Stockpiles continue to grow as capacity crisis deepens.

In February, we reported on a growing issue regarding the stockpiling of scrap tires in Ontario, due to changes in regulations that have lowered recycling targets. Now, in the wake of spring tire changeover season, Autosphere touched base again with Adam Moffatt, Executive Director of the Ontario Tire Dealers Association (OTDA) to see where things currently stand.

Service stoppages

Moffatt notes that unfortunately, the issues that began last fall continue to persist. Stockpiling of used tires continues to be growing problem, and there have been service stoppages with several producers across Ontario.

He notes that while tire recycling is taking place, collection levels are simply not keeping pace with the amount of scrap tires being generated and this posing a serious problem for tire dealers across the province. Some are having to deal with hundreds if not thousands of tires that simply aren’t being collected.

Compounding the problem is that some haulers have had no choice but to shut down operations, since current collection limits have made it simply uneconomical to continue. Others, meanwhile, are struggling, having to lay off staff, take trucks out of service and scale back collection activities.

An added issue, is that the scaling back of hauling operations, means that remaining capacity also shrinks and there simply isn’t an opportunity for other haulers to step in and replace those that have scaled back or shut down operations.

Peak season compound

“As we look toward the fall tire changeover season, this becomes a serious concern,” says Moffatt. “If current conditions continue, we risk entering a peak season where we’re already carrying a backlog of tires and this is only going to create even more environmental, health, safety and operational impacts for tire dealers in Ontario.”

While there have been some proposed amendments to existing scrap tire regulations, and Moffatt notes that limits on how long Producer Responsibility Organization (PRO) networks can store tires before they must be processed (plus stronger requirements to ensure tires are actually recycled) have been welcome changes, along with the removal of fine and penalty caps for PROs and producers in the province, there are still some serious concerns.

Another proposal that’s been put forward, is a call-in service model. While on paper, it is intended to address tires that are not currently being collected, it doesn’t provide long-term stability for those sites that have been affected by lower recycling quotas, nor does it address the reasons why these sites have been removed from collection networks.

Additionally, there are also concerns as to how this proposed call-in system would work in practice. By introducing a province wide call-in practice, the administrative burden could be significant for collection sites, as well as haulers and the Resource Productivity and Recovery Authority (RPRA), particularly if large volumes of collection sites have to rely on the system. There’s also a risk that such a province wide call-in system might not automatically re-establish sites within a collection network.

“If the expectation from the MECP is that producers and PROs are responsible for collection and managing all end-of-life tires as they become available, then it is time for both the MECP and RPRA to ensure those obligations are being met in practice.”

– Adam Moffatt, Executive Director, Ontario Tire Dealers Association

Two-tier system

Moffatt also draws attention to the current two-tier system that’s in place for collecting scrap tires in Ontario. “Under this model,” he says, “some collection sites are considered ‘in network,’ meaning they are registered with PROs to receive regular service, while others are classified as ‘out of network,’ meaning there is no consistent of guaranteed collection service for them.”

He notes that OTDA’s position is that any business in the province of Ontario that generates scrap tires as part of its normal operations should qualify as an in-network collection site and therefore, receive regular, scheduled service. “This is especially important given that tire recycling fees are paid at the point of sale and are ultimately passed through the system to consumers,” says Moffatt.

While he doesn’t rule out the possibility that a call-in service could work under some situations, such as municipal sites that handle very low volumes of tires, for most high volume generators like tire dealers, which produce scrap tires on a daily basis, that burden on trying to figure out how to dispose of them should not exist. Instead, dealers should be fully integrated into collection networks and recognized as priority sites for regular and reliable service collection.

Added pressure

Right now, dealers are already facing problems with the stockpiling of tires. With nowhere to put them, they are facing pressure from municipalities, including violations around fire and building codes, as well as landlord and insurance pressures.

“Many businesses are finding themselves in a position where they simply cannot control this aspect of their operations, and yet, they’re still being held to strict standards across other areas of compliance with little ability to manage them under current conditions,” Moffatt explains.

While some tire dealers have been able to divert tires to municipal drop-off sites, the problem is that many of these facilities are now being overwhelmed with their own collection delays and capacity restraints. As a result, municipalities are now implementing limits on scrap tire acceptance, meaning the burden shifts back to tire dealers and collection sites.

There’s also the risk, that with capacity overwhelmed and tires not being collected and processed, they will start accumulating in areas such as back alleys, fields, abandoned buildings, ditches and other areas because there is simply nowhere for them to be properly disposed of.

While current conditions are challenging, meaningful amendments to the tire scrapple regulations that address fundamental issues within the system could have significant and lasting impact. The trouble is that currently, most of the solutions proposed are simply band-aid fixes that fail to address the underlying structural issues around tire recycling in Ontario.

Clear, actionable enforcement

Moffatt believes that clear, actionable enforcement from RPRA would go a long way to ensure that when producers and PROs aren’t meeting their obligations under the rules, there is real accountability and consequences and that enforcement of the regulations must be consistent.

Ontario does have a viable tire recycling industry, but it needs stability and protection in order to function properly and that means having essential safeguards in place to enable that, and providing PROs, processors and haulers with the resources they need to safely, effectively and efficiently collect and process scrap tires. That means supporting stable business relationships and encouraging long-term investment across the province, which simply isn’t happening at present.

“If the expectation from the Ontario Ministry of the Environment, Conservation and Parks (MECP) is that producers and PROs are responsible for collection and managing all end-of-life tires as they become available, then it is time for both the MECP and RPRA to ensure those obligations are being met in practice,” says Moffatt. “Policy commitments alone are not enough without consistent action and enforcement behind them.”