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SEP-30-2010 15::32 T - BOY TRAILERS 2092397086 P.08 <br /> Additional c ..lents/questions by Tuff Boy s� itted to SJCEHD on <br /> October 01, 2010: <br /> a. None <br /> 21.Tuff Boy question submitted to SJCEHD on August 11, 2010. <br /> For off-road-field harvest equipment (field dollies) utilizing used tires with as little as <br /> 3/32" tread depth, is it possible for Tuff Boy to classify their existing loose "field only use" <br /> tire inventory in such a way that will allow for hauling spare tires exempt from waste tire <br /> manifest requirements? <br /> SJCEDH response to Tuff Boy on August 19, 2010. <br /> Tires that are for off-road-field harvest equipment (field dollies) and are used, must still <br /> be manifested if using a registered waste tire hauling vehicle and/or hauling 10 or more <br /> of such tires. When hauling tires, regardless of their intended use or reuse, there is no <br /> distinction made between used and waste tires_ <br /> Additional comments/questions by Tuff Boy submitted to SJCEHD on <br /> October 01, 2010: <br /> a. We have been told there is a distinction between used and waste tires. What <br /> regulation are you looking at? <br /> 22.Tuff Boy question submitted to SJCEHD on August 11, 2010. <br /> Are both the California Highway Patrol and the California Department of Transportation <br /> rules consistent with Cal Recycle rules in terms of waste tire designation, hauling and <br /> manifest requirements? <br /> SJCEDH response to Tuff Boy on August 19, 2010. <br /> The California Highway Patrol and the California Department of Transportation may have <br /> rules that overlap with the waste tire laws, but they are separate entities that follow and <br /> enforce different and distinct laws. <br /> Additional comments/questions by Tuff Soy submitted to SJCEHD on <br /> October 01, 2010: <br /> a. None <br /> 23.Tuff Boy question submitted to SJCEHD on August 11, 2010. <br /> As a tire dealer, how often can Tuff Boy expect the SJCEHD to conduct an inspection of <br /> the Tuff Boy facility? <br /> SJCEDH response to Tuff Boy on August 19, 2010. <br /> As a tire dealer, the number of inspections received by Tuff Boy Trailer Sales Inc. would <br /> not increase. The EHD is required to conduct a routine inspection at least once <br /> annually. However_ Inspections can occur twice in a calendar year, because the <br /> program is set on a Fiscal Year (July to June). Additional inspections can occur if the <br /> EHD receives a complaint regarding Tuff Boy or during a routine inspection a violation is <br /> issued, then a re-inspection would be required to verify compliance. <br /> Additional comments/questions by Tuff Boy submitted to SJCEHD on <br /> October 01, 2010: <br /> a. None <br /> 24.Tuff Boy question submitted to SJCEHD on August 11, 2010. <br /> What event or situation might cause Tuff Boy to be responsible for billing charges from <br /> SJCEHD (as per county office posting showing a billing rate of$122.00 per hour)? <br /> SJCEDH response to Tuff Boy on August 19, 2010. <br /> The waste tire program is funded by CalRecycle. The EHD can make referrals to <br /> CalRecycle regarding facilities that do not comply with the waste tire program <br /> requirements (i.e. continuous/ongoing violations of the law). CalRecyle has the authority <br /> to conduct penalty enforcements (see T14CCR Section 18429 and 18464). <br /> 7 <br />