations regarding to
improvement of the training module are mentioned as outcome of the analysis.
During the analysis phase, the chapters are reviewed by the SA Consulting staff several times, each
time with another perspective as follows:
-
First review is done to understand the content of the ALCVET training module
-
In the second review, the content of the ALCVET training module is analysed from the
perspective of a middle-stage educated SME staff.
-
In the final review, the structure of the ALCVET training module is analysed and discussed
internally whether the structure is suitable for the SME staff at all.
4.1 General Observations about the ALCVET training module
The content of the document is well organized. From the SME perspective, most of the needed
information is placed in the document. The need of car recycling process is well defined. The
regulations are stated in multiple chapters for the car recycling system. The steps of recycling are
explained briefly in the chapters. Even the equipment used in the recycling system is described with
some examples. Last but not least, the possible finance sources are mentioned in the training sessions.
Therefore, the information content of the training module is sufficient and understandable in general.
From the nature of the SME, the target groups who may use this training module from an SME would
have lower education level than other target groups. Therefore the training documentation oriented to
the SMEs as target groups could contain:
-
more visual materials rather than pure text explanations
-
more real life examples rather than calculation methods / formulas
Deliverable PO2: Report on the about initial investigations of the ALCVET project outcomes
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-
more basic navigations rather than stating the general standards and opportunities
-
more structural introduction of the chapters
If the training module contents would be analyzed from the perspective of the above mentioned criteria,
the following findings can be listed:
-
The lack of visual materials is very obvious. The training modules can be enriched with related
pictures, diagrams even with some videos. The ALCVET training module is very suitable for the target
groups having higher education level. If the training module can be improved with the visual materials,
the courses would be more understandable from the personal of the SMEs and the module can be
introduced to the SME environment more easily.
-
Most of the training course with SMEs as the target groups is practice oriented. The subjects are
explained with real examples so that the participant can compare his/her own situation with the given
example and try to understand the introduced system. The section “Economy of SMEs in Recycling
Area” is a very good example for method. The financial impact of establishment of such a facility is
described and then the concept is extended by a real example. With this method, the SME personal
can easily understand the financial requirements of such an investment. It would be much more
elegant if these kinds of examples would be introduced in other chapters. It is clear that it is possible
to explain all the chapters with real life examples with use cases. On the other hand, the more real
time examples the chapters contain, the more SME personal get/accept the concept and try to make
them real.
-
The regulatory standards are very important and a crucial part of the ALCVET training module. It
must be understood by the SME staff so that the objectives should be followed by these people.
Therefore, having the regulatory standards as part of the training module is the correct decision. On
the other hand, the language of the regulatory standards is not easy to understand for those people
who are not familiar with them. And the SME staff is mostly unfamiliar with these kind of text
descriptions. A brief explanation of the rules mentioned in the standards would be very helpful the
SME staff.
-
The sequence of the courses is important as much as the content of the courses. The regulatory
standards are introduced in the ALCVET training module as second and third chapters. Without
having detail information from the car recycling methods, it would not be very meaningful to describe
the regulatory rules about the methods. Because of their level of education, the SME staff may lose
Deliverable PO2: Report on the about initial investigations of the ALCVET project outcomes
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their interest more easily than other target groups if they do not understand the concept at that
chapter. Therefore, the needs of the SMEs should be taken into consideration when the chapters in
the training modules will be ordered
From the above mentioned observations, there is some improvement potential in the ALCVET training
system where these observations may be taken into consideration during the adaptation phase of the
TransREC project.
4.2 Specific Observations about the chapters in ALCVET training
module
In the previous section, the findings are mentioned generally where the specific chapters of the ALCVET
training module is not mentioned explicitly. In this section, the findings for each chapter will be
mentioned briefly. In order not to repeat the findings, the comments are limited for each chapter. The
following table contains the comments for each chapter.
Ch. Title
1
Comments
Human protection and the
-
environment
understand even for the less educated staff
-
The chapter is well structured and easy to
The reasons of the hazard are explained briefly.
But it would be more understandable if the
consequences of the hazards are explained with some
examples.
-
There are some statistical data mentioned in the
chapter, this is a con. On the other hand, the sources
of the statistical data are not mentioned in footprints.
