California Senate Bill 811 (SB 811) officially became law on September 30, 2026, and it replaces key elements of California’s previous metal-shredder framework with industry-specific permitting, operating, monitoring, financial assurance, and community-engagement requirements.
Who is Subject to SB 811?
SB 811 generally applies to facilities using stationary or mobile shredders, such as hammer mills, to process end-of-life vehicles, appliances, or other metallic feedstock to recover ferrous or nonferrous metals. The law excludes certain operations, including feeder yards and facilities that only crush, shear, or bale metal without shredding, as well as specified e-waste-only, tire-only, wood-processing, and exclusively nonferrous-metal operations.
The law also defines a “small metal shredding facility” as one processing no more than 250 tons per day or 65,000 tons per year using a stationary hammer mill, provided additional eligibility conditions are met.
What Is Changing?
Covered facilities must obtain a permit from DTSC. Qualifying existing facilities may operate temporarily under deemed-permit status while DTSC reviews a timely submitted application, provided the facility complies with applicable interim requirements. New facilities may not begin operation until DTSC issues a permit
Existing facilities must submit a notice of intent within 30 days of the effective date and submit a permit application no later than six months following the notice. Qualifying small metal shredding facilities have up to one year following the notice to apply. While the permit application is pending, the facility must keep operating under a DTSC-approved compliance plan.
Permit applications must include extensive facility-specific information and plans addressing topics such as:
- Metal processing operations and equipment;
- Facility inspections and housekeeping;
- Fire prevention, detection, and response;
- Inventory and pile management;
- Security, preparedness, contingency planning, and personnel training;
- Closure and financial assurance;
- Transportation and offsite management; and
- Compliance plans and implementation schedules, where applicable.
SB 811 also repeals DTSC’s 1988 Auto Shredder Waste Policy (OPP 88-6) and existing facility-specific nonhazardous-waste determinations for metal shredder waste upon the effective date. Facilities complying with the new program generally are not considered hazardous waste facilities based on their regulated metal-shredding operations. However, DTSC and Unified Program Agencies retain authority over other hazardous waste generated at the facility.
Operating, Site Assessment, and Air Quality Requirements
SB 811 establishes detailed operating standards addressing feedstock source controls (e.g., written acceptance policy and checking incoming loads), depollution, metal shredder aggregate and residue management, housekeeping, material containment, pile management, and fire prevention. A list of operating requirements from SB 811 is provided below. Note that the list is not exhaustive.
- Incoming Material Screening:
- A written policy barring hazardous waste, asbestos, PCBs, mercury devices, batteries, compressed gas cylinders, ordnance, regulated e-waste, and similar items.
- Loads must be checked and the records kept for 5 years. Hazardous waste accepted by mistake counts as generated at the facility.
- Fire Plan:
- Continuous infrared (or equivalent) temperature monitoring of piles, with alarms.
- Feedstock piles capped at 24 hours of processing capacity.
- Aggregate piles capped at 48 hours of processing capacity, and inactive piles can’t sit longer than 48 hours.
- Release Control:
- Daily cleanup of light fibrous material.
- Inspections out to 500 feet beyond the property line.
- Enclosure:
- Aggregate and residue, treated or untreated, must be stored under a roof with walls and a concrete or steel-plate floor.
- Outdoor conveyors, trommels, and augers must be enclosed or covered.
- Outdoor stockpiling needs DTSC’s written approval and 24-hour notice and is limited to 10 consecutive operating days.
- Stormwater:
- Containment for stormwater that contacts industrial processes.
- A toxicity testing plan.
- SWPPP and SPCC Plan.
- Coverage under the Industrial General Permit or NPDES permit from regional board.
- Shipping of Chemically Treated Metal Shredder Residue (CTMSR):
- Loads must be tarped or contained, with no more than 4 hours at a publicly accessible interim location.
