State of California
TIRE PRODUCT STEWARDSHIP
FINAL
ACTION PLAN
Prepared for the
CA Integrated Waste Management Board
By the
Product Stewardship Institute, Inc.
July 2005
Table of Contents
I.
II.
III.
IV.
V.
VI.
VII.
VIII.
PURPOSE OF ACTION PLAN ..................................................................................... 1
PROBLEM STATEMENT ............................................................................................ 1
PROJECT GOALS ......................................................................................................... 2
Primary Goal .................................................................................................................. 2
Supporting Goals ............................................................................................................ 2
THE PSI DIALOGUE PROCESS.................................................................................. 2
Phase I (Research and Outreach) .................................................................................... 2
Phase II (Tire Stewardship Forum) ................................................................................ 3
ISSUE PRIORITIZATION ............................................................................................ 3
Top Tier .......................................................................................................................... 3
Second Tier ..................................................................................................................... 4
Third Tier........................................................................................................................ 4
PROJECT TIMELINE ................................................................................................... 4
CURRENT TIRE MANAGEMENT .............................................................................. 4
Landfilling ...................................................................................................................... 5
Tire Collection ................................................................................................................ 5
Reuse/Retread/Remolds ................................................................................................. 6
Crumb Rubber ................................................................................................................ 8
Crumb Rubber Markets .................................................................................................. 9
Recycled Content in Tires .................................................................................. 9
Loose Fill Crumb Rubber Products .................................................................. 10
Molded Products from Crumb Rubber ............................................................. 10
Rubberized Asphalt Concrete ........................................................................... 11
Civil Engineering Applications .................................................................................... 13
Landfill Applications ........................................................................................ 14
Lightweight Fill ................................................................................................ 15
Septic Field Drainage ....................................................................................... 15
Road Base ......................................................................................................... 15
Tire Derived Fuel and Tire Chip Fuel .......................................................................... 15
EXISTING TIRE RELATED PROJECTS IN CALIFORNIA .................................... 17
Laws and Regulations................................................................................................... 17
Tire Management Fee ................................................................................................... 17
Extending the Lifespan of Tires ................................................................................... 18
Increasing the Recycled Content in New Tires ............................................................ 19
Tire Grant Programs ..................................................................................................... 20
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IX.
TIRE STEWARDSHIP PROJECTS OVERVIEW ...................................................... 21
Tire Product Stewardship in the United States ............................................................. 22
Tire Industry Overview ................................................................................................ 23
Tire Product Stewardship in Canada ............................................................................ 24
Tire Product Stewardship in Europe............................................................................. 24
Product Stewardship Models ........................................................................................ 26
Performance Goals – National Carpet Dialogue .............................................. 27
Cost Internalization – Rechargeable Battery Recycling Corporation .............. 28
X.
ISSUES AND STRATEGIES ...................................................................................... 28
Issue 1: Waste Tire Generation ................................................................................... 28
Potential Strategies ........................................................................................... 29
Issue 2: Waste Tire Markets ........................................................................................ 30
Potential Strategies ........................................................................................... 30
Issue 3: Tire Reuse, Retread, and Remold .................................................................. 31
Potential Strategies ........................................................................................... 31
Issue 4: Collection and Transportation ........................................................................ 32
Potential Strategies ........................................................................................... 32
Issue 5: Crumb rubber markets.................................................................................... 33
Potential Strategies ........................................................................................... 33
Issue 6: Recycled Content in New Tires ...................................................................... 35
Potential Strategies ........................................................................................... 35
Issue 7: Rubberized asphalt concrete markets (RAC) ................................................. 36
Potential Strategies ........................................................................................... 36
Issue 8: Shredded tire markets ..................................................................................... 38
Potential Strategies ........................................................................................... 38
Issue 9: Recreation markets ......................................................................................... 39
Potential Strategies ........................................................................................... 39
Issue 10: Tire-derived Fuel .......................................................................................... 40
Potential Strategies ........................................................................................... 40
Issue 11: Landfill Disposal .......................................................................................... 41
Potential Strategies ........................................................................................... 41
Issue 12: Sustainable Financing .................................................................................. 42
Potential Strategies ........................................................................................... 42
XI.
PROPOSED PROJECT SUCCESS METRICS ........................................................... 43
XII. RECOMMENDATIONS ............................................................................................. 43
APPENDIX A: PSI Interview List ......................................................................................... A-1
APPENDIX B: Stakeholder Survey and Tabulated Response ............................................... B-1
APPENDIX C: Resource Conservation Challenge Tire Cluster Goals .................................. C-1
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List of Tables
Table 1. Tire Management in California (2002) ............................................................................. 5
Table 2 Market Share by Major Tire Manufacturers.................................................................... 23
Table 3. Used Tires Analysis in 2002 in Europe ........................................................................... 26
Table 4. Summary of the National Goals For Carpet Recovery.................................................... 27
PSI Tire Stewardship Final Action Plan
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State of California
TIRE PRODUCT STEWARDSHIP
FINAL ACTION PLAN
I.
PURPOSE OF ACTION PLAN
This Tire Product Stewardship Action Plan, in draft form, prepared participants for a
one-day dialogue meeting facilitated by the Product Stewardship Institute (PSI).1 The
original Draft Action Plan included a proposed problem statement, project goals, technical
background information, key issues, and potential strategies derived from interviews with 22
key stakeholders. This Final Action Plan includes revisions made to the Draft Action Plan
based on comments made at the dialogue meeting, and provides a starting place for further
discussions. The contents of this Final Action Plan reflect varying perspectives on waste tire
management and not a unanimous approach.
II.
PROBLEM STATEMENT
California is faced with the challenge of diverting or safely managing more than 33
million reusable and waste tires2 generated in the state each year. Approximately 25 percent
of these tires are disposed of in landfills. Though California has more registered vehicles than
any state, concern over tires is not unique to the west coast. Across the country, the growth in
end use markets for waste tires has increased dramatically, from 11 percent of waste tires
generated in 1990 up to 80 percent of waste tires generated in 2003. Still, the markets are
not currently sufficient to accommodate the annual waste tire generation rate. Stockpiles of
tires create fire hazards, environmental threats, and serious health nuisances. In addition,
successful and comprehensive waste tire programs must also include resources for the
enforcement and abatement of illegal dumping. Owing to these concerns, state and local
government agencies often rank tires as one of their top waste management priorities.
1
Funding for this project was provided by the California Integrated Waste Management Board.
2
According to California statute 42807, Waste Tires are defined as “…a tire that is no longer mounted on a
vehicle and is no longer suitable for use as a vehicle tire due to wear, damage, or deviation from the
manufacturer's original specifications. A waste tire includes a repairable tire, scrap tire, and altered waste tire,
but does not include a tire derived product, crumb rubber, or a used tire that is organized for inspection and
resale by size in a rack or a stack in accordance with Section 42806.5.” Waste tires are also called scrap tires by
some organizations.
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III.
PROJECT GOALS
Primary Goal
To reach an agreement among government officials, manufacturers, retailers, environmental
groups, tire recyclers, and other participants that will result in fewer waste tires; the efficient
collection, reuse, and recycling of waste tires; increased and sustained waste tire markets;
maximum value from waste tires; and fewer waste tires going to landfills.
Supporting Goals




