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Selecting an Electronics Waste Recycler by pmv64896


									   Selecting an Electronics
Tips for local governments and small businesses
             US EPA Region 5
             January 19, 2010

This presentation has been provided as part of a U.S. Environmental
Protection Agency webinar. This document does not constitute EPA policy.
Mention of trade names or commercial products does not constitute
endorsement or recommendation for use. Links to non-EPA web sites do not
imply any official EPA endorsement of or a responsibility for the opinions,
ideas, data, or products presented at those locations or guarantee the validity
of the information provided. Links to non-EPA servers are provided solely as
a pointer to information that might be useful to EPA staff and the public.

The remarks made by Chris Newman are made in his personal capacity and
do not necessarily reflect the official position of the USEPA or any other
federal agency.

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Why evaluate an electronic waste recycler
Information about the industry; regulations,
standards, and more
Tools for selecting a recycler

Why Evaluate an Electronic Waste
Reduce liabilities
Verify environmental
   Can they demonstrate
   what they do?
   Confirm they have
   permits and certifications

Why Evaluate an Electronic Waste
Identify needed services
  Support services
  Cost off-set
Develop long term
  Easier to recycle
  equipment in the future
  Reduce equipment in
  storage to maximize reuse

Why Evaluate an Electronic Waste
Trust, but verify
   Contracting procedures
   may not address
   Good performance
   reduces your
   environmental and
   information liability

Information about the
 electronics recycling

  About Electronics Recyclers
An electronics recycler can utilize a variety of
processing methods, including:
   Brokering (matching buyers and sellers)
   Resale of whole units (selling of whole units)
   Remanufacturing (refurbishing equipment)
   Demanufacturing (disassembling into parts and
   Material recovery (physical separation to capture plastics,
   metals, glass, etc.)
   Material processing (shredding and grinding)
   Donation (school systems, non-profit organizations, etc.)

  About Electronics Recyclers
Where will the recovered materials go?
Most reuse markets are export
  Large for-profit and non-profit markets are in
  developing countries
Many recycling markets are export
  Strong foreign demand for raw materials, much
  manufacturing is outside the U.S.
  The U.S. has no copper/precious metal smelters for
  this material
  CRT glass furnaces are located off shore
  Plastic recycling markets are almost all overseas 10
 Electronic Waste Regulations
Generally, most e-waste in the US is:
  Non-hazardous (especially if recycled)
  Non-waste if recycled
Some electronics can be classified as hazardous waste
  Color cathode ray tubes (CRTs) consistently fail toxicity testing (TCLP)
  for lead
  Other electronics may or may not be hazardous, depends on many factors
Several hazardous waste exemptions and exclusions apply to
encourage reuse and recycling
  The Cathode Ray Tube Rule
  Exemption for whole and shredded circuit boards
More information on waste regulations:

 Electronic Waste Regulations
When do federal hazardous waste regulations apply?
   If the waste is generated by a non-household
   If it is generated at more than 220 lbs/mo
   If the waste has a hazardous waste ‘characteristic’, such as
   failing toxicity testing (TCLP)
      Some laptops, cell phones, etc.
   And if the waste is sent for disposal
Recycling is still encouraged!
   More information is at:

 Electronic Waste Regulations
Cathode ray tubes
  Exemption from federal hazardous waste management
  standards when tubes are destined for recycling or reuse and
  the rule is followed
  Notification and consent requirements for CRT exports
      Notification for reuse
      Notification and consent of receiving country for recycling
      Notifications posted on the rule website below
  If going to disposal, regular regulations apply
  Includes storage and management requirements
  CRT Rule website:

              State Regulations
Regulations can vary by state, and can be similar to the
federal rules
   Management and disposal
      Specific landfill disposal bans for electronics
      Hazardous waste rules still apply
      Electronics are universal waste in some states
   Mandatory take-back programs
      Manufactures to collect and recycle equipment from consumers
      Businesses may not be able to participate in consumer programs.
   Check you state for details, state rules can differ from federal
Some communities have regulations as well
   Illegal dumping laws
   New York City’s product stewardship laws

      Regulation of Recyclers
Varies by state and recycler practices
     If material is not sent to disposal, there maybe few
     environmental regulations
Some states have:
     Permitting requirements for e-waste recyclers
     Registration requirements to participate in state recycling
        Investigate what registration/permitting requires
     Waste, air, and water permit requirements, based on the
     recyclers practices
Even if they are registered, verifying practices helps you
to understand the services you are buying

                           Data Security
Data security may fall in several areas:
    Medical, privacy, financial, confidential business information
    Understand the information and the risk
Data security can be managed by:
    Data wiping
    Physical destruction
    Paper in printers, CDs
    Handheld devices, phones and PDAs
    Memory in copiers and faxes
Data security can be included in electronics recycling contracts
    It is also possible to do this in-house
Data security resources
    ‘Do the PC Thing’:
    National Institute for Standards and Technology Special Publication 800-88, Guidelines for
    Media Sanitization:

Recycler Performance Standards
Responsible Recycler Program (R2)
  Developed by group of OEMs, recyclers, governments and
  environmental groups
  Specific to the electronics recycling industry
  Has several focus materials that are important
     Lead, mercury, batteries, PCBs
     Includes worker health and safety, site management and closure
     Domestic and foreign downstream due diligence
  Third party audited
  Find groups certifying recyclers at:
  More information is at:

