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SWEEP Powered By Docstoc
					01 February 2006

Honourable David Forbes
Minister of Environment
Room 208
Legislative Building
Regina, Saskatchewan
S4S 0B3

Dear Minister Forbes,

In accordance with The Waste Electronic Equipment Regulations, this is to advise you that
Electronics Product Stewardship Canada (EPS Canada) wishes to cause a product management
program for waste electronics to be created as outlined in the attached proposal. This proposal is
submitted on behalf of the obligated first sellers listed and appended to this letter.

We look forward to working with your department and all Saskatchewan stakeholders to create a
model stewardship program for the province.

Yours truly,

David A. G. Betts
President and CEO

Copy: Victor Chang, SERM
  Corporations for which Electronics Product Stewardship Canada proposes to cause a product
          management program for waste electronics to be created in Saskatchewan*

Apple Canada Inc.
Best Buy Canada Ltd.
Canon Canada Inc.
Dell Canada
Epson Canada Ltd.
Hitachi Canada Ltd.
Hewlett-Packard (Canada) Co.
IBM Canada Ltd.
Lenovo (Canada) Inc.
LG Electronics Canada
Lexmark Canada Inc.
Microsoft Canada Co.
Mind Computer Products
Northern Micro Inc.
Panasonic Canada Inc.
Samsung Canada Inc.
Sharp Electronics of Canada Ltd.
Sony of Canada Ltd.
Toshiba of Canada Ltd.
Thomson Multimedia Ltd.

*It is the intention that this program would not be restricted to the above mentioned corporations.
The program would be made available to all first sellers obligated under the regulation.

                Proposal for a Product Management Program
               for Saskatchewan Waste Electronic Equipment
                                   01 February 2006

     Submitted to Saskatchewan Environment by Electronics Product Stewardship Canada
               working in conjunction with a multi stakeholder advisory committee

Contact: David Betts
President and CEO
Electronics Product Stewardship Canada
613 238 4822, ext 224

                                    Table of Contents

1. Introduction
2. Summary
3. Program Principles
4. Management structure of the program
        4.1 The advisory committee
        4.2 The formal governance authority
        4.3 Management and administration
        4.4 Local program management
        4.5 Collection and recycling
5.   Program Details
        5.1 Collection in all areas of the province
        5.2 Recycling options for waste electronics, listed in descending order of preference
        5.3 The policies and procedures to be followed by any person processing waste
            electronics equipment
6. How the program will be funded
        6.1 The environmental handling fee
        6.2 Setting the fee
        6.3 Funding flow
        6.4 Financing activities in advance of fee collection
7. Public education or public awareness aspects of the program, including tracking and
   auditing mechanisms
8. Quality control and assurance aspects including tracking and auditing mechanisms
        8.1 Auditing of obligated suppliers
        8.2 Auditing of recyclers
        8.3 Performance measurements and continuous improvement
9. Program milestones
10. Product included at program start up
        10.1 Product phase-in
Appendix A: List of members of the Saskatchewan advisory committee
Appendix B: List of corporations and organizations supporting this proposal
Appendix C: Recycler Vendor Qualification Standard

                          Proposal for a Product Management Program
                          for Saskatchewan Waste Electronic Equipment
                                        01 February 2006

1. Introduction
Electronics Product Stewardship Canada (EPS Canada) is pleased to provide the following
proposal for the development and implementation of a product management program for waste
electronics in the province of Saskatchewan. This proposal has been developed with the support
and approval of a Saskatchewan advisory committee which includes manufacturers, retailers, and
non governmental organizations both within and outside Saskatchewan. A listing of the
committee members is included at Appendix A.
This proposal is provided on behalf of the corporations and organizations listed at Appendix B. In
addition, it is the intent that participation in this program would be made available to all first
sellers obligated under the province’s Waste Electronic Equipment Regulations.
The proposal includes a commitment to meet Saskatchewan’s expectations for accelerated
program implementation, local program management, use of SARCAN Recycling for collection
and recycling services, and local participation in program governance.

