&EPA
United States
Environmental Protection
Agency
Report on the Panel Session
Emerging Electronics Issues
How Can We Minimize the
Health and Environmental
Impacts of
Electronics Recycling?
Foreign Country
Electronic Items
Ready for Recycling
Processing I Recoven/l Recovery
RESEARCH AND DEVELOPMENT
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EPA/600/R-05/101
September 2005
www.epa.gov
Report on the Panel Session
Emerging Electronics Issues
How Can We Minimize the
Health and Environmental
Impacts of
Electronics Recycling?
Prepared for
Brian Schumacher
Office of Research and Development
U.S. Environmental Protection Agency
Las Vegas, Nevada
Notice: The information in this document has been funded wholly by the United States Environmental Protection
Agency under contract 68-C-00-186 to the Eastern Research Group, Inc. It has been subjected to the
Agency's peer and administrative review and has been approved for publication as an EPA document.
Mention of trade names and commercial products does not constitute endorsement or recommendation
for use.
U.S. Environmental Protection Agency
Office of Research and Development
Washington, DC 20460
243CMB05.RPT * 1/5/2006
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Notice
This document is based on the results of an expert panel discussion conducted on May 19, 2005.
The panel discussion and the preparation of this document were wholly funded through the
United States Environmental Protection Agency's (EPA's) National Exposure Research
Laboratory in Las Vegas, Nevada, a part of EPA's Office of Research and Development, under
contract 68-C-00-186 to the Eastern Research Group, Inc. It has been subjected to the Agency's
peer and administrative review and has been approved for publication as an EPA document.
Prior to publication, a draft version of this report was sent to all members of the expert panel for
review. Three panelists responded with comments and suggestions. The authors also received
comments from Jeff van Ee and Kathy Osdoba of EPA, who both attended the panel session. All
comments were considered, and revisions were made to strengthen the report.
Mention of trade names or commercial products in this report does not constitute endorsement by
EPA. Likewise, the discussion of various state, international, and private-sector approaches to
electronics recycling is intended to provide context, and does not constitute an endorsement or
recommendation by EPA.
in
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IV
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Contents
Notice iii
Acronyms and Abbreviations vii
Executive Summary ix
Section 1 Introduction 1
1.1 Scope of the Issue 1
1.2 EPA's Objectives . 2
1.3 Industry Concerns 2
Section 2 Background 5
2.1 Electronics Recycling Processes 5
2.2 Existing Recycling Efforts 7
2.3 Existing Controls on Electronics Recycling Operations 9
2.4 Projections for the Future: Changes and Challenges 10
Section 3 Composition of Electronics Scrap 11
3.1 Chemical Constituents 11
3.2 Material-Specific Challenges , 12
Section 4 Potential Exposure Pathways 15
4.1 Occupational Exposure 15
4.2 Environmental Exposure 16
Section 5 Existing Controls: The Current Regulatory Framework 19
5.1 Occupational Standards 19
5.2 Environmental Regulations 20
5.3 Industry and Other Activities Related to Environmental Management 22
Section 6 Needs Identified by the Panelists 25
6.1 Research Needs 25
6.2 Best Practices Guidance 27
6.3 Standardization 28
6.4 Communication 28
6.5 Interagency Collaboration 29
6.6 Informed Decisions 29
Section 7 The Path Forward 31
7.1 Priorities 31
7.2 Roles EPA is Well Positioned to Play 32
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Section 8 Participants and Attendees 35
Section 9 Additional Resources 37
Appendix A Participant List A-l
VI
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Acronyms and Abbreviations
ARF advance recovery fee
BFR brominated flame retardant
CBD chronic beryllium disease
CDC Centers for Disease Control and Prevention
CESQG conditionally exempt small quantity generator
CRT cathode ray tube
EPA United States Environmental Protection Agency
EPEAT Electronic Product Environmental Assessment Tool
EU European Union
HAP hazardous air pollutant
HP Hewlett-Packard
LAER International Association of Electronics Recyclers
IEEE Institute of Electrical and Electronics Engineers
ISRI Institute of Scrap Recycling Industries
LCD liquid crystal display
MACT maximum achievable control technology
MSDS Material Safety Data Sheet
MSW municipal solid waste
NIOSH National Institute for Occupational Safety and Health
OECD Organization for Economic Cooperation and Development
OEM original equipment manufacturer
ORD Office of Research and Development (EPA)
OSHA Occupational Safety and Health Administration
PAH polycyclic aromatic hydrocarbon
PBDE polybrominated diphenyl ether
PCB polychlorinated biphenyl
PEL Permissible Exposure Limit
PVC polyvinyl chloride
RCRA Resource Conservation and Recovery Act
READ Recycling Electronics and Asset Disposition (contract)
RFID radio frequency identification
RIOS Recycling Industry Operating Standards
RoHS Restriction of Hazardous Substances (EU Directive)
SWANA Solid Waste Association of North America
TCLP Toxicity Characteristic Leaching Procedure
TSCA Toxic Substances Control Act
WEEE Waste Electrical and Electronic Equipment (EU Directive)
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Executive Summary
Background
The production and use of electronic products is growing and the rapid pace at which the
technology advances means that many electronic products become obsolete in a relatively short
period of time. These factors are contributing to a growing challenge for waste management
because electronic waste contains a vast array of materials, some of which are hazardous to
human health or the environment. As state and local governments seek options other than
disposal for properly handling electronic waste, the demand for electronics recycling services has
increased dramatically. Today's electronics recycling industry includes businesses specializing in
manual disassembly and parts recovery, automated shredding and material separation, and many
other processes that break electronic waste into primary materials that can be reused or otherwise
managed.
While EPA supports resource conservation and recycling, the agency also must confront the
possibility that increased electronics recycling could pose its own risks to human health and the
environment. To avoid unanticipated problems in the future, EPA wants to proactively identify
and mitigate potential risks associated with electronics recycling. To this end, EPA's Office of
Research and Development (ORD) convened a panel of experts to discuss the state of electronics
recycling and identify key challenges and research needs. The panel met on May 19, 2005 in New
Orleans at the 2005 Institute of Electrical and Electronics Engineers (IEEE) International
Symposium on Electronics and the Environment, and included individuals from several sectors
of the electronics recycling industry, academia, plastics industry, and the risk assessment
community. Panelists are listed in Section 8 of this report.
This report summarizes the panel's discussions and recommendations. It is intended to serve as a
reference for EPA and others in prioritizing research and other actions.
Current State of Electronics Recycling
The number of companies engaged in some form of electronics recycling is growing rapidly.
Recycling firms vary in size and scope, ranging from small companies specializing in a single
process (e.g., shredding circuit boards) to large companies that cover many parts of the recycling
chain. These firms collectively process over a billion pounds of electronic equipment each year,
producing many valuable commodity streams that can be used in new products.
