California Waste Management Board (CWMB) officials are discussing points brought up by Tire Retread Information Bureau (TRIB) Managing Director Harvey Brodsky at a meeting last Friday regarding a new California used tire hauling law that may subject retreaders to fines of up to $25,000 for "offenses" as minor as not filling out pickup and delivery manifests properly.
Brodksy argued that retreaders who haul used tires to plants for retreading should not be responsible for transportation paperwork since they, in fact, do not own the tires.
He asked CWMB officials to allow retreaders to carry a wallet-sized identification card that would list their names, addresses and DOT codes.
"This document could be carried in the retreader's vehicle and could be shown to the California State Highway Patrol, or any other state regulatory agency, on demand.
"The retreaders would then be relieved of any manifest requirements as long as the tires on his truck were being transported to/from one of his customers and were not tires that belonged to the retreader."
CWMB officials replied that any casings not the property of a retreader's customer would have to be manifested, including stock casings, casings a retreader's customer wants the retreader to throw away, or casings being hauled by a retreader to a legal dump site.
"I stated that if the CWMB was concerned about the number of scrap tires being dumped by retreaders, they should consider that the total number of tires that were illegally dumped by retreaders in California in a given year would probably fit in the trunk of my car," says Brodsky.
"Retreaders have a vested interest not to dump waste tires and would be about the last people to do so.
"I also explained that retreaders, on occasion, buy casings from casing dealers, but when this happens, casings are delivered by the dealer, either in a truck belonging to the casing dealer or by common carrier."
Ultimately, Brodksy would like to have California's used tire hauling policy overturned.