2. Summary
This document outlines a product management plan to divert end-of-life computers, computer
monitors, desktop printers, computer mice, computer keyboards, and televisions from landfill,
and from illegal export, through the provision of reuse information and through collection and
subsequent recycling of products at end of life. It is estimated that approximately 700 tonnes of
residential and commercial electronics waste will be available for collection in the first year of
the program with program costs approaching $1.5 million. Waste material and program costs will
rise considerably when televisions are added in the program’s second year.
The proposed product management program for Saskatchewan would be based on a shared
responsibility model where manufacturers, retailers, consumers, and government all have a role to
play. Consumers will be able to drop off waste electronics at collection depots at no charge to the
consumer. Industry will manage the program and ensure environmentally sound recycling.
Government will enforce the regulations to ensure full program compliance.
To provide the necessary program funding, the program will implement an environmental
handling fee on new sales in Saskatchewan of all electronics products obligated under the
Materials will be collected and recycled under a contractual agreement with SARCAN, and with
SARCAN subcontractors, who will be required to meet the EPS Canada recycler standard.
The program will seek to maximize recycling activities within the province, providing this
delivers cost effective and environmentally responsible solutions.
The program will include a communications plan and public education element including full
public transparency for financial and environmental reporting.
The program will be divided into three phases:
    Phase 1 will focus on program development and implementation activities.

    Phase 2 will begin in June 2006 with full program introduction and the necessary fees in
    place. (see the note at the end of this paragraph)
    Phase 3 will see the addition of television products to the program.
    Note: While we believe the above target dates are achievable, we will be relying upon
    successful SARCAN negotiations coupled with their operational ability to move forward
    within the deadlines specified.
3. Program principles
We are proposing a product management program which will:
    •   Be consistent with the Canadian Council of Ministers of the Environment Canada-Wide
        Principles for Electronics Product Stewardship (CCME Principles) including
        harmonization with other Canadian provinces.
    •   Be consistent with industry’s guiding principles for stewardship programs.
    •   Provide a level playing field (fair competition).
    •   Achieve a high level of compliance and eliminate the potential for free-riders.
    •   Adequately address the issue of orphan, historic, and imported products from companies
        with no Saskatchewan or no Canadian presence.
    •   Ensure the program is delivered effectively and efficiently at the lowest possible cost.
    •   Ensure materials are recycled in a responsible manner that safeguards the environment
        and worker health and safety.
4. Management structure of the program
The program will be managed initially by a multi stakeholder advisory committee which will
transition to a formal program governance authority.
Product Care Association has been selected by the committee to manage the day to day activities
of the program which will include a program coordination office in Saskatchewan. Product Care
will report to the advisory committee and subsequently to the governing authority.
Subject to successful negotiations, collection, transportation, disassembly, and recycling of
electronics waste will be managed through a contract with SARCAN. The contract with
SARCAN will be managed by Product Care on behalf of the program governing authority.
4.1 The advisory committee
A Saskatchewan advisory committee has been operating since November 2005 with
representatives from a broad range of stakeholders (see list at Appendix A). This committee has
been tasked with taking the necessary steps to develop this proposal and will manage the program
until a formal governance structure is in place. Actions to date have included approval of this plan,
the issuing and review of SARCAN statements of requirement for collection and recycling, and
the issuing and review of an RFP for program management services. The advisory committee
consists of representatives from national and local manufacturers, national retailers with a
presence in Saskatchewan, NGO’s, industry associations and government. Saskatchewan interests
have direct representation through the Saskatchewan Waste Reduction Council, SERM, and
Saskatchewan industry.

4.2 The formal governance authority

The advisory committee will cause a formal governance authority to be created. This authority
will assume responsibility for all aspects of the program and will include representation from
manufacturers, retailers, non governmental organizations, and government.

The preferred structure would see a not for profit Saskatchewan corporation created with a board
of directors representing all stakeholder interests. In that case, we recommend the board consist of
3 representatives from manufacturers appointed by EPS Canada, 2 representatives from retailers
appointed by RCC, two representatives from local Saskatchewan industry, one representative
nominated by SWRC, one representative nominated by Saskatchewan municipalities and one
representative nominated by the Saskatchewan government. All board members would vote with
the exception of the Saskatchewan government representative.

Should the advisory committee choose to recommend a different structure, we will request the
approval of Saskatchewan Environment.

Upon establishment of the formal governance authority we believe Saskatchewan interests will be
well represented on the board of directors and we will likely recommend that a separate advisory
committee is no longer required.
4.3 Management and administration
Following a comprehensive Request for Proposal process, the advisory committee selected
Product Care Association to manage the proposed program with a requirement to include a
significant Saskatchewan based management component.
Product Care is a not-for-profit industry sponsored association that currently manages
environmental stewardship programs for household special waste including paint, flammable
liquids, pesticide and gasoline on behalf of its members across Canada. Product Care has recently
been issued an approval to operate the Saskatchewan paint program.