The United States does not have a national electronics recycling program and EPA estimates
suggest that a majority of the nation's electronic information products (computers, faxes,
printers, and phones) are not currently recycled. However, a growing number of federal, state,
local, and private-sector initiatives are in place to encourage electronics recycling. For example,
the state of Maine recently enacted legislation requiring manufacturers to take back obsolete
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products and pay for recycling, while California has developed a system to fund collection and
recycling of cathode ray tube (CRT) monitors and televisions with "advance recovery tees
charged to consumers. Other countries have also established mandates or guidelines for
electronics recycling - particularly in Europe.
The discussions in the panel session underscored the fact that the expansion of electronics
recycling is taking place with very limited regulatory oversight. In addition, the absence of
widely accepted operating standards and best practices makes it difficult for recyclers who want
to "do the right thing." Federal actions may be needed to help "level the playing field." Panelists
also noted that the current maze of inconsistent state and international regulations makes it
difficult to do business. Other challenges facing the industry include changing technology (e.g.,
flat screens and smaller devices), downstream accountability, and economic viability.
Exposure Concerns
Concerns about the human health and environmental impacts of electronics recycling are related
to the composition of electronic waste. Computers and other electronic devices contain hundreds
of chemical constituents, ranging from large quantities of metals and plastics to trace amounts of
substances in circuit boards, batteries, bulbs, and flat screen displays. Several of these chemicals
are known to be toxic, including lead, found in CRTs, and mercury, found in bulbs and switches.
Other chemicals have not been studied well, but could be bioaccumulative (e.g., brominated
flame retardants). A list of chemical constituents in electronics appears in Section 3.
Electronics recycling processes could potentially cause both occupational exposures and
environmental exposures to toxic chemicals. The panelists identified the following potential
exposure points:
Occupational. Dermal or inhalation exposure to dusts or fumes from shredding,
disassembly, or thermal processes could occur. Emissions could contain lead, mercury,
beryllium or other metals, flame retardants, or other potentially toxic chemicals.
Environmental. Inhalation emissions from recycling processes could potentially occur in
the vicinity of recycling facilities. In addition, exposure to contaminated releases from
downstream materials handling (e.g., landfill leachate and smelter emissions) may pose
human health and environmental risks.
Needs Identified by Panelists
Members of the expert panel identified six key areas where further effort is needed in order to
prevent electronics recycling from posing unanticipated risks to human health and the
environment. These key areas, which Section 6 describes in further detail, are:
1. Research needs. Several parties have collected data that characterize health effects or
exposures - including studies of specific recycling processes. An important first step will
be to compile all the data available from different sources, including the government,
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academia, and recyclers themselves. Once the existing data are assembled, it would be
useful to identify critical data gaps, then conduct research to fill them.
2. Best practices guidance. The industry could benefit from clear guidance identifying
practices that are most protective of worker health and the environment. Specific areas
where best practices could be developed include exposure monitoring methods, actual
operational processes (based on process-specific research), and auditing procedures.
3. Standardization. The current framework of state and international regulations is
complicated. The industry could benefit from a clearer, more standardized regulatory
approach.
4. Communication. Panelists identified a need for greater communication, both within the
electronics recycling industry and with government and manufacturers. Recyclers and
manufacturers could both benefit by collaborating to design products that are easier to
recycle.
5. Interagency collaboration. Parts of the electronics recycling issue also fall under the
jurisdiction of other federal agencies, most notably the Occupational Safety and Health
Administration (OSHA) and the National Institute for Occupational Safety and Health
(NIOSH), which are concerned with occupational exposure. It may be useful to
collaborate with these agencies on research, education, and other related aspects.
6. Informed decisions. Panelists encouraged EPA and industry to remain mindful of
economic and monetary realities as they continue their collaboration. For example, EPA
will need to prioritize research efforts in order to make the best use of available funding.
EPA and industry can also work together to develop economic incentives and approaches
that consider all costs and benefits.
Within these six areas for further effort, panelists identified several key priorities for action.
These suggestions, which are discussed further in Section 7, include the following:
Analyze product content and key recycling processes to identify substances and exposure
points of concern.
Make a comprehensive effort to gather and review all relevant toxicology, exposure, and
process-specific data from recyclers, federal agencies, and organizations in other
countries.
Conduct research to fill gaps in the existing data on effects, exposures, and processes. In
particular, consider data needs for emerging chemicals, such as liquid crystal display
(LCD) mixtures. To evaluate leaching potential, conduct lysimeter tests.
Work to develop best practices guidance for processes, exposure monitoring, and
auditing/verification.
Develop a widely recognized certification program for electronics recyclers to help
consumers of e-cycling services readily identify recyclers that are conducting activities in
an environmentally sound manner.
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Ensure that existing protections are being enforced. For example, OSHA's lead standard
applies to all workplaces, including some electronics recyclers that may not have met
their obligation to demonstrate compliance. Also, RCRA prohibits disposal of hazardous
waste in unpermitted facilities, yet panelists stated that they believe many recycling
companies still dispose of hazardous electronic components in unpermitted solid waste
landfills and incinerators.
Improve communication within the industry and with government. Work toward a shared
understanding and a shared vocabulary.
Improve communication between recyclers and original equipment manufacturers
(OEMs). In particular, find a way to give recyclers and their employees more information
about the products and chemicals they are handling.
Although not specifically discussed at the meeting, individual panelists also suggested the
following:
Institute a nationwide solid waste disposal ban on e-scrap.
Institute a national hazardous waste exemption for e-scrap that is recycled in accordance
with environmentally sound management practices that are sanctioned by EPA.
Maintain support for integrated resource management where different resource recovery
technologies (i.e., mechanical, chemical, and thermal) are available to electronics
recyclers to ensure that materials that cannot be recycled can be landfilled in an
environmentally and economically sound manner.
EPA is well positioned to assist with several of these items, such as encouraging data sharing,
facilitating communication, spearheading the effort to develop best practices guidance, and
conducting research to fill some of the major gaps in health effects and exposure data.
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Section 1
Introduction
The rapid growth in production and use of electronic products, coupled with the increasing rate at
which these devices become obsolete, is posing new challenges for waste management. The
demand for electronics recycling services to manage obsolete products has been increasing as
state and local governments and others seek options other than disposal for properly handling
these materials. EPA supports resource conservation, which is promoted through electronics
recycling. At the same time, EPA seeks to proactively identify and mitigate any potential risks
associated with the significant increase in electronics recycling activity.
The key question being asked is: How might the increased recycling of electronics potentially
affect the environment and human health - particularly given the relatively unregulated state of
the industry and the ever-changing composition of electronic products? On May 19, 2005, EPA's
Office of Research and Development (ORD) convened a panel of experts to begin to discuss this
question. The panel included individuals from several sectors of the electronics recycling
industry, academia, the plastics industry, and the risk assessment community. The session was
part of the 2005 Institute of Electrical and Electronics Engineers (IEEE) International
Symposium on Electronics and the Environment in New Orleans. Panelists are listed in Section
8 of this report.