  Recycler Performance Standards
ISO 14001
      Goal to reduce pollution and waste from businesses
      Third party verified
      Incorporates ISO 14001 for environment, ISO 18001 for health and
      safety, SA 8000 for social accountability
      Has specific electronics industry performance requirements
      Developed by Basil Action Network
Certification to standards can be expensive, some recyclers may
follow a standard but not have the certification
Recyclers can provide services without any certifications
Approved Electronics Recyclers
U.S. EPA Approved
     U.S. EPA doesn’t approve recyclers for their practices
     An EPA ID # is not an approval of a recyclers practices
State Approved
     Some states may issue approval
     Some states register or permit recyclers
State mandated recycling programs may require registration
     Check with the state to find out what registration involves
     If you are not recycling something as part of the state program, the registration
    may not be necessary
“Certificates of Recycling”
     The recyclers certification that the material was received and properly managed
     Provides information for record keeping of each shipment
     Does not absolve the client or recycler of environmental liabilities in the event of

    Selecting an
Electronics Recycler

         Selecting a Recycler
There are several steps to
shopping for recycling
services                                  Select

  Identifying what you need              Verify their
  Learn what recyclers can
                              Learn what recyclers can provide
  Verifying their
                                    Identify your needs
  Select the recycler

     Identifying your needs
Data security           Learn more about the e-
Where does material       waste recycling industry
end up                    EPA’s e-waste web site:
Requirements on
reuse or resale
Logistics and support
                          Institute of Scrap
                          Recycling Industries e-
                          waste site:


Learn what recyclers can provide
Due Diligence – The process of examining a recycler to learn about their processes, and
make sure that it’s what you want done
Identifying recyclers is a two step process
         Learning the services provide
         Onsite reviews to understand and verify
Begin with a broad search
         Marketing materials
         References from others
         Phone book/internet
         Due diligence reviews others have done
         Recycling association membership lists
         State environmental agency lists
         IT manufactures and vendors
         Certifying groups, ex. ANAB
         Manufactures/retailer programs
Make contact with recyclers to learn about their business

Learn what recyclers can provide
Resources - EPA’s Plug-in to eCycling Guidelines:
For materials that will be recycled
       Are reuse, refurbishment, and recycling techniques used to
       the fullest extent possible?
       Is incineration and land disposal minimized?
       Are legal requirements pertaining to transport, processing,
       and management complied with?
       If exporting are US and importing countries requirements
       complied with?
       Is attention paid to materials of concern?

Learn what recyclers can provide
Resources - EPA’s Plug-in to eCycling Guidelines:
For materials that will be reused or refurbished:
   Are materials screened for legitimate reuse?
For materials that will be recycled:
   Do business records demonstrate downstream processing?
   Are facilities permitted and have an environmental management system?
For the facility and others they use
   Is there a facility plan for occupational and environmental health and
   Is there an emergency release plan?
   Do they track key parameters, such as input/out put and releases?
   Is there an adequate plan for closure?
Learn what recyclers can provide
Resources – The Federal Electronics Challenge ‘Checklist for the Selection of Electronic
Recycling Services’:
Can be used to ask the recycler questions, or evaluate information you’ve gathered.
     Basic business information
     Services provided
     Regulations that apply, and compliance history
     Procedures for environmental management, and recycling processes
     Information on down stream processors, and export
     Disposal practices
     References that have used their services
Then evaluate who you might want to work further with. Do they:
     Provide the services you need
     Claim responsible management
     Have a pricing structure that fits your budget
     Meet other needs that are important to you

                   On-Site Review
FEC onsite review tool -

Guides a recycler visit by providing
information on
    Suggested topics to talk about
    What to look for
    Programs they may participate in
    Links to other resources that can support
    your review
                   On-Site Review
What to look for during a review
   General facility facts:
       Is the facility as they described it?
       Does the balance of material going in compare with what goes out?
       Do they have or need an EPA ID number?
       Do they have certifications? (Recyclers can provide good services without
       Is the facility clean and orderly, is material stored and managed to protect it’s
       Does the facility strive to maximize reuse and refurbishment, and minimize
       incineration and landfilling, within the facility?
       Do they need permits? Electronics are not necessarily hazardous waste, and
       they may not need a permit for their work.
       How is data security managed? Sanitization and disposal are different.

              On-Site Review
Electronic waste outputs:
   Does it go to recipients that maximize reuse and refurbishment, and minimize
   incineration and landfilling?
   Is equipment sent for reuse tested? If not are recipients able to test and
   refurbish non-working equipment?
   Do they know who their downstream processors are, and what their practices
Documentation and Records:
   Documentation will vary depending on the recycler and their practices.
   Recyclers that directly export CRTs should have records of their notification
   to EPA, as well as records for their shipments. If downstream vendors are
   exporting CRTs, ask for their information.
   Processed CRT glass does not require export notification.
   Ask about the legality of other materials such as equipment containing
   mercury, PCBs, batteries, or circuit boards.
   If they are can’t provide the documentation during the visit ask them to send
   it to you as soon as possible

                  On Site Review
  FEC onsite review tool -

  Plug-in Environmentally Sound Management Guidelines -
  State specific examples
       Wisconsin -
       Georgia –
       State recycling programs may have specific requirements
            Check with your state environmental agency

            Select Recycler
Select the recycler:
  Compare recycler reviews
  Compare services provided
  Price, remember free is not always the best value
  Other factors?
Set up your contract
  Specify services
  Any cost off-sets from reuse
Monitor for performance

       Managing Future Waste
Reduce the amount of electronics you need to manage
   Purchasing EPEAT – Electronics Product Environmental Assessment
   Tool –
       Greener desktops, laptops, and monitors
       Manufactures can increase the ratings by offering take-back of equipment
   Add life-cycle management as an item in your purchasing contracts
       To manage the equipment you are replacing
       Add options for other types of equipment
   Examine systems that don’t require as frequent refreshes
       Cloud computing
       Alternative operating systems

      Contact Information
Chris Newman
Materials Management Branch
U.S. EPA Region 5
Chicago, IL


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