3rdconf tonetti

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Education

Published on January 11, 2008

Author: Reginaldo

Source: authorstream.com

SELECTING AN E-WASTE RECYCLER FOR OBSOLETE EQUIPMENT What federal agencies need to know :  SELECTING AN E-WASTE RECYCLER FOR OBSOLETE EQUIPMENT What federal agencies need to know ROBERT TONETTI EPA OFFICE OF SOLID WASTE FEC CONFERENCE FEB 2007 FOCUS OF PRESENTATION:  FOCUS OF PRESENTATION UNDERSTANDING THE BASICS OF HOW EPA HAZARDOUS WASTE RULES DO & DON’T APPLY GUIDELINES FOR ENVIRONMENTALLY SOUND MANAGEMENT (ESM) ESM OPTIONS FOR FEDERAL AGENCIES EPA RULES:  EPA RULES GENERALLY, MOST E-WASTE IN THE U.S. IS EITHER: NON-HAZARDOUS NON-WASTE SEVERAL HAZARDOUS WASTE EXEMPTIONS & EXCLUSIONS APPLY TO ENCOURAGE REUSE & RECYCLING HAZARDOUS WASTE EXEMPTIONS/EXCLUSIONS:  HAZARDOUS WASTE EXEMPTIONS/EXCLUSIONS NON-HAZARDOUS WASTES HOUSEHOLD WASTES SCRAP METAL FOR RECYCLING WHOLE CIRCUIT BOARDS FOR RECYCLING PRECIOUS METALS FOR RECYCLING HAZARDOUS WASTE EXEMPTIONS/EXCLUSIONS:  HAZARDOUS WASTE EXEMPTIONS/EXCLUSIONS NON-WASTES MATERIALS OR EQUIPMENT FOR REUSE INTACT CRTs FOR RECYCLING PARTIALLY PROCESSED CRTs FOR RECYCLING CONDITIONS APPLY PROCESSED CRT GLASS FOR RECYCLING PROCESSED SCRAP METAL FOR RECYCLING SHREDDED CIRCUIT BOARDS FOR RECYCLING HAZARDOUS WASTES:  HAZARDOUS WASTES IF ALL FOUR ELEMENTS APPLY: GENERATED BY NON-HOUSEHOLDS GENERATED AT MORE THAN 220 lbs/mo HAVE A HAZ WASTE “CHARACTERISTIC,” e.g., FAIL TCLP. EXAMPLES: CRTs SOME LAPTOPS, CELL PHONES, ETC. SENT FOR DISPOSAL CRT RULE:  CRT RULE FINAL RULE ISSUED JULY 2006 CODIFIED EPA’s WORKING APPROACH THAT CRTs TO RECYCLING ARE NOT HAZARDOUS WASTE CONDITIONS APPLY FOR RECYCLERS EFFECTIVE 1/29/07 EXPORTERS MUST PROVIDE ONE-TIME NOTIFICATION IF EXPORT FOR REUSE PROVIDE NOTIFICATION AND RECEIVE CONSENT IF EXPORT FOR RECYCLING NO NOTIFICATION IF EXPORT OF PROCESSED GLASS EPA POLICY:  EPA POLICY JUNE 2002 FEDERAL REGISTER: BECAUSE OBSOLETE ELECTRONICS ARE OFTEN CAPABLE OF REUSE, THEY ARE NOT CONSIDERED WASTES UNTIL A DECISION IS MADE THAT THEY CANNOT OR WILL NOT BE REUSED SUCH DECISIONS ARE MADE BY PERSONS WITH SPECIALIZED EXPERTISE (UNLESS DESTRUCTION SPECIFIED) i.e., RESELLERS & RECYCLERS BOTTOM LINE FOR FEDERAL AGENCIES:  BOTTOM LINE FOR FEDERAL AGENCIES YOU ARE NOT WASTE GENERATORS UNLESS YOU REQUIRE DESTRUCTION YOU GENERATE USED ELECTRONIC EQUIPMENT AVOIDING DISPOSAL AVOIDS HAZARDOUS WASTE ISSUES UNDER FEDERAL RULES SEND USED EQUIPMENT TO RECYCLERS DO REASONABLE DUE DILIGENCE ON YOUR RECYCLER HAZARDOUS WASTE CLASSIFICATION:  HAZARDOUS WASTE CLASSIFICATION REMEMBER: BE AWARE OF STATE RULES STATE RULES MAY BE MORE STRINGENT THAN EPA SOME STATES CLASSIFY E-WASTE AS UNIVERSAL OR HAZARDOUS WASTE GUIDELINES FOR ENVIRONMENTALLY