CATS AND DECANNING
Members and strategic partners of the Federation will no doubt recall that the BVSF have been trying to obtain cast iron directives relating to storing catalytic converters and de-canning catalytic converters since the "discovery" of RCF matting within some CATS and the inability of the manufacturers to confirm which ones have it !! This detail alone is amazing, how can vehicle manufacturers NOT KNOW whether their vehicles contain this dangerous substance, what, for example happens in an impact situation if the Cat is broken and the RCF escapes with people affected by the impact in close proximity, particularly police and recovery agents who may be exposed more often due to their involvement on a day to day basis.
Returning to the effect that the ruling will have upon BVSF members, as far as we understand it and relative to CoTC qualifications if you are a permitted ATF then you are ok to store safely, complete CATS that you obtain or remove from vehicles. If however you decan CATS then it is a totally different matter.
Hopefully therefore this will clarify things - Storage only of catalytic converters at an ELV site.
• If they are produced as part of the dismantling activities on site then the existing ELV TCM qualification covers this.
• If they are imported to the site from 3rd parties then the existing ELV TCM qualification will cover this.
Required permit changes.
• Permit changes… If your permit doesn’t allow you to accept waste with the List of Waste code 16 01 21* you must apply to vary (change) your permit if you want to continue to accept catalytic converters from third parties.
To give you time to vary your permit, the Environment Agency has issued a temporary RPS. This RPS will end on 31 August 2017 and you must apply to vary your permit by this date.
Decanning Catalytic Converters.
If catalytic converters are being de-canned then this is a hazardous treatment activity and is a lot more complex and risky both to the environment and to human health. The processing and abatement needs to be carried out using correctly, maintained and monitored equipment to prevent the release of RCF fibres. Hazardous waste treatment
activities need to have a Technically Competent Manager who has the high risk tier Hazardous Waste Treatment qualification.
Clearly some members of the BVSF may have the alternative certification options under the E/U Skills scheme but these would need to be updated to include catalytic converter processing.
There has been no regulatory changes in relation to catalytic converters they have historically been misclassified and the magnitude of the risks misunderstood. Catalytic converters with RCF should have been classed as hazardous waste, the movements consigned and the relevant competence qualifications in place. Since the EA have become aware of the issue they have taken steps to raise awareness and ensure time is given for people to come into compliance.
Under normal circumstances BVSF members affected by the changes would be required to have the relevant qualification when the variation to their permit is issued. In this particular situation the EA have again agreed that operators who are varying their permits in relation to Catalytic converters and have to gain additional qualifications will have a year from variation issue to gain the relevant qualification.
The BVSF will have met with a training company by the time this article goes to print to investigate the ramifications of these changes and the costs involved.
The ability of bona fide vehicle dismantlers and salvage buyers to sell on “provenance known” air bags has been rumbling on for years now, yet still the latest code of practice (Draft) prevents our members from selling these items from insurance contracted vehicles. The BVSF strongly challenged the insurers over the sale of these items citing the fact that provenance unknown bags would be a danger to the public. And it was for this reason alone that the BVSF refused to support the latest draft of the code as we did not want to be party to a document that effectively put the buying public in danger.
However, back in February this year we reported that a number of counterfeit bags were discovered for sale and indeed it is thought that well in excess of 600 were purchased by unsuspecting buyers.
We are now advised that Representatives from vehicle manufacturers are assisting the police investigation into suspected counterfeit airbags and components seized by the City of London Police Intellectual Property Crime Unit (PIPCU).
Furthermore we are also informed that Motor industry safety experts are assisting with detailed physical analysis of the items which they have recovered from the address of a person alleged to be involved in online sales of counterfeit airbags. The news goes on to say that this process is a crucial part in determining not only the legitimacy of the items but also the dangers they pose to the public.
It would be interesting to note what sort of analysis is taking place particularly when we, the BVSF and indeed the MVDA did our own investigation into this, proved beyond doubt that “PROVENANCE KNOWN” and “CORRECTLY TESTED” air bags were indeed safe for re-use and the representatives of the manufacturers said of our testing, “all you have proven is that they will go bang”, yet when we suggested they perform an “Analysis” on “our bags” this was simply waved aside.
Obviously we, at the BVSF hope that no one has been injured (or worse) by the fitting of these counterfeit airbags but we said that this was the reason for not supporting the code and our worst fears have now come to reality. We can only hope that now that the point is proven, sense will be seen.
It really is about time that the insurers sat up and took notice of this investigation before it gets any worse.
An article found on the internet goes on to say….and the insertions in italics are the thoughts of the BVSF.
“With the safety of the public being our primary focus in this investigation, (As the draft of the code should be considering) we are urging anyone who has concerns about a possible counterfeit car part they may have, to contact their nearest authorised car dealer. They will have the expertise to examine the vehicle and determine if it is safe and roadworthy. ( Presumably doing exactly the same test as our airbag investigation which was rejected by the manufacturers representatives) Furthermore, if you suspect you have purchased a counterfeit product or have come into contact with a counterfeit website please report the matter to Action Fraud.
“Finding a good deal online should not lead to compromising you own safety. (So let us sell the ones that will work as they should then) We are reminding the public to use reputable suppliers, and if you have any doubt about what you are buying, don’t cut corners, and don’t buy it.
I think the old term is “I rest my case”.