IV.
Increase tire life to reduce generation rates.
Attain the highest value possible for waste tires, according to the following
management options:
― Reduce
― Reuse
― Retread
― Recycling into other products (including civil engineering applications)
― Tire-derived fuel and chipped-tire fuel (energy value from combustion)
― Proper disposal
Improve collection and recycling practices.
Reduce the illegal dumping of waste tires.
THE PSI DIALOGUE PROCESS
PSI’s Tire Stewardship Initiative is devoted to bringing together key parties to jointly
solve problems related to the management of post-consumer waste tires. The tire stewardship
meeting that PSI facilitated included representatives involved in the manufacture,
distribution, sale, use, processing/recycling, and disposal of waste tires.
Phase I (Research and Outreach)
The Tire Product Stewardship Draft Action Plan culminated the first phase of the
project. It highlighted research conducted by PSI, and outlined key issues and potential
solutions to problems associated with managing waste tires in California. The issues and
solutions were identified from 22 interviews with key stakeholders. (See Appendix A for a
list of stakeholder groups that PSI interviewed.)
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Phase II (Tire Stewardship Forum)
The Draft Action Plan provided information that laid the foundation for a one-day
Tire Stewardship Forum on July 28, 2004. At the forum, stakeholders discussed priority
issues, potential solutions, and goals outlined in the Draft Action Plan. PSI coordinated and
facilitated this meeting, developed the meeting agenda, presentations, and summary, and
maintained a web site with project information. Funding limited the dialogue phase to one
meeting.
Following the forum, PSI developed this Final Tire Product Stewardship Action Plan,
which includes a revised problem statement and dialogue goals, a revised list of issues, and a
refined set of strategies. It also incorporates meeting highlights, agreed upon next steps, and
recommendations for future consideration. This Final Action Plan ultimately lays the
groundwork for future meetings pertaining to the management of waste tires.
V.
ISSUE PRIORITIZATION
The Tire Stewardship Forum was designed to provide input on elements of the Draft
Action Plan. Since funding was available for only a one-day meeting, PSI designed the
meeting to address stakeholder priorities. PSI distributed a written survey to all stakeholders,
and asked them to rank each of the twelve issues and corresponding strategies. Thirteen
participants completed the survey – six tire manufacturers, three government officials, two
retailers, one recycler, and one consultant.
The respondents ranked the issues for the dialogue from 1 (being the highest priority),
to 12 (being the lowest priority). They also ranked individual strategies, from 2 (strongly
agreeing with that strategy), all the way to negative 2 (strongly disagreeing with the strategy),
with zero being neutral. Respondents also had the opportunity to add strategies and make
comments, both of which PSI recorded. Based on the survey responses, PSI organized the
issues in the following three categories based on the level of interest demonstrated in the
surveys (see Appendix B for the survey and tabulated responses). The issues appear below
with the ranking they received from the tabulated surveys (e.g., #1, #2, etc.) and the issue
number to which they correlate in this Final Action Plan (e.g., Issue 2, Issue 10, etc.).
Top Tier
#1 - Waste Tire Markets (Issue 2)
#2 - Tire-derived Fuel (Issue 10)
#3 - Recycled Asphalt Concrete (Issue 7)
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Second Tier
#4 - Shredded Tire Markets (Issue 8)
#5 - Crumb Rubber Markets (Issue 5)
#6 - Collection and Transportation (Issue 4)
#7 - Waste Tire Generation (Issue 1)
#8 -Tire Reuse, Retread, Remold (Issue 3)
Third Tier
#9 - Recreation Markets (Issue 9)
#10 - Sustainable Financing (Issue 12)
#11 - Landfill Disposal (Issue 11)
#12 - Recycled Content in New Tires (Issue 6)
As the surveys indicated, stakeholders value issues differently. PSI attempted to
design the Forum so that the issues discussed were of the highest interest to the most number
of people. Since PSI was constrained to a one-day meeting, the meeting was designed so that
nine issues were covered generally, with three issues being discussed in slightly more depth.
PSI recommends that the nine issues be discussed in greater depth in future stakeholder
meetings.
VI.
PROJECT TIMELINE
January – February 2004
February – March
April – July
July 28
April 2005
Post-April 2005
VII.
Developed Workplan/Conducted Research
Conducted Stakeholder Interviews
Developed Draft Tire Stewardship Action Plan
Stakeholder Meeting in Sacramento, CA
Developed Final Tire Stewardship Action Plan
Additional CIWMB Stakeholder Meetings
CURRENT TIRE MANAGEMENT
California is faced with the challenge of managing 33.5 million waste tires generated
in the state each year, of which about 75 percent are diverted from stockpiles or disposal (see
Table 1 below). In addition, while California has made great progress in cleaning up tire
dumps, an estimated 2 million tires remain in stockpiles or illegal dumps, increasing the risk
of fires. In fact, California has experienced two devastating waste tire fires – in the city of
Westley in 1999, and in the city of Tracy in 1998.
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Table 1. Tire Management in California (2002)3
Application
Tires (in millions)
Percentage
Reused
Crumb rubber
Civil engineering applications
Other recycling uses
Retread (light and heavy)
Tire derived fuel
Net Export
Total Tires Diverted4
Tires Disposed
Total Tires Generated in CA
1.5
5.8
3.0
5.9
2.3
6.1
0.5
25.1
8.4
33.5
4.5%
17.3%
9.0%
17.6%
6.9%
18.2%
1.5%
75.0%
25.0%
100%
Landfilling
Currently, 25 percent of waste tires generated in California are landfilled, even though
state solid waste regulations require that only shredded tires be legally accepted at landfills.
The low cost of landfilling shredded tires in the state makes this method the least expensive
of all management options. Landfilling is also a convenient disposal option, as most of
California’s landfills accept shredded tires for disposal. In addition, some tire haulers own
and operate landfills, further reducing their business costs in comparison to other options.
While landfills serve as the option of last resort for waste tires, it will take greater market
development for fewer tires to be landfilled.
Tire Collection
Tires are typically collected by retailers, tire dealers (including those that deal
exclusively in used tires), the waste management industry, public and private fleets, and
municipal and county governments. In California, as in most locations across the country,
waste tires collected by government agencies often occur through tire “Amnesty Days” or at
one-day special collection events (such as in conjunction with household hazardous waste).
One challenge faced by those collecting tires is the need to contract with a hauler who
can meet all state and federal environmental laws. In California, anyone who collects, hauls,
stores, or processes tires must be registered with the state. In addition, any person
transporting 10 or more waste tires at a given time must be a registered hauler. In California,
there are 16,000 state registered tire generators.
California Waste Tire Generation, Market & Disposal – 2002 Staff Report. California Integrated Waste
Management Board. October 2003. http://www.ciwmb.ca.gov/Publications/default.asp?pubid=1047.
4
Includes 0.5 million net exported tires.
3
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In 1995, California instituted a tire manifest system that was designed to provide
oversight of tire haulers and processors to reduce non-compliance with California’s laws. In
2001, California revised its law (SB876) to provide even more oversight. Under the new law,
the requirements for tire haulers and processors did not change dramatically, although
enforcement increased. In addition, the new law included tire generators in the manifest
system, so generators now have to submit paperwork to the state. The goal of the revision
was to increase oversight and tracking to ensure that tires are being managed properly. While
this law was successful in reducing non-compliance, the manifest and reporting system
became burdensome for smaller retailers and haulers who, in many cases, were not properly
tracking materials as was required in the past.
Today, only two of the state’s large haulers are capable of submitting the proper
manifest paperwork electronically, saving them reporting costs, while others must submit by
mail. Retailers find that this factor contributes toward reduced competition and high hauler
costs. The lack of competition for who can meet the new manifest requirements also means
that collectors have little leverage in specifying more environmentally sound management
methods. The state has offered technical assistance to companies interested in submitting
forms electronically although, to date, none of the companies that expressed interest followed
through and used the resource.
Retailers have raised other collection concerns. When a person purchases a new tire,
they usually leave their old tire behind for proper management. While this system offers a
convenient collection point for consumers, it also creates challenges for the retailer. In most
cases, retailers have limited space to store waste tires. In addition, many local governments
will not allow retailers to store used tires outdoors. Therefore, retailers struggle with locating
space within their facility to store tires until a hauler can pick them up for proper
management in a timely manner so that the number of tires do not become unmanageable or
unsafe. To accomplish this, smaller tire retailers often become part of a “milk run” operation,
whereby a hauler comes by at a regularly scheduled pick-up time (such as weekly or
monthly) to collect the tires.
Reuse/Retread/Remolds
Reuse refers to when a tire has been used once but still has useful life and could be
used again.5 Tires are most often reused and resold by retailers or dealers changing tires on a
vehicle. Reuse also occurs by haulers who segregate and sell used tires to some tire dealers.
5
According to California statute 42806.5, Used Tire is defined as “…a tire that meets all of the following
requirements: (a) The tire is no longer mounted on a vehicle but is still suitable for use as a vehicle tire. (b) The
tire meets the applicable requirements of the Vehicle Code and Title 13 of the California Code of Regulations.
(c) (1) The used tire is ready for resale, is stored by size in a rack or a stack not more than two rows wide, but
not in a pile, and is stored in accordance with local fire and vector control requirements and with state minimum
standards. (2) A used tire stored pursuant to this section shall be stored in a manner to allow the inspection of
each individual tire.”
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According to California’s 2001 report,6 1.5 million tires were reused that year. One
stakeholder estimated that approximately 10 percent of all tires disposed of at retail could be
reused, while another noted that 2 to 5 percent of all incoming tires are currently segregated
for reuse. While there are more opportunities for reuse than are being taken today, used tires
must often compete with inexpensive new tires, so consumer prices for used tires must
remain low. It was also noted by one stakeholder that there could be significant market
potential for used tires in Mexican tire markets.
In addition, tires can be retread, in which the tire casings are recapped. Approximately
1,060 retreading plants in North America are owned and operated by independent small
businesses, new tire manufacturers, and a major tread rubber supplier. Nationally, retread
businesses sold about 20 million retreaded tires in North America in 2003, with sales totaling
more than $2 billion. The majority of these sales were medium truck tires. In California,
there are 59 companies and retailers that sell retread tires for light and large commercial
trucks, industrial and farm vehicles, and passenger vehicles. The Tire Retread Information
Bureau estimates that 737,500 retread tires are sold in California each year.7 Retreading is
most cost-effective and viable for large commercial truck tires.
Waste tires with casing integrity can be retread after passing company inspection for
flaws and other concerns. Unfortunately, retreads have a bad reputation among those who
mistakenly assume that tire pieces on the side of the road are derived from retreads and
believe them to be inferior to new tires. The fact is that retreading a tire extends the tire
casing life and gives that tire another life equal to its original. Tire pieces along the road are
most often a result of a failure to maintain sufficient air pressure, which causes tire casings to
become extremely hot and eventually come apart. A retread is no more likely to come apart
than a new tire. While California state government and the private sector recognize the
benefits of retread tires, there is a tremendous opportunity to increase retread use in local
government fleets.
In addition, a July 2003 draft report from the California Integrated Waste
Management Board8 notes that increasing retreads could have a positive impact on the ability
of tire manufacturers to acquire high-quality, pure rubber feedstock. Since high-quality
buffings, used in new tires, are a byproduct of the retread process, increasing retread use in
passenger and light truck tires would increase the supply of buffings and make recycled
content in new tires more feasible. Countering this, however, the Tire Retread Information
Bureau contends that there is only a small market for retreads in passenger and light truck
tires since there are no cost savings by using retreads over new tires. When consumers are
given the choice, they will always choose a new tire.
6
California Waste Tire Generation, Market & Disposal – 2002 Staff Report. California Integrated Waste
Management Board. October 2003.
7
Telephone conversation with Harvey Brodsky, Tire Retread Information Bureau, April 2004. Estimated by
taking the weekly average of 250 tires x 59 companies x 50 weeks. There are more large retread plants in
California than other states. California likely sells more retread tires annually than this figure represents.
8
California Integrated Waste Management Board. Increasing the Recycled Content in New Tires (draft). July
2003.
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Remolded tires are another option for extending the life of an existing tire. Remolds
are a technology that allows old tire rubber to be remolded into new tires. While remolds are
only just gaining acceptance in the United States, they have gained significant market
acceptance in Europe.
Crumb Rubber
The use of crumb rubber9 as a product or as a feedstock raw material in new product
manufacturing is considered one of the highest value end uses for waste tires. Over the years,
crumb rubber production has become more efficient and cost-effective, as technologies have
evolved to manufacturer a greater amount of tire material into crumb rubber products. These
markets, however, have been slow to develop, and crumb rubber product is costly to
manufacture. While the potential exists for greater crumb rubber use, the Rubber
Manufacturers Association10 has reported that crumb rubber markets have actually decreased
in California from 6 million tires in 2002 to 5.8 million in 2003. Nationally, markets have
also decreased, from 34 million in 2001 to 28 million in 2003.
In California, four tire processors manufacture a crumb rubber product, using
approximately 5.8 million waste tires per year. Some of these processors are targeting
specific markets, such as molded products, while others are manufacturing their own end
products. Within California, markets have not matured to the point of being able to absorb all
the tires produced in the state. To date, it is estimated that 18 percent of the state’s waste
tires go to crumb rubber applications. Tire processors are diversifying their markets to avoid
economic collapse if any one market drops significantly. The hope is that diverse and
sustainable markets will strengthen the tire recycling infrastructure over time and enable
more waste tires to be turned into crumb rubber products.
One barrier to wider use of crumb rubber is a lack of awareness of existing
specifications for the material. The American Society for Testing and Materials (ASTM) has
already developed crumb rubber specifications, and the Institute of Scrap Recycling
Industries (ISRI) is also in the early phases of establishing its own specifications, both of
which could have the potential to enhance waste tire recycling markets. For example, when a
potential end user of crumb rubber requests a specific size of rubber, they expect to receive
pure rubber powder. Without these standards, however, buyer and seller can still determine
the specifications that will set up mutual expectations as to how fine the powder must be
ground or how pure the material must be.
Another barrier to increased crumb rubber use pertains to the chemical make-up of
tires. Currently, each tire manufacturer has its own manufacturing recipe. In addition, each
tire component (e.g., sidewalls vs. the inner liner) is comprised of different compounds. As a
According to California statute 42801.7, Crumb rubber is defined as “…rubber granules derived from a waste
tire that are less than or equal to one-quarter inch or six millimeters in size.” Crumb rubber is also sometimes
called ground rubber by other organizations.
10
E-mail from Michael Blumenthal, RMA, to Julie Rhodes. June 27, 2004.
9
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result, waste tires sent to recycling facilities do not have the exact same chemical properties,
making it impossible to remanufacture a truly homogenous product. When molding rubber,
chemical makeup is important, as it will dictate material performance during manufacture, its
melt threshold, binders or chemical additives needed, and end product performance. While it
is not realistic that manufacturers will share a uniform recipe, there would be greater market
opportunities for crumb rubber if the tires had a more consistent chemical makeup.
Developing such consistency, however, would have to be deemed viable within the confines
of anti-trust legislation.
Finally, a third barrier is the cost to produce recycled crumb rubber as compared to
virgin rubber. The grinders, hammermills, and other equipment needed for waste tire
recycling are expensive to purchase and maintain. In addition, there is an overcapacity of
crumb rubber production in California. While tires diverted to crumb rubber processors
avoid landfills, there are few markets for the crumb rubber, resulting in the stockpiling of
processed material. As a result, it has been difficult for tire processors and recyclers to
manufacture a quality crumb rubber product that can compete with virgin material at an equal
or lower cost. Tire manufacturers and molded product manufacturers would potentially use
greater quantities of recycled rubber in their products if the cost were more competitive with
virgin supply.
Crumb Rubber Markets
Recycled Content in Tires
As revealed in CIWMB’s 2003 draft report, Increasing the Recycled Content in New
Tires, some new passenger tires contain up to 3-5 percent of the rubber component as
recycled content,11 at a ground rubber size of 80 – 400 mesh. The report also showed that
manufacturers could add as much as 10 to 15 percent recycled content, although there is a
debate as to the impact that adding any amount of recycled content has on tire longevity and
performance.
As mentioned above, one of the greatest challenges to increasing the market for
crumb rubber is that each tire is comprised of multiple materials. Mixed rubber from a
variety of tire brands is challenging to turn into a recycled content tire. For this reason,
manufacturers are often more willing to use waste rubber that is internal to the plant instead
of post-consumer tire waste. In addition, adding post-consumer recycled crumb rubber can
reduce the physical properties of tires, therefore reducing the life of a tire and resulting in
more tires being landfilled, not fewer.
It was also mentioned that, in today’s marketplace, recycled rubber is more expensive
and less predictable than virgin rubber. This creates a major barrier to the use of recycled
content in new tire manufacture. To illustrate this point, tires that have been cryogenically
processed (instead of ambient grinding) are more suited for use in new tires because they are
11
Some manufacturers do not use any recycled content in their new tires.
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typically of higher quality (without metal or fluff) and can be more easily made into smaller
mesh sizes. However, this process for tire recycling is more expensive than ambient
processing and, therefore, more costly for tire manufacturers to purchase as an industrial
feedstock.
One stakeholder commented that the percent of recycled content used in a tire could
only be increased through solutions such as advances in devulcanization technology or a
lower cost of recycled crumb rubber. Another stakeholder said that the most immediate way
to increase the amount of waste tires used in new tires was to promote recycled content
purchases among fleets and consumers. Although some tires currently sold have between 5
and 10 percent recycled content, others have no recycled content. Therefore, the average
percentage of recycled content in all tires sold would go up. This stakeholder emphasized
that this could be done without a single tire being reformulated.
Loose Fill Crumb Rubber Products
Owing to the increased cost of waste tire material over gravel, wood mulch, or other
materials, recyclers that manufacture rubber recreational products today rely on government
subsidies. To encourage the use of waste tires in recreational applications, California offers
the Waste Tire Track and other Recreational Surfacing Grants and Waste Tire Playground
Cover Grants. One such grant was provided to Eastgate Park in Garden Grove, which used
21,800 pounds of California ground tire rubber in its playground. California has allocated
$800,000 per year to assist in further developing these markets. In 2003, California gave out
grants for playground projects totaling $470,304 and grants for running tracks totaling $1.4
million.
The potential exists to increase the use of crumb rubber in loose fill material for
playgrounds, and even horse arenas. Crumb rubber, compared to pea gravel or mulch, has
been proven to be safer than traditional materials when children fall.12 Crumb rubber, at onehalf inch to one inch in size, can also provide improved drainage and absorb impact. In
addition, crumb rubber can be poured in place for playing surfaces.
Even so, some people are concerned that the material can be dirty, can leave black
marks or smudges on clothes or shoes, can have a strong rubber smell, and that there could be
steel fragments left in the tire that could cause harm. In addition, there is some concern over
crumb rubber burning should someone put out a cigarette or otherwise ignite the surface.
Molded Products from Crumb Rubber
Crumb rubber, ground to between 4 and 100 mesh in size, can be used as a raw
material in the manufacture of a variety of rubber products, from mats, hoses, and truck bed
12
Rubber Manufacturers Association website link.
http://www.rma.org/scrap_tires/scrap_tire_markets/playgrounduse.cfm
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liners to flower pots and more. Market acceptance of these products has been slow, although
some products are starting to find greater recognition. As mentioned previously in relation to
other uses of crumb rubber, a significant barrier is the inconsistency of the chemical makeup
of tires. This difference in chemical composition can affect the manufacturing process of the
product, as well as its performance. Another major challenge is developing a ready market
for the tire-derived products that are manufactured. Government agencies, tire retailers, and
others (including some tire manufacturers) do not have purchasing policies that favor tirederived products. This is especially true of companies that sell large quantities of tire-derived
products to consumers, and which also sell a significant quantity of new tires, such as large
discount retailers. Probably the largest single barrier to market acceptance, however, is a lack
of knowledge about which products are available and where to buy them.
Rubberized Asphalt Concrete
Crumb rubber can be mixed with liquid asphalt and used in road paving to make
Rubberized Asphalt Concrete (or RAC). At least 38 states have incorporated RAC into some
of their roads in the past, but only four routinely use it in their asphalt paving (Arizona,
California, Florida, and Texas). Arizona, California, and Texas all use a process that meets
the ASTM definition of asphalt rubber (at least 15 percent crumb rubber), whereas Florida
uses a process that contains between 5 percent and 12 percent crumb rubber. California and
Texas also use a modified binder that contains less than 10 percent crumb rubber.
Arizona has assumed a leadership role in the widespread use of RAC. Today, 70 to
80 percent of the state’s road projects have some component of rubberized asphalt. The
quantity (by weight) of rubberized asphalt laid makes up 25 to 30 percent of all asphalt
pavement placed. Arizona has used rubberized asphalt since 1970 (in chip seals) and began
common use of the material in hot mix in 1988. The state has been able to reduce its costs
and build quieter-riding roads as a result of adding crumb rubber to its asphalt design mix.
One common criticism of the use of RAC is that it increases initial project costs.
However, even though RAC is more expensive per unit of material compared to traditional
asphalt, Arizona found that its overall road budget did not increase owing to its technique for
laying thinner layers of rubberized asphalt. Instead of placing a 4 to 6 inch layer of traditional
asphalt over a cracked road surface, the Arizona Department of Transportation can lay as
little as 1 inch of rubberized material. Roads laid this way have reportedly lasted 40 percent
longer before cracking occurs. Arizona uses rubberized asphalt as standard operating
procedure in the majority of its pavement projects. As a result, both material and lifecycle
costs can actually be reduced with the use of RAC.13
The California Department of Transportation (CalTrans) has been using asphalt
rubber in chip seals since the 1970’s and in RAC since the early 1980’s. These mixes
performed well in the 1980’s, and allowed RAC thickness to be decreased. 14 However, once
13
Interview with George Way, Arizona Department of Transportation, April 2004.
Standard mix design guidelines can be found on the Rubberized Asphalt Technology Center website at:
http://www.rubberizedasphalt.org/ar_design_guide/index.htm. Examples of the cost differential between RAC
14
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11
the patents on asphalt rubber disappeared in the early 1990’s, several new suppliers entered
the market with RAC product that did not perform well. The Department worked with
industry to develop an improved specification that resulted in a better product with greater
reliability and more consistent performance and wear. CalTrans continues to promote RAC
use, where appropriate, and has initiated a performance-based warranty pilot program for
RAC projects. Five projects have been constructed to date to evaluate the warranty program.
CalTrans has indicated that it will attempt to increase its use of RAC to over one
million tons in 2005. However, RAC is not considered a suitable solution for every pavement
project in California. Factors that CalTrans considers in selecting the appropriate material for
projects include the paving strategy, condition of the existing pavement to be repaired,
climate, proximity to available batch plants, need for handwork/detail, and material life-cycle
costs. Finally, CalTrans bases its contract awards on low-bid and performance, and does not
promote one material, such as RAC, over another.
Another barrier to more RAC use in California is that recent budget constraints have
resulted in fewer roads being paved, translating into fewer opportunities for CalTrans and
other agencies to use RAC. In addition, asphalt batching plants require technical
modifications to produce RAC, which can increase cost. Other factors contributing to
CalTrans not using RAC more widely include contractors being more accustomed to handling
traditional aggregate and asphalt materials, performance concerns related to past projects
using RAC, and RAC not always being available when needed at road construction jobsites.
In addition, some California county air resource boards have placed a moratorium on the
operation of rubberized asphalt batch plants owing to concerns about emissions created when
processing RAC.
The CIWMB and CalTrans have an interagency arrangement called the CalTrans and
CIWMB’s Agreement to Evaluate RAC Processing, which is investigating a variety of issues
and barriers, including the impact of climate on material performance, the amount of crumb
rubber that can be incorporated in roads, and the recycling of roads once crumb rubber is
added. This agreement was initiated on November 15, 2003, and will run until May 15, 2007.
In addition, a special subcommittee of the CalTrans-Industry Task Force will evaluate other
technical barriers associated with RAC use. This subcommittee meets approximately twice a
year, and has met for three years.
Each year, CalTrans reports to the California State Legislature on its waste tire use. In
2001, CalTrans reported using 1.1 million tires in road construction, compared to 2.7 million
in 2000, and 0.8 million in 1999.15 In early 2003, the agency exceeded its own internal goal
of 15 percent RAC use in all flexible asphalt pavement projects, using RAC in 15.7 percent of
these type of projects, equal to 414,160 metric tons of RAC.
and traditional pavement are outlined at the Rubberized Asphalt Concrete Technology Center website at:
http://www.rubberizedasphalt.org/cost.htm.
15
Annual Report to the Legislature and the California Integrated Waste Management Board, Senate Bill 876,
Waste and Used Tires. 2001. http://www.dot.ca.gov/hq/oppd/rescons/sb876/2001-SB876-annual-rpt.pdf#xml.
PSI Tire Stewardship Final Action Plan
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CalTrans, as well as local highway departments in California, and construction
contractors, all have opportunities to use more RAC. California passed legislation in 2002
that encourages RAC use in public works projects by providing grants to cities, counties,
districts, and other local government agencies. While CalTrans is not eligible for these grants,
other state grant programs are available for RAC use, including the state agency purchases
and development program, Rubberized Asphalt Concrete Technology Centers Program, and
the Civil Engineering Uses Program. Combined, they represent over $1 million available for
the use of RAC in projects. In addition, in 2004, Californians Against Waste sponsored
Assembly Bill 338 that, if passed, would require CalTrans to include RAC in 20 percent of its
asphalt pavement projects by January 1, 2007, increasing to 25 percent by 2010 and 35
percent by 2013. The new legislation would also require the use of crumb rubber that is
manufactured in the United States and derived from waste tires taken from vehicles owned
and operated in the United States. The outcome of this proposed legislation is still pending.
Civil Engineering Applications
Shredded waste tires have been substituted for commonly used materials, such as
aggregate, stone, and sand in a variety of civil engineering applications across the country.
Many stakeholders believe these applications hold the greatest promise for waste tire market
opportunities, particularly because of the large numbers of tires that are needed for each job. To
date, CalTrans has conducted one test project with shredded tires as lightweight fill, using
660,000 tires on an embankment project on the Dixon Landing in Santa Clara County in 2001.16
CalTrans also placed 75,000 tires as lightweight fill behind a retaining wall in Riverside
County.17
Nationally, since 1988, more than 70 projects have been constructed using shredded
tires with a thickness of 1 meter or less, and an additional 10 fills were constructed with a
thickness of less than 4 meters. In 1995, three tire shred fills with a thickness greater than 8
meters experienced a catastrophic internal heating reaction, resulting in a fire. This
unfavorable experience temporarily curtailed the use of tire shred fills on highway projects.
Since the development of the ASTM specifications, however, many successful lightweight
fill projects have been built nationwide.
Possible causes of the 1995 incident are oxidation of the exposed steel belts and
rubber. Microbes may also have played a role in the internal combustion reaction. Although
details of the reaction are being studied, the following factors are thought to create conditions
favorable for oxidation of exposed steel and/or rubber: access to air or water; retention of
heat caused by the high insulating value of tire shreds in combination with a large fill
thickness; large amounts of exposed steel belts; smaller tire shred sizes and excessive
amounts of granulated rubber particles; and the presence of inorganic and organic nutrients
that would enhance microbial action.
16
Annual Report to the Legislature and the California Integrated Waste Management Board, Senate Bill 876,
Waste and Used Tires. 2001.
17
See: www.dot.ca.gov/hq/oppd/rescons/sb876/Approved-SB876-Annual-Report2004.pdf
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The Rubber Manufacturers Association (RMA) has developed design guidelines to
minimize the potential for heating of tire shred fills by minimizing the conditions favorable
for this reaction. As more is learned about the causes of the reaction, it may be possible to
ease some of the guidelines, which are divided into two classes: Class I Fills with tire shred
layers less than 1 meter thick, and Class II Fills with tire shred layers in the range of 1 meter
to 3 meters thick. Although no projects using less than 4 meters of tire shred fill have
experienced a catastrophic heating reaction, to be conservative, tire shred layers greater than
3 meters thick are not recommended.18 These guidelines considered the insulating effect
caused by increasing fill thickness and the favorable performance of projects with tire shred
fills less than 4 meters thick. Thus, design guidelines are less stringent for projects with
thinner tire shred layers.
The following sections outline the most common civil engineering applications using
shredded tires between 2 and 12 inches in size that serve as a lightweight fill or aggregate.
According to RMA, tires in civil engineering applications show 10 times better drainage
properties than soil and 8 times better insulation properties than gravel.19
At the Tire Stewardship Forum, one of the stakeholders expressed a concern about the
ability to recycle waste tires after they are used in civil engineering applications. Another
barrier to the use of shredded tires for these applications is competing materials and related
cost and availability of the material.
Landfill Applications
Shredded tires can be used for several landfill applications – as daily cover, in the
landfill drainage layer, as part of a landfill cap, and to assist landfill gas venting. Shredded
tires have been used in the required daily cover layer at landfills, replacing dirt, sand, or other
cover material. Chipped tires have also been used during new landfill construction in the
bottom layer to provide drainage in the leachate collection system. While use of waste tires
for landfilling applications provides benefits that disposal does not, some stakeholders do not
support these applications because they view landfill applications as simply another form of
land disposal. Others believe that there are higher-value end uses that have not been fully
explored. In addition, there are risks of fire if shredded tires are not installed properly,
although the risks of spontaneous combustion are very low when tires are laid as a landfill
drainage layer less than 3 feet thick. However, a recent tire fire at an Indiana landfill has
raised new questions about using tires in the liner layer of landfill construction (Monroe
County Landfill, January 10, 2004).
18
RMA website. Design Guidelines to Minimize Internal Heating of Tire Shred Fills. July 7, 2004.
https://www.rma.org/scrap_tires/scrap_tire_markets/tireshredfills.cfm.
19
RMA. U.S. Scrap Tire Markets 2001. December 2002.
https://www.rma.org/publications/scrap_tires/index.cfm?PublicationID=11106
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Lightweight Fill
Chipped tires can be used as a lightweight fill substitute, especially on top of weak
soils, as subgrade fill and in the construction of bridge embankments, retaining wall
reinforcements, and other projects. In these applications, tires are substituted for other raw
materials, such as gravel or sand. ASTM standards have been developed for testing the
physical properties of chipped tires and provide data for assessing the leachate generation
potential of processed or whole waste tires. The ASTM website20 outlines typical
construction practices to demonstrate use.
One challenge that must be overcome, however, is that is has been difficult to get
large quantities of shredded tires to a jobsite when needed. Since civil engineering projects
are under construction for only a limited period of time, there are logistical challenges to
transporting the tires, finding temporary storage, and managing waste tires at the job site.
This challenge is not insurmountable, however, as the Dixon Landing pilot project used
660,000 tires at one location, and scheduled the delivery of the shreds to coincide with the
contractor’s daily installation/compaction rate.
Septic Field Drainage
Chipped tires can also be used as a backfill around effluent leach field piping in septic
systems. While in some areas of the country, such as South Carolina, chipped tires in septic
fields have gained acceptance, this is not true for all communities across the country.
Road Base
Shredded tires can be used in the base layer of a road construction project in place of
aggregate or stone. However, while tires have been used successfully in such applications for
years, many still recall the state of Washington road fires, which were caused by using
chipped tires at too great a thickness level. New standards have significantly reduced the
risk of spontaneous combustion of tires used as an aggregate substitute in road base.
Unfortunately, a negative perception still remains among many transportation officials. In
addition, since road construction occurs over a limited period of time, the logistical
challenges mentioned above for lightweight fill apply here as well.
Tire Derived Fuel and Tire Chip Fuel
In 2002, it was estimated that 6.1 million tires per year were combusted in California
cement kilns and co-generation plants for energy recovery. Waste tires can be used whole or
20
ASTM website. (D6270-98 (2004)) Standard Practice for Use of Scrap Tires in Civil Engineering
Applications. July 7, 2004.
http://www.astm.org/cgibin/SoftCart.exe/DATABASE.CART/REDLINE_PAGES/D6270.htm?L+mystore+pgz
s0386+1066851199
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chipped, depending on the facility, and fed into industrial boilers, electric arc furnaces,
cement kilns, pulp and paper mills, and co-generation plants to serve as an energy substitute
for coke or coal. Tires provide a good energy source as they generate 14,000 BTUs of energy
per pound, compared to coal, which generates 12,500 BTUs of energy per pound. In
addition, in some instances, such as in cement kilns and in electric arc steel furnaces, the
iron/steel contained within a waste tire is converted into raw material for the manufacture of
end products. Additionally, tire-derived fuel markets are typically more economically viable,
and allow for a greater degree of minor contaminants than tire processing markets. In some
cases, the facility removes the bead wire prior to incineration to recover the metals value.
Those in favor of using waste tires for energy production point to a fuel that is
cleaner, more efficient, and more environmentally-friendly than the mining, transportation,
and use of coal that is typically supplied to California from Utah, Montana, and other western
states. Again, some stakeholders are concerned that promoting tire-derived fuel decreases the
potential to use waste tires in higher-value applications. In addition, they argue, burning a
tire loses the long-term value of the initial resource. As a result of these different
perspectives, as well as the high cost of transporting tires, three of nine cement kilns that have
been permitted in California to use TDF are not burning the tires. An additional nine cement
kilns could potentially be permitted to accept waste tires should TDF become a more
acceptable solution.21
Both the California Air Resources Board and the U.S. Environmental Protection
Agency have approved waste tires as a fuel substitute. In fact, sulfur dioxide (SOx) and
nitrogen oxide (NOx) emissions can be substantially reduced when substituting tires for coal
in cement kilns in the preheating phase of the kiln. However, some stakeholders expressed
significant concerns with the burning of waste tires as TDF, particularly regarding the
emission of dioxins and furans during TDF burning.
Other barriers to the widespread use of TDF relate to regulatory and facility retrofit
costs, as well as tire transportation costs. A significant cost is the “test burn” that is required
to ensure that the facility can meet air quality standards. In addition, equipment installation
and conversion costs that enable a facility to process waste tires for fuel can be high.
(Industrial boilers may or may not require significant adaptation to burn tires as an energy
source, while electric arc furnaces do not require significant conversion costs.) For example,
the cost for a cement kiln to drill a hole in the shaft/tube and install a conveyance or feed
system to bring the tires from the ground level into the kiln is approximately $1.5 million per
kiln. Further, costs are often significant to transport waste tires to facilities that can burn
them. Currently, under California law, no state funding can be used to support TDF use
because it has been determined to be a lower market priority by state officials. Some
stakeholders, however, believe that this creates a stigma on TDF markets and support
subsidizing TDF markets, like other tire markets, to provide a level playing field.
21
There are nine companies operating 17 cement kilns in California.
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Tires can also be burned for energy in co-generation plants, or facilities specifically
built for energy recovery. In the case of chipped tire fuel for co-generation plants, while the
product has value, there is also a cost to process the waste tires prior to sending them to cogeneration plants. There could be additional co-generation markets developed if proven
economical.
VIII. EXISTING TIRE RELATED PROJECTS IN CALIFORNIA
California is one of the most aggressive states regarding the management of waste
tires, combining legislative and regulatory solutions with research and grant funding to
encourage new waste tire markets. There are five principle areas in which California has
taken action:





