Overview of Electronic Device Recycling Issues & Solutions

July 23, 2009Anne Peters, Gracestone, Inc.

With help from Kristyn Rankin, Dell

Overview of Electronic Device Recycling Issues &

Solutionsfor the CO Electronic Device

Recycling Task Force

Topics Covered

• Nature & size of problem, CO data• History• How e-scrap is recycled• Costs• How other states have tackled this • Other important issues to track

What is electronic waste?

Obsolete, broken, unwanted, and used electronic equipment.

How many types of electronics are in your home?Your office?

Why are scrap electronics a problem in CO?

Why is it a problem?• Computers double in speed and

capacity every 18 months• Millions tons of scrap electronics

discarded annually in the US• Electronics contain hazardous wastes

that can pollute the environment & create liability for some generators

• Costs to local governments

Size of the Problem

• How much electronics are used & discarded each year?

US ColoradoUnits/year becoming obsolete 400,000,000 6,500,000Units in storage 3,000,000 49,000Tons/year e-waste generated 235,000,000 3,800,000Source: EPA estimates

Estimated Number of CRTs in Colorado

-

2,000,000

4,000,000

6,000,000

8,000,000

10,000,000

12,000,000

1990 1992 1994 1996 1998 2000 2002 2004 2006 2008 2010

Monitors f rom CII

Monitors f romHouseholds

TVs from CII

TVs fromHouseholds

CDPHE 2004 Study by Gracestone

Electronics Actually Recycled• 7,700 – 8,500 Tons in 2006

Source: Gracestone, Inc. study for CDPHE HMWMD, 2004 & for CDPHE 1/08

Tons of Recycled Electronics in CO, 1999-2006

40 81 26

1,274

3,301

6081,254

8,100

01,0002,0003,0004,0005,0006,0007,0008,0009,000

1999 2000 2001 2002 2003 2004 2005 2006

Fate of Obsolete CRTs in Colorado

-

200,000

400,000

600,000

800,000

1,000,000

1,200,000

1,400,000

1990 1992 1994 1996 1998 2000 2002 2004 2006 2008 2010

Recycled CRTsStored CRTsLandfilled CRTs


The environmental risk:Computer Component Hazardous Material

Monitor Pb in glass

Printed circuit boards Pb, Cr, Cd, Hg, As, Ag, CCl4

Batteries Lead, cadmium, mercury, lithium

Flat Panel displays Mercury

Plastics Brominated Flame Retardants (PBDE, PBB)

Older circuit boards (early 80s) PCBs

Pb Risk in Context: EPA Landfill estimates (‘95)

• Pb Acid storage batteries 64%• CRTs (TVs & monitors) 29%• Other electronics 1%• Glass & ceramics products 3%• Plastics 1%• Other products 1%

Potential Toxics in Landfill from CRTs(Preliminary Results)

-

2,000

4,000

6,000

8,000

10,000

12,000

14,000

16,000

1990 1992 1994 1996 1998 2000 2002 2004 2006 2008 2010

Tons

PhosphorChromiumBariumPlasticsLeadLeaded Glass


TCLP Test Data:Anything with a chip…

• Research: many electronic devices with printed circuit boards possess a reasonable likelihood of exhibiting the toxicity characteristic for lead (and other metals).

• Results indicate that CPUs are likely to be hazardous waste, too.

• Also – cell phones, VCRs, PDAs, iPods, TV remotes, smoke detectors, etc.

