2016 ReviewRETREAD MANUFACTURERS ASSOCIATION

RMA WELCOMES MIKE WILSON

In June, the RMA appointed a new Director, Mike Wilson, who replaces Alan Bithell. Mike has a long association with the tyre industry, having joined Michelin in 1974. He is also a Board Member for the UK Tyre Industry Federation.

Following varied experience with Michelin in Stoke on Trent, the Republic of Ireland and the head office in London, Mike took responsibility for the marketing and sales of retread products and end of life tyres. This subject continues to be of great interest to Mike and he has already been engaged in much of the RMA’s work in this field.

WELCOME TO THE RMA ANNUAL REVIEW 2016. It’s been a challenging year for everyone in the tyre retread and recycling industry with a range of deep-seated issues emerging and ongoing which pose a significant risk to us all.

These issues need a robust response which makes it even more important that we encourage new and renewed membership, mustering a combined strength to affect positive outcomes for the future of many businesses and the jobs they create.

As the voice of retreaders in the UK the RMA, together with the TRA and TIF, has been working collectively to raise our concerns and highlight these pressing matters both nationally and at European level. From new fire plan regulations and end of life status to REACH health concerns over tyre crumb use and Asian imports, the subjects are diverse and challenging.

We have made some progress on these projects with much still to achieve in 2017 and beyond, shaping the strategic direction and commitment of the association to support all its members. We thank you for your continued membership and confidence in us. If you feel as passionately about the future of the industry as we do, please do consider taking a role on the board or a committee to help steer the RMA and help preserve the various industry sectors.

Under current regulatory requirements tyres are classed as waste from the moment they are removed from vehicles and determined to be no longer fit for purpose. This status continues through to the point when they have been fully retreaded, when they become a product (also known as end of waste). Significantly, the storage regulations for waste are far more onerous than those for product.

RMA has engaged consultants to undertake a study to identify whether end of waste can be determined earlier in the supply chain.

The potential cost savings, in terms of permits and site size requirements, will be of enormous

benefit to the industry while still providing the necessary environmental controls required by the EA.

The three-phase project has included site visits to a spectrum of companies, including casings agents and retread manufacturers to understand the process. Following this, the consultants have undertaken legal and technical reviews and written a roadmap for delivery.

The final stage will involve EA engagement and drafting of an RMA quality protocol that is understood, able to be followed and auditable, with the new directive in place by May 2017.

The influx of cheap tyre imports from the east is threatening the European tyre industry as prices fall below the basic manufacturing costs, even of a retreaded tyre. It has become clear that the European Commission is unable to protect British industry against these cheap tyre imports due to a lack of current legislation.

The RMA, working in association with BIPAVER, has been lobbying the European Commission Directorate-General (Trade) for more than a year to consider the case.

Although presented with several technical and legislative solutions, the EC has said it is not able to defend our interests as there is a lack of legislation for this specific situation. The RMA is calling on Commissioner Cecilia Malmstrom to reassess the situation.

In the meantime, the Indian government is considering an anti-dumping duty import on Chinese tyres, and in the USA most truck and bus tyres from China are due to be assessed, on a tariff of more than 50%.

MESSAGE FROM THE BOARD

CHEAP IMPORTS, TARIFFS AND THE EC

END OF LIFE CASINGS

The Fire Prevention Plan guidance was published by the Environmental Agency (EA) in July 2016. While much of this new guidance is acceptable best practice, there are elements which make it unworkable such as requirements for maximum stack heights and stack separation distances.

To accommodate the plans, existing regulated sites would need to expand their footprint by up to four times – which is neither commercially viable nor possible due to the availability of sites.

Some of the challenges are directly linked to a clear misunderstanding by the EA of fire science relative to tyres. The Fire Prevention Plan (FPP) guidelines heavily reference a 1995 Home Office Report ‘Fire Safety for Tyres’ which represents a theoretical analysis of the potential self-heating properties of rubber crumb - a totally different scenario from stacked tyres. The effectiveness of fire suppression systems is also under dispute.

The guidance impacts the whole recycling sector and the EA have advised that local EA officers will work with operators closely over the next two years.

BUSINESS IMPACT ASSESSMENT SURVEY

It is a legal requirement, under the Regulators Code, to assess the impact on businesses however this assessment had not been undertaken prior to publication of the FPP. At industry’s request the EA have now carried out

a business impact assessment survey that RMA members contributed to. The responses have been sent to the independent Regulatory Policy Committee and the outcome will be published mid-March.

LETTER TO BEIS

In November, the Tyre Industry Federation (TIF) wrote to Margot James MP, Parliamentary under Secretary of State at the Department for Business, Energy and Industrial Strategy (BEIS) on behalf of the industry highlighting concerns over the process and the lack of communication of the scientific evidence of the FPP.