Laws and regulations
Tire Management Fee
Extending the Lifespan of Tires
Increasing the Recycled Content in Tires
Tire Grant Program
Laws and Regulations
California has instituted numerous laws and regulations related to waste tire
management from 1989 through 2003, with the intent of diverting an increasing number of
waste tires to recycling and providing safer tire management. The following laws and
regulations have been the most significant in relation to waste tire management:






a waste tire fee to fund state programs;
safe collection, storage, transportation, and handling requirements for waste tires;
a grants and loans program for tire research and recycling activities;
a program to remediate illegal tire piles;
tire law enforcement program; and
programs to encourage the use of rubberized asphalt concrete in public works projects
and to increase state procurement of tire-derived products.
Tire Management Fee
In 1989, California passed the California Tire Recycling Act that originally placed a
$0.25 per tire visible fee on all passenger and truck tires sold in the state. This fee was raised
to $1.00 per tire in 2000, but is scheduled to be scaled back to $0.75 per tire on December 31,
2006. The fee is collected from consumers at the retail level and deposited into a statemanaged fund, which is used to pay for market development research and projects, stockpiled
tire abatement, and tire regulation and enforcement. Each year, the fee brings in
approximately $31 million. Some retailers add an additional charge onto this fee to cover
their administrative costs, including contracting with a tire hauler to properly dispose of the
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tires. The cost of this service was reported to be, on average, $0.75 per tire. Retail charges
are not set by regulation, and are based on what the market will bear.
Extending the Lifespan of Tires
In July 2003, Symplectic Engineering Corporation and the University of California at
Berkeley’s Institute for Transportation Studies completed a report entitled, Extending the
Lifespan of Tires, which concluded that improving tire maintenance can extend the life of
about 60 percent of all light-duty tires. Researchers used data from Michelin to conclude that
50 percent of all light-duty tires entered the waste stream with abnormal wear owing to poor
tire maintenance. Another 10 percent of tires entered the waste stream owing to oxidation
and separation, both of which are also linked to poor tire maintenance, primarily low air
pressure.
Studies conducted by the National Highway and Traffic Safety Administration
(NHTSA) also concluded that inadequate passenger vehicle tire pressure leads to a shortened
lifespan for tires. The NHTSA study cited Goodyear, which reported that an improperly
pressurized tire loses 17.8 percent of its life. On a typical tire expected to run for 80,000
miles, tire life would thus be reduced to 65,760 miles, causing that tire to enter the waste
stream much sooner than necessary. The study suggests that “smart tire systems” that
continuously maintain air pressure can deliver a significant jump in the average tire life.
The report concludes with four broad strategies to extend the lifespan of tires:




Advancing auto-inflate systems where tire pressure is automatically maintained
through voluntary or mandatory efforts;
Educating the public to better maintain their tires, such as by adjusting air pressure,
rotating tires, and keeping proper tire alignment;
Mandating that producers that sell tires in California meet an overall average standard
tire life within the mix of light-duty tires they sell, much like the national standards
set on automotive manufacturers for fuel efficiency. For example, an average
standard tire life might be based on existing industry standards, such as the tread wear
rating component of the uniform tire quality grading, as well as the weight of the tires;
and
Employing a combination of taxes and rebates to replace the uniform $1 tire disposal
fee with an ad-valorem tax, which would require those who purchase heavier weight
tires to pay a larger fee than those purchasing lighter weight tires. Oklahoma and
Arkansas currently charge a lower fee for passenger tires than for truck tires.
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Increasing the Recycled Content in New Tires
In May 2004, work was completed on a report entitled, Increasing the Recycled
Content in New Tires, which was produced by the Nevada Automotive Test Center (NATC),
along with the California Integrated Waste Management Board. In this report, researchers
evaluated how recycled content in new tire manufacturing can affect tire rolling resistance
and tire lifespan. As a result, an integrated approach was recommended that balanced
inherent tradeoffs between higher recycled content and reduced tire life.
According to the NATC report, crumb rubber that is recycled into new tires represents
12.5 percent of all material going into recycled rubber products. The NATC concluded that
this represents approximately 4.2 million tires a year that are recycled into new tires, although
it is not clear how much of this material is generated from internal factory waste as compared
to post-consumer waste tires.
Based on the NATC findings, over the past 10 years, the recycled content in some
new passenger and light-truck tires has increased from 0.5 percent (by weight) to up to 5.0
percent.22 In some cases, incorporating recycled content of up to 10 to 15 percent in new tires
is reported as technically feasible, without adversely affecting the performance characteristics
of tires. However, tire manufacturers limit the recycled content to under 5 percent due to
several factors, including concern about performance and durability, economic considerations
(e.g., transportation, energy cost, and low price of virgin rubber), supply and quality of crumb
rubber, and the perception that tires with recycled content are inferior.
According to the NATC report, the recycled content in new tires could be increased if
one or more of the conditions or actions listed below are implemented, although NATC
recommends a detailed economic feasibility analysis before taking any action.






22
Provide grants to ensure that a reliable supply of high-quality crumb rubber is
available.
Conduct pilot projects using government fleets to demonstrate safety and performance
effectiveness of tires with recycled content.
Encourage vehicle manufacturers to develop recycled content requirements and
standards for new tires.
Provide government incentives, including tax exemptions, and grants for equipment
and land.
Identify large sources of waste tires in densely populated northern and southern areas
of the state to attract processors.
Increase retreading, which can generate a greater quantity of high-quality buffings,
which may be more readily accepted as a feedstock in new tire manufacturing. (The
process used to generate buffings is less capital intensive than the process used to
develop crumb rubber from whole tires.)
Some manufacturers do not use any recycled content in their new tires.
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

Educate consumers through comparative testing of tires with recycled content as
compared to similar tires using virgin components.
Locate tire processing facilities in areas in need of economic revitalization.
In conjunction with the above-listed conditions or actions, NATC found that the
following factors and recommendations are also important:






The automotive industry is the most significant influence in redirecting the recycling
of waste tires from landfilling to use in new tire manufacturing. In addition, the
automotive industry is targeting a 25 percent increase in recycled content of their
products and encouraging supplies to provide components with such recycled content.
Increasing the use of retreaded passenger car and light-truck tires can complement
efforts to use crumb rubber in new tire manufacture.
For consumers to be more receptive to purchasing recycled-content tires, testing and
demonstration projects will need to change their perception about these tires so they
have a more positive image.
Compounds should be developed that have higher resilience characteristics to reduce
excessive temperature rise, while maintaining desired performance characteristics
such as resistance to cutting, chipping, cracking, and abrasion.
The availability of more dependable casings can expand retreading, increasing the use
of buffings as recycled content in tires.
More research is required to understand how recycled crumb rubber behaves in rubber
compounds. Resources should be allocated for research and development to
understand the effect of increased recycled tire content on the dynamic properties of
tires in the end-user environment. This can be accomplished at academic institutions
or independent organizations that can provide the necessary technical expertise.
Even so, the report's executive summary reads: “Using waste tires in civil engineering
applications, as a fuel source, and in production of rubberized asphalt concrete, and in other
tire derived products are currently the most cost-effective ways to divert waste tires from
disposal." The executive summary also states that "…there are few incentives for tire
manufacturers to increase the use of recycled material in new tires."
Tire Grant Programs
The California Integrated Waste Management Board's tire grant programs encourage
activities that promote the reduction of waste tires disposed of in landfills and the elimination
of waste tire piles. Funded activities include tire pile cleanup and enforcement, waste tire
market development, product procurement, and demonstration projects. Eligible projects have
included individuals, businesses, local governments, universities, school districts, park
districts, and qualified California Indian tribes. Revenue for the grants is generated from the
$1.00 fee on each new tire sold.
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California’s current tire grant programs include the following:23
IX.

Local Government Waste Tire Cleanup Grants – funds local tire clean-up projects,
involving law enforcement agencies, county and city departments, fire districts, code
enforcement agencies, and qualifying California Indian organizations.

Local Government Public Education and Amnesty Day Grants – competitive grants
used to develop educational programs on the requirements for proper tire disposal and
on ways to properly care for tires. The program also includes amnesty events aimed
at the consumer to deal with nuisance tires and small tire pile clean-ups.

Waste Tire Track and other Recreational Surfacing Grants – competitive grants used
for the purchase and installation of recreational surfaces made from California waste
tires.

Waste Tire Playground Cover Grants – grants to cover expenses related to playground
surfaces that are manufactured using California-derived waste tire rubber.

Tire Product Commercialization and Research Grants –competitive grants available to
research institutions, individuals, businesses, and qualifying Indian tribes to assist
with development of commercial processes and technologies using waste tires.

