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The Waste Tyre Regulation
Act, while regulating the tyre scrapping process, will not prevent
trucks running on illegal rubber. |
It's been over half a decade in the making but the law controlling the disposal of waste tyres has been gazetted and is due for promulgation in mid 2007. Having statutes in place to prevent old tyres from being resold to transporters and motorists will go a long way to reducing the number of road accidents caused by tyre failure. It will also reduce the tons of tyres illegally burnt in the veldt for steel recovery. Known as the Waste Tyre Regulation Act, this new set of laws will have a profound impact not only on the tyre industry and its customers, but will create new job opportunities and reduce the environmental impact of scrap tyres.
Paul Collings reports.
The Department of Environmental Affairs and Tourism (DEAT) is responsible for managing the roll-out and regulation of the new Act (WTRA), ensuring all tyres sold locally follow a specific 'cradle-to-grave' path, from manufacturing plant, through the retail and retreading processes, to the scrapping phase, where tyre dealers will have to 'mutilate' old casing to a point where they are made unusable on a vehicle, to the collection process where trucks will transport scrap rubber to recycling plants and alternate fuel users, like cement kilns, for example.
Green fee
Assisting DEAT in implementing the Act is the SA Tyre Recycling Process Company (SATRP Co), a Section 21 organisation headed up by Dr Etienne Human, who says, "tyre suppliers, be they manufacturers, importers or retreaders, have formed this non profit operation to implement and manage the waste tyre collection process. A 'compulsory charge' will be instituted by the tyre manufacturers, retreaders and importers to cover the cost of the tyre collection process and stimulate a sustainable waste end-user industry. As well as paying for the transport of waste tyres, companies accepting waste tyres for recycling or tyre-derived-fuel (TDF) will not have to pay for the tyres and will also receive a certain percentage of the 'green fee'."
All potential users of waste tyres will have to tender for the waste tyres and the portion of the subsidy to be received, says Human: "The least costly tenderers will be accepted according to a pre-designed and agreed score card. This is similar to the Swiss system for electronic and white goods waste recovery."
The SATRP Co will calculate the amount required to operate the waste tyre collection process throughout SA and translate this to a cost per tyre. The greatest cost lies in the transport of waste tyres which can be as much as R10 for a passenger tyre and R60 for a truck tyre within a 400 km radius, explains Human. "The manufacturers and importers will add this charge as a separate line item on the invoice for new tyres to the tyre dealer. No charge will be made on retreaded tyres. The tyre dealer will pass the charge onto the consumer at the same rate, without adding a profit margin. The charge will be instituted three months before the actual collections start in order to build up a fund for the collection process."
An audit company will be appointed to verify the financials of the stakeholders and publish annual reports to prevent fraud in the system, adds human. "Casings imported for retreading will be subject to a charge, payable by the importer. This is because these casings add to the waste stockpile accruing in South Africa. This fee will be absorbed in the cost of retreading the imported casing and in the selling price to the end-user as it is very difficult to distinguish between local and imported casings during the retreading process. Local casings have already attracted the fee"
As far as bulk tyre consumers are concerned, Human says, "discussions are being held with vehicle and equipment manufacturers, Government Tender Board and transporters who buy directly from the tyre suppliers, to recover an 'environmental charge' and link it into the above processes. This process is in line with best practice and environmental concepts for sustainable development throughout the world."
Human adds that the industry has spent over 40 000 man hours and millions of Rands on the project so far and has had over 560 meetings with interested parties including NGOs and government and hundreds of articles have appeared in the press over the past eight years: "The economic viability of the process has been studied in the greatest of detail," he says, "and the main aim is making the project sustainable without prejudice or enriching entities in the process."
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Full of holes
and
still running!
These tyres are fit for the scrap heap, as is the unscrupulous truck
owner. |
Removing risks
The fact that the end user is footing the bill for the process, without finance from government and seemingly from the tyre industry might seem a little unfair but in the value chain, the consumer is the only source of funds, explains Human, and the benefits are worth the extra paid on each new tyre: "Currently, only 4% of scrap tyres are being recycled. The rest find their way to unscrupulous merchants who regroove and patch these casings for resale to motorists," he says. "The DoT estimates that 51% of vehicle component failure accidents are caused by tyre failure and the use of second hand waste tyres is considered the biggest contributor. The collection process will significantly help prevent this from happening."
Mitigating environmental damage caused by scrap tyres is also a primary objective of the WTRA. "Tyres get dumped in the veld and are a massive fire risk. Smoke from a burning tyre is extremely toxic and a danger to society," Human continues. "They are currently also being used in landfill sites but are unsuitable for this as they rise up through the soil over time, creating highly unstable tracts of land. They are also ideal breeding grounds for rodents, mosquitoes, and can spread malaria."
Other beneficiaries
While motorists and truckers get safer roads and cleaner air, massive opportunity exists for jobs to be created in the rubber recycling industry. "A new industry of collecting and recycling waste rubber will be established," says Human. "At present, there are approximately 12 plants in the country using parts of waste tyres. Only two plants produce rubber crumb, with others using the crumb in applications such as road building and low specification commodities. The others are smaller entrepreneurs making mats, sandals, etc. New investors are planning an additional five to eight plants once the project is established."