The panelists discussed the current state of electronics recycling and the electronics recycling
industry and, with input from several members of the audience, identified some of the key
challenges facing the industry. The panel then made recommendations for further research,
communication, and other actions that would help ensure that increased recycling of electronics
does not result in undesirable, unintended environmental and human health consequences. This
report summarizes the panel's discussions and recommendations. It is intended to serve as a
reference for EPA and others in prioritizing research and other actions.
1.1 Scope of the Issue
"Electronics" is a rather broad term: technically speaking, anything that has a circuit board could
be considered an electronic product and eventually "electronic waste." However, this report will
focus primarily on computers (both desktop and portable models), computer monitors, and
peripheral devices (e.g., printers and scanners) because:
The current electronics recycling infrastructure is largely focused on computer equipment.
These products constitute the bulk of the material entering the electronics recycling
stream, in part because they have a high turnover rate.
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. Computer equipment is more complicated than most other household electronics, and it
typically contains the broadest array of possible constituents of concern.
Recent state regulatory efforts have specifically targeted computer recycling.
For the purposes of this report, electronics recycling is defined as demanufacturing or shredding
and material separation of electronic products for purposes of recovering component parts
and/or raw materials for other uses. When collecting electronic scrap from businesses or
communities, electronics recyclers may segregate whole products for sale in reuse markets.
"Reuse" can refer to either passing on a product to another user as is or passing it on after it is
upgraded or repaired.
Electronics recycling is a global issue. Like the manufacture and sale of computer products,
electronics recycling relies on global markets. For example, an obsolete computer collected in the
United States could be resold as is in a developing nation, or it could leave the U.S. at some point
further down the recycling chain in the form of scrap or raw materials. This means that a
computer may be manufactured in one country, purchased and used in another, and recycled in
several additional countries. Thus, a regulation in any single country has the potential to directly
affect businesses in many other countries. Recent European standards provide a useful example,
as they have forced U.S.-based manufacturers selling overseas to adopt new practices in dealing
with their products as they become obsolete.
1.2 EPA's Objectives
EPA convened the May 2005 expert panel to focus on the environmental and human health
ramifications of electronics recycling. The panel was charged with three specific objectives:
1. Identify materials of potential concern.
2. Identify research or action needs to assess potential risks.
3. Assist ORD in developing a plan for action.
Recognizing that the electronics recycling industry will continue to evolve as technology
accelerates and more electronic devices are recycled, EPA is seeking to anticipate problems that
could arise in the future, and to discuss ways in which government and industry might
proactively address these potential problems through research and guidance rather than reach a
point where regulation becomes necessary.
1.3 Industry Concerns
The electronics recycling industry faces a number of challenges, such as:
Changing technology. With the rapid pace of technological development, the electronics
recycling industry constantly encounters new types of products in the waste stream. In some
cases, the construction and composition of these products may require entirely new recycling
processes, because existing technologies are not appropriate for new products or because new
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constituents interfere with processing equipment. For example, with the growth in laptop
computers has come the challenge of handling the chemical mixtures used in liquid crystal
displays (LCDs), the composition of which may be a protected trade secret. As products become
smaller and more intricate, they may be more difficult to disassemble. This creates challenges for
demanufacturing operations as well as shredding operations, which may require the prior
removal of components containing hazardous materials. Also, as flat screen technology gains
market share, more products with CRTs will become obsolete and enter the waste stream, while
at the same time, markets for recovered CRT glass will shrink creating an added challenge for
recyclers.
Lack of federal regulation. Compared with other industries, the electronics recycling industry is
relatively unregulated by the federal government. Some large facilities may be required to
comply with general permitting regulations related to air emissions or disposal, as discussed
further in Section 5.2. However, there are currently no general standards or permit requirements
specific to the electronics recycling industry. Where specific federal guidance and regulations
exist, they tend to be slow to catch up with technological change. For example, EPA's CRT rule
was still not final at the time of this publication even though CRTs are now increasingly being
replaced by flat screen technology.
Variable international standards. In general, the global electronics recycling industry has
adapted to take advantage of different levels of regulation in different countries. However, in
some ways, different standards can lead to extra complications for recyclers. For example,
Canada defines "hazardous" differently from the United States for circuit boards; thus, recyclers
have to consider multiple sets of regulations when deciding on the most cost-effective ways to
move materials across borders.
Variable standards within the United States. Individual states may differ in their definitions of
waste classifications, which can complicate matters for recyclers trying to transport materials
between states. Further, because of the relative lack of federal regulations, some states have
adopted their own mandates governing electronic waste handling. Section 2.2 discusses some of
these efforts in greater detail. Individual state efforts have begun to create a climate in which
manufacturers and recyclers will have to learn and abide by many different sets of rules regarding
what must be recycled and who is accountable for the cost.
Level playing field. Industry representatives are concerned that voluntary guidelines could put
those who follow them at a competitive disadvantage against businesses seeking to cut costs by
not following best practices.
Traceability. Most recyclers sell recovered materials and/or whole products to other downstream
handlers. Without a legal requirement for material life cycle accountability, there is little
incentive for recyclers to investigate whether these materials are being managed responsibly once
they leave their facility. Only in some cases will customers (e.g., manufacturers, large
institutions, and governments) ask for verification of responsible downstream handling.
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Economic viability. Electronics recycling must be economically viable in order to keep recyclers
in business. The industry originally focused on extracting value from the precious metals in
computer equipment. However, it has shifted somewhat toward providing an environmental
service to consumers and manufacturers, especially since newer products have smaller amounts
of valuable materials (i.e., fewer metals and larger amounts of plastic). There are a limited
number of processors for secondary plastics, and the markets for this material are less mature.
Recyclers need a steady and reliable waste stream and viable end markets for recovered materials
to stay profitable. Many need a large volume to operate at a capacity that allows them to recoup
their investment in expensive processing equipment (e.g., automated shredders). Yet many
consumers have not accepted that end-of-life services for products they have used are necessary
and there is no direct regulatory mandate to provide the impetus that might change this thinking.
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Section 2
Background
2.1 Electronics Recycling Processes
While exact step-wise processes involved in electronics recycling vary widely by recycling firm
and type of product being processed, Figure 1 provides a general overview of some of the major
steps and decision points in electronics recycling. Some recyclers perform several of these steps,
while others specialize in a single step.
Electronic devices enter the recycling chain when the user decides a unit is obsolete or no longer
needed and brings the unit to a collection point, hi some cases, products are taken back by the
original equipment manufacturer (OEM) or leasing company; in others, municipalities, retailers,
nonprofit organizations, and others collect equipment directly from users.