Negotiations are underway with Product Care covering the following responsibilities:
    •   Management of the program.
    •   Identification, registration, and auditing of obligated first sellers.
    •   Collection and disbursement of fees through a process which ensures confidentiality of
    •   Program communications.
    •   Serve as an interface for the public and with parties contracted under the program.
    •   Preparing the public annual report.
    •   Defining the performance management targets for the program including the plan for
        continuous improvement.
    •   Overall day-to-day management of the program including liaison with Saskatchewan
        stakeholders and the Saskatchewan government.
    •   Management of contracts with the collection and recycling service provider(s).
    •   Setting and adhering to operating budgets.

4.4 Local program management
We are committed to a significant local program management component reporting to Product
Care. We will be seeking an individual or organization who can provide the following services:
Municipal relations
    • Maintain municipal awareness of program.
    • Respond to enquiries/complaints.
    • Develop promotional opportunities (e.g. distribution of program brochures with routine
Consumer relations
    • Respond to consumer enquiries about program including delivery of “hot line” function.
Retailer relations.
    • Maintain database of retailers of program products.
    • Maintain retailer awareness by written, telephone and store visits.
    • Store visits to identify brands.
First seller compliance
    • Assist program auditors in compliance reviews including site visits.
Collection system
    • Interaction with SARCAN management regarding ongoing program delivery including
         assistance with product definition issues.
    • Visits to depots to ensure program consistency.
    • Routine visits on behalf of program to processing sites.
    • Assist in vendor qualification audits.
Communication and education
    • Coordinate design and production of promotional materials including brochures, retail
         and depot signage.
    • Assist in website content maintenance.
    • Manage advertising function – identify options.
    • Public relations – interact with new media, develop and provide public service
    • management of office requirement.
    • arranging meetings.
    • program reporting.
4.5 Collection and recycling
The advisory committee has received a detailed response from SARCAN for the collection,
disassembly, and recycling services for the program. SARCAN proposes to:
    •   Utilize its current network of 71 depots to collect electronics waste material. Consumers
        will deliver waste material to one of SARCAN’s 71 depots where it will be segregated in
        e-waste containers.
    •   SARCAN will transport the material to consolidation centers.
    •   Material will be stored at the consolidation centers until sufficient quantities are collected
        to transport the material to selected disassembly facilities.

    •   The disassembled material will be returned to consolidation centers, segregated by
        commodity, and prepared for shipment to qualified recyclers.
    •   Material will be shipped to qualified recyclers for final processing and recovery.

SARCAN will disassemble the waste material to obtain maximum value from qualified recyclers.
Precious metals will be recovered wherever possible. We are committed to the recycling
hierarchy for e-waste material and maximizing diversion of designated materials from landfill.

5.0 Program details
5.1 Collection in all areas of the province
Designated waste electronics will be collected in all areas of the province utilizing the SARCAN
5.2 Recycling options for waste electronics, listed in descending order of preference
    •   Reuse: Reusing older products will be promoted through the communications program.
        The public will be informed of the importance of reuse and a variety of options for reuse
        will be recommended as the first and most desired option including support of charitable
        organizations. These recommendations will be consistent with our position that we do not
        export our end of life management challenges to less developed countries.
    •   Recycle: Recycling will be promoted as the final option for handling. Recycling will
        focus on recovery of base materials. All recycling will be completed by contractors who
        have been qualified under EPS Canada’s Recycling Vendor Qualification Program
        (attached as Appendix C).
5.3 The policies and procedures to be followed by any person processing waste electronics
SARCAN procedures will be followed by all persons involved in the collection, transportation,
and disassembly activities. SARCAN has created:

    •   An Occupational Health and Safety Manual for all aspects related to the safe handling,
        dismantling, and clean up of electronics.
    •   A training program and manuals for all individuals who will be involved in electronics
        waste processing.
    •   An Electronics Recycling Manual covering the dismantling of electronics.

The EPS Canada recycler vendor qualification standard will be followed by SARCAN and all
recycler subcontractors. This standard is included as Appendix C and covers such issues as
worker health and safety, prohibition of waste export to developing nations, and regular recycler

6.0 How the program will be funded
6.1 The environmental handling fee
Consumers will be able to drop off designated waste electronics at any SARCAN depot free of
charge. The program will be funded by an environmental handling fee remitted by the first seller
of designated products on all product sales. It is expected that most first sellers will choose to
make this fee visible to the consumer.