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2
3
Legislation dealing with environmental
-
No additional suggestion necessary. The chapter
protection and ELV in Europe - the
is only about the EU directives
present condition, needs, goals and
-
activities (summary)
directives in a more simple way for the SME staff?
Legislation dealing with environmental
-
protection and ELV recycling different
some state organizations mentioned in some sections.
countries
This is ambiguous for the other trainees from other
What about explaining some details of the
The chapter is about the legislations and there are
countries, even for some of the polish SME staff. It
would be better to give short descriptions about the
public authorities responsible in any part of the chain.
-
Some definitions are needed in general.
-
The German legislations are missing, but this is
not a big issue since the target groups are more or
less from Poland.
4
State of development of recycling in
-
The objections of the chapter are not clear. The
the world and Europe
content is divided again into two and the countries are
analyzed in each section in different ways. It is a little
bit confusing.
-
There are not SME details at all.
-
The contents of each section are very well
defined. Rules are Statistics are mentioned in the
sections. It would be better to have a common table
which compares the status in different countries to
give a better perspective to the trainee.
5
6
Tasks and Requirements for
-
Dismantling Stations of ELVs
relationship of the subject with the target group.
Economy of SMEs in Recycling Area
It is necessary to mention explicitly the
-
The content of the chapter is excellent
-
This chapter is very important for the SMEs.
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-
Some prices are given in some sections. But they
are very different in different countries. It makes sense
to give the prices from different countries and
compare them.
-
In TransREC, the Turkish local funds should be
mentioned as in this chapter.
-
Adaptation of this chapter to the Turkish market is
crucial for the TransREC training module.
7
Possibilities of financing waste
-
The content of the chapter is well defined and
management activities from the
very useful for the SMEs.
national funds
-
In sections, some data is given for different
countries where different currencies are used. By this
way, the trainee cannot compare the data between
countries. Unification of currency and all other units in
the training module is important.
8
Possibilities of financing ELV recycling
-
The content is very well defined and useful for the
activities from the EU funds
SMEs.
-
Maybe, this can be the part of Chapter 7.
-
Is it possible to explain the funds in SME
perspectives with some examples like :
9
-
Fund source X is useful for first investment
-
Fund source Y is useful for staff cost
-
etc.
Technical and organizational solutions
-
The content of the chapter is well defined and
for Dismantling Stations of End-of-Live
structured.
Vehicles (ELV)
-
It would be better if this would be described in the
early chapters. (Chapter sequence is not OK)
10
The Technical Equipment of ELV
-
The chapter is well defined and it is easy to
Dismantling Stations
understand
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-
During adaptation maybe, some new technologies
can be added
11
Needs for ICT in recycling SMEs
-
Chapter contains general information about
applying of ICT to the SMEs
-
Some examples would make the need more
obvious
12
13
Problems by selection and introduction
-
The chapter can be combined with chapter 11
of ICTs in SMEs
since it is very short and related to that chapter
Computer based technology and
-
The content of the chapter is well defined
software modules for ELV recycling
-
During adaptation of the chapter, the content of
the chapter can be enriched with:
14
-
Software used in Turkey
-
New introduces software alternative since then
Quality aspects for spare parts and
-
The placement of this chapter to the end is not a
materials
good idea.
-
The content is important and well documented
-
There are some missing section
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5 SUMMARY OF THE REGULATION ON CONTROLLING
THE END-OF-LIFE VEHICLES
5.1 CHAPTER 1: Objectives, Scope, Grounds, Definitions and
General Principles
-
Objectives (Article 1)
This regulation aims to protect human health and environment by preventing the formation of waste
resulting from the vehicles, to reuse the components of withdrawn vehicles, to reduce the amount of
waste to be disposed by recycling and recovery and to determine the standards and the obligations
regarding economic operators and temporary storage areas.
-
Scope (Article 2)
This Regulation is applied regardless of how the used parts of the vehicles have been serviced or
repaired, and whether the repaired parts are relevant to the existing legislation. It is also applied
depending on national legislation about the particular safety standards, air emissions, noise control and
soil and water conservation.