Once electronic devices are in the recycling chain, they enter the "asset management" stage, in
which each piece of equipment is evaluated to determine if it can be resold, easily repaired, easily
upgraded, or if it has components or subassemblies with any resale value. Those products that
can be reused or resold are directed to resellers, both domestic and international. Often, broken
equipment that is not saleable in the United States is sold to markets in developing countries.
Some products may be refurbished for sale using parts from other machines.
This report focuses on the stages of the recycling process that take place after the asset
management stage. There are two main types of recycling operations: (1) demanufacturing and
(2) shredding and material separation.
Electronic waste that goes to a demanufacturer is manually disassembled. Some components may
be salvaged for resale, while the rest will be directed into resource recovery streams - e.g.,
sending CRTs to a glass recycler or smelter. Components that hold no value as recycled material
may be disposed of as non-hazardous or hazardous waste, depending on the composition.
Shredding and material separation operations are automated. Shredders may shred whole pieces
of equipment, but often there is some degree of demanufacturing prior to shredding to remove
potentially hazardous bulbs or batteries. Shredders may also process secondary component
streams from demanufacturers, such as CRTs. Generally after shredding, a series of magnets and
other separation technologies are utilized to separate commodities.
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Obsolete electronics
(in use or in storage)
Asset Management
Can it be repaired/upgraded?
NO
Shredding and Demanufacturing/
Material Separation Parts Recovery
Automated processes
(e.g., grinding and
pelletizing)
Automated material
separation
(e.g., by magnet)
Manual disassembly
Parts recovery
Material sorting
Product resale
Parts resale
Primary Material Processing
CRT glass
Metals
Non-ferrous mix
Mixed plastics
Sorted plastics
Waste
1
1
1
1
,
Reuse by CRT manufacturers
Smelting/refining
Energy recovery
Plastics recycling/product manufacturers
Waste Management
Waste disposal
(landfill, etc.)
Hazardous waste
disposal
Is the waste
hazardous?
Figure 1. Key Steps in the Recycling Process
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The final step in electronics recycling is "primary materials processing." At this stage, leaded
glass from CRTs may be recycled directly into new CRTs (the "glass-to-glass loop") or smelted
to separate the glass from the lead (the "glass-to-lead loop"). Metals can be recovered and reused
through smelting and refining. These metals include aluminum, copper, steel, and precious
metals. Sorted plastics may be directly reused by manufacturers of plastic goods or be sent to a
plastics processor for additional purification. Mixed plastics may be reused in structural products
(e.g., outdoor furniture, plastic lumber products, railroad ties) or road paving materials, but these
outlets are limited to secondary plastics with low contamination. More contaminated mixed
plastics are often burned for energy recovery. Mixed plastics can also be processed into various
petrochemicals, but currently this is only done in Europe and Asia as it is not economically
feasible in the United States. Like earlier steps, primary processing may generate some materials
that cannot be reused or recycled safely or economically. These wastes may include unmarketable
mixed plastics and hazardous materials such as heavy metals, and must be managed accordingly.
2.2 Existing Recycling Efforts
According to the International Association of Electronics Recyclers (IAER) 2003 Industry
Report, more than 400 companies in the United States are considered to be electronics recyclers.1
As of 2003, these firms collectively processed over 1.5 billion pounds of electronic equipment
annually, yielding approximately 900 million pounds of recyclable materials and annual revenues
in excess of $700 million. There are a few companies that process large volumes, but most
companies in the industry are relatively small. The 400 companies include nonprofit
organizations that collect and resell computer equipment, as well as for-profit brokers, resellers,
and exporters who facilitate the movement of materials through the recycling chain. Since the
2003 IAER report was published, the number of recyclers has more than doubled, according to an
IAER official.
EPA estimates that approximately 19 percent of the nation's obsolete electronic information
products (computers, fax machines, printers, and phones) are being recovered for recycling or
reuse.2 The rest are either disposed of or stored (e.g., in attics or closets). Other estimates vary
widely, but all suggest that the vast majority of electronic waste is not entering the reuse or
recycling stream. The United States does not currently have a national electronics recycling
program. However, the federal government is engaged in a number of efforts to promote the
responsible recovery and recycling of electronics. These efforts include the following:
Plug-In To eCycling, an EPA consumer electronics campaign launched in January 2003
as a component of EPA's Resource Conservation Challenge (see
http://www.plugintoecycling.org/). The campaign focuses on the following three goals:
o Providing the public with information about electronics recycling and increasing
their opportunities to safely recycle old electronics.
1 International Association of Electronics Recyclers. 2003. IAER Electronics Recycling Industry Report: 2003.
Albany, NY: IAER.
2 U.S. EPA. 2003. Municipal Solid Waste in the United States: 2001 Facts and Figures. EPA530-R-03-011.
Washington, DC: U.S. Environmental Protection Agency, Office of Solid Waste and Emergency Response.
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o Facilitating partnerships with communities, OEMs, and retailers to promote
shared responsibility for safe electronics recycling. For example, Office Depot and
Hewlett-Packard (HP) sponsored a 21/2-month free electronics collection and
recycling program.
o Establishing pilot projects to test innovative approaches to safe electronics
recycling.
The Recycling Electronics and Asset Disposition (READ) contract, a government-wide
contract being used by EPA to promote and advance the disposition, reclamation, reuse,
and recycling of electronic assets held throughout the federal sector. See
http: //www. epa. gov/oam/read.
The Federal Electronics Challenge, a voluntary interagency partnership to better manage
electronic assets. See http://www.federalelectronicschallenge.net/.
The Electronic Product Environmental Assessment Tool (EPEAT), a tool for evaluating
the environmental performance of electronic products throughout their life cycles. The
tool was developed to meet the growing demand by large institutional purchasers -
particularly state and federal government agencies - to buy "greener" electronic products.
EPEAT uses criteria, developed using a multi-stakeholder consensus process, to assess
products and assign ratings in several categories of product performance, such as
materials selection and design for end-of-life. See http://www.epeat.net/.
hi the absence of a national recycling infrastructure, several states have created their own
programs to promote and fund recycling of electronics. For example, Maine passed a law that
holds manufacturers responsible for the costs of handling and recycling all household-generated
waste computers, monitors, and televisions once they are received at consolidation facilities in
the state. Maryland recently legislated that manufacturers selling computers in the state must pay
an annual registration fee to help pay for recycling CRTs, while California has established a
program to reimburse authorized collectors and recyclers with money collected from an advance
recovery fee (ARF) at the point of sale on television and computer CRT screens.
Bills on waste electronics management have been and are being considered in dozens of other
states. California, Minnesota, Massachusetts, and Maine have banned CRTs from municipal solid
waste landfills. Many states have created educational programs to promote reuse and proper
recycling of electronics, and some have also provided financial assistance to municipalities to
help pay for local collection and recycling programs.
