The Institute of Scrap Recycling Industries (ISRI) is petitioning the U.S. Federal Motor Carriers Safety Administration (FMCSA) for regulatory relief for the transport of ferrous and non-ferrous metals, which would expand on the FMCSA’s Expanded Emergency Declaration of March 18, which granted the same relief for the transport of paper and plastics material.
In the petition, ISRI points out that all recyclable commodities are necessary feedstock for the manufacturing of essential supplies and equipment, and therefore require the same regulatory relief given to paper and plastics.
Excerpts from ISRI’s petition follow.
(For full text of petition, click HERE.)
Petition for Consideration: The Institute of the Scrap Recycling Industries, Inc. (ISRI) is requesting emergency relief for the transportation of ferrous and non-ferrous metals as an essential item to be included in the National Emergency Declaration for Commercial Vehicles Delivering Relief in Response to the COVID-19 Outbreak.
ISRI is submitting this request on behalf of the scrap and recycling industry, in accordance with 49 CFR §390.23(a)(1)(i), which provides for times of emergency warranting an exemption from Parts 390 through 399 of the Federal Motor Carrier Safety Regulations. Specifically, ISRI is petitioning for relief to transport scrap ferrous and non-ferrous metals as an essential item to supply “Critical Manufacturing Sector” as outlined in the U.S. Department of Homeland Security (DHS) “Memorandum on Identification of Essential Critical Infrastructure Workers during COVID-19 Response”, which formally recognizes that the essential manufacturing of materials and products is wholly dependent on manufacturers’ ability to obtain the feedstock necessary to feed their operations.
… Concern: Over the past several days, many state and local governments have been ordering the shutdown of “non-essential” businesses, an action we recognize and fully support in order to stop the spread of COVID-19. As indicated above, the supply of raw materials (which includes recycled ferrous and nonferrous metals, paper, plastics and other commodity-grade materials) to critical manufacturing has been deemed essential by DHS, and therefore there is a corresponding critical need to include the commercial motor vehicle operations involved in the such operations in the determination of what is considered essential, otherwise recycling enterprises could be caught in the non-essential closures, curtailing the supply of raw material feedstock into steel mills, foundries and other metals manufacturing operations needed for the manufacture of essential supplies and equipment.
DHS has formally recognized iron and steel mills, ferrous alloy manufacturing, and nonferrous metal production and processing as part of the U.S. critical manufacturing sector (source: https://www.cisa.gov/critical-manufacturing-sector). And the U.S. steel industry relies on ferrous scrap as its largest single raw material input. … In fact, copper’s anti-microbial properties are a key element to reducing the spread of disease and are widely used in hospitals and other settings to reduce transmission rates. All these metals are required for the production of the rebar, wiring, tubing and other key materials that are needed for everything from the construction of new hospitals to the manufacturer of new hospital beds, surgical instruments and other essential supplies needed to keep Americans safe during this critical time.
