Respirable Crystalline Silica Exposure Alert! Avoid Million Dollar Payouts!

Does your company have a potential respirable crystalline silica exposure? Did you know that lawsuits for victims of silica exposure can rise into the hundreds of millions?

Our brokers are up-to-date on standards and policies. Contact us to review your insurance coverage and discuss the recent OSHA update. Protecting your employees and your business is a top priority.

Over 2 million people are exposed to silica through their daily work. To protect these workers, OSHA created two respirable crystalline silica standardsBusinessInsurance.com recently shared OSHA's update regarding The Occupational Exposure to Respirable Crystalline Silica Rule that takes effect June 23.

According to the report, OSHA will enact a "good-faith" grace period for "employers that are making good-faith efforts to meet the new standard’s requirements". Read the full OSHA Update article on BusinessInsurance.com

Crystalline Silica is found in material like sand, stone, and concrete. Drilling, crushing, cutting, and grinding creates small particles called respirable crystalline silica. Certain industries run the risk of exposure to inhalation of this respirable crystalline silica dust, which can cause serious sometimes fatal silica-related diseases such as cancer, kidney disease, and silicosis.

If you have this potential exposure and questions about the recent policy update, contact of our knowledgeable insurance brokers today.

Central to our business strategy is early renewal planning, comprehensive policy review, and full disclosure. Partnering with us, you’re sure to receive the most competitive price and the most dedicated service.

Alert: China's New Tariffs on Scrap Aluminum

ISRI Alert.jpg

Latest ISRI update: "ISRI learned late last night that the Chinese Government announced its intent to target 128 U.S. product exports in retaliation for the Trump Administration's imposition of tariffs on steel and aluminum imports. On the Chinese Government's list is the intent to impose a 25% import tariff on Harmonized Tariff Code 7602.00 – Aluminum Waste and Scrap.

In 2017, the United States exported more than $1.2 billion worth of aluminum scrap to China, which has been in a positive trade balance for more than a decade. The Chinese Government's announcement will impact this significant U.S. scrap export, spurring concern that exports of additional scrap commodities could be impacted in future announcements.

The tariffs will not be imposed immediately. There will be a 30 day open comment period, and ISRI will submit comments that provide information on the supply chain impact of these tariffs. Additionally, ISRI is working with the Administration and members of Congress to find a path towards minimizing the impact of these tariffs."

Additional facts: 

  • The U.S. exported $2.34 billion/1.57 million metric tons of aluminum scrap worldwide in 2017. Approximately 50% of these exports went to China.
  • The U.S. exported $1.17 billion/820,000 metric tons of aluminum scrap to China in 2017. This was approximately 50% of China’s total imports of aluminum scrap that year.
  • A 25% tariff would mean a nearly $300 million price burden on a trade relationship that represents nearly 25% of the entire world’s trade in aluminum scrap.
  • Aluminum in the municipal recycling stream represents a substantial source of revenue that keeps down the cost of waste disposal and recycling programs.
  • The second largest exporter of aluminum scrap to China in 2017 was the European Union at $360.51 million/231,556 metric tons.
  • The U.S. has an overwhelmingly large positive trade balance in aluminum scrap vis-à-vis China. The United States’ positive trade balance with China in aluminum scrap is $1.17 billion for 2017 which is 94% of our positive trade balance with the entire world.
  • South Korea ($248.6 million), India ($110.7 million), Hong Kong ($72.6 million), and Malaysia ($69.5 million) complete the top 5 economic partners with a positive trade balance in aluminum scrap with the U.S.

Our knowledgeable brokers specialize in the recycling industry and are available to answer your questions.

ISRI Update: China Publishes Final Scrap Import Standards

Alert_recycle.png

Below are the latest Import Standards for China, shared by ISRI:

China’s Ministry of Environmental Protection (MEP) has published the final Environmental Protection Control Standards for Imports of Solid Wastes as Raw Materials (GB 16487.2-13) – the quality standards for imported scrap.

