Bunker Silo Covers: Know What You Are Buying When Replacing Tire Inventory
Caution: It is important to understand that radial tire sidewalls may contain protruding wires that present a hazard to workers and could penetrate plastic covers and contribute metal into the feed supply. Consider if this risk is worth taking with your herd. Bias ply sidewalls without wires can be purchased, but supply and availability are reported to be limited. One producer reports noticing an increase in hardware disease after cutting a number of radial tires in half, and cases declined substantially after eliminating those from use on the bunker. We are also hearing that some receivers of used tires require them to be clean – not simply rain clean, but hosed off. To avoid rejected loads, be sure you know the requirements before sending old tires for disposal. Be aware that burning and on-farm burial of used tires is not legal. By: Karl Czymmek, Cornell CALS PRO-DAIRY
New York Farm Bureau with support from Northeast Dairy Producers Association and PRO-DAIRY continue to work with NYS DEC to address challenges with the new regulations for waste tire usage. While discussions continue and progress is being made, the implementation deadline (May 2018) is approaching and many farms are taking steps to comply. We should appreciate that DEC has indicated a willingness to use enforcement discretion, meaning there will be some level of flexibility in the enforcement of this regulation, at least initially. But the lack of suitable replacement options and uncertainty about what to do with existing tire stocks on farms as well as costs for all of this present serious challenges and are part of the ongoing discussion agenda with DEC.
For more general information on the topic, see the article Reducing Mosquito Breeding Sites When Using Tires as Anchors for Silo Covers.
Additional information is also provided by NYFB below.
Waste Tire Update from NYFB – Enforcement Discretion
An update from NY Farm Bureau
In September, the Department of Environmental Conservation released the final regulations for Part 360 (Solid Waste Management), including limits on storage of waste tires while allowing for “beneficial use” of tires to hold down covers with certain restrictions for on-farm uses. With increasing public health concerns about zika and other serious diseases that can be transmitted by mosquitos, one of the chief policy objectives is to address the shallow water that collects in tires and provides ideal mosquito breeding conditions. To this end, the beneficial use determination requires that tires be either halved or have holes in them to prevent the retention of water. These rules will have important impacts on agricultural and other uses of waste tires. NYFB provided comments to DEC prior to the completion of the regulator changes and we have pulled together a group that includes farmers, and advisors along with PRO-DAIRY, and NEDPA to work further with DEC on this topic.
The regulation reads:
Section 360.12 Beneficial use:
(iv) waste tires required to secure tarpaulins in common weather protection practices such as agricultural storage covers and salt pile protection, provided the number of passenger tire equivalents used does not exceed 0.25 passenger tire equivalents per square foot of cover or bunker area, and whole tires are cut in half or have sufficient number of holes drilled in them to prevent retention of water;
Passenger tire equivalent means a conversion measurement that is used to estimate waste tire weights and volume amounts and in which one passenger car tire with a rim diameter of 17 inches or less is equal to 20 pounds. One cubic yard of volume shall contain 15 passenger tire equivalents. Tires larger than a passenger car tire shall be evaluated for volume using this conversion measurement.
Waste tire means waste which consists of whole tires (on or off the rims) or portions of tires from a vehicle or motor vehicle as defined in ECL section 27-1901, including tire casings separated for retreading and tires with sufficient tread suitable for resale. Waste tire does not include crumb rubber derived from waste tires.
A copy of the regulation is online.
Currently, in order for a farm to be in compliance with the new regulation, there can only be 0.25 passenger tire equivalent per square tire and all tires on the bunk would either have to be cut in half or have holes drilled in them. The deadline for implementation is May 2, 2018.
Since these regulations were released we have been working with DEC to help them understand some of the practical hurdles faced by farms as a way to develop guidance as well as a reasonable implementation schedule for the regulations. We will provide further information as it becomes available as well as any guidance material for farmers.
We are aware that a large majority of tires that farmers have on their bunk silos are radial-ply tires, which have metal wires in both the tread and side walls. These tires, if cut in half or have holes drilled in them can pose a significant health hazard to cattle. If a cow consumes any metal from the tire, there are life-threatening consequences. Cutting in half or stamping plugs out of sidewalls of radial-ply tires can difficult to begin with, and poses health risks for farm staff doing the modification and subsequent handling.
In the meantime, we encourage farmers to start thinking about what implementation will look like on your farm. We also urge farmers to no longer accept tires for your bunks if the tires cannot meet the halving or holing requirement. Penn State University Extension developed a tire management document with best management practices for farmers, which can be a resource as you begin to consider management of tires on your bunks.