The e-scrap problems on a global scale

1. Challenges in Product
Stewardship and Management of
Waste Electronics
Dwight Clark, CHMM
Presented at the 10th Annual Semiconductor
Environmental Health and Safety Association
(SESHA) Mini Conference

2. Presenter
Dwight Clark is an Environmental Engineer and
Certified Hazardous Materials Manager with over
25 years of experience in a wide array of
environmental projects.
Dwight is as an ISO 14000 Lead Auditor as well as an
auditor to the Responsible Recycling®, e-
Stewards®, and Recycling Industry Operating
Standards® (RIOS) certification programs.

3. Basics
Electronic waste (e-waste) is a term
that is used loosely to refer to
obsolete, broken, or irreparable "What is in a
Computer?"
electronic devices like televisions, Rekacewicz, P.
(2004) Vital
computer central processing units Waste
Graphics
(CPUs), computer monitors (flat [map].
http://
screen and cathode ray tubes), maps.grida.no/
go/graphic/
laptops, printers, scanners, and what_is_in_a_
computer
associated wiring. E-waste has
become a concern in the United
States due to the high volumes in
which it is generated, the
hazardous constituents it often
contains (such as lead, mercury,
and chromium), and the lack of
regulations applicable to its
disposal or recycling.

4. Toxic Substances in a Monitor
Image from GAO
Report No.
GAO-08-1044

5. Toxic Substances in a CPU
Image from GAO
Report No.
GAO-08-1044

6. The Technology Life Cycle

7. The Problem
Discarded electronics is one of the fastest growing segments of our nation’s
waste stream, already accounting for 5% of the total waste volume.
Researchers estimate an additional 75% of old electronics are stuck in storage,
in part because consumers don’t know what to do with them. If properly
handled; these materials pose little risk and can be recycled or reused safely.
The problem extends to the Original Equipment Manufactures’ through the
electronics take back programs and other extended producer responsibility
programs. The brand image is a worst case scenario.

8. Federal Regulatory Framework
• Federal: The US does not yet have national regulation
specific to the disposal for electronics waste, with the
notable exception of the CRT Rule and (Printed Circuit
Board) determinations as scrap metal.
• The regulatory scrutiny is primarily the high lead levels in
the CRTs and the PCBs.
• Additional concerns for the other electronics which may
contain cadmium, mercury, arsenic, and chromium is
growing within the regulated community
• State and Local: The absence of Federal Regulation has
resulted in 23 states and New York City having
implemented some form of electronics waste law.

9. Regulation of the Recyclers
• The Federal Programs, which allow most electronics waste to be
exempt if being recycled, also do not place requirements on the
recycling activities specifically. This typically includes export,
with the noted CRT Rule requirements.
• The speculative accumulation requirements are the common
driver which can place the materials once thought to be recycled
back into regulation.
• Several recyclers that have been visited were unaware of the
universal waste regulations for batteries, mercury devices, and
certain lighting devices.
• Regulations such as air permitting will apply based on the
process.

10. CERCLA Interaction
• The Comprehensive Environmental Response,
Compensation, and Liability Act (CERCLA) aka
Superfund regulations have many implications in the
recycling business. The joint and several liability
provisions can easily apply if the recycler is not
managing the materials properly.
• The Superfund Recycling Equity Act of 1999 (SREA)
allows for the exemption of certain recyclable materials
from Superfund liability, and contains particular
statutory criteria that must be satisfied in order to qualify
for the exemption. This is an important exemption the
waste generators to have documented.

11. International Regulations
• Organization for Economic Co‑operation and
Development (OECD)
• Members include the “Developed World” - primarily
Europe, and North America
• Regulates trans-boundary movement of hazardous
wastes
• Basel Convention
• 170+ countries, notable exception of US
• Further regulates movement of hazardous wastes to
non-developed countries.
• Expands scope of Hazardous Waste Regulation

12. So toxic, why recycle?
In 2001 the United States Geological Survey (USGS),
yes the Geology People, issued a Fact Sheet 060-10 that
concluded “Obsolete computers contain significant
amounts of recoverable materials including metals from
wires and circuit boards, glass from monitors, and
plastics from casings. For example, 1 metric ton (t) of
electronic scrap from personal computers (PC’s)
contains more gold than that recovered from 17 t of gold
ore. In 1998, the amount of gold recovered from
electronic scrap in the United States was equivalent to
that recovered from more than 2 million metric tons
(Mt) of gold ore and waste.”