Thus, at present, most recycling of consumer electronic waste in the United States takes place
through state-sponsored initiatives and voluntary programs offered by the private sector Some
OEMs have taken steps toward creating their own recycling programs - in part due to state
regulations and in part due to demands from customers who buy or lease large amounts of
computer equipment and want to make sure it is disposed of properly. For example, HP and Dell
both offer computer recycling services to their customers for a fee
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By comparison, many other countries have taken greater steps to promote electronics recycling.
The European Union (EU) issued the Waste Electrical and Electronic Equipment (WEEE)
Directive in January 2003, requiring OEMs to take responsibility for the end-of-life recovery of
virtually all consumer electronic products ("anything with a plug") using the best available
technology. EU member nations must use manufacturer funding to implement collection systems,
and must collect annual data on the number of products marketed, collected, reused, and
recovered. In Asia, South Korea has also mandated a take-back program, while Taiwan and
Japan have officially mandated electronics recycling. In Japan, the take-back program is run
through collection co-ops for manufacturers. In Canada, an industry-led coalition called
Electronics Product Stewardship Canada is working on developing a national electronics end-of-
life program (http://www.epsc.ca/): the province of Alberta has set up its own program, with an
ARF on computers and televisions, to fund collection, transport, recycling, and education.
2.3 Existing Controls on Electronics Recycling Operations
As already mentioned, there are no industry-specific regulatory controls for electronics recyclers.
Recyclers must comply with general regulations concerning occupational health and toxic
releases to the environment, as is discussed further in Section 5. However, no specific system is
in place to evaluate recycling processes or offer recyclers a standard for "compliance."
Several multilateral agreements and directives have been developed to address the electronics
recycling issue from an international perspective. Significant examples include the following:
The Basel Convention on the Control of Trans boundary Movements of Hazardous Waste
(adopted 1989). This framework requires a manifest and notification system to account
for hazardous wastes including discarded hazardous electronic equipment - that cross
international borders. The Convention also prohibits parties to the Convention from
trading hazardous wastes with countries that are not parties to the Convention, which
includes many developing countries. Basel does not apply to U.S. recyclers because the
United States is not a party to the convention.
Organization for Economic Cooperation and Development (OECD) technical guidance.
In February 2003, OECD published guidance on environmentally sound management for
used and scrap personal computers (PCs). This guidance describes standards for
refurbishment, disassembly, material recovery, component treatment, energy recovery,
transport, and packaging. The United States is a member of OECD.
The EU's Restriction of Hazardous Substances (RoHS) Directive. Issued in January 2003,
this directive bans the use of lead, mercury, cadmium, hexavalent chromium, and certain
brominated flame retardants in most electric and electronic products sold in the EU by
July 1, 2006, with a few exceptions. This directive will indirectly affect electronics
recyclers and the processes they use. In North America, the multinational Commission for
Environmental Cooperation is currently meeting with the electronics industry to discuss a
voluntary challenge to meet the RoHS Directive in the United States, Canada, and
Mexico. U.S. manufacturers selling products in the EU will have to comply with these
restrictions.
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2.4 Projections for the Future: Changes and Challenges
Although it is impossible to predict exactly what the electronics recycling landscape will look
like years from now, current trends suggest that numerous changes and challenges will confront
government and industry in the future.
The amount of material designated for recycling will probably continue to rise as technology
becomes cheaper, computers and cell phones become more widespread, and product life spans
continue to be limited because of the fast pace of product innovations. The number of CRT TVs
entering the recycling stream could also rise in the near future due to the pending switch to
digital TV and flat panel technology.
The composition of electronic waste will also continue to change. Increasingly, consumers are
choosing to replace CRT monitors and TVs with flat screen technologies such as LCDs and
plasma screens, which pose their own unique challenges to recyclers. Electronics also appear to
be trending toward smaller and more complicated devices, which may make it more difficult for
recyclers to recover value from individual constituents or components. Other new technologies
on the horizon include:
Nanotechnology - developing materials at the molecular level.
Microelectromechanical sensors - tiny wireless monitors.
Interactive multimedia - electronic and interactive news delivery.
Organic light-emitting diodes - display screens that directly emit light.
3-D displays - three-dimensionality built into the screen display.
In the future, some new technologies may be designed to facilitate recycling. For example, some
researchers have proposed a system of radio frequency identification (RFID) tags that can be
affixed to components within a computer. An RFID scanner at the recycling facility could link to
a database containing information about the composition of each component.
To date, there have been some efforts to create a national recycling infrastructure in the United
States, and it is likely that some of these efforts will continue into the future. In January 2005, a
bill called the National Computer Recycling Act was introduced into the House of
Representatives; this act would establish a grant program to fund collection and recycling of
electronic waste, funded by a fee on new computers. In the Senate, a bill introduced in March
2005 (the Electronic Waste Recycling and Promotion and Consumer Protection Act of 2005)
would create a national infrastructure to recycle computers, laptops, monitors, and televisions,
with tax credits to reward companies and households that recycle.
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Section 3
Composition of Electronics Scrap
3.1 Chemical Constituents
Electronic devices can contain hundreds of chemical substances. Table 1 lists some of the most
significant constituents from a recycling perspective; these materials are notable because of their
prevalence, value, or toxicity. Table 1 also describes where each substance is found within a
typical product. By mass, the most prevalent materials tend to be plastics and ferrous metals (e.g.,
steel), which generally form the overall structure or housing of the device. Several other
substances are present in small quantities yet play a critical role in complicated chips and
circuitry; these include precious metals like gold, as well as toxic heavy metals like mercury.
Table 1 is not a complete list. Many additional elements and compounds can be found in trace
amounts in semiconductors, circuit boards, monitors, and LCD displays, and as functional
additives in plastics.
Table 1. Notable Materials Found in Electronics
Material
Aluminum/alloys
Antimony
Arsenic
Barium
Beryllium
Brominated flame retardants
Cadmium
Chromium
Copper
Gold
Lead
Lithium
Mercury
Where Found
Structural; disk drives
Flame-retardant; solder alloy in cabling; small amount
in CRT glass
Integrated circuits (with silicon)
Contained in CRT glass
Switches, relays, and circuit board connectors
(copper-beryllium alloy)
Added to plastic components, including housings,
circuit boards, and cables
Batteries (nickel-cadmium); circuit board plating;
small amount as coating on CRT monitor screen
Metal plating (anti-corrosion treatment); small amount
as hardener/stabilizer in plastic components
(hexavalent)
Wires; connectors
Printed circuit boards
Radiation shielding in monitor CRT (frit is 70% lead;
funnel glass is 22-25% lead oxide, by weight); solder
on circuit boards; cable assemblies; batteries; paints;
piezoelectric devices; sealing glasses
Batteries
Miniature switches; batteries; fluorescent back light
for flat screen/LCD display
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Table 1. (Continued)
Where Found
Printed circuit boards
PCBs (polychlorinated biphenyls)
Capacitors; transformers; cabling (production of PCBs ceased in 1977)
Pentachlorophenol
Capacitors
Phosphorus
Monitors
Plastics:
ABS (acrylonitrile-butadiene-styrene)
polycarbonate
polyethylene
polypropylene
polystyrene
PVC (see separate listing)
Structural (housing, etc.); circuit boards; wire coatings
Platinum
Printed circuit boards
PVC (polyvinyl chloride)
Housings; wire coatings
Silicon
Integrated circuits
Silver
Printed circuit boards
Steel
Structural
Zinc
Batteries
3.2 Material-Specific Challenges
At EPA's May 2005 meeting on electronics recycling, panelists and members of the audience
identified a number of components and materials that pose a particular challenge to recyclers.
