Since our phone conversation, I looked through the files for Sims Metal and also talked with the Public Health Dept. staff that completed their compliance assessment.
Through the Green Business assessment process, we evaluated Sims Metal's energy and water efficiency, waste management and pollution prevention at the local SF site (Green Business recognition is tied to the business practices at the facility that they are operating at). Under the pollution prevention section, we evaluated their use of toxic chemicals (such as those used for cleaning the premises) and prevention of stormwater/waste water pollution (through dry sweeping, closed loop water system). The evaluation was done only at the SF site that was ultimately recognized as a green business. Their recognition is now almost 3 years old, which means they will be up for re-evaluation soon.
The DPH Compliance inspector I talked to (and that originally completed the GB assessment for compliance) was not aware of their position on the automotive shredder waste reclass. She mentioned the following -- "We only handle local compliance and they are great in my book. What they do with DTSC and rule making changes just don't get to our local level."