Townsend et. al. 2002, 2003

Toxic chemicals & your body:

source: Silicon Valley Toxic Coalition

• Mercury – damages brain, kidneys, fetus; travels easily in the food chain– PBT - persistent, bioaccumulative, toxic

• Cadmium – damages kidneys (PBT)• Chromium VI – damages DNA• Toners – carbon black - respiratory

problems; may be carcinogenic• BFRs – unknown impact; found in

human tissue worldwide

History of the Issue in CO• 1998-9: 1st e-waste collection event attempted in

Boulder County– but end-market issues came up – 1st study

• 2001: OEMC Task Force on electronics recycling• 2000: CO state legislature enacted legislation on

creating the CO CRT Recycling Pilot Project:– To educate business and residents– To help build the infrastructure for better recycling– Project of CDPHE’s HMWMD 2003-2005– Educated hundreds of stakeholders; website; pubs; report

• 2003: E-waste classified as Universal Waste by CO• 2000 to Present:

– Healthy growth of e-waste recycling industry– Many local gov’ts, businesses, nonprofits & manufacturers,

collect e-waste– 11/08: 60 Minutes expose of CO e-cycler

Denver: Dell collected 275 Tons of e-scrap in epic Memorial Day 2003 event.And the need continues…

Residential Collection - Free Branded + Free with Purchase (Dell)ReConnect Partnership (Dell-Goodwill)Staples (Dell)

Waste Management (Sony +)SamsungMRM

Some Manufacturer Programs Currently Available in Colorado

Nat’l & Int’l History• 2002 - 05: European Union leadership

– WEEE & RoHS Directives 2005• 2002 - 04: NEPSI effort

– Effort toward a national solution failed• 2002: BAN & Greenpeace expose shocking practices in

China – problems continue in Africa & China to present• 2000’s: Big global economic growth in past decade

– Fueled demand for metals, plastics– Rise in prices for commodities spurred industry growth– Commodity market crash 10/08 hit e-scrap industry hard

• 2005: CA 1st law passed (ARF); 2006: Maine (PR)• Now 19 states + NYC have laws (all but CA are PR)• E-waste federal law 2009?

– Research $$– Export ban

Responsibility for e-waste

• Electronics are hazardous waste if sent for disposal – Households are exempt– E-waste is managed as Universal Waste

• It is illegal for business to dispose of hazardous waste in landfills

• If electronics are not disposed, they are not regulated as haz waste

• See CDPHE Compliance Bulletin

Working or non-working?

Put in trash:Regulated as hazardous waste. ILLEGAL

Pay for or be paid by recycler or broker to

take equipment to resell or refurbish.

Not regulated as hazardous waste.

Pieces and parts from refurbishing or repair are put in trash:

Regulated as hazardous waste.ILLEGAL

If working…

Donate for reuse

Not regulated as hazardous

waste.

If not working…

Donate to nonprofit for refurbishingNot regulated as hazardous waste.

Send for diagnosis and

repair.Not regulated as hazardous waste.

Is it waste or not? Unwanted electronics equipment owned by a business.

potential CERCLA liability

Costs to Manage E-WasteFor generators• $0 - $8 - >$25/unit for

residents when charged at d-o’s & events– Varies with type of

productFor processors• $.15 - .50/pound

– Varies with type of processing, etc.

State programs• $.30 -.50/pound• Varies depending on

– Targets vs. no targets– Environmental

standards for e-cyclers

How E-waste is ManagedFirst it is collected, then:

Source: Gracestone presentation, E-Scrap conference 2008

Equipment refurbished/resold for reuse as originally intended

(i.e., CPU remains a CPU)

Incineration for energy recovery

Equipment stays in the market with minimal additional resource consumption,

product life-cycle is extended

Waste Minimization Hierarchy Planetary Benefits

Components and parts refurbished/resold for reuse as

originally intended (i.e., CRT into a new TV)

Components stay in the market with some additional resource consumption, creates jobs in

de-manufacturing

Component materials salvaged as scrap metal,

plastics, glass

Raw materials stay in the market with additional

resource consumption, but prevent re-mining of virgin

metals and thereby conserves natural resources

No materials remain in the market but the BTU value of

the material is converted into energy

Landfill disposal None

Recyclable PlasticsCarcass

Fan shroudKeyboard

Front Bezel and chassisBattery case

Ink and Toner Cartridges

Recyclable Scrap MetalHard Drive

Metal platesScrews

Housing and framesPower supply units

Recoverable Precious MetalPrinted Circuit Boards

WiresBattery cores

Recyclable GlassDisplaysTypically Disposed of

Unrecyclable battery cores (typically incinerated)Residual ink and toner remaining in cartridges (typically incinerated)