Specific streams of concern include the following:
CRT glass. Recyclers noted that leaded CRT glass is heavy and costly to transport. Of particular
concern are regulatory inconsistencies that increase processing costs. They expressed the need for
clear direction on what constitutes hazardous waste, since definitions can vary among states and
countries. Transportation costs are much higher if the cargo is deemed "hazardous." Other
concerns about CRT glass relate to recycling practices. Common practices currently include
removing CRT yokes with hammers and crushing the glass via "gravity drop." However, it is
unclear whether further study would find these to be best practices. Finally, recyclers noted that
in addition to the concern of lead exposure, workers handling CRT glass have suffered back
injuries and cuts, even when wearing protective gloves.
Mercury. In flat panel displays of portable computers, the small fluorescent bulb used as a
backlight typically contains 4 to 12 milligrams of mercury.3 Mercury is also found in switches
and relays in computers, medical equipment, and telecommunications devices. Recyclers agreed
that identification and removal are primary concerns, noting that mercury-containing switches
and bulbs are not labeled as such. Even if a switch or bulb can be identified, it may be hard to
- Williams, E. 2003. "Environmental impacts in the production of personal computers." In: Kuehr, R. and Williams,
E., Eds. 2003. Computers and the Environment. Dordrecht, The Netherlands: Kluwer Academic Publishers pp
41-72. 'FH'
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remove, and breakage can be a problem. For example, to remove the mercury backlight in a
laptop, the recycler may have to remove up to 27 screws. As a result, many recyclers do not
remove mercury components (they are not required to do so). Because these bulbs are highly
energy efficient and there is no adequate mercury-free alternative at this time, mercury use in
lighting applications is exempted from the EU RoHS Directive's mercury ban.
Beryllium. Recyclers are concerned that parts containing this highly toxic metal can be hard to
identify and handle appropriately. In general, recyclers need to ensure that their processes do not
liberate beryllium dusts, and secondary smelters need to be particularly careful when handling
copper alloys that contain beryllium. Dermal exposure is an additional concern.
Batteries. Electronic devices contain many different types of batteries; these include standard
alkaline, nickel-cadmium, lithium ion, and lead-acid types. Batteries may not be labeled, yet
some types are especially toxic and may need to be removed before shredding, both to protect
worker health and to avoid contaminating commodity streams. As with mercury components,
safe removal of batteries may be labor-intensive.
Plastics. Overall, plastics make up a significant proportion of the material handled by electronics
recyclers. Plastic has good recovery potential, but for many applications, processors of plastic
scrap require that plastics be sorted by type, and sometimes by color within a type. Sorting can be
difficult for recyclers because plastics in electronics are not always labeled by type, and while the
technology exists to physically separate by type, it is currently not always economically feasible
at the end-of-life product demanufacturing stage. Color separation is even more difficult, given
the multitude of different products that recyclers handle. Further, recyclers note that domestic
markets for recycled plastics tend to be volatile and heavily dependent on the price of oil. Thus,
most mixed plastics are currently landfilled, exported, or burned to produce energy if suitable
energy recovery facilities exist. The technology to recycle mixed plastics into petrochemicals
exists and is used in Europe and Asia, but it currently is not being used in the United States.
Brominated flame retardants (BFRs). This category includes polybrominated diphenyl ethers
(PBDEs) and tetrabromobisphenol-A, which are among the additives most commonly embedded
in circuit boards and plastics in electronic devices. BFRs are a concern because they are
persistent and bioaccumulative and; therefore, could pose risks to human and ecosystem health.
Studies have shown rapidly rising levels of PBDEs in human breast milk in Sweden and North
America, as well as evidence of elevated levels of PBDE and other flame-retardant compounds in
workers engaged in the demanufacturing of computers.4 However, the toxicity and the exposure
routes of many types of brominated flame retardants have not been extensively studied and are
not well understood. Although PBDEs have been banned for use in electric and electronic
products sold after July 1, 2006, in the European Union, and the chemical industry voluntarily
agreed to stop production of penta- and octa-BDEs in the United States in 2004, older products
coming into the waste stream will continue to contain these compounds for quite some time.
Other concerns about brominated materials include their potential to generate certain halogenated
4 Williams, E. 2003. "Environmental impacts in the production of personal computers." In: Kuehr, R. and Williams,
E., Eds. 2003. Computers and the Environment. Dordrecht, The Netherlands: Kluwer Academic Publishers, pp.
41-72.
13
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dioxins and furans during open burning and improper incineration. As a practical matter,
recyclers noted that it is often more difficult to find recycling markets for plastics with embedded
BFRs.
Plasma screens and liquid crystal displays (LCDs). Recyclers expressed concern that these
emerging technologies contain new or uncommon chemical mixtures, the exact composition of
which is often known only to the OEM that holds the patent. In general, it is known that LCD
screens contain a mixture of polycyclic aromatic hydrocarbons (PAHs) and halogenated aromatic
hydrocarbons.6 There have not been peer-reviewed scientific studies of the carcinogenic potential
of LCD mixtures,7 although there is evidence that some chemicals within these mixtures may be
carcinogenic in humans (e.g., certain PAHs).8 Recyclers need more information in order to
design appropriate processes. For now, they generally shred plasma or LCD displays, since these
cannot easily be demanufactured.
Toners and inks. Some toners and inks are potentially carcinogenic. These materials also pose a
potential explosion hazard, create a mess in shredding operations, and contaminate commodity
streams. When recyclers remove whole ink and toner cartridges, they find few options for reuse.
Manufacturers do not typically reuse inks and toners, and once products with different formulas
are commingled, they cannot be reused for the same application. Further, while recovery is
technically feasible, it is cheaper to landfill the cartridges (allowed in some jurisdictions) or use
them for waste-to-energy.
Other materials. Members of the expert panel noted a few other materials that may present
significant issues to recyclers. hi some instances, metals and abrasives may damage processing
equipment. For facilities handling computer chips, gallium-arsenide or other toxic blends may be
a concern.