Within one year of the effective date, covered facilities generally must conduct and submit a preliminary endangerment assessment evaluating areas where releases containing hazardous constituents may have occurred. A facility may satisfy this requirement through a qualifying assessment completed within the preceding five years if associated corrective-action requirements are being or have been implemented. Corrective action may be required where releases pose a significant threat to human health or the environment.
Air quality is also an important consideration. If an applicable air-quality health risk assessment has not been conducted, the facility must complete an analysis of equivalent scope and depth approved by the local air district. Depending on district requirements and existing facility information, this could involve emissions characterization, source testing, air dispersion modeling, and health-risk evaluation.
SB 811 also aligns the permitting program with California’s fence-line monitoring requirements. Covered facilities must implement hazardous-waste-constituent monitoring overseen by DTSC and facility-wide air-quality monitoring requirements developed by the applicable local air district. Air-monitoring requirements address contaminants including lead, zinc, cadmium, and nickel, as well as health-protective thresholds, community notification, response to exceedances, reporting, and enforcement.
Community Engagement and Permit Review
SB 811 incorporates substantial public participation and agency review into the permitting process. Before filing an initial or renewal application, the applicant must conduct at least one public meeting or another DTSC-approved community-engagement activity, with at least 30 days’ advance notice.
Following submission of a complete application, DTSC must conduct periodic progress meetings at least annually during the permitting process. The DTSC will ensure that the application and proposed permit for the facility comply with existing environmental plans and authorizations (such as local air quality management district permit, AB617 Community Emission Reduction Plans, etc.) as well as environmental justice considerations. Before making its permit decision, DTSC must also provide a public-comment period of at least 45 days, conduct a public meeting, and respond to public comments within 60 days after the comment period closes.
For existing facilities, DTSC generally must take final action within three years after determining the application is complete, although the review period may be extended as necessary for the California Environmental Quality Act (CEQA) process. SB 811 notes that approving an application for an existing or new metal shredding facility is a discretionary decision.
What Should Regulated Businesses Do Now?
Facilities potentially subject to SB 811 should begin preparing early. Priority actions include:
- Confirm applicability and whether the operation qualifies as a small metal shredding facility.
- Establish a compliance calendar for the notice of intent, permit application, community engagement, preliminary endangerment assessment, financial assurance, monitoring, and other requirements.
- Conduct a compliance gap assessment addressing existing operations, fire prevention, material management, housekeeping, training, closure, and environmental programs.
- Evaluate facility improvements potentially needed for material containment, covered storage, drainage, fire protection, and pile management.
- Review air-quality and monitoring needs, including existing emissions information, health risk assessments, source testing, air dispersion modeling, and fenceline monitoring.
- Evaluate historical site conditions and determine whether a new preliminary endangerment assessment will be necessary.
- Budget for implementation. Applicants must reimburse DTSC for permit-processing costs, including a 25% deposit based on DTSC’s estimated processing costs, and pay applicable CEQA costs. The program also includes annual fees and financial-assurance requirements.
How Trinity Can Help
Trinity Consultants can help metal shredding facilities develop an integrated strategy for SB 811 permitting and implementation, including:
- SB 811 applicability and compliance gap assessments;
- DTSC permit applications and agency coordination;
- Operating, inspection, housekeeping, fire-prevention, contingency, and training plans;
- Preliminary endangerment assessments and corrective-action support;
- Air emissions inventories, source testing, and air permitting;
- AERMOD/HARP air dispersion modeling and health risk assessments;
- Fenceline and ambient air-monitoring program support;
- Material and waste characterization;
- Closure planning and cost estimates;
- Stormwater, wastewater, hazardous materials, and hazardous-waste compliance; and
- Community-engagement and public-meeting support.
SB 811 creates significant new permitting and compliance obligations for California’s metal shredding industry. Facilities that establish their compliance schedules, identify technical and infrastructure gaps, and begin developing required plans early will be better positioned to maintain operations and navigate DTSC’s new permitting process. To discuss your business obligations and readiness, contact Principal Consultant Charles C. Lee, Ph.D., or Trinity CA Local Office.