Plastics UsesPlastic pellets used as feedstock for

molded plastics manufacturing

Ferrous Scrap Metal UsesTypically blended with virgin

metals and formed into steel parts (e.g., construction steel)

Aluminum Scrap UsesReformed into new aluminum

parts (e.g., auto parts)

Precious Metals UsesSmelted to recover copper, gold,

palladium, platinum, silver, cadmium, etc. which are returned to the market

as commodities

Glass UsesCullet glass is typically cleansed of

metals and used as feedstock for glass manufacturing

Cardboard and PaperPackaging Manuals

Cardboard and Paper UsesReused as packing and reprocessed

into new paper and cardboard

Primary Recoverable Materials Materials Uses

Company AIncoming Material

~ 8 mil lbs.__ employees

Accepts all consumer electronics

As of 4/2/08 was 80% recycle-20% recycle. As of

8/25/08 now is about 50%-50%.

REUSE, REFURB & RESALE: No resale of CRTs. Will resell working LCDs. Test W/NW – all parts and components. Only sell P4 & G5. Their downstream includes vendors buying non-working units which those companies refurbish.

RECYCLE: Non-working units and parts to recycle.

Monitors and TVs

CRT tubes

De-manSystems

Hig

h-gr

ade

Boa

rds

Low

-gra

de

Boa

rds

For smaller CRTs: Face & funnel separated with hot wire into shadow mask,

funnel, panel glass streams.

To China through Company C

XYZ Refining

CA

Mercury processor A

Arizona

All

Batte

ries

Plas

tics

Wire

s &

cabl

es

Company Amapping its process & downstream

As of 8/27/08Keep suppliers confidential from one another

Collection Events

Corporate Customers

Lapt

ops

& co

mpu

ters

LCD

D

isas

sem

bly

Mon

iitor

D

isas

sem

bly

Baler

Hg

Lam

ps

Battery Co 2California

Local Metal Co

California

BIG CO. RefiningCanada

Get documentation of transactions



Three tiers here is not ideal.

CRT recycler in OH

For larger CRTs (mostly TVs): Casing removed &

whole tube shipped

Recycler C in Mexico

Laptops

Work-Not work?

Working, >P3 goes to Resale

Co. B

Not working – goes to vendors who do parts salvage like Recycle Co. A

Various components –circuit boards, drives, etc.

Work-Not work?

Working, sold through

various online

sources

Smaller units of various,

Not Working

Shred Boards

Manual disassembly

of non-working

equipment

Batteries

RBRC, & 2 other battery co.

India

Malaysia?

© Gracestone, Inc.

E-Cycling Business Models & Material Flow

Company G Incoming Material

~ 1.5 mil lbs.12 employees

Accepts all electronics

90% to reuse, 10% recycle

Test whole units

RECYCLE: Non-working units and parts to recycle.

Monitors and TVs

CRT tubes

HD Destruction, Manual De-

manSystems

Saving them, will send to OECD

smelterOnly expect to ship

1x/year

Haz Mat co that processes

this stuffAsset Recovery-focused company G

mapping its process & downstream 7/11/08

Corporate __% No residential

No outlet

Leftover components &

parts

Local Metals Co

Laptops & CPUs are repaired, refurbished.

Contract mfgrs material ?%

“destruction”

Working units: Sold

Non-Working: Storing CRTs

for shipment to OH CRT glass

processor

Work/Not Work?

Not Working? Broken into parts

Overseas

Sales of new components from contract

mfgrs.

Not tested

Sold on BrokerForum.com

If not sold in 60 days, sent to

recycle

Facility in State 1

Opening one in State 2

90% are Working -sold on web (Ebay)

or at local shops, 1-2 at a time

Work/Not Work?