5 INEMI, 2004. 2004 Roadmap: Environmentally Conscious Electronics. International Electronics Manufacturing
Initiative. December, 2004.
u i^ o, ^3-"Envir°TentelpactslntheproductionofPersonalc°mputers.^
IU Eds. 2003. Computers and the Environment. Dordrecht, The Netherlands: Kluwer Academic Publishers, pp.
1 Ibid.
U.S. EPA_ 2005. Integrated Risk Information System (IRIS). Washington, DC: U.S. Environmental Protection
Agency. Online at http://www.epa.gov/iris/.
8
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Section 4
Potential Exposure Pathways
There are several potential routes of exposure to hazardous substances associated with the
processing of electronic waste. For many of these chemicals, toxicologists have conducted ample
research about the health effects caused by various levels of exposure. However, much less is
known about the actual exposures associated with the handling of electronic waste at recycling
facilities. To evaluate these exposures, it is important to know the level and duration of exposure
(i.e., the dose) as well as the exposure route or pathway (e.g., inhalation). In addition, effects can
be highly dependent on particle size and form. This section outlines what is known about
exposures related to electronics recycling, while Section 6 addresses needs for additional
research.
Potential exposures can be divided into two categories: occupational exposures (which occur
within the recycling facility) and environmental exposures (which occur outside it).
4.1 Occupational Exposure
Occupational exposures to hazardous substances could occur in several ways over the course of
the workday. Chief among these are recycling processes that produce dust. Processes of concern
include shredding or grinding operations and processes used to crush leaded CRT glass. Crushing
or shredding materials that contain heavy metals may liberate some of the metal into the air,
where fine particulates can enter the body via inhalation. In cases of dust inhalation, the
associated health effects may be highly dependent on the size of dust particle that the recycling
process produces. A related hazard is the inhalation of vapors produced when hazardous
components are broken, particularly mercury vapors from broken bulbs. Other potential
inhalation exposures include hazardous fumes from smelting or other thermal processing
operations.
In addition to inhalation exposure, dermal exposure may pose an occupational risk. Workers
handling hazardous materials without gloves or other protection may absorb dust particles
through the skin, provided the particles are sufficiently small. A particular concern is that
workers who cut themselves while handling sharp CRT glass may risk dermal absorption of lead.
Government, corporations, and researchers have gathered some data on occupational exposures
in the recycling industry. Available data include the following:
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A recent Swedish study analyzed exposure to PBDEs among a group of computer ^
technicians, who spent much of their workday dismantling and rebuilding computers.
This study found elevated levels of PBDEs and other flame retardants in blood serum.
Some companies actively monitor inhalation exposure by outfitting employees with
personal monitoring devices. Data from personal monitors may be more valuable than
data from blood tests because blood level results can be confounded by exposures to
substances outside of the workplace. Some companies may have accumulated a
substantial amount of exposure data by now and this information might help in assessing
exposures across the industry.
Research institutions such as the National Jewish Medical and Research Center in
Denver, Colorado, have collected a great deal of data about beryllium exposure and the
progressive lung disease it can cause (chronic beryllium disease, or CBD). CBD is
believed to have led to several hundred deaths in the United States since the 1940s,
including some associated with scrap metal recycling.10 Although CBD has historically
been associated with larger volumes of beryllium (e.g., military applications), inhalation
exposure to even tiny amounts of this toxic metal during handling or smelting can put
workers at risk. Thus, if there is even a trace of beryllium or beryllium alloys in electronic
equipment, there could be risks associated with recycling processes. (Recent research
suggests that sensitization to beryllium, which is a precursor to CBD, may occur as a
result of dermal exposure.11 Gloves are one simple way to reduce the risk of this
exposure.)
4.2 Environmental Exposure
In addition to occupational exposure pathways, electronic waste management operations could
expose people to hazardous substances even if they do not work in waste handling facilities.
These non-occupational exposures could occur through a variety of environmental media, such as
air, drinking water, or soil. The following scenarios highlight a few of the most plausible routes
of environmental exposure.
Air emissions. Recycling facilities may emit hazardous substances to the outside air through
point sources (vents and stacks) or fugitive releases (general releases not routed through a
controlled exit point). Air emissions from electronics recycling could potentially include the
venting of dust generated by demanufacturing, shredding, or compacting processes, as well as
gaseous and particulate byproducts from thermal processing - e.g., refining or smelting. Thus, air
emissions have the potential to expose nearby individuals to heavy metal particulates, harmful
byproducts of combustion, and other hazardous substances associated with the processing of end-
Jakobsson, K., Thurreson, K., Rylander, L., Sjodin, A., Hagmar, L., and Bergman, A. 2002. "Exposure to
polybrommated diphenyl ethers and tetrabromobisphenol among computer technicians." Chemosphere 46: 709-
716.
Roe, S. 2001. "Deadly metal's use endangers workers: Employers often don't warn about risks from beryllium."
Chicago Tribune. 29 July, 2001.
Tinkle, S.S., Antonini, J.M., Rich, B.A., Roberts, J.R., Salmen, R., DePree, K., and Adkins, E.J. 2003. "Skin as a
route of exposure and sensitization in chronic beryllium disease." Environmental Health Perspectives 111(9):
1202-1208.
16
9
10
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of-hfe electronic devices. To assess these exposures would require either ambient air monitoring,
a combination of stack testing and dispersion modeling, or engineering calculations.
Landfill leachate. When a material with hazardous constituents is landfilled, there is some risk
that harmful substances can leach out of the material and enter the soil, groundwater, or nearby
lakes and streams. Contaminated soil and water could lead to several different human exposure
scenarios, including dermal exposure via water or soil, ingestion or inhalation of particles from
soil, and ingestion via drinking water. Several tests have been designed to assess the risk that a
given material will leach. EPA uses the Toxicity Characteristic Leaching Procedure (TCLP) to
determine whether a material should be classified as hazardous under RCRA. TCLP studies of
CRT monitors and circuit boards have indicated that the United States' regulated limit of 5.0
milligrams per liter for lead is exceeded.12'13'14 However, in a review of several recent studies, the
Solid Waste Association of North America (SWAN A) found that leachate from existing
municipal solid waste (MSW) landfills generally has relatively low levels of metals.15
Recognizing the limitations of TCLP tests, researchers have developed lysimeter leaching tests,
which more accurately simulate movement of chemicals through landfill waste.
12 Townsend, T., Jang, Y., Tolaymat, T., and Jambeck, J. 2001. Leaching Tests for Evaluating Risk in Solid Waste
Management Decision Making. Draft report. Gainesville, FL: Florida Center for Solid and Hazardous Waste
Management.
13 Townsend, T., Musson, S., Jang, Y.C., and Chung, I.H. 1999. Characterization of Lead Leachability from
Cathode Ray Tubes Using the Toxicity Characteristic Leaching Procedure. Report #99-5. Gainesville, FL:
Florida Center for Solid and Hazardous Waste Management.