Waste Tire Enforcement Grants – competitive grants available to local enforcement
agencies and cities and counties with regulatory authority for inspection, compliance,
and surveillance activities.
TIRE STEWARDSHIP PROJECTS OVERVIEW
This section provides an overview of tire stewardship activities in the United States
and abroad. Each stewardship effort operates on the principle of shared responsibility
between manufacturers, retailers, government agencies, tire haulers, tire recyclers, and
consumers, although there is a wide range of perspectives as to how this responsibility should
be distributed. The exact nature of this “shared” aspect of responsibility is at the heart of
product stewardship negotiations.
The responsibilities to be shared are generally divided into two basic categories –
physical responsibility to manage the waste tire from generation through its end-of-life
management, and financial responsibility involving who pays the management cost, how it is
collected, what it is used to fund, and how it is disbursed. There is also a program
management responsibility as well, which involves setting goals, evaluating performance,
planning, and providing overall leadership.
23
A recent bill that was passed does not currently allow state funding to be used for energy recovery, although
such grants were provided in the past.
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The existence of a financing system that can sustain the management of waste tires is
a critical component of a successful program, and financing fuels all current efforts to
manage waste tires. The ultimate goal of managing tires, however, is to reduce waste and find
value-added markets for waste tires with economic value so that no extra funds are needed to
manage the product. Currently, though, the management costs exceed the inherent value in
the waste material, and funding has been required to properly manage waste tires, prime the
market for recycled tire products, and conduct demonstration projects and technical research
on longer-lasting tires. This section describes efforts in the United States, Canada, and
Europe where systems have been put in place to manage waste tires and move towards a
sustainable economic scenario.
Tire Product Stewardship in the United States
Currently, 35 states across the country have enacted a waste tire fee (or advanced
recycling fee, ARF) on new tires, which is usually understood as a visible fee paid by a
consumer at retail to pay for the costs of tire management programs.24 These legislatively
mandated fees are assessed based on the costs associated with the product’s end-of-life
management costs. These fees are quite variable among the different states, ranging from
$0.25 to $5.00 per tire, with the most common fee being $1.00 per tire (as is the case in
California). In addition, nine states have sunset tire fees previously in place, and two
additional states are scheduled to sunset fees in 2010. North Carolina is the only state that
does not charge a flat fee, but instead charges 2 percent of the cost of the tire.
A few states, like Maryland and South Carolina, collect fees and allow the retailer to
keep a portion of the fee to cover administrative costs. In states where this does not occur,
the retailer typically charges an additional fee on top of the state fee to cover its actual
disposal or recycling costs. The funds are paid to the state and cover a variety of activities,
including tire abatement, enforcement, market development, demonstration projects, loans,
grants, and educational programs. In some cases, state tire funds have been raided to fund
general fund activities unrelated to tire activities.25 This was particularly prevalent in 2003
when many states experienced budget shortfalls and searched for supplemental funding.
There are numerous other tire program requirements that vary by state. For example,
37 states ban whole tires from landfills. Of those, 28 states require tires to be quartered or
shredded before landfilling may legally occur. Nine of those states have banned shredded
tires from landfills as well. Related to market development, 14 states provide incentives for
the purchase of tire-derived products by state government agencies, most of which allow a 5
to 10 percent price preference for state purchases of tire-derived products over virgin material
counterparts. California’s law provides a 5 percent price preference for tire-derived products.
24
For a state-by-state breakdown of state legislation related to scrap tire disposal, see RMA website at:
https://www.rma.org/publications/scrap_tires/index.cfm?PublicationID=11121.
25
Rubber Manufacturers Association, State Legislation – Scrap Tire Disposal Report – September 2003.
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ARFs in the United States have also been enacted on a state level to manage motor oil
and lead-acid vehicle batteries, with the fees being paid into a government fund. These fees,
which are authorized by legislation, serve to educate a consumer about the reason for the
product price increase, but are viewed more as a way to cover costs and develop markets than
as a means to provide a financial incentive for manufacturers to redesign their products to
produce fewer environmental impacts, one of the tenets of product stewardship.
Each stakeholder in the tire stewardship initiative has a role to play in managing waste
tires. Consumers, for example, pay a fee to fund end-of-life management costs, and have an
obligation to maintain their tires at proper pressure and in safe condition. They also have the
responsibility to bring their waste tires to an appropriate collection point and not dump it
illegally. State government plays a key planning and enforcement role to level the playing
field, whereas local governments often provide a part of the collection infrastructure, and
may enforce against tire dumping and educate residents about recycling opportunities.
Retailers also provide collection and consumer education, as well as fee collection. In this
vein of responsibility, on the national level, manufacturers, through the Rubber
Manufacturers Association and the Tire Industry Association, typically provide support to
state and federal tire management programs through information, workshops, and other
educational activities.
While waste tire management in California is not faced with a lack of funding, there
are a significant number of programs with little agreement among stakeholders about how the
funding should be distributed. There may be opportunities in the current system for greater
efficiencies through increased stakeholder cooperation in system management.
Tire Industry Overview
The five largest tire manufacturers collectively accounted for an estimated 82.9% of
the $23.5 billion tire sales in North America in 2003. All five of these manufacturers were
present at PSI’s Tire Stewardship Forum. A six manufacturer, Yokohama, was also present.
Table 2. Market Share by Major Tire Manufacturers
Tire Manufacturers
Goodyear/Dunlop
Michelin/Uniroyal Goodrich
Bridgestone/Firestone
Cooper
Continental Tire
Other
TOTAL
Percentage of Market Share of
Annual Sales
26.4%
24.6%
17.9%
7.2%
6.8%
17.1%
100%
Source: Tire Business, a Crain publication, Market Data Book, February 2, 2004, page 9
PSI Tire Stewardship Final Action Plan
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Tire Product Stewardship in Canada
Each of the Canadian provinces has developed similar tire product stewardship
programs, although there are regional variations. Each program includes a mandatory fee on
new tires purchased between $2 per tire (passenger tires in Prince Edwards Islands) and $35
per tire (truck or agricultural tires in Saskatchewan). Five of the Canadian programs are
managed by third- party organizations, two are managed by government, and one program is
in development in Ontario.
There are two basic Canadian provincial models based in part on which entity
manages the funds used to cover tire program costs:

Government Model: Under this model, the provincial government places a fee on
new tire purchases, with the money going to the provincial environmental agency to
cover the costs for waste tire collection and recycling. Retailers collect the tires and
the fees. This type of program is operating in Quebec and British Columbia. In
British Columbia, not all of the money collected has gone back into tire programs, but
instead has been spent on other provincial priorities.