© Gracestone, Inc.


Company AIncoming Material

xx TPY # of employees

Accepts all consumer electronics

About 20% for resale, 80% to

recycle

RESALE: Monitors > 5 yrs failed. < P3 failed.

Test monitor for W/NW. PCs – test, wipe HD,

make workable machine. Anything sold to overseas brokers?

RECYCLE: Non-working units and parts

to recycle

Monitors and TVs

All recycle equipment to either Co 1

or Co. 2

Company 1(received xx lbs. in ’07 from Company

A)

Company 2(received xx lbs. in

’07

De-manSystems

Band on outer edge of tube removed. Andela

crusher sorts sheet metal, glass

To China through Company D. Looking

for US processor

Sell to Company Y

Sell to Company X

Hi & lo-grade board blend to smelter E in

Asia

Low grade boards to smelter F in Canada

Low grade boards shred & ship to Company C or

Company G - smelters

Sample SchematicCompany A’s downstream

Provide detail on

downstream activities

© Gracestone, Inc.


Policy ParadigmsWho should pay for electronics recycling?

Two dominant models1. Producer Responsibility (or, Extended

Producer (EPR), Product Stewardship, or Shared Responsibility)– All involved in product life cycle shares

responsibility for health & enviro impacts from production, use, & EOL management

– Brand owner should pay for collection andrecycling (“cost internalization”)

– Will lead to increased design for recycling, reduced toxicity lower recycle costs

– Little or no involvement from government– Generally, no out-of-pocket costs to consumers

• Most popular legislative model now

2. Advanced Recovery Fee• Point-of-sale fee collected and run by gov’t or

mfgr-managed 3rd party org.– California, Alberta

• 3rd party org. or gov’t pays collectors and recyclers

• No charge to consumer at end of life• Based on principle of shared responsibility

– sharing costs along the value chain– customer sees the fee paid for “recycling” service

• Not being introduced any more

Policy ParadigmsWho should pay for electronics recycling?

Thoughts on Various Methods of Financing

•• Visible fees (ARF)Visible fees (ARF)–– Consumer educationConsumer education–– Engage others along product chain Engage others along product chain –– Little incentive for designLittle incentive for design--forfor--environmentenvironment

•• NonNon--visible fees (PR visible fees (PR –– state usually state usually involved)involved)–– Facilitate compliance Facilitate compliance –– Flexibility to manage through sales chain Flexibility to manage through sales chain

•• Cost internalization (PR only)Cost internalization (PR only)–– Strongest signals for DFEStrongest signals for DFE–– Significant flexibilitySignificant flexibility

Individual vs. Collective Systems

•• Individual responsibilityIndividual responsibility–– Supports DFE objectivesSupports DFE objectives–– Linkage to brand Linkage to brand –– Supports marketSupports market--driven system driven system –– Administratively more complexAdministratively more complex–– Requires more attention to performance goals Requires more attention to performance goals –– Concern with duplicative infrastructure Concern with duplicative infrastructure

•• Collective responsibilityCollective responsibility–– Addresses historic and orphan wasteAddresses historic and orphan waste–– Ease of compliance Ease of compliance –– Lack of DFE incentiveLack of DFE incentive–– Subject to competition/monopoly Subject to competition/monopoly

19 States have passed E-Waste Recycling Laws

(plus New York City)

AK

MT

WYID

WA

OR

NVUT

CA

AZ

ND

SD

NE

CO

NM

TX

OK

KS

AR

LA

MO

IA

MNWI

IL IN

KY

TN

MS AL GA

FL

SC

NC

VAWV

OH

MINY

PA

MDDENJ

CT RI

MA

MEVT

NH

HI

Producer responsibility law passed

18 states plus New York City

ARF (Consumer fee) laws passed.