WISH GUIDANCE

The FPP affects other waste streams such as the Wood Recyclers Association and British Salvage Vehicle Federation, and Mike Wilson attended the Waste Industry Safety & Health Forum (WISH) meetings in July and October. As well as trade and professional associations, WISH members include representatives from HSE, trade unions, recycling organisations and involved national and local government bodies.

WISH reviewed its existing fire prevention guidance and, with direct input from the RMA and other sectors of the waste industry, has produced its own updated guidelines on the subject.

In addition, Mike Wilson attended the November Fire Prevention Conference, where Peter Taylor gave a presentation focussing on the threat to reputable businesses if the FPP ‘one size fits all’ guidelines are adopted. It also highlighted that the FPP would encourage an increase in sites exempt from regulation, which the EA admits it does not have the funds to inspect.

A new business-facing approach from the EA was called for, together with a more constructive tyre waste industry engagement and a fire guidance policy which incorporates the conclusions of the scientifically conducted burn tests organised by WISH Fire and Rescue Service support.

FIRE PREVENTION PLAN

The RMA continued to contribute to BIPAVER on projects of joint interest in 2016 including tyre labelling.

BIPAVER’s objectives include: providing an effective forum where policies of mutual interest can be agreed between members; directly influencing national, European or international governments; providing a channel of communication with European tyre manufacturing organisations such as ETRMA and ETRTO; promoting members’ views regarding technical issues relating to retreading and associated standards, such as repair; influencing EU legislation; and raising awareness of the benefits of tyre retreading.

RMA also worked closely with BIPAVER in producing a lengthy report, The socio-economic impact of truck tyre retreading in Europe: the circular economy of tyres in danger. A copy of the report can be downloaded from the members’ section of the RMA website.

BIPAVER COLLABORATION The socio-economic impact of truck tyre retreading in Europe

The circular economy of tyres in danger

October 2016

End of life tyre granulate infill used in artificial pitches has been the subject of heightened attention due to media reports of cancer links and a Dutch documentary stating there were no controls in the materials used. All tyres used for this purpose must be compliant with REACH (Registration, Evaluation, Authorisation & Restriction of Chemicals), a Europe-wide legislation aimed at ensuring chemicals are properly tested before going on the market.

All European tyre manufacturers registered with REACH in 2010. Of the materials used in manufacture, PAHs used in the extender oils had severe restrictions and limits, however REACH does not apply to carbon black.

The website has been a continued success in 2016, with information on retreads, training and news. All members are able to send their news to the administrator to be uploaded on the site, which has proved a useful extra promotional channel for many. In a drive to promote the retread industry and the association,

RMA’s marketing took a fresh direction in 2016.

Branded mugs and posters were placed in the top 12 truck stops in the UK. Six full page colour advertisements were placed in selected issues of Truckfest Original show programme as the show toured the country. The posters and advertisement, Rethink Retread, emphasise the quality, value, environmental advantages and benefits of choosing British retread tyres.

In addition, an advertisement and free editorial was negotiated for Truck Stop News, and a feature on the RMA appeared in Freight Industry News. Fifty mugs were also supplied to each member organisation to raise the RMA’s profile within companies.

The popular Certificate in Retread Process Workshop Practice (3961), accredited by City & Guilds, ran from September until June in 2016. The annual Highest Achiever Award, for the person scoring the top mark nationwide and a distinction, was this year presented to Jason Humphries from Vacu-Lug. He received the award at the NTDA dinner on 6 October from Mike Wilson.

TYRE CRUMB INFILL

WEBSITE NEWS

RMA MEMBERS

MARKETING INITIATIVES

CITY & GUILDS AWARDS

Rethink Retreads. Discover more and locate your local retread operator atwww.retreaders.org.ukTel: 01787 226 995

Retread Manufacturers Association

QualityRetreaded tyres are manufactured to ECE regulations. Quality, integrity and performance on a par with new tyres

ValueMile-for-mile, no other tyre is more cost effective over its lifetime than a retread tyre

EnvironmentRetreading a tyre uses far less raw material than the manufacturing of a new tyre and cuts waste

BritishEnsuring there’s a retread operator near you provides 2,500 British jobs

£

RETHINKRETREADRetreaded tyres are manufactured to the highest standards, ensuring their performance is on par with a high quality new tyre

CALEDONIAN TYRES LTD

STRATHAM TYRES LTD

EKS TYRES (NI) LTD

INVICTA RETREADS LTD

For further information please contact:

Retread Manufacturers Association, Peershaws, Berewyk Hall Court, White Colne, Colchester CO6 2QB

Tel: 01787 221026 • Email rma@greentyres.com • Web: www.retreaders.org.uk