Producer Responsibility Organizations (PROs): These third-party entities are
formed with the express purpose to allow industry to collectively raise funds to
manage the take-back and final disposition of waste tires. These PROs are not-forprofit and arms-length from government and the tire companies. Under this model,
fees are placed on new tire purchases and collected by retailers, with the fee covering
the cost of waste tire collection and recycling. A multi-stakeholder board oversees the
funds and programs. While called a “producer responsibility” program,
manufacturers/producers of tires do not sit on these governing boards. Instead,
retailers are the industry representatives on the boards, along with government
officials and other entities. This PRO model is operating in five Canadian provinces.
A third model, in Ontario, was under development at the time of the Tire Stewardship
Forum. Ontario’s Waste Diversion Act created a third-party organization called Waste
Diversion Ontario, which manages not only tires but other products. Individual industry
funding organizations have been created to develop diversion plans for individual materials.
In March 2003, tires were phased in under the Act, and Ontario Tire Stewardship was created
to fund tire management programs. It has a Board comprised of tire manufacturers and
retailers.
Tire Product Stewardship in Europe
In Europe, 372 million waste tires are generated annually with about 252 million tires
(or 68 percent) reused, recycled, or otherwise recovered for value. According to the Bureau
de Liaison des Industries du Caoutchouc (BLIC), throughout the European Union, each
country has its own organization dedicated to managing waste tires. In many countries, these
PSI Tire Stewardship Final Action Plan
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24
organizations are legislatively required. These organizations assist companies in meeting
their responsibilities under the law.
While Europe has enacted an “End-of-Life Vehicle Directive,” it only requires that
tires be removed from the vehicles. In addition, whole tires were banned from landfills in
July 2003, and shredded tires will be banned as of mid-year 2006. These two regulations
create the need for tire management systems. A number of countries have enacted laws
requiring the producer or importer to take responsibility for tire management, including
Belgium, the Czech Republic, Finland, France, the Netherlands, Norway, Poland, Portugal,
and Sweden, with legislation pending in Greece and Hungary. There may be a consumer
contribution to the financing of this system but it is invisible, not a distinctive visible lineitem fee on their bill. Other countries in the European Union work on a free market system,
requiring that the last holder of a tire have responsibility for handling it.
According to information from the Rubber Manufacturers Association (United
States), European countries follow three basic systems.26
Free Market System: The distributor deals directly with the recycler of his choice on
a free market basis. Free market systems are active in Ireland, United Kingdom, Spain,
France, Italy, Austria, Germany, and Greece.
Take Back/Fund System: Take back/fund systems mandate individual producer
responsibility. Producers contribute to a collective fund that finances the recycling
organization. Take back systems are active in Norway, Sweden, Finland, Denmark, Poland,
Portugal, and the Czech Republic
Tax System: Under this system, producers pay a tax to the government, and the state
is responsible for the overall organization and pays recyclers. A tax system is active in
Denmark, Slovakia, and Hungary
Tire markets in Europe are similar to those in the United States. Europe has increased
the amount of tires recycled from approximately 8 percent to over 20 percent in the past
several years.
The main market for recycled tires in Europe is crumb rubber, which is converted into
products such as tiles, horse arenas (a very popular use in the United Kingdom), and minor
uses in road applications. The use of rubberized asphalt has been hindered by political and
economic factors, as road construction is a government responsibility. Energy recovery is a
large market for waste tires, and electric generation plants that use tires are working
especially well in Southern Italy. There are also pilot projects currently underway in France
(with one about to start in Spain) where carbon from the tires is extracted for use in making
26
Rubber Manufacturers Association, European End of Life Tyres (ELT) by Dan Pyanowski, presentation to
the RMA Rubber Recycling Conference in Montreal, Quebec, October 2002.
PSI Tire Stewardship Final Action Plan
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steel. As in the United States, Europe has a healthy retread market for truck tires, but not for
car tires.
Table 3 below outlines the various markets for European waste tires by country. The
table also provides information on tire disposition in Europe for 2001 and 2002.
Table 3. Used Tires Analysis in 2002 in Europe
Tire
Generation
(000 Tonnes)
Reuse
(%)
Export
(%)
Retreading
(%)
Material
Recycling
(%)
Energy
Recovery
(%)
Landfill &
Used Tire
Unidentified Recovery Rate
(%)
(%)
55
0
0
0
46
54
0
Austria
100
75
2
3
4
23
31
37
Belgium
63
43,5
0
0
9
76
15
0
Denmark
100
37
0
0
3
97
0
0
Finland
100
390
0
10
14
33
19
24
France
76
578
4
8
10
18
52
8
Germany
92
50
4
2
3
14
3
74
Greece
26
43
0
8
0
4
23
65
Hungary
35
360
5
2
14
14
33
32
Italy
68
35
0
85
0
15
0
0
NL (pc tires only)
100
101
0
0
15
8
27
50
Poland
50
50
0
0
30
40
16
14
Portugal
86
263
0
4
14
8
10
64
Spain
36
76
1
15
4
35
45
0
Sweden
100
53
0
40
2
30
28
0
Switzerland
100
485
16
2
10
32
10
30
UK (estimates)
70
2695
5
7
11
24
27
27
EU average 2002
73
2617
6
6
13
19
21
35
EU average 2001
65
Source: From website of Bureau de Liaison des Industries du Caoutchouc, www.blic.be. November 2003.
In December 2000, the European Commission passed the Directive on Incineration of
Waste, which fixed emission limits for all new cement kilns after December 28, 2002.
Beginning in December 2005, new provisions will apply to existing plants that are coincinerating waste, including cement kilns burning waste tires. Most or all existing cement
kilns will be unable to meet the new, more stringent air quality standards set by the
commission. Existing cement kilns are not likely to be able to burn tires at all once the 2008
standards come into effect. This measure will reduce the overall capacity for tires used to
produce energy by approximately 10 percent.
Product Stewardship Models
Two United States product stewardship initiatives may be instructive in the
development of a tire product stewardship dialogue in the United States – the National Carpet
Dialogue, an example of how performance standards were set to drive market development
efforts, and the Rechargeable Battery Recycling Corporation, an industry-run third party
organization that internalizes the costs of collecting and recycling rechargeable batteries.
PSI Tire Stewardship Final Action Plan
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26
Performance Goals – National Carpet Dialogue
Setting product performance goals is one means to strategically drive market
development efforts. In the National Carpet Dialogue, carpet manufacturers helped set goals
for reuse, recycling, energy recovery, and landfill diversion, as well as to set up a non-profit
organization to meet the goals. This approach is expected to reduce the environmental
impacts of carpet throughout its life cycle – from design to end-of-life management.
As a result of mounting quantities of discarded carpet in the waste stream, members
of the carpet industry, government officials, and non-governmental organizations met
beginning in 2000 to develop a strategy for diverting carpet from disposal. At that time, total
carpet discards reached 4.7 billion pounds per year, with only a small percentage of the
material being reused or recycled. National concerns about disposal capacity, combined with
the carpet's bulk (which makes it difficult and expensive to handle), contributed to the search
for increased recycling and reuse opportunities.
In January 2002, stakeholders signed a joint Memorandum of Understanding (MOU)
for Carpet Stewardship. This agreement established an ambitious ten-year schedule to
increase the amount of recycling and reuse of post-consumer carpet and reduce the amount of
waste carpet going to landfills. The MOU set forth national goals over a ten-year timeframe
to significantly increase the amount of recycling and reuse of post-consumer carpet. By
2012, the parties plan to achieve a landfill diversion goal of 40 percent. These goals are
intended as steps toward fulfilling a long-term commitment to eliminate the disposal
(including energy recovery) of waste carpet. The parties will resume negotiations in 2010 to
set new goals that go beyond the 2012 timeframe.
The carpet industry created the Carpet America Recovery Effort (CARE) to meet the
goals of the agreement (see Table 4 below). The multi-stakeholder group includes members
from the carpet industry and government, and is responsible for monitoring, evaluating, and
assessing progress toward meeting the goals. CARE is funded and administered by the carpet
industry.
Table 4. Summary of the National Goals For Carpet Recovery
Figures rounded to millions of pounds. Data on carpet discards provided by the Carpet and Rug Institute.
2002
Total Discards 4,678
2003
4,828
2004
4,537
2005
5,038
2006
5,261
2007
5,590
2008
5,642
2009
5,887
2010
6,020
2011
6,605
2012
6,772
Reuse
0
25
113
211
203339
Recycling
180
353
620
903
1,354
-1,693
Waste-to-Energy
(WTE)
Cement Kilns Landfill
4,498
48
45
50
100
4,510
53
56
56
300
4,552
59
60
200
4,646
Recycling Rate
3.8%
7%
11%
15%
Landfill
Diversion Rate
3.8%
10%
19%
23%
PSI Tire Stewardship Final Action Plan
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68
200
4,812
2025%
27 34%
27
Cost Internalization – Rechargeable Battery Recycling Corporation
Another type of product stewardship model is exemplified by the Rechargeable
Battery Recycling Corporation (RBRC), which was established by manufacturers, without
legislation (initially), to collect and recycle rechargeable batteries. In this case, the consumer
is not aware that the recycling infrastructure was created through funds derived from a charge
assessed by RBRC, a “third party organization,” on its member manufacturers. Each
manufacturer recovers these costs in the course of doing business, and internalizes them into
the product purchase price, passing them on invisibly to the consumer in full or in part.
Some stakeholders prefer that end-of-life management costs be internalized into the
product price invisibly, believing that such a mechanism gives greater incentive to
manufacturers to reduce product impacts, as compared to visible fees. They reason that a
manufacturer that reduces its end of life costs should be able to pass on that savings to
consumers through a lower product price, thus developing a competitive advantage.
In the RBRC model, rechargeable batteries are collected from consumers by
municipalities, retailers, businesses, and public agencies across the United States. The
program is free to consumers and municipalities, as RBRC pays the shipping costs to the
battery recycler. The fee paid by manufacturers into a fund is determined by a formula set by
RBRC based on battery type and market share. The fees pay for collection, shipping,
recycling, and program outreach.
X.
ISSUES AND STRATEGIES
This section of the Tire Stewardship Action Plan outlines key issues and potential
strategies to address the problems related to waste tire management identified by the Product
Stewardship Institute (PSI) from 22 interviews with government officials, tire manufacturers,
retailers, recyclers, and other key participants.
Issue 1: Waste Tire Generation
Solution: Increase lifespan of tires
In the state of California, 33.5 million tires are generated as waste each year. The
magnitude of this estimate indicates the clear need to reduce the generation of waste tires.
The most effective way to reduce the costs and environmental impacts of waste tire
management is to avoid the generation of tires in the first place by extending the life of tires
so that they last longer. The Rubber Manufacturers Association and the Tire Industry
Association both educate consumers on how to properly maintain tires and, therefore, to
minimize or delay waste. Expanding the life of tires will reduce the number of tires entering
the waste stream.
PSI Tire Stewardship Final Action Plan
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28
Potential Strategies
1.
Increase consumer education on tire maintenance at retail and other locations.
Most consumers are unaware that tire maintenance is related to increasing the life of
their tires and could save them money. Education on tire maintenance could occur at
retailers, municipal locations, auto repair shops, and through the media. Existing
materials provided by RMA and TIA could be incorporated. A specific target for
education on tire maintenance could be commercial fleets. One suggestion for
consumer education was to place windshield stickers on vehicles to remind them
about tire service and maintenance, much like those used to remind consumers of oil
changes.
2.
Provide free and convenient pressure gauges and air for tire maintenance.
Providing easy access to a tire gauge to test pressure, and providing free and
convenient air when tires are low could increase consumers’ ability to properly
maintain their tires. These could be provided at gas stations, service stations, and
retailers.
3.
Install “smart tire” systems on new vehicles (recommended in the report entitled,
Extending the Lifespan of Tires – Final Report). 27 Smart tire systems do not require a
change in consumer behavior, but instead rely on computerized devices to maintain
proper tire function. Three examples include: (a) a device that alerts drivers when a
tire is low on pressure and should be filled; (b) an auto-inflate system that monitors
and maintains tire pressure at optimal levels; and (c) a system that can communicate
information from tires to the vehicle suspension and braking system to help reduce
breaking distances. This strategy could be implemented either voluntarily by the
manufacturing industry or through state or federal legislation.
4.
Manufacture longer lasting tires (recommended in the report entitled, Extending the
Lifespan of Tires – Final Report). With so many inexpensive tires on the market, it is
difficult to get many consumers to purchase higher-end tires. However, in most cases,
cost is directly related to quality and to the mileage one gets from a tire.
Manufacturers increased the life of a standard tire from 28,000 miles for a light-duty
tire in 1981 to 43,000 miles in 2001, resulting in a 15 percent reduction in waste tires.
An even longer lasting tire would further California’s effort to reduce waste tires
being landfilled.
5.
Encourage consumers to buy longer life tires. While longer lasting tires are
currently in the marketplace, many consumers are still purchasing low-cost, shorter
life tires in an effort to save money. Information about tire lifecycle costs and
benefits could help encourage more consumers to invest in better quality, longerlasting tires.
27
Extending the Lifespan of Tires Final Report by Schmuel L. Weissman and Jerome L. Sackman, Symplectic
Engineering Corporation and David Gillen and Carl Monismith, Institute for Transportation Studies, University
of California at Berkeley, July 2003.
PSI Tire Stewardship Final Action Plan
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29
6.
Develop a unified approach to optimal tire pressure. Currently, information
provided to retailers by automobile manufacturers and/or tire manufacturers is not in
agreement with retailer’s opinion about the optimal tire pressure. Retailers typically
pressurize tires at a higher level than recommended by the automobile manufacturer.
Lower pressure often provides the consumer with a smoother ride. However, the tire
then is more likely to be low on air and, therefore, have a shorter life. Higher pressure
levels increase tire longevity and translates into better fuel efficiency for the vehicle.
However, too much air in a tire can mean the vehicle will not handle as well and can
cause safety risks. The automobile manufacturer prints the optimal tire pressure on a
label placed on the vehicle, usually on the inside panel of a door. Participants could
convene a multi-stakeholder workgroup to develop a common strategy to optimal tire
pressure.
7.
Encourage proper wheel alignment on the vehicle. Wheel alignment can have a
big influence on tire life, and therefore placing an emphasis on wheel alignment with
auto manufacturers and retailers could help reduce wear on tires and ultimately reduce
the number of tires entering the landfill. Wheel alignment is addressed in a public
education piece developed by the RMA promoting importance of “PART” –
“pressure,” “alignment,” “rotation,” and tread.
Issue 2: Waste Tire Markets
Solution: Develop performance metrics for program success
Currently there are no agreed upon goals in California for the amount of tires that
should be diverted from disposal or into different market development efforts. Setting goals
for these efforts could help focus priorities, much as it did with the carpet industry. The
Environmental Protection Agency’s Resource Conservation Challenge Tire Cluster has
agreed on a set of measurable national goals, which could be considered and adopted by
California (see Appendix C). One of those goals is to divert 85% of newly generated scrap
tires to reuse, recycling, or energy recovery by 2008.
Potential Strategies
1.
Set measurable goals for market development and reduced disposal. Setting
long-term goals for reuse, retread, recycling, and reduced disposal of waste tires can
draw attention to the need to develop new markets, and to prioritize market
development activities. California’s tire programs do currently address many of the
issues and strategies outlined in this Action Plan. However, stakeholders expressed
an interest at the forum in prioritizing market opportunities and allocating grant
funding based on evaluative criteria. This work should be accomplished with agreed
upon timelines and a method for monitoring the progress towards meeting the goals.
By developing priority programs together, all stakeholders would have a vested
interest in the program as a whole, which might provide greater momentum towards
resolving priority issues.
PSI Tire Stewardship Final Action Plan
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30
2.
Conduct life cycle assessment and comparison among different market
opportunities. At the Tire Stewardship Forum, stakeholders expressed interest in the
development of a life cycle assessment across all markets as a way to compare life
cycle costs and benefits of the different market development options. By evaluating
markets based on objective criteria, funding strategies could be better prioritized.
3.
Evaluate regulatory barriers. While California has defined “waste tires” by statute,
some believe that the term “waste” sets up a perception of a waste material and not a
valuable or potentially valuable market commodity. In addition to this statutory
barrier to market development, there could be other regulatory barriers that inhibit
market opportunities. CIWMB could evaluate these regulatory barriers by market and
address those that negatively impact tire recycling.
Issue 3: Tire Reuse, Retread, and Remold
Solution: Increase Reuse and Retread Markets for Tires
Reuse is second on the waste management hierarchy only to waste prevention. Reuse
refers to when a tire has been used once, but still has useful life and could be used again.
While reuse of waste tires can be more challenging than reuse of other products, there are
some legitimate reuse opportunities that could impact the number of tires being landfilled. A
separate market that offers even more opportunities to reduce waste exists for retread tires.
Retreading refers to reusing a tire casing with a new tread applied to the tire surface.
Retreads offer performance equal to a new tire at a significantly lower cost. There are more
reuse and retread opportunities available today that could be explored to divert tires from
disposal to beneficial use, including export markets. However, both practices are hampered
by a poor perception among consumers. There is also an emerging domestic market for
remolded tires, a technology that has been used in Europe for some time, but has only
recently been looked at in the U.S.
Potential Strategies
1.
Promote use of retreads among government and commercial fleets. Retreads are
most common and practical in commercial fleets for large truck tires. While state
government fleets and many private business fleets in California are currently having
their tires retread, there is a tremendous opportunity to increase retread use by county
and city fleets, federal government fleets, as well as commercial fleets. Education
could be accomplished through workshops, outreach, and targeted campaigns,
including a model local government procurement strategy for retread tires.
2.
Reduce liability concerns over reused tires. While segregating usable tires for
reuse is a common practice, the potential for reuse is not being fully realized. Some
retailers are concerned that their liability insurance might be voided if they mount
used tires on vehicles, instead of using new tires. It was particularly suggested that
more reused tires could be sold in Mexico if this insurance barrier could be overcome.
However, any pursuit of new Mexican markets must take into account the need for
PSI Tire Stewardship Final Action Plan
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31
proper management of tires at end-of-life to avoid current challenges with illegal tire
piles along the U.S./Mexico border.
3.
Promote tire repair. Consumer education on tire repair and the availability of tire
repair services by retailers could increase tire life. When a tire is repaired, it is
important that the damaged area be properly reinforced in order to provide adequate
safety and performance of a repaired tire.
4.
Education on maintenance of truck tires to increase retreadability. When a
consumer of commercial or heavy-duty truck tires properly maintains a tire, the
ability and likelihood that it can later be retread is increased. Retreaders need a good
casing for effective retreading, which can only be achieved through proper
maintenance in its first life.
Issue 4: Collection and Transportation
Solution: Reduce regulatory barriers to lower costs of tire collection
A new Waste Tire Hauler and Manifest System went into effect in California on July
1, 2003. The manifest system in California, like most other states, was enacted to discourage
the illegal disposal of tires, which would contribute to existing tire pile problems. These
regulations have reduced the illegitimate tire hauling businesses in the state. However, recent
increased enforcement of the regulations has also resulted in fewer haulers that can meet the
burdensome reporting requirements. This loss of competition makes it harder to find a hauler
to pick up waste tires, and harder to find a company from which to buy waste tires. In
addition, collection of waste tires by small retailers poses a particular problem owing to
limited space and the need for more frequent pickup. Further, some local governments have
passed ordinances that do not allow tires to be stored outdoors because of the possible
attraction of mosquitoes and vermin.
Potential Strategies
1.
Streamline tire manifest system. CIWMB could streamline its existing tire manifest
system to reduce regulatory costs without easing up on environmental protection.
According to several stakeholders, only two processors are reportedly able to submit
manifests electronically, which creates an uneven playing field for tire haulers across
the state. While the state has been providing incentives to get other haulers on the
Electronic Data Transfer (EDT) program, such as computer consulting assistance,
those efforts are yet to be successful. In addition, registration and reporting
requirements have also been described as burdensome. Reviewing and revising the
waste tire management rules and regulations to be more conducive to smaller
collectors, haulers, and processors could increase competition and decrease costs of
tire management in the state.
2.
Develop cooperative collection contracts. Work with organizations, such as the
Chamber of Commerce or CIWMB to develop cooperative contracts with collectors
PSI Tire Stewardship Final Action Plan
July 2005
32
of waste tires. This could reduce costs by bringing smaller businesses under one
contract. Cooperative collection and management will make tire markets more
efficient no matter what market the waste tires go to.
Issue 5: Crumb rubber markets
Solution: Develop sustainable and diversified crumb rubber markets
When tires are processed cryogenically (frozen and broken) or ambiently (ground) to
a small particle size, the finished product, crumb rubber, can be used in a variety of
applications, from loose fill to molded products to rubberized asphalt. Crumb rubber markets
struggle owing to the high cost of producing crumb, along with technological barriers and the
lack of use of existing specifications. In order to develop long-term, diversified, and
sustainable markets for crumb rubber, there need to be technological advancements, financial
assistance, and education to overcome the barriers that exist today.
Potential Strategies
1.
Promote existing specifications for crumb rubber. Tire processors often do not
produce a product to a standard specification even though there are existing ASTM
standards for recycled vulcanizate particulate rubber,28 and another specification
under development by the Institute for Scrap Recycling Industries (ISRI) through its
Scrap Tire Workgroup. The lack of awareness of these specifications contributes to a
lack of clarity of expectations between those who buy and sell recycled rubber
products. Stakeholders could work jointly to promote the existing standards for
widespread use in California’s tire industry.
2.
Increase government and business purchase of tire-derived products. While
there are a wide variety of tire-derived products available in the marketplace, building
market acceptance and sustainability continues to be a challenge. Few government
agencies or businesses are purchasing tire-derived products, such as mats, liners (e.g.,
for truck beds), and rubberized asphalt (such as parking lots). Start-up companies
have a difficult time securing customers to purchase their products, and there remains
a glut of crumb rubber in the marketplace. The purchase of tire-derived products by
government agencies and businesses can be increased by developing model
procurement policies, as well as marketing plans that target specific areas that show
the best potential for increased use. Businesses, such as tire processors, retailers, and
manufacturers could particularly benefit from such action.
3.
Overcome perception related to inferior quality of recycled content tires. As
with other types of recycled-content products, consumers must learn that recycled
doesn’t mean inferior. Overcoming negative perceptions about tire-derived products
could open doors for new markets and products. This holds true especially in product
28
ASTM D5603-96 Standard Classification for Rubber Compounding Materials – Recycled Vulcanizate
Particulate Rubber
PSI Tire Stewardship Final Action Plan
July 2005
33
categories such as new tires with recycled content. Consumers could be educated on
the price, quality, and availability of tire-derived products and how this compares to
products containing only virgin materials. Such education could be conducted in
conjunction with tire-related associations to make information more readily available
for consumers at the point of purchase.
4.
Research and develop strategies to overcome technical barriers to using crumb
rubber as a raw material. Two approaches are included in this strategy: (a)
Research on devulcanization technologies, and (b) Material Safety Data Sheets
(MSDSs). Today, partial devulcanization exists, which still limits the amount of
material that can be incorporated into new product manufacturing. If devulcanization
could be accomplished in full to break the sulfur bonds that hold tire rubber together,
there could be a much greater potential for using crumb rubber in new tire production.
A second approach would involve tire manufacturers providing generic MSDSs on
tires so that those manufacturing crumb rubber, or products made from crumb, had a
full understanding of the chemical properties with which they were working. Any
solution, however, would have to allay any anti-trust concerns.
5.
Equipment grants for crumb rubber manufacture. Equipment for processing tires
is expensive to purchase and maintain. It is estimated that, for every tire a processor
recycles annually, they need one dollar in capital investment. Grinders, cutters,
slicers, and sheers must be sharpened and replaced regularly in order to keep
equipment operating. Providing funding for equipment, start-up projects, or expansion
projects could help overcome some of the initial economic inequities of recycled
rubber over virgin, particularly if the current matching requirements were reduced. In
addition, it might level the playing field with Canadian companies that receive
subsidies for tire recycling. However, most stakeholders agree that initial funding
should not lead to long-term subsidies of the industry. In addition, some stakeholders
noted that if CIWMB was going to subsidize the tire infrastructure, they should
support the end markets and not the hauler/recycler. Financial assistance could also be
directed to the purchase of energy-efficient equipment.
6.
Provide marketing assistance for California tire-derived product manufacturers.
In Georgia, the state assists manufacturers of tire-derived products by providing
funding for marketing costs, including the cost of international trade trips to market
products abroad. The state of California does provide trade show grants, but these are
generally for domestic marketing. International trade marketing assistance is useful in
finding new markets. The tire recycling industry is still in its infancy, and marketing
assistance will enable tire-derived product manufacturers to mature as the markets
develop.
PSI Tire Stewardship Final Action Plan
July 2005
34
Issue 6: Recycled Content in New Tires
Solution: Increase the percentage of recycled content in new tire manufacture
Today, the tire industry uses between .05 and 5 percent recycled content in new tire
manufacturing (although some tires do not contain any recycled content). According to a
2003 report commissioned by CIWMB on recycled content, it is technically feasible for
manufacturers of tires to use as much as 10 to15 percent recycled content, although there is a
debate as to the impact that adding any amount of recycled content has on tire longevity and
performance.29 Tire manufacturers, however, do not agree that it is technically feasible to use
10-15 percent recycled rubber in new tires. The goal would be to increase recycled content in
tires without compromising performance and safety, and without causing tires to degrade and
enter the waste stream earlier.
Through technological advancements and financial assistance, and by overcoming
public perception of product inferiority, there could be opportunities for greater recycled
content in new tire manufacturing. The potential for increased recycled content in new tires
without impacting tire performance, safety, and longevity has been challenged by tire
manufacturers, and should be addressed in future meetings. It was also noted that requiring
California recycled rubber in new tires would not be practical due to the distance to tire
manufacturers.
Potential Strategies
1.
Conduct research on technologies to increase recycled content in tires.
Devulcanization is a technology that holds the greatest potential for enabling tire
manufacturers to add higher percentages of recycled content into new tire
manufacturing. Increasing research on devulcanization could help reduce costs of
using recycled rubber and improve crumb rubber feedstocks. Of all the potential
markets for crumb rubber, use in new tire manufacturing would be the highest and
best use of the material. Stakeholders could explore the means for overcoming the
technological and cost barriers to increasing recycled content in new tire
manufacturing.
2.
Provide financial incentives to increase demand for recycled rubber. Since the
cost of recycled rubber is typically higher than virgin rubber, it is difficult for it to
compete in the marketplace. Short-term financial incentives, such as procurement
grants to test new products, or tax credits, could increase demand for recycled rubber
and drive down long-term pricing.
3.
Develop recycled-content tire procurement specifications along with a strategy
for procurement of recycled-content tires and molded products. To stimulate
demand, state and local government fleets, as well as large private sector procurement
entities, could require or encourage the purchase of new tires that contain greater than
29
Increasing the Recycled Content in New Tires, Draft Report, July 2003.
PSI Tire Stewardship Final Action Plan
July 2005
35
5 percent post-consumer recycled content. In addition, California state government
could consider changing its price preferential policy to allow purchases on recycled
content tires and other specified products that are up to 10 percent higher than virgin
counterparts, as many states now do. California could also develop a campaign to
increase the amount of tire-derived products purchased (new tires with recycled
content or other products that contain recycled content), including setting
procurement targets, developing an internal marketing campaign, and conducting
demonstration projects. Further, the state could set a goal for the increased use of
recycled-content incrementally over time. Finally, CIWMB could work with
automobile manufacturers to specify and procure recycled content in tires. This
would be possible if manufacturers were to specify which tires contained recycled
content and at what quantities.
4.
Provide incentives to manufacturers to use recycled content. According to the
NATC’s Increasing the Recycled Content in New Tires report, there are two
suggested strategies to provide incentives to tire manufacturers to increase their
recycled content: reliable, cost-competitive supply of high-quality crumb rubber; and
requirements imposed by vehicle manufactures and government agencies. These and
other incentives can be further explored in an effort to increase the percentage of
recycled content in new tire, as well as to provide incentive to manufacturers that do
not currently use any recycled content in tire manufacturing.
Issue 7: Rubberized asphalt concrete markets (RAC)
Solution: Develop sustainable and diversified rubberized asphalt concrete markets
The states of Arizona and Florida successfully use rubberized asphalt pavement for
many road-paving projects. However, RAC use has often faced barriers regarding a
perception of higher cost and lower performance. California’s Department of Transportation
(CalTrans) has developed an internal goal, which it has exceeded, of using RAC on 15
percent of all its flexible pavement projects. Californians Against Waste sponsored
Assembly Bill 338, which, if passed, would require CalTrans to include RAC in 20 percent of
its asphalt pavement projects by January 1, 2007, increasing to 25 percent by 2010, and 35
percent by 2013. There is great potential to increase RAC use within CalTrans, county
highway departments, and among asphalt contractors through education, financial assistance,
use of existing specifications, and technological advancements.
Potential Strategies
1.
Promote the use of existing standardized asphalt mix designs and paving
standards for rubberized asphalt concrete (RAC). Using specifications from the
Arizona Department of Transportation and others, California could develop standards
for asphalt mix designs in conjunction with CalTrans that could be incorporated into
state transportation standard operating procedures for road construction. Standard
RAC mix designs and paving standards could be tested and proven to work under
PSI Tire Stewardship Final Action Plan
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36
California climate conditions. Following successful demonstration projects, the state
could promote the use of RAC for other projects.
2.
Train and educate state and local highway engineers, and others on rubberized
asphalt use, costs, and benefits. When evaluating crumb rubber as part of a
rubberized asphalt project, it is important to look beyond initial costs and towards
long-term benefits. Rubberized asphalt has been proven to improve vehicle traction
and, when installed properly, it can increase the useful life of the road and reduce
cracking. Most governments look at budget cycles and lowest bid when constructing
a road, which makes it difficult for rubberized asphalt to compete. However, when a
lifecycle analysis is completed, including the improved safety features, rubberized
asphalt can compete well with traditional road construction.
CalTrans, county highway departments, and other state and local agencies could be a
major consumer of rubberized asphalt if staff is given the technical specifications and
education on how and why to do so. Training could also benefit paving contractors
for use on private jobs, such as parking lots and private roads. Education is
particularly needed to overcome perception issues related to cost and performance,
and will be essential to employee understanding of the technical aspects of the
material. Continued state grants are an essential component of this strategy.
Currently, CIWMB offers grants for RAC, although these grants could be marketed
more widely and used in more projects by the paving industry. However, as
rubberized asphalt gains greater market acceptance and market share, these subsidies
could be eliminated.
3.
Gain acceptance of RAC use: Promote successes to convince those who are
skeptical about the practicality of using RAC. RAC has been used successfully in Los
Angeles County and Orange County, California.
4.
Require CalTrans and others receiving state funding to purchase California tirederived tire rubber. Most of the rubber used in California in rubberized asphalt
originates from Canada. To further develop markets for California-made crumb
rubber, the state could require that the rubber be supplied by a California
manufacturer. Assembly Bill 338 would require the use of crumb rubber that is
manufactured in the United States and derived from waste tires taken from vehicles
owned and operated in the United States.
5.
Develop infrastructure and logistics for material delivery at jobsites. There is a
need to further develop the crumb rubber infrastructure so that tire processors can
amass enough crumb rubber supply in advance of a road paving project. This could
include consolidation areas, storage areas, and cost-effective transport systems. In
addition, delivery and storage logistics need to improve for crumb rubber at the
jobsite so that material is available at the quantities needed and at the time needed.
Becoming a more dependable source will enable companies to develop long-term
PSI Tire Stewardship Final Action Plan
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37
contracts for crumb rubber supply and delivery on a regular basis and develop more
secure markets for crumb rubber.
6.
Evaluate RAC market potential and funding: Research whether the funding for
RAC projects has been effective at increasing RAC markets, and the potential for
RAC markets, particularly whether RAC can be promoted for noise reduction
purposes to attract federal highway funding. Determine the results of previous RAC
funding.
Issue 8: Shredded tire markets
Solution: Increase the civil engineering applications for shredded tires
Shredded tires can be substituted for traditional civil engineering materials, such as
aggregate or stone, and as a lightweight fill material. There are existing ASTM standards for
the use of shredded tires in many civil engineering applications, including road base,
embankments, landfill drainage, and landfill cover. Owing to past problems associated with
using waste tires in these applications, there is some reluctance to use shredded tires today.
In addition, some have expressed a concern about the reuse or recyclability of shredded tires
after their use in civil engineering applications, and whether they become eventually
landfilled. Through local and state government education and use of standard specifications,
these barriers may be able to be overcome. Additional strategies will be needed to address the
“after use” issue.
Potential Strategies
1.
Provide education and information on benefits of using waste tire shreds in
landfill applications. Chipped and shredded waste tires have been successfully used
to line the bottoms of landfills and to provide drainage in the leachate collection field.
In addition, they can be used as daily cover material at landfills as an alternative to
dirt, sand, or other cover. Strategies could target landfill operators and solid waste
authorities, such as the Solid Waste Association of North America’s CA Chapter.
2.
Educate transportation officials about ASTM specifications for tire shreds.
Those using waste tires as an aggregate substitute for bridge embankments, sub-grade
fill, retaining wall reinforcements, and other civil engineering applications need to
understand and follow the existing ASTM standards for maximum project
performance. This can be accomplished by educating transportation officials and
writing ASTM standards into state and local contracts.
3.
Allow for, and promote, waste tire use in local septic fields/drainage through
local ordinances and state rule. Regulators and lawmakers, such as state and local
departments of health, could formally accept tire chips as an alternative to aggregate
and sand when installing or repairing a septic system. In addition, there would need to
be education provided on the proper installation of septic fields using tire chips
among residents and those who install septic systems.
PSI Tire Stewardship Final Action Plan
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38
4.
Educate about specifications to increase the use of tires in road base. There are
existing specifications that have been widely accepted for the use of tire chips in road
base applications. This should lead to reduced risk of problems such as those that
occurred in the past. There is a need to educate about these specifications and to
overcome negative press by highlighting success stories. In addition, proper technical
applications should be shared with both state and county highway engineers.
Issue 9: Recreation markets
Solution: Develop sustainable and diversified recreation markets
Loose fill crumb rubber can be used in a variety of applications for recreation and
outdoor use, such as playgrounds, running tracks, sports fields, horse arenas, golf courses,
and walking trails. However, crumb rubber is often not chosen as a ground cover or fill owing
to cost barriers and a public perception of product inferiority. CIWMB has implemented a
successful grant program to help encourage the use of the crumb rubber in recreation
application. Yet, there are still limited markets and questions as to what it will take for this
market to be sustainable so that subsidies can be eliminated. Through public education,
grants, marketing, and other avenues, stakeholders could build more sustainable markets for
recreational use of waste tires.
Potential Strategies
1.
Develop a market development plan for recreational uses. California currently
offers grants for the use of crumb rubber in playgrounds. However, to move these
products into the mainstream and provide a sustainable market, a focused marketing
plan would be needed. This could involve assistance to manufacturers of crumb
rubber to market their recreational products to parks departments, schools, and
daycare centers. California could use existing demonstration projects, evaluate the
applications, and use the demonstration projects as testimonials. Recycled plastic
lumber is a good example of a recycled product that overcame the initial difficulty
entering the market against wood decking and fencing. Now the material is readily
available and, even though recycled plastic lumber is more expensive than wood in
the short term, it is used widely owing to its positive attributes and long-term
economic viability. Crumb rubber in recreation applications could follow that lead.
2.
Promote benefits of crumbed and chipped rubber over traditional materials used
in sports fields, playgrounds, horse arenas, golf courses, walking trails and as
mulch. In many cases, tire material used for playgrounds, sports fields and other
recreational applications can perform better than traditional materials. However, there
remain certain negative perceptions about the product that create barriers to its
widespread use. Through proper installation techniques and education of parks and
recreation officials (public and private), schools, day care providers, and others, these
barriers could be overcome. The result could be an increased use of crumbed and
chipped rubber in these markets.
PSI Tire Stewardship Final Action Plan
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39
Issue 10: Tire-derived Fuel
Solution: Increase tire-derived fuel markets
Currently, six of nine permitted cement kilns in California are burning tires. Another
nine kilns in the state are not currently permitted to burn tires. In addition, there are two cogeneration plants in state burning tire-derived fuel. As a result, there is an opportunity to
increase waste tire use in these applications and divert more tires from landfills. Many
Forum participants expressed the belief that, without more TDF use, at least in the short term,
there would be little hope of eliminating landfill disposal of waste tires. In addition to cement
kilns and co-generation plants, there are other facilities, such as industrial boilers, steel mills,
and pulp and paper mills that could also use tires as a fuel source or other beneficial use.
While tires are not considered the highest and best use for a waste tire, often it is the only
economical market available to divert material from landfills. In addition, the mining and
transportation of coal or coke as a fuel source is less efficient and more environmentally
damaging than using local tires for energy. Finally, tires can also improve air quality by
reducing air pollutant emissions as compared to the combustion of coal or coke. These
environmental costs and benefits could be part of the life cycle analysis of waste tire markets
mentioned earlier under Issue #2: Waste Tire Markets.
Potential Strategies
1.
Overcome perception related to environmental hazard of burning tires for fuel.
U.S. EPA has recently developed a draft TDF policy that is circulating internally for
approval, and has been conducting outreach to gain wider acceptance of the use of
TDF. Once the final policy is published, there will be official federal support for
TDF, which could be leveraged in California. EPA is also working on a white paper
on best management practices for pulp and paper mills and cement kilns using TDF,
which will provide further support for the use of TDF for fuel. While TDF may not be
considered the highest and best use of the tire resource by many stakeholders, it can
be an effective means of reducing tires disposed while other markets are being
developed. Education of the fuel alternatives and their environmental impacts, such
as the mining and transportation of coal and the reduction in NOx emissions with
TDF over coal might help some opponents better understand the potential benefits of
TDF markets over landfilling.
2.
Provide financial assistance for facility conversion or other start-up costs.
Currently, California law does not allow any of the waste tire fees collected to be used
for tire-derived fuel projects. If operators of boilers, furnaces, and kilns had access to
financial assistance to defray start-up capital costs or to assist in overcoming logistical
barriers, more tires might be converted from landfills to tire-derived fuel markets.
There is agreement among those who use TDF that, while start up financial assistance
would help stimulate the TDF market, long-term subsidies would not be required. At
the Forum, there was interest among some participants to at least consider whether
there was an objective basis for requesting a statutory change to allow funding for
PSI Tire Stewardship Final Action Plan
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40
TDF projects. This would be best addressed in the life cycle study previously
mentioned.
Issue 11: Landfill Disposal
Solution: Reduce tire landfilling through incentives and disincentives
The biggest deterrent to diverting more tires from landfilling is that it remains the
least expensive management option. In order to overcome this barrier to recycling markets,
California could level the playing field and make tire recycling as economical, or more
economical, than landfilling. Some participants, however, believe that it is more appropriate
to let market forces drive tire management options rather than government intervention.
Potential Strategies
1.
Phase in a landfill ban on tires. Though California currently does not allow whole
tires in landfills, a complete ban on processed tires would provide incentive for
materials to move to other markets for recycling. However, any ban would need to be
phased-in over time to avoid stockpiled tires without a market destination.
2.
Increase landfill tipping fees. To provide added incentive to recycle and dissuade
landfilling, CIWMB could add a surcharge on waste tires disposed of at landfills
beyond what is currently charged for municipal solid waste. This could be done in the
form of a state or local fee placed on tires per ton, per cubic yard, or per tire, to create
a financial disincentive to landfill tires.
3.
Provide recycling incentives for retailers or haulers. One consideration is to pay a
reduced fee, less than the $1.00 per tire currently require to the state, for those tires
collected and destined for recycling markets over landfilling. This option would
provide a financial incentive to those who seek recycling outlets for waste tires over
landfilling.
4.
Require storage and marketing of tires before landfilling. The State of Illinois
requires that all waste tires taken to a landfill must be held for 30 days, with efforts
made to find recycling markets for the materials instead of landfilling. Landfills can
accept the material following the 30-day period, but must first post the material
availability in a materials exchange for possible market placement. This policy could
be instituted in California to encourage less landfilling.
PSI Tire Stewardship Final Action Plan
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41
Issue 12: Sustainable Financing
Solution: Develop agreement on long-term funding strategy
Today, California has a $1.00 per tire fee that is collected at the point of retail from
consumers on each new tire purchased. That fee funds all of the state of California’s tire
programs. Having a funding source will be critical to the success of any statewide tire
collection and processing program. However, the goal of funding should be to provide the
market stimulus necessary for waste tires to have value at the end of their life and that tire
markets be able to sustain themselves. Some states, such as Oregon, have sunset their tire
fees before that sustainable dynamic has occurred and quickly had new illegal tire piles with
no funding source for proper management.
Keeping costs low will require the active involvement of all stakeholders, particularly
the tire industry, which best understands market dynamics. Cost-effective system
management has often been the trademark of private sector involvement. While government
has a key role in tire management, there may be more room for greater efficiencies as
stakeholders work more closely together on system management.
Potential Strategies
1.
Develop a third party organization that can provide cost-effective system
management. A third party organization (TPO), comprised primarily of tire
industry officials, with a multi-stakeholder advisory panel could manage the tire
infrastructure system, market development projects, and other critical initiatives.
The TPO could also function as the fund manager, keeping government out of fund
collection and distribution. Government could maintain its planning and
enforcement role and set overall system goals. Having a third party organization
manage the fund could ensure that tire fees are not raided to meet state general fund
needs. Research would be needed, however, to determine how a TPO could be
integrated into existing government-managed fee-based systems. At the Forum, one
stakeholder suggested that a TPO could serve a function other than collecting and
distributing fees, such as on education, contracting for collection and recycling
services, and other tasks. In other product stewardship initiatives, such as the
RBRC, a third party organization oversees all funding and programs. In other
instances, like CARE, an industry third party organization helps set, meet, and
evaluate goals. Whether led by CIWMB or an independent organization, evaluating
the fee on a regular basis and setting and working towards reaching goals will
ensure that adequate funding is available and spent to meet predetermined goals for
waste tire diversion from landfills.
2.
Distribute funding according to negotiated priorities. Funds could be distributed
based on a negotiated agreement among stakeholders representative of the key
interest groups in California. Funding would follow priority strategies agreed to as
part of this dialogue process. This could be done in conjunction with a life cycle
market assessment. Such a mechanism could lead to greater commitment from
PSI Tire Stewardship Final Action Plan
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42
stakeholders to a full package of options rather than staying focused on their own
particular interests. The goal of the funding strategies would be to work towards a
sustainable tire infrastructure, and fund program priorities set by CIWMB and other
participants in the context of the Final Tire Product Stewardship Action Plan.
Stakeholders would need to develop a process for updating priorities and evaluating
projects and funding allocations. The TPO could play a critical role in this process.
XI.
PROPOSED PROJECT SUCCESS METRICS






