Regulatory InterpretationSupport

1

2001 Electronics and the Environment Recycling
Summit
Regulatory Interpretation/Support R. Tonetti


2
2001 Electronics and the Environment Recycling
Summit

• Major Points
• Consistent rules and implementation through
  government needed (vertically and
  horizontally)
  
• EPA should issue regulatory interpretation for
  CRTs ASAP or States should collaborate to
  issue.
  
• The longer EPA delays its interpretation, the
  greater inconsistency at State and Local
  levels
  
• Once regulatory policy is clear, consistent
  enforcement is needed
  
• Incentives/mandates to facilitate product
  stewardship and shared responsibility.

3
2001 Electronics and the Environment Recycling
Summit

• Specific Needs/Suggestions for Improvement
• Regulatory Policy direction and leadership from
  EPA
  
• Deregulation of CRTs (especially important for
  charities)
  
• Reduce regulatory barriers if there is a proven
  environmental benefit and no increased risk
  
• EPA could use universal waste approach
• EPA could define Point of Discard to discern
  wasteotherwise,product
  
• Regulatory approach should prevent sham recycling
  and speculativeaccumulation
  
• Should have regulatory consistency for household
  electronicsand those from non-households
  

4
2001 Electronics and the Environment Recycling
Summit

• Specific Needs/Suggestions for Improvement
• Incentives/mandates to facilitate resource
  conservation,collection, takeback, toxics
  reduction, DfE, DfD (dismantling)For example
  
• Mandated waste minimization
• Procurement guidelines..re recycled content
• Premium government prices for EPP
• Tax incentives
• Hazardous waste generation/product fees
• Eliminate procurement rules that require use of
  all new components in products
  
• Disposal bans to help develop markets, once
  infrastructure isfurther developed

5
2001 Electronics and the Environment Recycling
Summit

• Specific Needs/Suggestions for Improvement
• Establish and enforce aggressive recycling goals
• Shared responsibility legislation
• Harmonize regulations to be more protective, not
  less
  
• Consistent North American regulatory policies
• Develop strategy to distinguish legitimate export
  from export ofhazardous waste. Use a
  certification process
  
• Standards/guidelines for environmentally sound
  recycling
  
• Easily available and understandable information
  for electronicsconsumers
  
• Regulatory policy
• Recyclers who are compliant

6
2001 Electronics and the Environment Recycling
Summit

• Specific Needs/Suggestions for Improvement
• Technical information sharing by recycling
  industry regulators
  
• Flexibility in permitting to risks of operations

7
2001 Electronics and the Environment Recycling
Summit

• Areas for Collaboration
• Technical information sharing by recycling
  industry withregulators
  
• Coordination on toxicity and risk research and
  informationsharing, particularly with
  regulators
  
• States should collaborate to issue consistent
  regulatorypolicy, in lieu of EPA
  
• States, Federal Government and North American
  countriesshould harmonize standards