13. Material Fractions in Electronics Scrap
From: Effective electronic waste management and recycling process involving
formal and non-formal sectors, S. Chatterjee and Krishna Kumar, International
Journal of Physical Sciences Vol. 4 (13) pp. 893-905, December, 2009

14. Analysis of
Printed Circuit Board Recovery Value
From: Effective electronic waste management and recycling process involving
formal and non-formal sectors, S. Chatterjee and Krishna Kumar, International
Journal of Physical Sciences Vol. 4 (13) pp. 893-905, December, 2009

15. Typical Recycling Flow

16. Typical Processing
The recycling business for electronics is based on the scrap value
of the components.
• The typical recycler will preferentially sell the equipment for
re-use as this is the highest revenue stream.
• If the unit is not functioning, the high value parts may be
removed and re-used
• The remaining material is then segregated and recycled.
The processing of this material can be a labor intensive and an
environmental damaging function; therefore overseas markets
are very attractive. One report has documented that the cost to
manually separate a computer system in the US is
approximately $20 and the same system in India has a labor cost
of $2, creating a margin of $18.

17. Differences in Recyclers
• A recycler that removes hazardous constituents from e-scrap,
sorts and disassembles its e-scrap, and exports the waste to a
responsible recycler or confirms that devices are in working
order before exporting them for reuse, will likely offer its
services at a significantly higher rate than a recycler that simply
ships unsorted e-scrap abroad.
• The recycler that ships unsorted e-scrap can still make the claim
that it is operating in a “green” way because it diverts the waste
from landfill disposal.
• A recycler can also claim that it does not export its waste, but
that is a claim that would be very hard for the average consumer
(or even a state or charitable organization using the recycler) to
confirm.

18. GAO Study Excerpts
• The study conducted a search of one Internet e-commerce site and
observed brokers from around the world place 2,234 requests to
purchase liquid-crystal display (LCD) screens. On the same site, we
found 430 requests for central processing units and 665 requests for
used computers.
• In an extensive search of two Internet e-commerce sites over a 3-
month period, brokers in developing countries made over 200 offers to
purchase over 7.5 million used CRTs. Over 75 percent of the brokers’
requests offered $10 or less per unit, and almost half offered $5 or less.
Low prices (under $10 per unit) indicate a high likelihood that these
items will ultimately be handled and disposed of unsafely. About 70
percent of the requests came from developing countries in Asia, with
China and India posting the largest number by far; the remaining
requests came largely from Africa.
• These results indicate that the demand is strong for CRTs, likely for
recovery of metals.

19. Map of Country’s requesting Used CRTs during GAO internet research

20. More GAO Findings
• The 2008 GAO Study reviewed claims of
several recyclers by interview as the GAO
gauging the effects of the CRT rule on their
business and by setting up a fake broker for
overseas customers. The results include:
• 43 companies responded to requests for export
of CRTs from the US. Of those only one was
registered for export and not to the country
indicated in the request.

21. GAO Study
• A regional manager for a trading company in
California stated that he was not aware of CRT
rule notification requirements, but his company
does not export CRTs. In an e-mail to our
fictitious broker in Pakistan, however, he
offered to sell “as-is” CRT monitors. In
addition, his company offered 900 as-is CRT
monitors, some with power cords cut, on a
Chinese e-commerce Web site.

22. GAO Study
• A sales representative for a large electronics recycler in New Jersey
said that he was not aware of the CRT rule and was not the right
person to speak to about this issue. This same individual, however,
told our fictitious buyer from Hong Kong not to worry about U.S.
laws’ holding up export of untested CRT monitors. He explained
that “it’s the laws at [the port of Hong Kong] that you have to find
out about.”
• A representative of a metal-recycling company in Illinois told us
that the CRT rule does not apply to this company because it sends
all of its CRT glass to a lead smelter in the United States. In
response to an e-mail inquiry to ship nonworking and untested CRT
monitors to Southeast Asia, however, this person wrote back,
“What are you paying for the monitors? Let me know and I’ll give
you an inventory count.”

23. GAO Study
• A representative of an electronics-recycling company in Colorado
told us that the company does not export CRTs; instead, all CRTs
are recycled in-house, so the CRT rule does not apply. This same
person offered to sell 1,500 CRT monitors and 1,200 CRT
televisions, which were ready for immediate shipment, to our
fictitious broker in Hong Kong.
• A representative of an electronics-recycling company in
Washington State told us that all of its CRT monitors are sent to its
shredding facility in Oregon. A sales associate at the company,
however, offered to sell 4 containers of CRT monitors
(approximately 3,200 units) in April 2008 and another 20
containers (approximately 16,000 units) in June 2008 to our
fictitious broker in Hong Kong.