Almost all types of vehicles are the subjects of this regulation except military vehicles. The recycling
process of military vehicles is regulated under the law of The Foundation of Mechanical and Chemical
Industry (Government).
-
Grounds (Article 3)
This regulation has been prepared according to the provisions in the article 4856 dated 1st May. 2003
(The legislation about the organization and duties of Ministry of Environment and Forestry) and the
article 2872 dated 9th Aug. 1983 (The Environmental Law).
-
Descriptions (Article 4)
Components: Any component incorporated to a vehicle during the production process.
Vehicle: All types of motor vehicles and trailers. The vehicles with maximum 8 seats besides the driver
for passenger transport (M1), freightage vehicles able to carry maximum 3500 kilograms (N1) and threewheeled vehicles except motorcycles and mopeds.
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Owner: The most recent owner of the vehicle before scrapping according to the Road Traffic Law No.
2918 dated 10th Oct. 1983.
Ministry: Ministry of Environment and Forestry
Disposal: Any of the procedures mentioned in the Regulation on General Principles of Waste
Management Annex II A published in the Official Gazette No. 26927 dated 7th May. 2008.
Economic Operators: Manufacturers of vehicles and their parts and materials, distributors and
importers, and the ones, who collect, dismantle, shear, shred, recover or recycle.
Energy Recovery: The direct use of combustible wastes or other wastes to produce heat for power
generation.
Temporary Storage Area (TSA): In accordance with Annex 1, TSA is the area where vehicles are
decontaminated, dismantled and kept temporarily until they are sent to operation centers. These areas
have to get environmental permits and licenses in accordance with Article 15.
Recycling: The use of the original or other waste materials for reprocessing in a production process
excluding energy recovery.
Processing: All the activities processed after the delivery of end of life vehicles to a facility; the
operations applied for purification, removal, cutting, crushing, shredding and recycling.
Processing Facility: The facility able to do the activities like cutting, crushing, shredding, recycling or
disposing end of life vehicles and their components. These facilities are founded according to Article 15
(environmental permits and license).
-
General principles (Article 5)
The rudiments on the control of end of life vehicles are mentioned below were prepared through the
provision derived from General Principles of Waste Management Law.
a) Import of end of life vehicles is prohibited.
b) To promote recycling practices, the use of recyclable materials in vehicle production is increased.
c) The new materials and components of vehicles and their design and manufacture are done in
accordance with the dismantling of end of life vehicles and to facilitate the recovery and recycling.
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5.2 CHAPTER 2: Duties, Authorities and Liabilities
-
Duties and Liabilities of the Ministry (Article 6)
Ministry
o is responsible for giving environmental permits and licenses according to Article 15
o evaluates reports prepared in accordance with Article 20 and to create a database on it
o supervises economic operators and if any violation is determined according to the
provisions of this Regulation, it applies criminal proceeding
-
The responsibilities of the owner of the vehicles (Article 7)
The owner of the vehicle is responsible for leaving his/her vehicle to end of life vehicles facilities and
TSAs in accordance with Article 12, and also obliged to take approved withdrawn and disposed vehicle
in accordance with article 13.
-
The responsibilities of the economic operators (Article 8)
Economic operators are responsible for complying ban on the use of hazardous substances, required
coding, reporting, licensing and type approval to fulfilling their obligations, setting up ELV system or
taking part in one of those, processing collected ELVs, re-using, recovering and recycling at determined
rates.
-
The responsibilities of the insurance companies (Article 9)
The insurance companies are responsible for leaving the vehicles are not economic to repair to TSAs. If
there is a controversy between the owner and insurance company about the damaged vehicles, the
insurance company is responsible for leaving the vehicles to TSAs. Also the insurance company must
inform the Ministry about unregistered vehicles annually. The damaged parts taken from the vehicles
while repairing must be transferred to TSAs by the insurance companies.
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5.3 CHAPTER 3: Prohibition of the Use of Hazardous Substances in
Vehicles and Labelling
-
Prohibition of the Use of Hazardous Substances (Article 10)
The use of hazardous substances in vehicles is limited to facilitate recycling, to prevent the spread of
hazardous substances to the environment and to reduce spread of hazardous waste to be disposed.
