The Tyre Recovery Association (TRA) recently introduced the Responsible Part Worn Tyres Programme (RPWTP) to improve professionalism across the whole industry. It will achieve this by ensuring retailers are aware of their responsibilities and providing them with the support needed to meet the required standards.
RPWTP is an audit-based programme which comprehensively guides participants through every aspect of part worn retailing from the law to Duty of Care; inspection to repair; testing to tyre husbandry. By introducing elements of best practice into this marketplace, the best possible use can be made of previously-used tyres. RPWTP ultimately aims to ensure all part worn tyres sold by a retailer in the programme are legally compliant.
The bulk of part-worn tyres come to market from vehicle dismantlers and dedicated importers. Both the British Vehicle Salvage Federation (BVSF) and the Vehicle Recyclers Association (VRA) support the aims of RPWTP, as does the Tyre Industry Federation. The entire RPWTP process is overseen and audited by the TRA, and focuses on five main elements:
• The Law
• Inspection
• Repairing
• Testing
• Traceability
Additionally, participants will also be made aware of their Duty of Care regarding waste tyres. The audit takes approximately four to five hours, following which a report is issued highlighting areas completed to the required standards and those requiring further action. In such circumstances, a follow-up audit takes place to ensure corrective measures have been implemented.
During the course of this year all pre-owned tyres that are still deemed suitable for road use will be professionally examined by a trained operative and specifically marked as suitable for re-use.
The Law
Any tyre permanently removed from a vehicle is considered to be ‘waste’. Even pre-owned tyres selected for retreading or selling as part-worns are waste until they have been properly and thoroughly inspected and marked. The inspection and marking process is set out fully in the Motor Vehicle Tyres (Safety) Regulations 1994 (reg.7.), part of the Consumer Protection Act. The regulations apply to all tyres sold as part worns whether they are fitted to the wheel rim or not (see page 5 of the RPWTP leaflet www.drive.google.com for further details).
Inspection
In the course of a tyre’s life it may be subject to an enormous amount of abuse. It can be damaged in many ways that could affect the structural integrity, with hidden anomalies that may cause premature tyre failure. As such, inspection is the most critical stage in assessing the suitability of a tyre for resale. RPWTP includes training in:
• Initial inspection methods and procedures
• Tyre damage recognition
• Outer damage preparation
• Damage classification in accordance with BS AU 159
• Use of repair charts
Repairing
During the course of inspection, damage or a puncture may be identified which is legal and safe to repair. Part worn tyres may be legally resold with repairs but they must conform to BS AU 159. RPWTP provides instruction in these repairs covering:
• Inner liner preparation
• Use of solutions and cements
• Storage of repair materials
• Filling procedure for minor/major repairs
• Curing methods (chemical/hot)
Testing
Marking is the most common area of non-compliance in the retail of part worn tyres, yet it is arguably one of the easiest regulations to adhere to. RPWTP ensures participants are aware of where the ‘PART WORN’ stamp may or may not appear, and other critical
final checks required before a tyre goes on sale including:
• Final inspection procedures
• Pressure testing (if applicable)
• Marking – Traceability – Internal & External – Pre-vulcanised TRA label
* To include practical demonstrations
Duty of Care
All involved in the tyre recovery chain, even the motorist, have a legal Duty of Care when handling used or waste tyres. The correct processing of used tyres minimises the
impact on the environment and converts them into a useful, sustainable and valuable commodity, and benefits the economy. However, this is only possible if used tyres are
returned to responsible retailers who abide by a strict code of conduct and practice. To avoid used tyres entering illegal waste storage sites, it is the retailers’ responsibility
to ensure their waste is handled by an authorised waste carrier.
This liability and powers to prosecute non-compliance is dramatically increasing. In November 2017, the government introduced powers to make sites operating without the relevant environmental disposal permit, and those knowingly facilitating illegal waste disposal, liable to pay Landfill Tax and face fines amounting to an additional 100% of the tax’s value. The Department for Environment, Food & Rural Affairs (Defra) began consultations to further extend liability and ease of prosecution.
In England and Wales, tyre retailers may store up to 1000 used car tyres and 500 truck tyres at their depots without a permit. However, if you yourselves transport any of these on the public highway for whatever reason you will need to apply for a Waste Transfer Permit. While you cannot totally escape your personal Duty of Care using a collector audited and accredited by the TRA under our industry-approved Responsible Recycler Scheme (RRS), using an RRS accredited operator will show that you have exercised due diligence. Responsible retailers, fleet companies and other users of tyres who use RRS are guaranteed that the tyres collected by members of the RRS are disposed of in an environmentally friendly and acceptable method. The RRS was devised to make life easier for tyre retailers by ensuring RRS members and their sites are fully permitted and that the waste tyres they take are recycled or reprocessed in ways that meet UK and European standards. Retailers not using a Responsible Recycler Scheme member to remove waste tyres should ask themselves these questions:
1. Does your collector have a Waste Carrier Licence?
2. Do they issue you with a Waste Transfer Notice?
3. Do your collected tyres go to a licenced recycling facility?
4. Is your waste fully audited?
You must be able to tick each of these four questions, if not, you have a legal duty to assure yourself that your non-RRS collector is acting entirely within the law. The TRA has been actively improving awareness of Duty of Care when disposing of tyre waste with its ‘kNOw Tyre Waste’ campaign.
Visit tyrerecovery.org.uk to find out more or if you would like to know more about RPWTP or to enquire about participating in the programme, please contact: office@tyrerecovery.org.uk or call 01787 226995
To read the full leaflet click here: www.drive.google.com