The fee will be set by product category, not a flat fee across all products, and will reflect the true
costs of managing that product. The fee will fund:
    •   Collection, Handling and Recycling.
    •   Communication and Public Education.
    •   Recycler Evaluations (excluding offshore evaluations).
    •   Administration Expenses (including board travel).
    •   Compliance and enforcement provisions required over and above government measures.
6.2 Setting the environmental handling fee
The environmental handling fee will be specific to product type and will reflect the true costs of
managing the program. The fee will be evaluated on an annual basis and will be adjusted, where
necessary, to ensure there is enough revenue generated to operate the program and maintain a
reasonable surplus, to ensure funds are not being over accumulated, and to ensure there is a
proper nexus between the fee and the services provided. To be harmonized with existing
Canadian waste electronics management programs, the program will consider program
commencement with the following fees:
    •   Personal desk top computer, including the central processing unit and all other parts
        contained in the computer: $10.00.
    •   Personal notebook computer, including the central processing unit and all other parts
        contained in the computer: $5.00.
    •   Computer monitor including the following types of computer monitor: cathode ray tube,
        liquid crystal display, plasma: $12.00.
    •   Computer mouse, including cables: See note 1 below.
    •   Computer keyboard, including cables: See note 1 below.
    •   Computer printer including the following types of computer printer: dot matrix, ink jet,
        laser, thermal and including any computer printer with scanning or facsimile capabilities,
        or both: $8.00
Note 1: Consideration will be given to implementing a fee on mice and keyboards or requesting
that the obligated first sellers of these products make an annual program contribution. The
treatment of such peripheral devices will be managed to minimize the administrative complexity.
Note 2: The EPS Canada national funding model and experiences in Alberta will be reviewed
with estimates specific to program costs in Saskatchewan to ensure that the above fees are
6.3 Funding flow
First sellers will remit fee payments based on net designated product sales (net designated sales
accounts for such things as product returns). The collected funds will be disbursed to pay for the
operation of the program.
6.4 Financing activities in advance of fee collection
Program development and implementation activities undertaken following passage of the
regulation and in advance of fee collection may be reimbursed from future program revenues,
with reasonable interest, to those organizations providing the services. Examples include:

     •   EPSC activities to create and manage the program plan, define the partner requirements,
         and negotiate contracts.
    •    All activities undertaken by the management /administrative organization.
    •     All activities undertaken by the collection and recycling partner(s) once selected
         including any initial collection and recycling undertaken in advance of fees being in place.
    •    Any direct contributions made by industry.

A procedure defining allowable expenses will be approved by the advisory council and
subsequently ratified by the governance authority including an appropriate time period for
payback and the formula for calculating interest.

7.0 Public education or public awareness aspects of the program, including tracking and
auditing mechanisms
The short time frame for initial implementation will limit the amount of public consultation and
public education. Our efforts will focus on two key public communication activities:
    •    Ensuring consumers are aware of the program including how and when they can send
         their products for recycling. This will include such activities as ensuring SARCAN
         depots have promotion material, selected media spots, establishment of a program web
         site, and call center services. SARCAN has provided a detailed communication proposal
         as part of their response to the advisory committee.
    •    Ensuring the first seller community has point of sale education material. Following
         program introduction, and based to a degree on the initial response from Saskatchewan
         consumers, a more detailed communications program will be developed.
The program will also implement a survey program sometime following program introduction to
test the consumer knowledge of the waste electronics program and to seek input on program
8.0 Quality control and assurance aspects including tracking and auditing mechanisms
The necessity for full program compliance requires a system to ensure that all first sellers are
registered and are in full compliance. Recyclers must be audited on an ongoing basis to confirm
their compliance with program waste management standards.
8.1 Auditing of obligated first sellers
A member auditing program will be implemented which will set guidelines and targets for the
first seller audit program including:
    •    Timing and criteria for initial audits of first sellers.
    •    Criteria for repeat audits depending upon remittance level, compliance records etc.
    •    Audit procedures .
8.2 Auditing of recyclers
A recycler audit program will be developed, most likely performed by independent consultants, in
accordance with the EPS Canada recycler vendor qualification standard. Activities will include:
    •    Recycler evaluation.
    •    Processor program audit.