Human says that large purpose-built trucks will be needed to transport waste tyres from collection points to the plants and kilns. Operators will be selected according to their existing infrastructure via a tender process which should commence in mid-2007.
As far as the cement manufacturing industry goes, "once converted to accept waste rubber as part of their fuel source (to replace up to 10% of coal), cement kilns and other environmentally safe alternate fuel users will be a constant consumer of waste tyres," Human adds. "All waste tyre users will have to comply with national environmental standards as per DEAT requirements. The process of using waste tyres as alternate fuel is old technology, well researched and emissions controlled to international standards which in practice means emissions are lower than 10% of the WHO target limits."
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New
Road safety will be
improved when regrooved tyre ‘shops’ are outlawed from our
pavements. |
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Effective
waste tyre recycling will
hopefully create jobs and outlaw used tyre vending. |
Hang on...
While it surely is a good thing to not have millions of waste tyres lying around posing health, environmental and safety risks, the WTRA as it stands now, has come under fire from certain quarters. Strong objections, by way of example, come from Pietermaritzburg-based 'environmental justice service and developmental organization', groundWork, whose director, Bobby Peek, in a letter to the Director General of DEAT, Pam Yako, spelled out his organisation's concerns regarding the Act: "Currently, there is a limited understanding of the waste tyre situation in South Africa. We believe that Waste Tyre Regulations cannot reasonably be drafted, let alone be commented on and promulgated while there is such imperfect information."
He adds that, "we believe that the only reason there is a perceived necessity to push these regulations through right now is an economic one."
Peek says that the problem of tyres lying in the open veld being burned, while constituting an environmental 'injustice', has not escalated to any significant degree in recent years to warrant the passing of the Act "where it will more or less fit," i.e. through the Environmental Conservation Act, rather than the Waste Management Act.
Cementing the deal?
Apart from the environmental impact of tyre incineration in cement kilns, the sharp edge of Peek's letter is his implication that the Act is really a money-making scheme between the SATRP Co and the three major cement manufactures in South Africa, PPC, Holcim and NPC.
"The cement industry is probably banking on receiving 96% of waste tyre stocks and therefore R27.4 million per year over five years in subsidies and disposal fees, which is almost R137 million over this period. In other words, the consumer is going to subsidise cement company shareholders to the tune of nine free kiln upgrades and R137 million," Peek says. "If the cement industry were to receive the maximum disposal fee of 14c per kg of waste tyres, they would receive R50.4 million in disposal fees over five years. This is on top of an about equal saving on coal itself. In other words...their net profits should increase by R100 million over a five year period at zero capital cost."
In defense
Human and the SATRP Co will manage the flow of tyre levies to pay transporters, recyclers and cement companies. He says that while there exists a relatively small tyre recycling sector in South Africa, the recycling of waste rubber will receive priority over use as an alternate fuel use. "This split is likely to change as the process matures," says Human. "Cement kilns, once converted to TDR will be a constant market for scrap tyres. It must be mentioned that these kilns operate according to the Clean Air Act and other environmental protection regulations and millions of rands are spent each year on advanced filtration systems to minimize emissions. The fact that very little waste rubber is used as alternative fuel at present confirms the negative return on investment such projects realise without financial assistance. By the way, it costs R25 million just to convert one cement kiln to receive waste and can only replace 10% of its coal with alternate fuels. It is also important to mention that waste rubber is a renewable source of energy whilst coal, as a fossil fuel is not and needs to be conserved for future generations."
Tyre recycling machinery, on the other hand, whether to make rubber crumb or value-added products is prohibitively expensive, says Human, making it difficult for entrepreneurs to establish themselves profitably in the recycling business. "There is very limited demand for waste tyre crumb products as they compete against plastics, metals and bricks which are cheaper and perform better, " he says.
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Bulk tyre users will
have to comply with scrap tyre storage rules as stipulated by the
WTRA, or face stiff penalties. |
More energy
As Peek explains, "it takes 120 MJ (megajoules) to create one kilogram of rubber. When we burn tyres as fuel, we recover about 30 MJ- in other words, 90 MJ is lost forever. When we make a kilogram of rubber crumb from a tyre, however, this costs us 2.2 MJ per kilogram, which could be regarded as the energy loss, meaning the energy recovery would about 118 MJ, which is a substantial difference.
Last word
While Peek may have valid criticisms of the Act and its implementation, the fact remains, South Africa does need to address its waste tyre problem, sooner rather than later. The fact that the consumer is financing the 'removal' process alone does seem a tad unfair. Human says, "to date the entire life cycle of the rubber tyre has not been recovered in the process. Adding the green fee is completing the last link in the value chain."
This may be the case, but why isn't government and the tyre industry assisting financially in the establishment of waste tyre transport and recycling enterprises that not only create wide scale employment but process waste tyres with as little harm to the environment as possible?
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