1 State

Source: Electronics TakeBack Coalition

13 More states are trying to pass e-waste laws:States with e-waste recycling laws plus bills introduced in 2009

AK

MT

WYID

WA

OR

NVUT

CA

AZ

ND

SD

NE

CO

NM

TX

OK

KS

AR

LA

MO

IA

MNWI

IL IN

KY

TN

MS AL GA

FL

SC

NC

VAWV

OH

MINY

PA

MDDENJ

CT RI

MA

MEVT

NH

HIProducer responsibility law passed



1 State

E-waste bill introduced in 2009

Source: Electronics TakeBack Coalition (June, 2009)

Producer Responsibility Laws: Differences in Important Details

• Scope of products covered• Filing and approval of plans, registration fees for mfgrs.• Recycling standards• Who is covered

– Just consumers? Small local gov’ts? School districts? Very small businesses?

• Use of goals or “drivers” – Incentives for participation to drive high collection volumes and

prevent illegal dumping or other problems• Role of state government• Requirement for ESM e-cycling or not• Design for environment requirements

– Toxic material restrictions• Green electronic purchasing requirements for state

Producer Responsibility State Laws

How do different producer responsibility laws drive high collection volumes (or not)?

No collection drivers.Manufacturers decide what they want to do.

Partial collection drivers Bills with strong drivers for high collection

Several bills: Companies must simply have a program. No specific requirements.

Local Governments Manage Collection Producers pay for recycling, but not always for collection.

Return Share BillsCompanies are assigned a “return share” based on the portion of their products coming back in all collection activities.

Bill motivates collection of e-waste in various ways with some kind of performance measures or convenience metrics.


States passing laws with “Drivers” for high recycling volumes (in light green)

AK

MT

WYID

WA

OR

NVUT

CA

AZ

ND

SD

NE

CO

NM

TX

OK

KS

AR

LA

MO

IA

MNWI

IL IN

KY

TN

MS AL GA

FL

SC

NC

VAWV

OH

MINY

PA

MDDENJ

CT RI

MA

MEVT

NH

HILaws with strong collection drivers

5 states

Producer responsibility law passed



1 State


Ways to Drive More CollectionThree ways states are driving increased recycling:• Convenience: Mandate how convenient collection must be (Site

in every county, plus one site in each city for 10,000 or more)– Washington (started in January 2009)– Oregon (started in January 2009)

• Market Share Goals: Mandate collection goals tied to what companies sell in the state– Minnesota (started in Aug 2007)– Indiana (starts April 2010)

• Escalator: Set initial goal, then mandate escalator from year to year– Illinois (starts Jan 2010)

Possible Partial Collection Drivers

States where local government manages collection

• Maine (started in 2006)• Connecticut (starts July)• North Carolina (starts 2010) - Collection also done by

retailers, non-profits

States with Return Share bills (and no other drivers)• New Jersey (starts 2011)

• Rhode Island (started Feb 2009) – has some market share requirement for TVs.

E-Waste Collection Volumes Under State-Mandated Recycling Programs

Monitors TVs Computers Laptops

TOTAL COLLECTED in

PoundsNotes Population

Collection rate per capita

California(Includes

products from business)

Year 1 2005 not covered 64,809,498 36,457,549 1.78

Year 2 2006 not covered 127,979,144 3.51

Year 3 2007 not covered 185,190,929 5.08

Year 4 2008 not covered 215,500,079 2008 data incomplete

5.91

Maine Year 1 2006 1,205,726 2,954,848 not covered Laptops numbers

under monitors

4,160,574 1,321,574 3.15

Year 2 2007 1,393,775 3,290,682 not covered 4,688,552 3.55

Year 3 2008 1,421,284 3,853,020 not covered 5,274,304 3.99

Minnesota Year 1 2007 -2008

No breakdown. MN program also collects printers,keyboards; fax machines; and DVD players