XII.
Fewer tires stockpiled and disposed (reflecting education and other efforts on tire
purchase, maintenance, reuse, retreading and recycling)
Of the waste tires collected, increased levels of tires reused, retreaded, and recycled.
Increased amount of tire-derived products available on contract and purchased.
Increased levels of recycled content in new tires.
Increased markets for scrap tires, including crumb rubber, tire derived fuel, civil
engineering applications, molded products, etc.
Reduced cost of tire management for generators, haulers, and processors.
RECOMMENDATIONS
The Product Stewardship Institute makes the following recommendations:
Expand Stakeholder List: Over 50 participants attended the Tire Stewardship Forum,
including six tire manufacturers that represent the vast majority of the market share. Even so,
several groups were missing. At the conclusion of the Forum, participants identified
additional stakeholders that it felt should be invited to attend future meetings on tire
stewardship. Efforts should focus on obtaining additional representation from environmental
groups (e.g., Sierra Club and National Resources Defense Council), the automobile industry,
state and local government officials, the pavement association, the California Ash Coalition,
and Waste Management Inc. PSI has previously discussed this topic with many of its 31 state
members, who have already expressed interest in participating in a national tire stewardship
dialogue. In fact, tires were ranked as the sixth most pressing waste management concern
among state officials prior to PSI’s first national product stewardship forum, which launched
the organization in 2000.
Distinguish Dialogue Focus – National vs. California/State: Stakeholders at the Tire
Stewardship Forum were split on whether the initiative should be national or local. Those
who focused on the need for scrap tire markets wanted to set goals for California, since the
RCC has already established national goals. Those who focused on broader strategies, such as
longer-life tires and recycled content in new tires, saw the need for a national dialogue. As a
first step, PSI recommends that consensus be reached with stakeholders on which issues are
national and affect the entire tire industry, and which are more local and regional in scope.
Dialogue goals should reflect these distinctions.
PSI Tire Stewardship Final Action Plan
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43
Set Short-term and Long-term Goals: Several participants at the Forum suggested that the
group first find markets for 100 percent of the scrap tires in California, then move toward
solutions that are continually more environmentally sound. Setting short-term and long-term
goals will allow for a dynamic vision for tire management that does not lock into a single
approach.
Coordinate with Existing National and State Efforts: Any future effort should coordinate
with the RCC, California’s Five-Year Tire Plan, and other relevant national and state
initiatives so duplication and conflicting agendas are avoided.
Convene TDF and RAC Work Groups: Prior to the next meeting, two work groups should
be established – on TDF and RAC, as decided at the Forum. These groups already
determined the issues on which they would report to the full group.
Develop a Steering Committee to Guide Meeting Design: The group decided at the Forum
to create a Steering Committee to develop the agenda for the next meeting and frame the
issues.
Hold Four Meetings over a Year: The Forum participant group concurred with the concept
of planning for four meetings as long as the meetings were useful. All issues and strategies
that PSI identified in the Final Tire Stewardship Action Plan should be discussed over the
course of the four-meeting dialogue. Those at the Forum became more comfortable with the
dialogue process when they understood that their top issues would be discussed at some point
in an equal manner to other issues, even though other issues might be discussed first.
Including the full range of issues in future meetings will also allow for a greater opportunity
to trade-off issues of varying importance to the different stakeholders.
Hold 1 ½ Day Long Meetings: PSI recommends that CIWMB consider holding meetings for
1-½ days, as recommended by the participants at the Forum. For a national dialogue, people
will be coming from different parts of the country. To make it cost-effective, and to cover the
significant number of agenda items, PSI recommends a day and a half for each meeting. In
addition, this arrangement will allow for more informal meeting time to build relationships,
which will enhance the success of the dialogue.
Consider Conducting a Life Cycle Market Assessment: Forum participants expressed a
strong interest in developing a life cycle assessment of all the tire markets to help prioritize
efforts and funding. Such a study could enlighten participants about the true costs and
benefits of each market opportunity, and would be a useful tool with which to engage
stakeholders in objective discussions. Forum participants particularly emphasized the need to
develop sustainable markets that are not continually subsidized financially.
Conduct Additional Research on the Following:

How and whether the chemical composition of the tire impacts tire markets, and
whether strategies exist to remove this potential barrier.
PSI Tire Stewardship Final Action Plan
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44

How would third party organizations be integrated into fee programs in the U.S.,
which already have the funds going to state agencies to run?