    •   Waste tracking and inventory assessment.
    •   Downstream end processor review.
8.3 Performance measurements and continuous improvement
A system of management reporting will be developed within the first year of the program based
upon “key performance indicators”. These key performance indicators will include, but not be
limited to, system cost per tonne and per unit, administrative costs per tonne, quantity of
obligated material collected, and processing cost per tonne. A mass balance approach will be
taken to outlining the final disposition routes for all obligated materials.
The program will continuously review program improvements, both from an operational and
strategic perspective. Among other things we will review on an ongoing basis:
    •   The definition of obligated products to ensure we are current with changes in the
    •   Electronics waste management developments in other jurisdictions.
    •   Methods to reward, in the marketplace in an economically and efficient manner, those
        companies making environmental investments. This will include, but not be limited to,
        reviewing the option of sun-setting environmental handling fees at some point in the
A percentage of the collected fees will be devoted to continuous program improvement.

9. Program milestones
Negotiations are currently underway with both Product Care and SARCAN to agree on the
detailed program schedule elements. This schedule is being built around the following major
milestones and are dependent upon approval of the program plan by Saskatchewan Environment
no later than 28 February as indicated below:

1.Product management plan submitted                             01 February 2006

2. Product management plan receives SERM approval               28 February 2006

3. SARCAN negotiations complete                                       March 2006

4. Formal governance structure approved and in place                    April 2006

5. Obligated companies registered                                       May 2006

6. Program start up, including consumer fees                             June 2006

10. Products included at program startup
The program will begin with the products obligated by the regulation. To provide additional
clarity to obligated first sellers we recommend that the following expanded definitions of
obligated products be adopted as defined below (Note: Given the nature of our industry it will be
necessary to continuously monitor and upgrade program definitions to ensure full compliance and

Computer monitors: Products branded and marketed as computer monitors
Computers: Desktop computers (including Central Processing Units, mouse, keyboards, cables
and other components in the computer). This includes whole and incomplete desktop computers;
desk top computers acting as servers; notebook, laptop or portable computers. This does not
include PDA’s.
Desktop printers: A desktop printing device that is able to provide output on paper up to 8.5
inches wide. This includes stationary and portable desktop printers, networked and standalone
printers, desktop printers with scanning and fax capabilities and all related cables. This does not
include photocopiers, floor standing printers, point of sale printers, point of sale printer
mechanisms, label printers, mid range printers, wide format printers and plotters, photo
developing equipment, offset printing presses, and any other printing device that does not meet
any of the above mentioned categories.
10.1 Product phase-in
Televisions will be added to the program in accordance with the regulation.

                                       Appendix A

                            The Saskatchewan Advisory committee
                                Established in November 2005
           to respond to the Saskatchewan Waste Electronic Equipment Regulations

Nick Aubry, Sony
Peter Balyk, Canon
Dave Betts, EPS Canada
Rebecca Brown, Dell
Victor Chang, Saskatchewan Environment
Christa Copeland, Best Buy
Sean DeVries, Panasonic
Frances Edmonds, Hewlett-Packard
Joanne Fedyk, Saskatchewan Waste Reduction Council
Jim Innes, Epson
Jay Illingworth, EPS Canada
Rachel Kagan, Retail Council of Canada
Paul Labbe, VCOM, Saskatoon

                                           Appendix B

Corporations and organizations supporting the Electronics Product Stewardship Canada proposal
to develop a product management program for electronics waste dated 01 February 2006.


Best Buy
Mind Computers
Northern Micro

Associations and organizations

Electro-Federation Canada

Electro-Federation Canada (EFC) is a national, not-for-profit industry association. Together, its
six councils represent over 300 member companies that manufacture, distribute, and service
electrical, electronic, and telecommunications products, contributing over $50B to the Canadian

Electronics Product Stewardship Canada

Electronics Product Stewardship Canada is a not for profit organization established by Canada’s
leading information technology and electronics manufacturers to work with governments as end
of life stewardship programs are considered.

Information Technology Association of Canada

ITAC is the voice of the Canadian information and communications technology industry.
Together with its affiliated organizations across the country, the association represents 1300
companies in the information and communications technology (ICT) industry in all sectors
including telecommunications and Internet services, ICT consulting services, hardware,

microelectronics, software and electronic content. ITAC's network of companies accounts for
more than 70 per cent of the 566,000 jobs, $130 billion in revenue, $5.2 billion in R&D
investment, $20.7 billion in exports and $11.5 billion in capital expenditure that the sector
contributes annually to the Canadian economy.

Retail Council of Canada

Founded in 1963, Retail Council of Canada is the Voice of Retail. RCC is a not-for-profit
association whose more than 9,000 members represent all retail formats, including
national and regional department stores, mass merchants, specialty chains, independent
stores and online merchants.

               Appendix C

Recycler Vendor Qualification Standard


Description: the product management plan filed by SWEEP