33,100,000 5,197,621 6.37

Washington Year 1 Q1

2009 Jan- Apr

4,176,758 6,729,154 1,234,126 Under computers

12,140,038 Data from Jan-Apr only

6,468,424 5.63

% 33.0% 57.1% 9.9% 35,663,680 Annualized

Oregon Year 1Q1

2009 Q1 1,644,534 2,750,767 543,240 Under computers

4,938,541 Data from Q1 only

3,747,455 5.27

% 33.3% 55.7% 11.0% 19,754,164 Annualized lbs per person

Collection Results from State Programs


California* Maine Minnesota Washington Oregon

Year 1 1.78 3.15 6.37 5.68 5.27

Year 2 3.51 3.55

Year 3 5.08 3.99

Year 4 5.91

Pounds Per Person Collected in State Programs

* CA program includes e-waste from businesses


Federal Legislation

What about a federal take back bill?

Detailed Information

OregonWashington

OregonHB2626 (June ’07)

• Free – covers computers, monitors, and TVs– Free recycling of CEDs to anyone bringing 7 or less

items to a participating collection site at one time. – Collection sites may accept > 7 items from

households, small businesses and small 501(c)(3) nonprofits with 10 or fewer employees.

– Residents can choose to take their electronics to an Oregon E-Cycles site for recycling, or to another site, or dispose of unwanted electronics

• LF disposal ban on PCs & TVs 1/1/10

OR - Manufacturers• Must label CEDs with visible, permanently affixed brand,

& register brands with DEQ. • Must pay a registration fee

– Covers DEQ’s admin. costs to implement Oregon E-Cycles.• Must participate in a recycling pgm.

– Either pay a recycling fee to participate in DEQ-administered State Contractor Pgm or,

– If are big, can implement & pay for own statewide program– Either way, they are paying to cover costs including collection,

transportation, & recycling of collected devices & mgmt. of their program.

• If fail to comply with req’ts can’t sell products in or into Oregon. – Law provides DEQ with authority to enforce these req’ts.

• May choose to provide add’l “premium services”– Could include mail back or pick-up services. – Can charge a fee.

• Fees set in statute

OR - Manufacturers• OEMs register by 1/1 yearly; reporting req’ts.

Details:– Pay annual registration fee of $15-40,000, (linked to prior

yr. sales) – $$ to state’s “Covered Electronic Devices Account”– Meet return share goals or pay fee– By 1/1/10, OEMs submit a plan to state. Plan details

include:• Program finance & management• Collect, transport & recycle of all CEDs• Advertising, promotion, education statewide (and on a regular

basis)

• Must establish at least 1 staffed collection site for cities > 10,000

OR - Retailers• Must provide customers buying new CEDs w/ printed

info. about Oregon E-Cycles at point of sale.• Must only sell brands listed on DEQ’s manufacturer

compliance list as “pending” or “compliant” andproducts are affixed with a permanent and visible brand label.

• If brand is not listed, it may not be sold in or into OR. Sales restrictions apply only to brands of CEDs, not to other electronics/products a manufacturer may make. – Applies to all sales methods (retail, catalog, phone & web) – Sale or reused or refurbished products exempt from requirements.

• DEQ - ensures that retailers are providing POS info. to customers & only selling registered brands.– The law provides DEQ with authority to enforce.

OR - Recyclers• Recyclers who are contracted with mfgr. plans as

part of OR E-Cycles must meet DEQ EMPs• Contracted recyclers - reimbursed by pgm they

contract with • Those not contracted perceive unfairness b/c:

– Mfgrs. not req’d to select everyone to be in pgm, &– Feel given a choice between free or paid recycling,

customers will choose free. • However, because OR E-Cycles doesn’t provide free

recycling to large businesses, schools or other entities other than those clearly defined (households, small biz, NPs), there’s still material to be recycled & they may charge for CEDs & other products not covered under law.