Distinguish what the tire fees fund in the U.S. versus what they cover in Canada.

Determine whether Canadian markets impact tire markets in California.

Confirm reuse numbers nationally and for California.

Better understand the potential for post-consumer recycled rubber to be incorporated
into new tires without dramatically impacting tire performance and safety.
PSI Tire Stewardship Final Action Plan
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45
APPENDIX A: PSI INTERVIEW LIST
Organization
Type
Interviewee(s)
US EPA, Region 5
Government – Federal Agency
Paul Ruesch
US EPA, Region 4
California Integrated Waste Management
Board
Illinois Environmental Protection Agency
Government – Federal Agency
Pamela Swingle
Government – State
Michael Paparian
Government – State
Todd Marvel
Georgia Department of Natural Resources
California Department of Transportation
(CalTrans)
Arizona Department of Transportation
(retired)
Government – State
Lon Revall
Government – State
Linda Fong
Tire Industry Association
Government – State - Recycled
Asphalt Concrete
Trade Association – Tire
Manufacturer
Trade Association – Tire
Manufacturer
Trade Association – Retailier
Tire Retread Information Bureau
Trade Association – Retreaders
Rubber Manufacturers Association
Rubber Manufacturers Association
BLIC
Cooper Tire & Rubber Company
Michelin
Golden By-Products, Inc.
U.S. Rubber Recycling Inc.
BAS Recycling
Trade Association – European
Tire Manufacturers
Tire Manufacturer
Tire Manufacturer
Manufacturer – Tire Derived
Products
Manufacturer – Tire Derived
Products
Recycler
Lakin Tire
Recycler
Big O Tire
Retailer
California Portland Cement
Tire Derived Fuel User
Californians Against Waste
Environmental Organization
George Way
Michael Blumenthal
Tracy Norberg
Dick Gust
Harvey Brodsky
Fazilet Cinaralp
Tom Wood
Clarence “Red” Hermann
Jana Nairn
Rick Snyder
Murray Quance
Randy Roth
Jerry Kiefer and Bruce
Cherry
John Bennett
Scott Smithline
Symplectic Engineering Corporation
Consultant
Shmuel Weissman
Waste Tire News
Consultant
Mary Sikora
T&L Associates
Consultant
Terry Leveille
PSI Tire Stewardship Final Action Plan
July 2005
A-1
APPENDIX B:
Stakeholder Survey and Tabulated Response
Tire Stewardship Dialogue Survey
July 8, 2004
The California Tire Stewardship Action Plan, e-mailed to dialogue participants on July 8,
2004, organizes topics for the upcoming dialogue into 12 key issue categories. The purpose of
this survey is to prioritize those issues, as well as potential strategies to address each issue, for our
stakeholder meeting in Sacramento, California, on July 28. Each of the issues and strategies are
described in greater detail in the Action Plan. PSI recommends that dialogue participants review
the Action Plan as they complete this survey.
Please provide your contact information:
Name: ________________________________________
Company/Agency/Org. __________________________
Phone: _______________________________________
E-mail: _______________________________________
RANKING THE ISSUES
Please prioritize the 12 key issues listed below, based on the perspective of your agency,
organization, or company. Place a number 1 through 12 to the left of the issue statements
where “1” indicates the issue of highest priority, “2” indicates the issue of second highest
priority, and so forth. We will use this part of the survey to prioritize issues to be discussed
at our stakeholder meeting in Sacramento. Please assign a different number for each issue.
PAINT ISSUES
Priority
______
______
______
______
______
______
______
______
______
______
______
______
Issue
Waste tire generation
Waste tire markets
Tire reuse
Collection and transportation
Crumb rubber markets
Recycled content in new tires
Rubberized asphalt concrete markets
Shredded tire markets
Recreation markets
Tire-derived fuel
Landfill disposal
Sustainable financing
PSI Tire Stewardship Final Action Plan
July 2005
B-1
PREFERENCES ON TIRE STEWARDSHIP STRATEGIES
The Action Plan outlines Solutions and Potential Strategies to address each of the 12
waste tire management Issues. In the following issue tables, please respond to the statements
by placing a check in the appropriate box. These statements are designed to gauge
stakeholders’ interest in pursuing strategies to support the solution identified. Please
prioritize each listed Strategy according to the degree to which you think they can resolve
the associated Issue. For example in Issue #1 below, if your organization strongly agrees that
“Manufacture longer lasting tires” should be prioritized as a Strategy to “Increase lifespan of
tires,” you would check “Strongly Agree.” If your organization were neutral on this strategy,
you would check “Neutral,” and so on. If there are additional strategies that are not listed
that you want to see addressed, please note them in the row provided at the end of each table.
Any additional comments can be noted in the space provided at the end of the document.
Issue #1: Waste tire generation
Solution: Increase lifespan of tires
Strategies
Strongly
Agree
Agree
Neutral
Disagree
Strongly
Disagree
Comments
1. Increase consumer
education on tire
maintenance at retail
and other locations
2. Provide free and
convenient pressure
gauges and air for tire
maintenance
3. Install “smart tire”
system on new
vehicles
4. Manufacture longer
lasting tires
5. Encourage consumers
to buy longer life tires
6. Develop a unified
approach to optimal
tire pressure
5.
Additional Strategies (please describe)
PSI Tire Stewardship Final Action Plan
July 2005
B-2
Issue #2: Waste Tire Markets
Solution: Develop performance metrics for program success
Strategies
Strongly
Agree
Agree
Neutral
Disagree
Strongly
Disagree
Comments
Disagree
Strongly
Disagree
Comments
Strongly
Disagree
Comments
1. Set measurable goals
for market
development and
reduced disposal
2. Additional Strategies (please describe)
Issue #3: Tire Reuse
Solution: Increase reuse and retread markets for tires
Strategies
Strongly
Agree
Agree
Neutral
1. Promote use of
retreads among local
government and
commercial fleets
2. Reduce liability
concerns over reused
tires
3. Additional Strategies (please describe)
Issue #4: Collection and Transportation
Solution: Reduce regulatory barriers to lower costs of tire collection
Strategies
Strongly
Agree
Agree
Neutral
Disagree
1. Streamline tire
manifest system
2. Develop cooperative
collection contracts
3. Additional Strategies (please describe)
PSI Tire Stewardship Final Action Plan
July 2005
B-3
Issue #5: Crumb rubber markets
Solution: Develop sustainable and diversified crumb rubber markets
Strategies
Strongly
Agree
Agree
Neutral
Disagree
Strongly
Disagree
Comments
1. Promote existing
specifications for
crumb rubber
2. Increase government
and business purchase
of tire-derived
products
3. Overcome perception
related to inferior
quality of recycled
content tires
4. Research and develop
strategies to
overcome technical
barriers to using
crumb rubber as a
raw material
5. Equipment grants for
crumb rubber
manufacture
6. Provide marketing
assistance for
California tirederived product
manufacturers
7. Additional Strategies (please describe)
PSI Tire Stewardship Final Action Plan
July 2005
B-4
Issue #6: Recycled content in new tires
Solution: Increase the percentage of recycled content in new tire manufacture
Strategies
Strongly
Agree
Agree
Neutral
Disagree
Strongly
Disagree
Comments
1. Increase recycled tire
rubber in new tire
manufacturing and
other molded
products
2. Conduct research on
technologies to
increase recycled
content in tires
3. Provide financial
incentives to increase
demand for recycled
rubber
4. Develop recycledcontent tire
procurement
specifications along
with a strategy for
procurement of
recycled content tires
and molded products
5. Additional Strategies (please describe)
PSI Tire Stewardship Final Action Plan
July 2005
B-5
Issue #7: Rubberized asphalt concrete markets
Solution: Develop sustainable and diversified rubberized asphalt concrete markets
Strategies
Strongly
Agree
Agree
Neutral
Disagree
Strongly
Disagree
Comments
Strongly
Disagree
Comments
1 . Use standardized
asphalt mix designs
and paving standards
for rubberized asphalt
concrete
2. Train and educate state
and local highway
engineers, and others
on rubberized asphalt
use, costs, and
benefits
3. Require CalTrans and
others receiving state
funding to purchase
California tirederived tire rubber
4. Develop infrastructure
and logistic for
material delivery at
jobsites
Issue #8: Shredded tire markets
Solution: Increase the civil engineering applications for shredded tires
Strategies
Strongly
Agree
Agree
Neutral
Disagree
1. Provide education and
information on
benefits of using
scrap tire shreds in
landfill applications
2. Educate transportation
officials about ASTM
specifications for tire
shreds
3. Allow for, and
promote, scrap tire
use in local septic
fields/drainage
through local
ordinances and state
rule
PSI Tire Stewardship Final Action Plan
July 2005
B-6
Issue #8: Shredded tire markets
Solution: Increase the civil engineering applications for shredded tires
Strategies
Strongly
Agree
Agree
Neutral
Disagree
Strongly
Disagree
Comments
Strongly
Disagree
Comments
4. Educate about
specifications to
increase the use of
tires in road base
5.
Additional Strategies (please describe)
Issue #9: Recreation markets
Solution: Develop sustainable and diversified recreation markets
Strategies
Strongly
Agree
Agree
Neutral
Disagree
1. Promote benefits of
crumbed and chipped
rubber over
traditional materials
used in sports fields,
playgrounds, horse
arenas, golf courses,
walking trails and as
mulch
2. Develop a market
development plan for
recreational uses
3. Additional Strategies (please describe)
PSI Tire Stewardship Final Action Plan
July 2005
B-7
Issue #10: Tire-derived Fuel
Solution: Increase tire-derived fuel markets
Strategies
Strongly
Agree
Agree
Neutral
Disagree
Strongly
Disagree
Comments
Strongly
Disagree
Comments
1. Overcome perception
related to
environmental
hazards of burning
tires for fuel
2. Provide financial
assistance for facility
conversion or other
start-up costs
3. Additional Strategies (please describe)
Issue #11: Landfill Disposal
Solution: Reduce tire landfilling through incentives and disincentives
Strategies
Strongly
Agree
Agree
Neutral
Disagree
1. Phase in a landfill ban
on tires
2. Increase landfill
tipping fees
3. Provide recycling
incentives for
retailers or haulers
4. Require storage and
marketing of tires
before landfilling
5. Additional Strategies (please describe)
PSI Tire Stewardship Final Action Plan
July 2005
B-8
Issue #12: Sustainable Financing
Solution: Develop agreement on long-term funding strategy
Strategies
Strongly
Agree
Agree
Neutral
Disagree
Strongly
Disagree
Comments
1. Develop a third party
organization that can
provide cost-effective
system management
2. Distribute funding
according to
negotiated priorities
3. Additional Strategies (please describe)
Please identify any additional comments in the space provided below.
_____________________________________________________________________________
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_____________________________________________________________________________
_____________________________________________________________________________
_____________________________________________________________________________
_____________________________________________________________________________
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_____________________________________________________________________________
_____________________________________________________________________________
_____________________________________________________________________________
_____________________________________________________________________________
PSI Tire Stewardship Final Action Plan
July 2005
B-9
Overall
Rank
Government
Manufacturers
and RMA
Retailers
and TIA
Recyclers
Other
1. Waste tire generation
7
1
10
3
10
10
2. Waste tire markets
1
2
1
2
1
1
3. Tire reuse
8
4
11
5
2
3
4. Collection and
transportation
6
6
7
1
5
11
5. Crumb rubber markets
5
3
5
9
7
4
6. Recycled content in new
tires
12
7
12
6
9
8
7. Rubberized asphalt
concrete
3
2
3
10
6
5
8. Shredded tire markets
4
5
4
7
4
6
9. Recreation markets
9
6
6
8
11
9
10. Tire-derived fuel
2
5
2
11
3
7
11. Landfill disposal
11
7
9
4
8
12
12. Sustainable financing
10
8
8
12
12
2
Number of Responses
13
3
6
2
1
1
Issue
PSI Tire Stewardship Final Action Plan
July 2005
B-10
OTHER STRATEGIES
Respondent
Name
Issue #
Strategy
Mpaparian
Mpaparian
1
6
Tleveille
1
Tleveille
8
Tleveille
10
Tleveille
12
Jsheerin
1
Jsheerin
2
Jsheerin
Jsheerin
Tfaust
8
9
6
Tfaust
Tfaust
10
12
Incentives and educations strategies for fleet owners
Existing tires have a recycled content of between 0 and 10%.
Information could be made available to allow informed
decisions about recycled content specifications.
Nitrogen inflation systems (primarily for fleets). Remember,
success here, which is important, may alter tire recycling
markets by making waste tires more difficult to obtain.
Also, vibration dampening under light rail tracks, lightweight
fill behind retaining walls. Alternative Daily Cover issue and
use of tire shreds in civil engineering applications at landfills
(leachate collection systems, protection of geo membranes,
etc., should also be discussed.
Research into combustion technology and emissions control
technology needed; less theory on issue.
Care must be taken not to put all "eggs in one basket" (I.e.
RAC)
All strategies that promote public transportation, car polling,
and less vehicle miles.
The goal is 100% or more of annual generation going into
better and better markets, with no piles or landfill disposal.
Fund demonstration projects
Demonstration grants for local communities
We have developed new roofing product patented
devulcanized products.
TDF should be outlawed
Been trying to raise capital for 3 years. Have only raised $1.1
million. Goal is $5 million.
PSI Tire Stewardship Final Action Plan
July 2005
B-11
COMMENTS BY INDUSTRY
SNBhavsar
SNBhavsar
SNBhavsar
SNBhavsar
SNBhavsar
SNBhavsar
Dchapman
Dchapman
Dchapman
Dchapman
Dchapman
Dchapman
Bcherry
Bcherry
Tleveille
Tleveille
Mblumenthal
Mblumenthal
Mblumenthal
Mblumenthal
Mblumenthal
Mblumenthal
Mblumenthal
Mblumenthal
Mblumenthal
Mblumenthal
Mblumenthal
Issue 1, Strategy 3: Smart tire systems on new vehicles are addressed under TREAD
Act separately
Issue 2, Strategy 1: Strong follow-up to set goals and accountability
Issue 3, Strategy 1: Retreads applicable to truck tires, not passenger tires
Issue 3, Strategy 2: Not the right forum to discuss reducing liability concerns over
reused tires
Issue 4, Strategy 2: Tire recycling contracts should be determined by market
competition, not cooperative contracts
Issue 6, Strategy 1: Not the right platform to decide about increasing recycled content
in tires and other products. Tire safety and performance are of greater importance.
Issue 1, Strategy 3: Smart tires being addressed by TREAD Action issue -not a state
issue
Issue 3, Strategy 1: Retreads applicable to truck and heavy tires only
Issue 3, Strategy 2: Reducing liability concerns over reused tires is a tort reform issue
Issue 4, Strategy 2: Cooperative collection contracts are an anti-trust issue
Issue 5, Strategy 4: overcoming technical barriers best handled by the tire
manufacturers - they are most knowledgeable.
Issue 11, Strategy 4: Required storage of tires before landfilling could be opportunity
to create new piles.
Issue 6, Strategy 1: Only increase recycled content in tires and molded products if it
would not increase cost or quality of the product
Issue 11, Strategy 1: There would have to be a viable alternative first before phasing
in a landfill ban on tires.
Issue 8, Strategy 3: Only promote use in septic fields/drainage if proven viable and
cost-effective
Issue 12, Strategy 2: Distributing funds according to priorities can become a political
football.
Issue 1, Strategy 3: Smart tires is a federal issue, addressed under the TREAD Act
Issue 2, Strategy 4: Oppose mandates for manufacture of longer lasting tires
Issue 1, Strategy 5: Oppose mandates to encourage consumers to buy longer life tires
Issue 1, Strategy 6: Recommend tire pressure is set by auto manufacturers and
displayed on placard of vehicle
Issue 2, Strategy 1: Activities undertaken need more follow-up and benchmarking
Issue 3, Strategy 1: Retreads should apply to truck tires that are appropriate for
retreading
Issue 3, Strategy 2: Discussion about reducing liability concerns over reuse tires not
appropriate for this forum.
Issue 4, Strategy 2: Marketplace should determine collection organization and
structure.
Issue 5, Strategy 4: There are no ground rubber product manufacturers in California
Issue 6, Strategy 1: Discussion about increasing recycled content in tires and molded
products is not appropriate for this forum. Tire design is determined by tire
manufacturers, based on tire performance criteria, including safety.
Issue 6, Strategy 3: Market should determine demand for recycled products, not
financial incentives.
PSI Tire Stewardship Final Action Plan
July 2005
B-12
Mblumenthal
Twood
Issue 7, Strategy 3: Mandates do not work.
Issue 8, Strategy 3: Septic/drainage market would not be cost-effective in California
due to availability of sand and gravel.
Issue 11, Strategy 1 & 2: Must increase markets and maintain enforcement at the
same time of a landfill ban or increase in tipping fees.
Issue 11, Strategy 4: Need documentation on whether storing and marketing tires
before landfilling works in other jurisdictions that have such provisions.
Issue 1, Strategy 3: Smart tire systems will be required under TREAD anyway
Issue 1, Strategy 4: Longer lasting tires are already available at a price
Issue 1, Strategy 5: Consumers need to understand the tradeoffs to buying longer life
tires
Issue 2, Strategy 1: Promote the use of retreads on commercial vehicles, not
passenger cars
Issue 5, Strategy 5: Equipment grants tens to create unsustainable processors
Issue 6, Strategy 1: Best opportunities for recycled content is in products other than
tires
Issue 6, Strategy 2: A breakthrough is needed on technologies to increase recycled
content in tires
Issue 6, Strategy 3: Crumb must be able to compete with virgin material to be
sustainable
Issue 1, Strategy 3: Smart tires is a federal issue
Issue 1, Strategy 4: Alter demand, not supply
Issue 1, Strategy 6: Optimal tire pressure is a vehicle manufacturer issue.
Issue 2, Strategy 1: Develop a plan and execute it
Issue 3, Strategy 2: Reused tire liability seems to be beyond the scope of this group.
Issue 4, Strategy 2: Protect free markets
Issue 5, Strategy 2: Agree with increase tire-derived products purchase provided that
this is a promotion strategy, rather than a mandate.
Issue 5, Strategy 5: Supply outstrips demand now. Free market will provide capital
for equipment at appropriate time.
Issue 6, Strategy 1: Increasing recycled content in tires and other products is a stated
solution, not a strategy.
Twood
Twood
Issue 7, Strategy 1: RAC has worked in the past in CA. Is there a need for standards?
Issue 7, Strategy 3: Protect free markets.
Twood
Issue 7, Strategy 4: RAC has worked in the past in CA. Is there a need for standards?
Issue 11, Strategy 1: Landfilling may be needed for a long time. Increasing fees
would have similar effect to landfill ban.
Issue 11, Strategy 2: Plan for increased enforcement to avoid dumping. Fees should
be dedicated to issue.
Issue 11, Strategy 4: Should not encourage stockpiling, even temporarily.
Issue 12, Strategy 2: Stakeholder interests should be considered, but overall program
priorities should prevail.
Issue 1, Strategy 1: Be tire smart
Issue 1, Strategy 2: This service has costs that need to be recovered (tire gauges and
air)
Issue 1, Strategy 3: TREAD Act
Mblumenthal
Mblumenthal
Mblumenthal
Chermann
Chermann
Chermann
Chermann
Chermann
Chermann
Chermann
Chermann
Twood
Twood
Twood
Twood
Twood
Twood
Twood
Twood
Twood
Twood
Twood
Twood
Jsheerin
Jsheerin
Jsheerin
PSI Tire Stewardship Final Action Plan
July 2005
B-13
Jsheerin
Jsheerin
Jsheerin
Jsheerin
Jsheerin
Jsheerin
Jsheerin
Jsheerin
Jsheerin
Jsheerin
Jsheerin
Tfaust
Tfaust
Tfaust
Tfaust
Tfaust
Tfaust
Tfaust
Issue 1, Strategy 6: Tire pressure(s) set by auto manufacturers.
Issue 3, Strategy 2: Used tires are not as good as new. They come with no warranty.
Issue 5, Strategy 3: Perception is correct for higher percentage recycled content in
tires.
Issue 5, Strategy 5: Market is not production capacity limited.
Issue 6, Strategy 1: Would not benefit consumers to increase recycled content in tires
and other products.
Issue 6, Strategy 2: Not state's job to conduct technology research.
Issue 7, Strategy 3: RAC markets is led by trained transportation professionals - not
mandates.
Issue 10, Strategy 1: Develop technical and educational materials to document the
facts.
Issue 11, Strategy 1: A complete ban is impractical and over restrictive.
Issue 11, Strategy 4: Requiring storage and marketing of tires is difficult and
cumbersome.
Issue 12, Strategy 1: CIWMB manages now.
Issue 5, Strategy 4: We have done so (research to overcome technical barriers)
Issue 5, Strategy 5: Don't need more crumb rubber
Issue 6, strategy 1: Using devulcanized rubber it has tested at 30% loading
Issue 6, Strategy 2: Already proved devulcanized rubber at 30% loading
Issue 11, Strategy 2: $2 a tire
Issue 12, Strategy 2: Devulcanized rubber will reduce greenhouse gas by 34 times
current status
General comment: Industry has negative financial history. It has scared away all
investors. All state grants are too small to make any meaningful technology change.
We believe we could recycle 10 million California tires into molded products if we
had financing.
PSI Tire Stewardship Final Action Plan
July 2005
B-14
Gov, Manufacturer, Retail
Recycler, Other
1
2
3
4
Government
Government
Government
1
6
1
3
1
8
2
5
9
5
4
10
6
3
4
7
3
11
8
1
12
2
16
4
19
6
13
3
Dick Gust, Tire Industry Association
Trade Association
Sanat N. Bhavsar, Yokohama Tire Corp Manufacturer
David Chapman, Goodyear
Manufacturer
Bruce Cherry, Big O Tire
Retailer
Terry Leveille, TL & Assoc and TRIB Trade Association
Michael Blumenthal, Rubber Mftrs Assoc Trade Association
Clarence Hermann, Michelin N.A.
Manufacturer
Randy Roth, Lakin Tire West
Hauler/Processor
Tom Wood, Cooper Tire & Rubber Co Manufacturer
John Sheerin, Bridgestone/Firestone
Manufacturer
Tom Faust, Redwood Rubber LLC
Processor
1
8
9
3
10
9
10
10
10
10
3
1
1
2
1
1
1
1
1
1
5
11
9
2
9
9
6
6
7
1
11
10
7
5
7
7
Manufacturer, Retailer, etc.. Total
80
13
53
7
1
88
8
280
Respondent Name
Michael Paprian, CIWMB
Pam Swingle, EPA Region 4
Bob Boughton, CA OPP, Toxins Dept
Government Total
Government Rank
Manufacturer, Retailer,
Recycler etc. Rank
Total all responses
Overall Ranking
Total
PSI Tire Stewardship Final Action Plan
July 2005
ISSUES RANKING
5
6
7
8
9
10
11
12
4
3
5
8
3
6
9
3
7
11
3
3
12
7
2
10
2
12
21
7
12
2
17
5
19
6
17
5
21
7
24
8
9
4
5
9
4
5
5
7
5
5
2
11
12
10
3
3
10
5
3
3
6
3
3
7
5
4
7
6
4
4
4
4
4
12
12
7
6
8
9
6
8
11
8
8
2
8
2
2
11
7
2
2
3
2
2
12
4
9
8
4
12
8
12
8
6
12
12
2
10
10
12
2
7
6
12
12
6
1
67
60
81
49
61
85
53
95
80
2
6
4
8
3
5
9
2
10
7
25
1
69
3
86
7
73
5
102
9
61
2
78 104
6 10
70
4
116
11
104
10
79
216
277
231
330
190
250 337 221
376
337
5
3
B-15
6
8
11
9
11
11
2
DATA ENTRY
Gov, Manufacturer, Retail
Recycler, Other
1
2
1
1
2
2
0
-1
Issue #1
3
2
0
0
4
2
1
2
5
2
1
2
6
2
1
0
Issue #2
1
1
2
2
4
1
2
5
5
3
5
2
3
5
2
Dick Gust, Tire Industry Association
Trade Association
Sanat N. Bhavsar, Yokohama Tire Corp Manufacturer
David Chapman, Goodyear
Manufacturer
Bruce Cherry, Big O Tire
Retailer
Terry Leveille, TL & Assoc and TRIB Trade Association
Michael Blumenthal, Rubber Mftrs Assoc Trade Association
Clarence Hermann, Michelin N.A.
Manufacturer
Randy Roth, Lakin Tire West
Hauler/Processor
Tom Wood, Cooper Tire & Rubber Co Manufacturer
John Sheerin, Bridgestone/Firestone
Manufacturer
Tom Faust, Redwood Rubber LLC
Processor
2
2
2
2
1
2
2
2
2
2
1
1
2
-1
1
2
2
2
1
-1
0
2
-2
-2
1
2
-2
0
1
-1
-1
1
0
1
1
0
2
1
0
0
-2
1
1
0
1
1
2
1
1
0
1
1
2
1
0
1
0
2
1
0
1
1
-1
-1
1
2
1
0
1
1
2
2
1
1
0
2
1
1
2
2
1
0
2
1
1
2
1
-1
-2
2
2
-2
2
2
-1
0
2
2
2
0
2
2
1
0
2
1
1
0
-1
-1
-2
2
0
-2
1
-1
-1
0
2
Manufacturer, Retailer, etc.. Total
19
10
-1
5
11
4
12
15
5
13
-3
23
11
1
10
16
7
17
17
8
18
-1
69
33
3
30
48
21
51
51
24
54
-3
Respondent Name
Michael Paprian, CIWMB
Pam Swingle, EPA Region 4
Bob Boughton, CA OPP, Toxins Dept
Government
Government
Government
Government Total
Issue #3
1
2
1
2
2
2
-1 -1
Issue #4
1
2
1
0
2
1
2
1
Government Rank
Manufacturer, Retailer,
Recycler etc. Rank
Total all responses
Overall Ranking
Total
PSI Tire Stewardship Final Action Plan
July 2005
B-16
Gov, Manufacturer, Retail
Recycler, Other
1
2
2
0
2
2
2
-1
Issue #5
3
4
2
1
2
2
-1
-1
4
3
3
2
-1
1
1
2
Dick Gust, Tire Industry Association
Trade Association
Sanat N. Bhavsar, Yokohama Tire Corp Manufacturer
David Chapman, Goodyear
Manufacturer
Bruce Cherry, Big O Tire
Retailer
Terry Leveille, TL & Assoc and TRIB Trade Association
Michael Blumenthal, Rubber Mftrs Assoc Trade Association
Clarence Hermann, Michelin N.A.
Manufacturer
Randy Roth, Lakin Tire West
Hauler/Processor
Tom Wood, Cooper Tire & Rubber Co Manufacturer
John Sheerin, Bridgestone/Firestone
Manufacturer
Tom Faust, Redwood Rubber LLC
Processor
1
2
1
0
1
2
2
2
1
1
0
1
1
0
2
2
0
1
2
1
1
2
1
-1
-1
2
1
-2
1
2
-2
-1
2
1
-2
-2
-1
1
-2
2
2
1
-1
0
0
-2
-1
1
1
-2
-1
1
-2
-1
0
1
1
2
2
1
1
1
1
0
2
1
-2
-2
0
1
-2
1
0
-2
-2
2
Manufacturer, Retailer, etc.. Total
13
13
2
-1
-6
12
17
16
5
1
-7
51
48
15
3
-21
Respondent Name
Michael Paprian, CIWMB
Pam Swingle, EPA Region 4
Bob Boughton, CA OPP, Toxins Dept
Government
Government
Government
Government Total
5
1
0
-2
6
1
2
-2
1
2
-1
Issue #6
2
3
2
1
1
1
-1 -1
Issue #7
2
3
2
2
2
2
0
-1
4
2
2
-1
1
1
2
0
4
2
2
0
1
3
3
4
3
4
1
-2
-2
1
1
0
2
2
1
-2
0
-2
-2
1
1
-2
-1
2
-1
-2
1
-2
-2
1
1
0
-1
2
-2
0
2
1
1
1
2
2
0
1
0
0
1
2
1
2
2
2
2
2
2
1
2
2
2
0
0
0
2
2
-2
0
0
-1
-1
2
0
1
0
2
1
1
0
0
0
1
-5
2
-6
0
11
20
2
6
13
-4
4
-5
3
14
24
5 10
39
-12
12 -15
9
42
72
15 30
Government Rank
Manufacturer, Retailer,
Recycler etc. Rank
Total all responses
Overall Ranking
Total
PSI Tire Stewardship Final Action Plan
July 2005
B-17
Gov, Manufacturer, Retail
Recycler, Other
1
-1
2
0
Issue #8
2
2
2
0
3
0
2
0
4
1
2
0
Issue #9
1
2
1
1
2
2
-1
-1
1
4
2
3
2
2
4
Dick Gust, Tire Industry Association
Trade Association
Sanat N. Bhavsar, Yokohama Tire Corp Manufacturer
David Chapman, Goodyear
Manufacturer
Bruce Cherry, Big O Tire
Retailer
Terry Leveille, TL & Assoc and TRIB Trade Association
Michael Blumenthal, Rubber Mftrs Assoc Trade Association
Clarence Hermann, Michelin N.A.
Manufacturer
Randy Roth, Lakin Tire West
Hauler/Processor
Tom Wood, Cooper Tire & Rubber Co Manufacturer
John Sheerin, Bridgestone/Firestone
Manufacturer
Tom Faust, Redwood Rubber LLC
Processor
1
2
2
2
2
2
2
2
2
2
-2
1
2
1
2
2
2
2
2
2
2
-2
1
1
0
1
2
0
0
2
1
2
-2
1
2
2
1
2
2
0
2
2
2
-2
0
2
2
2
2
2
1
2
1
2
0
0
2
2
2
1
2
1
2
1
0
0
Manufacturer, Retailer, etc.. Total
17
16
8
14
16
18
20
10
17
54
60
30
51
Respondent Name
Michael Paprian, CIWMB
Pam Swingle, EPA Region 4
Bob Boughton, CA OPP, Toxins Dept
Government
Government
Government
Government Total
Issue #10
1
2
0
-1
2
0
2
2
1
1
1
2
Issue #11
2
3
1
1
2
1
2
0
4
1
1
0
Issue #9
1 2
0 1
1 1
0 0
1
4
5
2
2
1
1
2
2
2
2
2
2
2
2
2
-2
0
2
2
2
1
2
2
0
1
2
-2
0
1
0
0
-1
1
2
-2
1
1
2
0
1
0
-2
-1
1
2
-2
1
2
2
1
0
-2
1
0
-1
0
2
-1
-1
0
0
-1
-2
-2
-1
0
-1
-2
-1
-2
2
-1 -1
-1 0
-2 0
1 1
0 0
0 1
1 2
0 0
-2 -1
-2 1
2
13
17
12
5
4
-1
-10
-6
5
18
15
21
13
9
9
1
-8
-5
7
54
45
63
39
27
27
3
-24
-15 21
2
Government Rank
Manufacturer, Retailer,
Recycler etc. Rank
Total all responses
Overall Ranking
Total
PSI Tire Stewardship Final Action Plan
July 2005
B-18
APPENDIX C:
Resource Conservation Challenge
Tire Cluster Goals
The Resource Conservation Challenge Tire Cluster agreed to the following goals, as
recommended by the Goals Subcommittee, on December 11, 2003.
I.
Divert 85% of newly generated scrap tires to reuse, recycling or energy recovery
by 2008.
This goal was established with several understandings:







