ENVIRONMENTALLY SOUND RECYCLING OF ELECTRONICS FEDERAL ACTIVITIES

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ENVIRONMENTALLY SOUND RECYCLING OF
ELECTRONICSFEDERAL ACTIVITIES

• ROBERT TONETTI
• USEPA
• OFFICE OF SOLID WASTE

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THREE ACTIVITIES

• CRT RULE
• U.S. RATIFICATION OF BASEL CONVENTION
• BASEL CONVENTION UNDER UNEP
• CONTROLS IMPORT/EXPORT OF HAZARDOUS WASTE
• OVER 130 COUNTRIES
• EPA PLUG-IN GUIDELINES
• VOLUNTARY PROGRAM FOR END-OF-LIFE ELECTRONICS

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CRT RULE

• EXPECT TO ISSUE FINAL RULE LATER IN 2004
• PROVIDES SUBSTANTIAL RELIEF FROM RCRA FOR
  DOMESTIC COLLECTION, TRANSPORT RECYCLING
• WILL ADDRESS EXPORT OF CRTs
• LIKELY TO SIGNIFICANTLY IMPACT POOR EXPORT
  PRACTICES
• IN EX PARTE PERIOD, SO EPA IS LIMITED IN
  SHARING DETAILS OF RULE

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BASEL CONVENTION U.S. LEGISLATION

• U.S. IS NOT A PARTY TO THE BASEL
  CONVENTION--LEGISLATION IS NEEDED
• WORK ACTIVE ON ADMINISTRATION BILL
• DRAFT BILL LARGELY COMPLETED
• SEVERAL ISSUES HAVE HISTORICALLY HELD UP
  LEGISLATION

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BASEL CONVENTIONIMPLEMENTATION ISSUES

• BASEL DEFINITION OF HAZARDOUS WASTE DIFFERS
  FROM U.S. RULESFOR EXPORTS, BASEL DEFINITIONS
  WILL APPLY
• BASEL WASTE LISTS ARE UNCLEAR FOR MANY
  ELECTRONICSWORK BY PARTNERSHIPS MAY BE HELPFUL
• IF WASTE IS COVERED BY BASEL, THEN ESM
  DETERMINATIONS BY EPA WILL BE NECESSARY FOR
  EXPORT TO NON-OECD COUNTRIES. NOTICE AND CONSENT
  OF IMPORTING AND TRANSIT COUNTRIES ALSO NEEDED

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EPA PLUG-IN GUIDELINES

• GUIDELINES FOR SAFE MANAGEMENT OF END-OF-LIFE
  ELECTRONICS
• SET EXPECTIONS FOR PLUG-IN PARTNERS, AS WELL AS
  FOR PILOT COLLECTION PROGRAMS. ALSO USEFUL AS
  GUIDE FOR ANY E-WASTE RECYCLING
• BASED ON EFFORTS UNDER OECD, NEPSI, FEC OTHERS
• INCLUDES CORE ELEMENTS OF ESM FOR FACILITIES
• DUE DILIGENCE CRITICAL
• ADDRESSES EXPORT

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PLUG-IN GUIDELINESPARTNERSHIPS ALTERNATIVES

• PLUG-IN PARTNERS INCLUDE OEMs, RETAILERS,
  GOVERNMENT AGENCIES
• WILL NOT INCLUDE RECYCLERS AS PARTNERS DUE TO
  LEGAL ISSUE WITH NEED FOR DATA INFORMATION
• INSTEAD, EPA WILL PURSUE USE OF THIRD-PARTY
  ORGANIZATION (TPO) TO PROVIDE RECYCLER
  CERTIFICATIONS
• MULTISTAKEHOLDER INVOLVEMENT NEEDED IN
  DEVELOPMENT AND/OR OPERATION OF TPO
• CERTIFICATIONS WOULD REQUIRE EMS PLUS CONFORMANCE
  TO PLUG-IN OR OTHER GUIDELINES
• EPA WILL LOOK AT OTHER ALTERNATIVES IF TPO
  APPROACH IS NOT SUCCESSFUL

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PLUG-IN GUIDELINESMATERIALS COVERED

• FOR REUSE, REFURBISHMENT OR RECYCLING, ONLY
  EQUIPMENT CONTAINING OR CONSISTING OF THE
  FOLLOWING ARE COVERED
• CIRCUIT BOARDS, WHOLE OR SHREDDED
• CRTs
• BATTERIES
• MERCURY- PCB-CONTAINING EQUIPMENT
• FOR DISPOSAL, ALL EQUIPMENT COMPONENTS COVERED

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PLUG-IN GUIDELINESREUSE REFURBISHMENT

• SHIPMENT MEETS REUSE OR REFURBISHMENT
  SPECIFICATIONS
• EQUIPMENT IS PACKAGED TO PROTECT VALUE FOR REUSE
  OR REFURBISHMENT
• PROPER BUSINESS RECORDS KEPT OF TRANSACTION, INCL
  PRICE PAID

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PLUG-IN GUIDELINESRECYCLING FACILITIES

• APPROPRIATELY LICENSED
• HAVE AN EMS OR WRITTEN PLAN FOR RISK MANAGEMENT
  WITH REGULAR REEVALUATION
• WORKER ENVIRONMENTAL PROTECTIONS
• EHS TRAINING OF PERSONNEL
• WRITTEN HAZARDOUS MATERIALS PLAN THAT ADDRESSES
  SPECIFIC SUBSTANCES
• SPECIAL CONSIDERATIONS WHERE SHREDDING OR HEATING
  USED
• WRITTEN PLAN FOR POLLUTANT RELEASES EMERGENCIES
• LIABILITY INSURANCE
• COMPLETION OF EHS AUDIT, EVERY 1-3 YEARS
• MONITORING AND RECORDKEEPING
• CLOSURE PLAN, IF NECESSARY, FINANCIAL GUARANTEE

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PLUG-IN GUIDELINESEXPORT FOR RECYCLING

• REMOVE, PRIOR TO EXPORT, UNLESS TO OECD COUNTRY
• BATTERIES
• MERCURY- PCB-CONTAINING COMPONENTS
• CIRCUIT BOARDS, EXCEPT HANDHELD EQUIPMENT
• CRTs CRT GLASS PROCESS PRIOR TO EXPORT
• COMPLY WITH ALL REQUIREMENTS OF IMPORTING
  TRANSIT COUNTRIES
• NON-OECD COUNTRIES CANNOT LEGALLY ACCEPT
  HAZARDOUS WASTES w/o BILATERAL WITH U.S.

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PLUG-IN GUIDELINESDISPOSAL

• MINIMIZE DISPOSAL OF ALL COMPONENTS OF
  ELECTRONICS
• IF DISPOSAL NECESSARY, THEN ENERGY RECOVERY
  PREFERRED OVER LANDFILL
• DISPOSAL FACILITY IS FULLY LICENSED FOR THE WASTE
  
• DISPOSAL FACILITY HAS AN EMS