24. GAO Conclusions on Export
“Many of the companies that responded to our fictitious foreign
brokers, particularly the electronics recyclers, actively promote
an environmentally responsible public image. Nearly all of the
electronic recyclers claimed to be environmentally friendly, with
at least 17 of these companies citing on their Web sites the
hazards of improper disposal of used electronics equipment. At
least 3 of these recyclers held Earth Day 2008 electronics-
recycling events. Some of the electronics recyclers accept used
CRTs at no charge, while others charge the consumer,
ostensibly to cover recycling expenses. One Maryland
electronics recycler, for instance, charges from $10 to $30 for
CRT monitors, depending on size, to cover its “responsible,
domestic recycling costs.”

25. Potential Solutions
• The industry has responded to the concerns and
two separate third party accredited standards
were developed for certifying recyclers.
Responsible Recycling® (R2)
and
e-Stewards®
• These standards are similar in nature to ISO
certification through a Certifying Body

26. Responsible Recycling
• At a multi-stakeholder electronics summit in 2005, EPA was asked to
lead an effort to develop a set of sound recycling practices and a
system for certifying electronics recyclers who met them
• EPA convened a multi-stakeholder group to develop a set of practices
• R2 document process:
• Drafted by neutral facilitator (EPA funded) in a consensus-driven
process
• Reviewed by 4 experienced auditors
• Field tested at 6 recyclers (included a range of sizes and processes)
• EPA’s role in helping to get documentation from foreign countries
was tested (China, Hong Kong, India)

27. R2 Practices
• Sets a high bar for environmental and worker protection
• Establishes environmental, worker safety, and public
health practices
• Includes 13 general principles, and specific practices for
recyclers to follow
• The practices largely go beyond what is required under
regulation –recyclers are not required to be certified to R2
• Some States have, or are, developing standards in their
electronics regulations based on R2, e.g., Washington,
Oregon

28. R2 Features
• Signifies an upgrade of existing practices
• Due diligence requirements, documentation of
legality from countries of import
• Proper on-site practices are identified
• Requires clearing personal data from memory
• Allows export of materials if shown to be legal
and if goes to sound recyclers
• Through field testing, R2 was found to be a
practical approach that can be integrated into
existing ISO systems.

29. E-Stewards
• Certified e-Stewards:
• Requires a certified ISO 14001 environmental management system
• Prohibits all toxic waste from being disposed of in solid waste
landfills and incinerators
• Requires full compliance with existing international hazardous
waste treaties for exports and imports of electronics, and
specifically prohibits the export of hazardous waste from
developed to developing countries
• Prohibits the use of prison labor in the recycling of toxic
electronics
• Requires extensive baseline protections for and monitoring of
recycling workers
• Is written for international use

30. ISO Certifications and RIOS
• ISO 14001, ISO 9001, and OSHAS 18001 are
helpful, but may be too costly for smaller recyclers.
• The Institute of Scrap Recycling Industry (ISRI) has
developed an industry specific Quality,
Environmental, and Health and Safety (QEH&S)
Framework (management system) the is called the
Recycling Industry Operating Standard (RIOS).
This system is comparable (or a light version of) to
a combined 14001, 9001, and 18001 system.

31. Potential Risks
• Illegal export
• Data Security
• CERCLA liability from dumping or
improper facility operations
• RCRA issues is speculatively accumulated
• Brand image
• Imagine you property tag, box, carton, or
branded equipment in the previous photos.

32. Recycler Selection
• Certifications such as R2 and e-Stewards are an
excellent starting point.
• Accepting the third party certifications alone is risky, many
of the larger players (Dell, HP, Sony, etc…) still audit for
their own compliance certification
• Look for transparency in operations and downstream
processors.
• Document SREA due diligence
• Prevent CERCLA Liabilities from the receiving site
• Specific documentation requirements
• Remember no recyclers are EPA Approved or permitted
for recycling operations

33. References
• Electronic Waste: EPA Needs to Better Control Harmful
U.S. Exports through Stronger Enforcement and More
Comprehensive Regulation. GAO Report No.
GAO-08-1044
http://www.gao.gov/new.items/d081044.pdf
• Obsolete Computers, “Gold Mine,” or High-Tech
Trash? Resource Recovery from Recycling, USGS
Fact Sheet FS-060-01
http://pubs.usgs.gov/fs/fs060-01/fs060-01.pdf
• Managing Electronic Waste: Issues with Exporting E-
Waste, Congressional Research Service, September 27,
2010 http://www.fas.org/sgp/crs/misc/R40850.pdf