-
Labelling the Hazardous Substances (Article 11)
In producing vehicles and their parts and components, except for the exemptions listed in Annex 2 lead,
mercury, cadmium, hexavalent chromium is prohibited.
5.4 CHAPTER 4: Collection of End of Life Vehicles, Using
Unregistering and Disposing Vehicle Forms (Article 12, 13)
Economic Operators (EO) found the Temporary Storage (TSA) and Storage Areas (SA) from a
reachable distance. If this is not possible for EOs, the manufacturers are responsible to found. TSAs
and SAs accept the ELVs without demanding any fee.
5.5 CHAPTER 5: Processing Facilities with Normative
Considerations and Environmental Permits and Licenses
-
Processing Facilities with Normative Considerations (Article 14)
Processing facilities must operate according to following matters;
o To avoid contamination of the nonhazardous wastes produced in processing with
hazardous substances, end of life vehicles and parts will not be sent to recycling
facilities without removing or purified.
o Dismantling and storage operations, reuse of the vehicle parts, recovery and recycling
are carried out in a suitable way. To do so separate storage areas are formed for the
parts or components to be used again, recovered and recycled.
o To minimize the environmental impact arising from end of life vehicles, the vehicle's
disintegration and fragmentation are done in accordance with the manufacturers’
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manuals. These parts and components are marked as lead, mercury, cadmium,
hexavalent chromium, and are collected in separate containers.
o The vehicles accepted by TSAs must be decontaminated in 30 days according to
Annex 1.
-
Environmental Permits and Licenses (Article 15)
The permits and licenses are taken according to the article dated 04.29.2009 and numbered 27214
(Regulation about applying Environmental Law published in the Official Gazette.)
5.6 CHAPTER 6: Reuse-Recycle and Reuse-Recycle Ratio and Type
of Approval
-
Reuse-Recycle and Reuse-Recycle Ratio (Article 16)
If the removed parts from end of life vehicles meet the safety and environmental standards, they are
used again. If non-reusable parts are environmentally appropriate, they are recycled or recovered.
These activities are carried out according to the environmental requirements such as air emissions,
noise control. To do so, economic operators shall comply with the following principles;
o Reuse and recovery ratio of end of life vehicles must be at least 85% of the average
vehicle weight; reuse and recycling rate must be at least 80% of the average vehicle
weight.
o For vehicles manufactured before 1/1/1980, reuse-recovery rate cannot be less than
75% of the average vehicle weight, and reuse-recycling rate cannot be less than 70%
of the average vehicle weight.
o Reuse-recovery ratio for end of life vehicles manufactured after the date of 01/01/2020
must be at least 95% to the average vehicle weight; reuse-recycle ratios can be
increased to at least 85% of the average vehicle weigh.
-
Type of Approval (Article 17)
To design new vehicles; reuse, recycling and recovery rates are determined by the Ministry of Industry
and Trade. On the basis of these principles, the manufacturer shall receive the type approval from the
Ministry of Industry and Trade.
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5.7 CHAPTER 7: Miscellaneous and Final Provisions
-
Material Encoding standards and the Preparation of Dismantling Information (Article 18)
Encoding is done by car parts and material suppliers according to the specified standards to be able to
distinguish the suitable materials for recycling and re-use easily. For this purpose;
o TS EN ISO 1043-1, TS EN ISO 1043-2 and TS EN ISO 11469 standards are applied
for plastic materials weighing more than 100 grams in vehicles.
o TS 1531 ISO 1629 standard is applied for rubber materials weighing more than 200
grams in vehicles
o In order to attain the rates specified in the 16th article by the processing plants; the
manufacturers provide the information of dismantling of every new vehicle, the type
approval of which they receive the latest within six months after the vehicle is launched.
In the dismantling information, the places of plastic, iron, non-ferrous metals, rubber
and such different types of materials, parts and hazardous substances must be clearly
stated in the vehicle.
o On the condition that the commercial and industrial secrets are kept, parts
manufacturers have the responsibility of giving enough information regarding the
dismantling, storing testing of reusable parts in case the temporary storage areas and
the processing plants demand.
-
Informing (Article 19)
The manufacturer must have the vehicle design information of the vehicles in terms of recycling and
recovery and the data of environmentally compatible decontamination and dismantling procedures of
the dead cars in the prospectus of the vehicle.