SOUND MANAGEMENT:  GUIDELINES FOR ENVIRONMENTALLY SOUND MANAGEMENT EPA’S “PLUG-IN” GUIDELINES ISSUED IN 2002 “BEST MANAGEMENT PRACTICES” (BMPs) FOR CERTIFICATION OF RECYCLERS MULTISTAKEHOLDER DEVELOPMENTAL EFFORT ONGOING EPA PLUG-IN GUIDELINES:  EPA PLUG-IN GUIDELINES GUIDELINES FOR SAFE MANAGEMENT OF USED & END-OF-LIFE ELECTRONICS ENCOURAGES REUSE & RECYCLING DISPOSAL ALSO ADDRESSED DISTINGUISHES REUSE FROM RECYCLING; REUSE IS SIMPLIFIED EMPHASIZES DUE DILIGENCE ADDRESSES EXPORT PLUG-IN GUIDELINES REUSE & REFURBISHMENT:  PLUG-IN GUIDELINES REUSE & 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 PLUG-IN GUIDELINES RECYCLING FACILITIES:  PLUG-IN GUIDELINES RECYCLING FACILITIES APPROPRIATELY LICENSED HAVE AN EMS OR WRITTEN PLAN FOR RISK MANAGEMENT WITH REGULAR REEVALUATION MONITORING AND RECORDKEEPING CLOSURE PLAN, & IF NECESSARY, FINANCIAL GUARANTEE PLUG-IN GUIDELINES RECYCLING FACILITIES:  PLUG-IN GUIDELINES RECYCLING FACILITIES WORKER & ENVIRONMENTAL PROTECTIONS: EH&S 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 EH&S AUDIT, EVERY 1-3 YEARS PLUG-IN GUIDELINES EXPORT FOR RECYCLING:  PLUG-IN GUIDELINES EXPORT 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. REUSE & RECYCLING MARKETS:  REUSE & RECYCLING MARKETS MOST REUSE MARKETS ARE EXPORT LARGE FOR-PROFIT & NON-PROFIT MARKETS IN DEVELOPING COUNTRIES MANY RECYCLING MARKETS ARE EXPORT STRONG FOREIGN DEMAND FOR RAW MATERIALS NO U.S. SMELTERS FOR COPPER & PRECIOUS METAL RECOVERY FROM CIRCUIT BOARDS NO CRT GLASS FURNACES IN U.S. PLASTIC RECYCLING MARKETS ALMOST ALL OVERSEAS RECYCLER CERTIFICATION :  RECYCLER CERTIFICATION MANY STAKEHOLDERS WANT A RECYCLER CERTIFICATION PROGRAM HOWEVER, EPA DOES NOT & WILL NOT “CERTIFY” OR “APPROVE” RECYCLER CONFORMANCE WITH PLUG-IN OR OTHER GUIDELINES OR RULES BEST MANAGEMENT PRACTICES & CERTIFICATION:  BEST MANAGEMENT PRACTICES & CERTIFICATION EPA SPONSORING MULTISTAKEHOLDER EFFORT FOR DEVELOPMENT OF BMPs INVOLVES EPA, OSHA, STATES, MANUFACTURERS, RECYCLERS, ENVIRONMENTAL INTEREST GROUPS RECYCLERS WILL VOLUNTEER TO BE CERTIFIED AS TO CONFORMANCE WITH THE BMPs NATURE OF CERTIFYING ORGANIZATIONS STILL UNCLEAR PROGRESS CURRENTLY BEING MADE, HOWEVER, OUTCOME UNCLEAR; AT LEAST SEVERAL MORE MONTHS NEEDED TO COMPLETE BMPs MAJOR ISSUES INCLUDE EXPORTS, PRISON LABOR, PRESCRIPTIVENESS OF BMPs, SCOPE re FACILITIES & MATERIALS, IMPLEMENTATION, COST ESM OPTIONS FEDERAL AGENCIES:  ESM OPTIONS FEDERAL AGENCIES TWO OPTIONS THAT PROVIDE A HIGH LEVEL OF ASSURANCE OF ESM EPA’s READ CONTRACT UNICOR CERTAINLY, THERE ARE OTHER EXCELLENT RECYCLERS, BUT USE OF READ OR UNICOR REDUCES BURDEN FOR FEDERAL AGENCIES TO CONDUCT THEIR OWN DUE DILIGENCE ESM: EPA’s READ CONTRACT:  ESM: EPA’s READ CONTRACT 7 PRIME CONTRACTORS EPA FOCUSED ON SOUND