II.
that tire production is expected to increase 4-5% over the next 5 years
that the Rubber Manufacturer’s Association (RMA) database is the source of data to
measure progress on meeting this goal
that tire recovery, processing and end use is usually measured in weights (tons) and
that to be compatible for measuring progress on this goal, generation figures must be
converted into weights.
that the current (CY2001-best available info) recovery rate is approximately 70%,
according to RMA
that landfilling and monofilling do not count as diversion
that some states or regions already exceed this percentage (some over 100% - net
importers) but many do not, especially where landfilling and monofilling are
prevalent; accordingly, this goal is a national average of all efforts
that significant improvements in diversion may depend on changes in laws,
regulations or local, state and federal programmatic and financial investments and
capital investments by processors and end users.
Reduce by 55% the number of tires in (existing) stockpiles by 2008
This goal was established with several understandings:



that significant tire pile cleanups depend on state government funding and cleanup
programs, unless other sources become available.
that about 306,000,000 tires remain in tire piles, with the vast majority (85%)
remaining in just 8 states. Efforts in these states will determine this goal.
that many states currently exceed this level, with many achieving almost complete
cleanup after years of efforts and millions of tax dollars spent.
These goals recognize the long lead time necessary to establish and stabilize capacity
and end user markets for diversion of waste tire material from disposal to beneficial
PSI Tire Stewardship Final Action Plan
July 2005
C-1
end uses and the dependency of pile cleanups on governmental funding. Shifts in
either of these factors could affect these goals and longer time frames (i.e., 10 years)
could result in significantly higher percentages for both goals.
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July 2005
C-2