-
The Obligation to report (Article 20)
o Economic operators are obliged to send the tables in Annex 4, within the scope of
Article 16 of reuse-recycle and reuse-recycle ratios, by the end of February each year
to the Ministry.
o Manufacturers must give a report including the amount of yearly production for
domestic market, the amount of imports, exports and the activities related to their
obligations under the Article 8 each year to the Ministry until the end of February.
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-
Transport (Article 21)
The transportation of the end of life vehicles is done according to the regulations for the transportation of
hazardous materials via overland route, which was published in the Official Gazette with No. 26479 and
dated 03.31.2007,
-
Recovery, Recycling, Energy Recovery and Disposal (Article 22)
o The re-use, recycling, recovery and disposal of materials, components and waste
produced as a result of processing of dead vehicles are done according to the
regulations of Annex 1 of Article 5 listed.
o To classify the waste produced during the demounting process, sample is taken
according to the LAGA PN 98 standard or an equivalent one. In such wastes, the
determination of PCBs is done according to DIN 38414-20 standards, the hydrocarbon
content is done in accordance with EN 14039 standards.
-
Contrariety to the Regulation (Article 23)
In case of any violations against the regulations, the procedure is done according to the environmental
Law No. 2872 of Article 15 and Article 20, first paragraph of (g), (r), (s), (u) and (v) above and Article 23.
-
Export and Transit (Article 24)
The export and transit of the end of life cars are done according to the Hazardous Waste Control
Regulations which was published in the Official Gazette with No. 25755 and dated 03.14.2005.
-
Granting Licenses to Existing Processing Facilities (Temporary Article 1)
The existing processing facilities are required to obtain a license within twelve months following the date
of publication of this regulation according to the first paragraph of Article.
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5.8 STATISTICS ABOUT VEHICLE RECYCLING
Table 1: The statistics about the vehicles in (Temporary) Storage Areas
AGE
TOTAL
NUMBER
RATE CARS
%
RATE
COMMERCIAL
RATE
(CARS)
VEHICLES
(COMMERCIAL
%
VEHICLES) %
1-3
1.841.044
15.3
1.196.520
14.7
644.524
16.3
4-6
1.714.448
14.2
987.508
12.2
726.940
18.4
7-11
2.494.718
20.7
1.487.135
18.3
1.007.583
25.5
12-15
1.892.709
15.7
1.318.892
16.3
573.817
14.5
16-19
1.391.310
11.5
1.056.979
13.0
334.331
8.5
20+
2.727.785
22,6
2.066.077
25.5
661.708
16.8
TOTAL 12.062.014
100
8.113.111
100
3.948.903
100
Source: Statistical Institute of Turkey
Table 2: The projection to the reduction in green hose gases and other polluting gases by 2016 in
Turkey if the 12-year-old and over vehicles are unregistered (1000 tones/year and %)
Source: Statistical Institute of Turkey
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Table 3: Unregistered cars per year
YEAR
Number of
unregistered
cars
2012
2011
2010
2009
2008
2007
2006
2005
2004
2003
30.027
34.008
34.712
60.651
28.695
22.331
28.295
34.502
250.630
76.014
TOTAL
599.865
Table 4: Number of cars over 15 year-old.
YEAR
Number
of cars
1999
1998
1997
1996
1995
1994
1993
1992
1991
258.870
355.802
281.166
231.546
204.677
337.234
388.651
280.056
190.668
1990
203.715
YEAR
1989
1988
1987
1986
1985
1984
1983
1982 and before
112.543
124.647
107.915
84.520
64.190
51.826
39.139
397.765
TOTAL
3.714.930
Picture 2: The vehicle recycling process and methods
-Vehicle Identification: Collation
of documents to accompany
-Acceptance: The insurance
company or the owner brings the
vehicle to storage areas.
vehicle, determining extent of
dismantling work, recording into
software, issue of certificate of
-Shredding and post-shredding
destruction
process
-Removal of Core Scrap &
-Marketing used parts
Dismantling: Marketable used
-Marketing used materials
parts, marketable materials
-Removal of fluids and
hazardous materials
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Number
of cars
31