MANAGEMENT IN AWARDING THE CONTRACTS FOLLOW-UP SITE VISITS HAVE BEEN CONDUCTED FOCUS ON EH&S & DUE DILIGENCE FEC CHECKLISTS & PLUG-IN GUIDELINES USED IN VISITS EPA INTENDS TO DO PERIODIC FOLLOW-UP ASSESSMENT OF CONTRACTOR PRACTICES ESM: UNICOR:  ESM: UNICOR 7 UNICOR RECYCLING FACILITIES NATIONWIDE – NO COST TO FEDs UNICOR ALSO A SUB FOR ONE READ CONTRACTOR UNICOR BID AS READ PRIME WAS AMONG BEST re ESM SELECTED AS PRIME CONTRACTOR BUT REVOKED: NOT A SMALL BUSINESS ESM: UNICOR:  ESM: UNICOR AMONG BEST RECYCLERS IN A NUMBER OF AREAS: WORKER PROTECTION IN CRT GLASS BREAKING HEALTH MONITORING OF WORKERS WORKER EH&S TRAINING RECORDKEEPING MAXIMIZING REUSE MAXIMIZING MATERIAL RECOVERY ISO 9000 & IAER CERTIFICATIONS ARE COMPLETED OR IN PROCESS AT ALL 7 FACILITIES. BEGINNING ISO 14000 PROCESS SCREENING OTHER RECYCLERS:  SCREENING OTHER RECYCLERS IF YOU WANT TO USE RECYCLERS OTHER THAN READ CONTRACT OR UNICOR: YOU NEED TO CONDUCT YOUR OWN DUE DILIGENCE FEC WEBSITE HAS EXTREMELY USEFUL RESOURCES TWO CHECKLISTS OTHER MATERIALS GAINING A HIGH DEGREE OF CONFIDENCE IN A RECYCLER REQUIRES A CONSIDERABLE INVESTMENT OF TIME DOING YOUR OWN DUE DILIGENCE:  DOING YOUR OWN DUE DILIGENCE CONDUCT A SITE VISIT ASK QUESTIONS ASK TO SEE DOCUMENTATION e.g., permits & example invoices re downstream markets USE THE FEC TOOLS CONTACT REFERENCES STATE/LOCAL PERMITTING OFFICIALS MAJOR CUSTOMERS, ESPECIALLY ANY THAT HAVE DONE AN AUDIT OF THE FACILITY DUE DILIGENCE PRIORITIES:  DUE DILIGENCE PRIORITIES PERMITS & WORKING RELATIONSHIP WITH STATE/LOCAL PERMITTING AGENCIES DATA SANITIZATION/DESTRUCTION METHODS MINIMIZE DISPOSAL, MAXIMIZE REUSE & RECYCLING BASIC WORKER SAFETY PRECAUTIONS & GOOD HOUSEKEEPING RECYCLER’S DUE DILIGENCE PROCEDURE re DOWNSTREAM MARKETS DUE DILIGENCE PRIORITIES (CONT’D):  DUE DILIGENCE PRIORITIES (CONT’D) DOWNSTREAM MARKETS THRU TO REUSE OR RAW MATERIAL USE/SMELTING INFO NEEDED ON EACH LAYER, WHETHER U.S. MARKET OR EXPORT PRIORITY MATERIALS FOR DUE DILIGENCE WHOLE EQUIPMENT CRTs & CRT GLASS BATTERIES MERCURY-CONTAINING DEVICES (e.g., small lamps in laptops & flat panels) CIRCUIT BOARDS DUE DILIGENCE re REUSE MARKETS:  DUE DILIGENCE re REUSE MARKETS HOW SOLD OR DONATED? RED FLAG: OPEN AUCTION OF EQUIPMENT, EXCEPT WHERE FULLY TESTED & WORKING WHO ARE BUYERS/RECIPIENTS? RED FLAG: RECYCLER DOES NOT HAVE DUE DILIGENCE INFO ON BUYERS, EVEN IF ON-LINE (except tested, working equip) NO NEED TO LOOK AT RETAIL SALE OF INDIVIDUAL EQUIPMENT REASONS TO REJECT A RECYCLER:  REASONS TO REJECT A RECYCLER IF YOU HAVE ANY DOUBTS, ESPECIALLY REGARDING: PROPER PERMITTING DOWNSTREAM MARKETS OR DISPOSAL WORKER SAFETY DATA SANITIZATION/DESTRUCTION IF WON’T PROVIDE REFERENCES OR DOWNSTREAM CUSTOMER INFO

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