Unfortunately, there has been no change since the November notification to the World Trade Organization (WTO), and the contaminants thresholds remain the same:

Smelt Slag 0.5
Wood 0.5
Ferrous 0.5
Nonferrous 1.0
Electric Motors 0.5
Wires and Cables 0.5
Metal and Appliances 0.5
Vessels 0.05
Plastic 0.5
Autos 0.3

If your company falls into this category and you have additional questions, please contact us.

Chris Morse is our Recycling Insurance Lead. Connect with Chris.

China: New Guidelines for Exporters and Suppliers

Recycle alert.png

Exporters and suppliers seeking to apply for export permits to ship scrap to China should be aware of new guidelines that go into effect February 1, 2018.

ISRI recently shared the General Administration of Quality Supervision, Inspection and Quarantine of China (AQSIQ) update, highlighting these major points:

  • Much of the qualifications remain the same, including ISO 9001 or RIOS, but applicants must also be able to achieve the environmental control standards (i.e., contaminants thresholds) and have radiation detection equipment at your facilities; 
  • China will maintain the double-inspection system before and after the material is shipped;
  • CCIC will no longer be the only approved pre-shipment inspection company. AQISQ lays out a process for third party inspection companies to apply for a license from AQSIQ to conduct pre-shipment inspections but is clear that no processors may conduct inspections. These companies will also share the liability in the event material that was approved before shipment is rejected on arrival at a Chinese port. We anticipate, however, that those applications will take time to process.

If your company falls into this category and you have additional questions, please contact us.

Chris Morse is our Recycling Insurance Lead. Connect with Chris.

Air Quality Management District Prop 1407 Emissions Amendment

One Size Does Not Fit All

By Chris Morse & RJ Simmons

The South Coast Air Quality Management District (AQMD) is introducing an amendment to Rule 1407 with the purpose of further reducing fugitive emissions. Fugitive emissions are emissions of gases and vapors from recycling equipment that contribute to air pollution, climate changes, and serious health concerns.

The current purpose of Rule 1407 is to reduce emissions of arsenic, cadmium, and nickel from non-ferrous metal melting operations. This new amendment specifically targets hexavalent chromium and ferrous metal melting operations.

As discussions of this amendment take place, AQMD’s stand is to create an overarching guideline for recyclers to help reduce these emissions. However, every recycling plant is different and one size does not fit all.

Key changes with the new Prop 1407 requirements are that any melting operations must have a total enclosure, point source controls, and housekeeping around melting operations to control fugitive emissions entering the air.

One point of contention is the total enclosure regulation. Total enclosures of melting operations means that this process must be done indoors to minimize cross drafts and limit access to people and vehicles. For some recyclers, building an entirely new building around melting operations could be costly, not to mention some businesses may be constricted by location and space.

Under the Rule 1407 amendment, several new controls will be required and existing ones amended, in addition to the new total enclosure regulation:

  • Point Source Controls: in place to control fugitive emissions and base emissions of a specific toxin or emissions particulates, depending on what specific metal is being melted with periodic source testing to measure emissions, find the level of emissions and identify the toxin.
  • Parametric Device Monitoring: implemented around the parameters of buildings and yards to alert when emissions are not being controlled properly.
  • Installations of flow meters: required smoke tests once every 3 months to measure how many fugitive emissions are in the air.
  • Ambient Air Monitoring: to measure toxins amounts in the air and what kind.
  • Pressure Gauge System: to require a certain amount of pressure always be implemented during the melting process.
  • Broken Bag Detectors: alarm to notify if there is a leak of fugitive emissions and failures.
  • Housekeeping: requirements to minimize fugitive emissions around buildings and enclosures where metal is being melted and other processes, for example, the use of street sweepers to collect dust that can contain fugitive emissions.

The AQMD’s push to implement these potentially costly regulations affect all businesses involved with melting operations and recycling. Heavy fines could potentially be given to any business not following the new controls.

Since proposing this amendment, the AQMD’s seen pushback from recyclers and smelters asking them to consider plans that offer varied categories and options for recyclers with different operations, as every recycling plant is different.

The Prop 1407 amendment is still in discussion, a private hearing is set for April 6, 2018, and a public hearing for May 4th, 2018.

Our Recycling professionals are monitoring the Rule 1407 proposed amendment closely and are available to answer questions. Contact us for more information.