MEETING WITH GM, Rüsselsheim
Participants: GM: Willi Fey, Kai Siegwart
EGARA: Paul Fox, Lennart Scharff
Purpose of the meeting: To analyse the figures on work-time needed for de-pollution and dismantling for recycling as required in the ELV-directive, where EGARA has an estimate of approx 100 mins, GM around 23 mins – in the “worst possible case”.
After a general introduction where GM stressed that:
- they prefer to have dismantlers / authorized treatment facilities (ATF’s) as partners in their networks
- that they prefer having individual contracts with dismantlers / ATF’s
- these dismantlers / ATF’s should have experience in the business
- they look for “sustainable operations”
- concerning the UK they have 95% of their network ready
- concerning Denmark they have a non-exclusive contract with STENA and are in negotiations with H.J. Hansen – both shredder-companies running several ATF’s since there were no positive response from dismantlers. As valid for all other countries GM is also open for re-discussing and cooperating with dismantlers in Denmark.
- they consider a dismantler / ATF treating around 3.500 ELVs per year would be an ideal size for having an optimized business. But also facilities with 1.500 or less are in a position to provide a sufficient operation business.
the meeting went into discussing in great detail the “measurements” done by GM based on the attached Excel-sheet.
After having discussed some details concerning the individual items in the sheet and after having seen a video showing the process, a video that clearly demonstrated that the equipment used in no way was “fancy or advanced” but more had a character of “standard equipment”, it became clear that the differences between EGARA’s figures and GM had to do with the following facts:
- GM only consider the actual (pre-) treatment steps as work which falls under the context of discussion about necessary (pre-) treatment times.
- Administrative functions as required by the “authorities” could not be considered to fall under “producer responsibility” since these items are a natural consequence of environment legislation, primarily issued before the Directive came into effect
- Extra functions performed, such as: Greeting the client, moving vehicles around, preparing for delivery of waste fractions etc., do, in GM’s opinion, not count since these functions are performed anyhow – especially when we speak about “operational dismantlers”.
Although EGARA saw this differently and basically is of the opinion that with the “new rules in the directive” more time is spent on these functions, we understood GM’s views on this, but avoided a detailed discussion on “interpretation of producer responsibility seen in relation to the legal definition” of this. Basically GM wish to distinguish between:
Environment / Dismantler
i.e. the functions necessary to perform in order to comply with general environment law, including the administrative items specified in this, e.g. COD-issuing; i.e. the functions a dismantler would have to perform anyhow in order to have an operation, e.g. moving between work-places. Preparing for delivery of waste-fractions, hulks etc.
i.e. the items necessary to perform in order to comply with the rules for (pre-) treatment activities in Annex 1 of the ELV-directive, in order for producers to live up to their responsibility as described in the Directive rsp. in the national transcriptions.
Further we also, in the context of work-items and necessary time spent on this, had a discussion concerning new tooling developed for the deployment of pyrotechnic devices, avoiding the need (in most instances) to remove these devices where fitted, which would clearly mean time-saving.
EGARA will now in detail study the GM figures and based on this make a new calculation, where:
- the parallel operations will be taken into account
- the extra time as a result of the directive will be considered instead of total time spent
- will we seek to distinguish between “environment / dismantler responsibility” and “producer responsibility”
- Typical ELV – Percentage “Fit” data to be collated with reference to Alloy Wheels, Air Conditioning, and Pyrotechnic devices.
- With reference to Air conditioning and Pyrotechnic devices – How much ‘gas’ remains in a typical ELV, and is recoverable. How many air bags deploy using the new tooling.
- Analysis of Country data to show differences in “percentage fit”