Waste Tire Enforcement: TEA Toolbox
Frequently Asked Questions
Since the inception of CalRecycle's Waste Tire Enforcement Program, many questions have been generated by tire enforcement agencies (TEA) concerning the interpretation and implementation of the program. The purpose of this frequently asked questions (FAQs) page is to provide a compiled listing of questions and answers for easy reference for TEAs and CalRecycle staff.
For additional guidance concerning these FAQs, please use the map and list to locate CalRecycle staff contacts for each county.
The FAQs are organized into the following tire issue categories:
Tire Program Identification Numbers (TPID) Issues
When is a TPID number needed?
When a business/person transports 10 or more waste/used tires at a given time on a public road.
When is a new TPID number required to be issued?
The following scenarios address the most common situations in which a TPID number may or need to be issued/changed.
- If the generator maintains the same business name at the same location but, the ownership changes, then the generator will need to obtain a new TPID number.
- If a generator changes its business name at the same location with no change in the ownership, the generator will keep the existing TPID number
- If the generator moves the business location, then the generator will need to be issued a new TPID number. The new and the previous TPID number will be merged into one record in CalRecycle's database.
- If a waste and used tire hauler (hauler) moves or adds a new business location, the hauler will keep the original TPID number for the first location and be issued a new TPID suffix for the second location by CalRecycle. Therefore, the second location will have the same prefix as the original number but a new suffix (02). If tires are still stored at the old location, the original TPID and suffix will remain active. If the old site is closed, then the original TPID (site suffix) will be closed.
Tire Waste and Used Hauling and Manifesting Issues
Who issues common carrier and agricultural exemption certifications for hauling tires?
CalRecycle’s Waste and Used Tire Hauler and Manifest Program staff issues common carrier and agricultural exemptions. A letter requesting the exemption pursuant to Title 14, California Code of Regulations (CCR), Section 18453 and Public Resources Code (PRC) Section 42954 provides the statutory authority for the exemptions.
Why do some registered waste tire haulers show as unregistered when I call the hotline or check the website?
If the TPID number does not match up with a registered hauler name and application information, one of the following two things may be occurring:
- The hauler does not have a valid waste tire hauler registration, or
- The hauler may be using the wrong TPID number.
Many haulers are part of a regional or national company that operate under the parent company’s hauler registration. If this is the case, each hauler must use the decal number and TPID number that is issued to the parent company for all of its vehicles.
For example, the Wingfoot corporate office has a hauler registration with a TPID number of 1002615, and is located in Arkansas. However, their vehicles are stationed throughout California at different stores. All the drivers must use the corporate TPID number (1002615) issued to the Arkansas address for the hauler portion of their CTL forms, not the TPID number of the location where they park their trucks.
In this example, if there is a manifest or hauling violation, the violation would be issued to the corporate office in Arkansas, not the local hauler. If the corporate office is outside the TEAs jurisdiction, the case should be referred to CalRecycle. If the corporate office is in the TEAs jurisdiction, the TEA may issue a Notice of Violation. However, prior to taking any action, the TEA must first contact Keith Cambridge, supervisor of CalRecycle’s Waste and Used Tire Hauling and Manifest Section, to determine if there is pending enforcement actions against the hauler.
If a registered waste tire hauler transports less than 10 tires per trip, is the hauler required to leave a CTL form with the generator?
Yes, if the truck is certified under a registered hauler; any and all used and waste tires must be manifested.
However, some registered hauler companies may de-certify a specific truck so they can haul less than 10 tires without filling out a CTL. TEAs must make sure the truck license plate number is listed under the haulers registration before giving them a violation. Search by license plate number to find out if a vehicle is registered.
Are processed or whole tires allowed to be disposed of in a garbage bin?
There is no specific State or Federal law or regulation that prohibits tires from being thrown into a garbage bin. However, when 10 or more whole tires or passenger tire equivalents are discarded, the hauler is required to have a current hauler registration and to properly manifest the load. If the hauler is not registered, the generator of the tires can be cited for contracting with an unregistered hauler per PRC Section 42953.
PRC Section 42951 allows registered waste tire haulers to take waste or used tires to a "facility that is permitted, excluded, exempted, or otherwise authorized by CalRecycle, by statute or regulation, to accept waste tires, or to a facility that lawfully accepts waste or used for reuse or disposal." Where are registered waste tire haulers allowed to take waste tires?
Authorized facilities include the following:
- A solid waste facility permitted for disposal or transfers station or a major or minor waste tire facility that is permitted and in compliance with its conditions.
- An excluded facility or operation listed under 14 CCR, Section 18420 that meets all the requirements.
- An exempt cement kiln that meets conditions of approval (ask to see certificate).
- An approved "Beneficial Re-Use" site (ask to see approval letter).
- A facility location with less than 500 tires.
- Any facility or type of use that is approved by CalRecycle (e.g., Tire Derived Aggregate project site).
If you have questions, please contact your CalRecycle field staff contact.
Note: Tire dealers and auto dismantlers can have up to 1,500 waste tires if they are removed within 89 days, and the hauler has been given permission by the business owner to unload the tires at these locations. In any instance, they must include the tires being unloaded as part of the 500 or 1,500 tires.