OR – Dept. Enviro Quality• Oversees program including:

– Compliance and enforcement – Establishes fees to be paid by manufacturers– Education and outreach– Oversees the state contractor program– Establishes EMPs

• Majority of administrative costs are covered through the manufacturer registration fees – “(at least this is my understanding of how it is

supposed to work).” - Jan Whitworth, OR DEQ

Washington(March ‘06)

• Manufacturers provide free recycling services at no charge to owner

• TVs, monitors, desktops, laptops • Started 1/1/09• Covers HHs, charities, schools & sch. districts, small biz

(<50 employees), small govt. (special purpose districts, city govt. w/ < 50,000 pop., county govt. w/ < 125,000 pop.)

• Regulations – Set through “a very public process which solicits input from all

affected parties”– Very comprehensive, detail roles of all parties

• Manufacturers, retailers, collectors, transporters, processors and recycling plan authorized parties

– Specify: • what must be in recycling plan• how recycling plan is to be implemented• performance standards for all parties• enforcement for non-compliance

WA - Manufacturers• Must:

– Pay annual fees & register with state– Participate in a recycling plan – Provide 1 collection point per city of > 10,000 & at

least 1 per county– Collectively must pay for the collection,

transportation and recycling of covered products• Cost to mfgr. varies depending on

market share & return share• Regs detail requirements• Benefits for working with non-profits

WA - Retailers• Must:

– Provide consumers with info about where to recycle unwanted electronics.

– Sell only branded products from manufacturers who are registered with State

WA - Recylers• Must:

– Meet performance standards set by rule– Conduct an annual independent audit (may

cost up to $10,000)

WA – Dept. of Ecology• Must:

– Provide oversight for all parties– Work with many entities to educate the public

about the program– $225,000/yr for program oversight

• paid to Ecology by manufacturers• “We are underfunded.” (Miles Kuntz, DOE 5/15/09)

• Note WA population 6.5 mil (CO is 4.9 mil.)• What you'd do differently?

– Include keyboards and mice in the definition of a “computer.”

What, There’s More?!?

Further Issues to Be Aware Of . . .Export Issues

Certification of e-cyclersPrison labor issues

Green purchasing of electronics

Photos © BAN

Why is this a problem?• Basel Convention, int’l treaty, 1989

– To prevent export & dumping of hazardous waste in developing countries by developed countries

– USA is only developed country not to sign, therefore:• It is illegal for 140 countries (who have signed) to accept hazardous

wastes (as defined internationally) from US• No enforcement by US of export to developing countries• Drives prices of e-cycling down• Makes it hard for ethical businesses to compete

• Is that how we want CO e-waste to be managed?– Can’t ban export in state-level law, however

• Federal CRT Rule – Notification by e-cycler of export of CRT glass– EPA asks importing countries for permission to import– Loopholes for “reuse”– Not harmonized with international laws

E-Cycler Certification Programs• GRADE certification from IDC

– Strong on data security & business reporting• ISRI’s RIOS + EPA’s R2 (Responsible Recycling)

– Covers EHS, worker safety, etc.– Allows …

• Export for “recycling” or “reuse” • Use of prison labor• Shredding of mercury-containing devices

• E-Stewards Certification– Independent, accredited, 3rd-party audited program– Addresses..

• Worker safety Data security• No landfills, incinerators/prisons/export of toxics• Downstream accountability Reuse defined• Follows international law

Prison Labor• Unicor, Federal prison labor program,

competes for e-cycling services• Controversy over:

– Competition with businesses complying with US laws who thus have ‘normal’ overhead & create legitimate jobs

– Prison workers not protected under OSHA– Questions re worker safety protections for

workers & guards• Evidence of exposure to Pb, Hg, etc. in workers &

guards

Green Purchasing of Electronics

• Electronic Product Environmental Assessment Tool– Purchasing tool that ranks

computers gold, silver, bronze

– Many green criteria (energy, recycle, EHS, etc.)

• Addressed in some state bills, requiring state to purchase at least EPEAT bronze

Anne PetersGracestone, Inc.

Boulder, CO

303.494.4934 voice303.494.4880 fax

[email protected]

For more information:

Overview of Electronic Device Recycling Issues & Solutions

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