Why do mobile home dealers/manufactures have TPID numbers?
Once a manufactured home is sold, it is equipped with tires and axles so it can be delivered to the desired home site destination. Many mobile home manufactures lease or rent the tires and axels used to deliver manufactured homes to the mobile home buyers though a third party. Once the mobile home is set up at the home site, the wheels and axels are removed and the site becomes a tire generator. Typically over 10 tires are used to transport the home.
Issuing a TPID number to such a location can be impractical. Consequently, CalRecycle has come up with alternatives listed below that are intended to accommodate the manufactured home industry needs and prevent the issuance of TPID number unnecessarily.
- CalRecycle has authorized either the mobile home manufacture or sales representative to maintain the TPID number for their customers. The registered hauler can leave the CTL with the manufacturer or sales representative.
- The hauler can use its TPID number and the address would be filled out "same as hauler."
Note: If there are 500 or more waste or used tires stored at these sites, a waste tire facility permit is required.
Tire Storage Issues
Are waste and used tires required to be removed from the Tire Dealer and Automobile Dismantler facilities every 90 days?
Waste tires are required to be removed every 89 days. Used tries that meet the criteria described in PRC 42806.5 (racked and stacked) do not have a removal frequency or a storage limit placed on them. However, if the used tires are not stored in this manner, they are considered waste tires.
Background: Prior to the passage of SB 786 (in 2000) used tires were synonymous with waste tires. At that time, used tires were included in all waste tire counts. After SB 876 became law, used tires meeting the definition described in PRC 42806.5 (used tires), were no longer required to be counted as waste tires. Unfortunately, the bill also mistakenly inserted "used" tire into PRC section 42808(c), which delineates criteria for both the tire dealer and the auto dismantler exclusions. This error has caused the regulators as well as the regulated community considerable confusion because it 1) places a limit on the amount of used tires that can be in storage; 2) infers that used tires should be included in a waste tire count, and; 3) is not consistent with the definition of used tires (PRC 42806.6) and waste tires (PRC 42807). Each year, without success, CalRecycle staff has proposed clean-up legislation to remove the used tire language from PRC 42808(c). In 2003, a regulation package was approved that clarified the law by leaving used tires out of the criteria for automobile dismantler and tire dealer exclusions. The regulations do not limit the storage of "used" tires or assign a removal frequency to them. The specific regulation making the clarification is Title 14, California Code of Regulations, section 18420(a)(6) and (7).
Tire Inspection Form Issues
When should "closed" or "inactive" be marked under "operational status" on the inspection report form?
- Inactive--Waste tires are present; but tire operations are not active. Tires are not being moved in and out of the facility. Inactive sites will have a TPID, only for the purpose of the inspection report. However, the TEA is not required to inspect on a routine basis, unless there are over 500 tires. Inspections for these type of situations are inspected at the discretion of the TEA depending on the potential for the business to illegally dump or contract with haulers that illegally dump.
- Closed--Does not generate waste tires. The business may be active, such as an auto body repair shop, however, CalRecycle considers it "closed." Closed sites include former waste tire locations where all tires have been removed and tire operations are not longer or never were conducted. If the inspector determines the site is closed, they should fill in the closed bubble under "operational status" on page 1 of the Survey and Inspection Report (CIWMB 181), and explain why the site is considered closed in the comments section. Also, note the number of tires on the inspection report, usually zero.
Can compliance date in the "Enforcement Status" box be included in the inspection form when an "Area of Concern" is noted?
No, however, the inspector can place a compliance date in the comments section on the lower part of the inspection form. Remember, per the Terms and Conditions of the Grant Agreement, a waste tire inspector is required to cite a violation for un-permitted sites or unregistered hauler violations.
Can a waste tire enforcement agency (TEA) call the hotline and obtain a TPID number for a tire generator or end use facility?
Yes, state on the inspection report that a TPID number was obtained for the facility by the TEA, however please identify yourself to the hotline representative and tell them your purpose for calling.
When is a TEA required to complete page 2 of the Waste Tire Survey and Inspection Report form?
Page 2 of the Waste Tire Survey and Inspection Report form should be completed when inspecting:
- A facility stores 500 or more waste tires and has either an area of concern or violation noted under the storage standards.
- All permitted facilities.
- All exempt facilities (cement kilns).
- All unpermitted facilities that require a waste tire facility permit and do not have one. This would include facilities that are over their limits. For example, if a tire dealer has 1,501 waste tires on site, they would be in violation of PRC 42834.
Tire Grant Program Issues
If a TEA is unable to spend all of the funds under a specific task in the approved budget, can the TEA shift these funds to another line item in the grant?
TEAs may request an amendment to their budget if it follows the guidelines of the Grant Procedures and Requirements and application requirements. The TEA will need prior approval from CalRecycle’s grant manager before funds can be moved from one task to another task. If the TEA desires to make changes to their budget, they must write a narrative explaining the need for the change, revise their Budget Excel spreadsheet, and submit both items to CalRecycle's grant manager. The grant manager will approve or deny the request and notify the TEA.