14 Yang, G. 1993. "Environmental threats of discarded picture tubes and printed circuit boards." Journal of
Hazardous Materials 34(2):235-243.
15 O'Brien, J. 2005. "Recent studies indicate minimal heavy metal releases from MSW landfills: A summary of the
SWANA Applied Research Foundation's findings." MSW Management 15(3). Online at
http://www.mswmanagement.com/mw 0505 recent.html.
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Section 5
Existing Controls: The Current Regulatory Framework
5.1 Occupational Standards
The Occupational Safety and Health Administration (OSHA) does not have any regulations
directly targeted at the electronics recycling industry or at specific recycling processes. However,
OSHA does have a number of general regulations in place to protect the health and safety of
workers in any industry - including electronics recycling. Notable regulations include the
following:
Substance-specific standards (29 CFR Part 1910 Subpart Z). For some toxic chemicals, OSHA
has established detailed rules that limit all forms of occupational exposure. Among the chemicals
potentially encountered in the context of electronics recycling, lead, cadmium, and inorganic
arsenic each have a specific OSHA rule. A beryllium rule is currently in development. To comply
with these rules, a facility handling the substance in question must first make an initial
determination of the level of possible exposure - typically by measuring or estimating the
concentration present in the air. If the level of exposure exceeds the "action level" outlined in the
rule, further sampling, medical monitoring, or other protective or corrective action may be
required. For electronics recycling, OSHA's substance-specific rules - particularly the lead rule -
are critical for the protection of human health.
Permissible Exposure Limits (PELs) for air contaminants (29 CFR Part 1910 Subpart Z). For
many other substances, OSHA has set maximum levels to which workers at any company may be
exposed, hi general, these PELs are for 8-hour time-weighted average airborne concentrations -
reflective of exposure over the course of a workday - but for some contaminants, OSHA has also
established limits on peak or ceiling concentrations that occur within the 8-hour averaging
period. If concentrations exceed the PEL, the facility must either reduce them (e.g., by enclosing
the process or by improving ventilation) or provide employees in the affected area with
respiratory protection (e.g., a respirator). OSHA PELs are in effect for a number of substances
associated with electronics recycling, including mercury, other metal dusts, and general
"nuisance" dusts. No PELs have been established for BFRs or many of the more uncommon
chemicals found in flat screen technology.
Hazard communication (29 CFR Part 1910.1200). OSHA requires that employees be informed of
what substances they are handling and what hazards may be associated with exposure to these
substances. Any workplace where employees are exposed to hazardous chemicals must have a
written plan that describes how the hazard communication standard will be implemented in that
facility. Unfortunately, recyclers may have a difficult time acting on these provisions because
they are not always aware of the exact composition of the materials they are handling.
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Manufacturers are required to make a "hazard determination" and communicate it via Material
Safety Data Sheet (MSDS) to all downstream users of their products. However, the MSDS is
often not passed on to the recycler and may be difficult to obtain from OEMs.
Other OSHA regulations (29 CFR Part 1910). OSHA has many other regulations that apply to all
workplaces (including electronics recycling facilities). Additional health regulations include
standards for respiratory protection (i.e., respirator selection and fit) and noise exposure. Major
safety regulations include provisions for machine guarding and lockout/tagout, which are
designed to protect workers from dangerous machines with many moving parts - e.g., automated
shredders.
5.2 Environmental Regulations
On the federal level, no regulations have been developed specifically to address the
environmental impacts of electronics recycling. However, there are a number of general
environmental regulations that may apply to electronics recyclers if the size and scope of their
operations meet certain criteria. Key environmental regulations include:
RCRA. Of all the current federal environmental regulations, the one that affects electronics
recyclers most significantly is probably RCRA, which governs the handling and disposal of solid
waste. RCRA establishes criteria (e.g., ignitability, corrosivity, reactivity, or toxicity) for
determining whether a waste is officially "hazardous" and controls the generation, transportation,
treatment, storage, and disposal of such wastes. RCRA also establishes a general framework for
the management of non-hazardous wastes. Because RCRA follows a "cradle-to-grave" approach,
electronics recyclers will find that the ultimate fate of any hazardous residuals will be regulated -
e.g., through rules for the disposal of lead or mercury. However, RCRA contains exemptions that
could exclude some recycling operations from strict regulation. Most notably:
The Conditionally Exempt Small Quantity Generator (CESQG) exclusion, which covers
any entity generating 220 pounds (100 kilograms) or less of hazardous waste per month
(40 CFR Part 261.5(a)). Under RCRA, wastes from CESQG and household wastes (40
CFR Part 261.4(b)(l)) are not classified as "hazardous."
Shredded circuit boards being recycled, which are not considered hazardous provided that
they are containerized prior to recycling, and provided that all mercury switches, mercury
relays, and nickel-cadmium or lithium batteries have been removed prior to shredding (40
CFRPart261.4(a)(14)).
The disposal of non-hazardous wastes is governed by RCRA Subtitle D; this includes wastes
exempted from hazardous waste requirements under the provisions above. Subtitle D provides
technical requirements for any municipal solid waste (MSW) landfill, including criteria for
location, design, and operation. These requirements are designed to protect human health and the
environment by limiting potential exposure to contaminants from all pathways. Among other
things, an MSW landfill is required to have a flexible membrane liner, a leachate collection
system, and a groundwater monitoring program.
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Technical requirements for hazardous waste disposal are outlined in RCRA Subtitle C, again
with the intention of protecting human health and the environment. To minimize the toxicity
and/or mobility of certain substances, Subtitle C provides standards for treatment that must occur
before disposal. For some substances, the standards give a maximum allowable concentration;
for others, they require that a specific technology be used to physically or chemically alter the
substance. Subtitle C includes more stringent technical criteria for hazardous waste landfills;
these include a double liner, a double leachate collection and removal system, and a leak
detection system. If hazardous wastes are combusted instead of landfilled (e.g., waste-to-energy),
the facility must comply with operation and control standards designed to ensure that hazardous
constituents are sufficiently destroyed or contained.
Clean Air Act Amendments (Title V). Under Title V of the 1990 Clean Air Act Amendments, any
stationary source releasing more than a certain mass of chemicals into the air is required to obtain
an operating permit from the state in which it is located. For hazardous air pollutants (HAPs), the
threshold for Title V permitting is 10 tons per year of any single HAP emitted to the air, or 25
tons per year of all HAPs combined. Smelters and waste-to-energy facilities in the United States
would almost certainly be regulated under Title V, which specifies maximum achievable control
technology (MACT) standards, as well as emission limits after controls have been installed.
However, toxic releases from many smaller recycling operations are probably below the
applicable thresholds.
Clean Water Act. The Clean Water Act authorizes EPA to regulate water pollution by requiring
discharge permits and by setting wastewater standards for industry. Any company with
wastewater or significant stormwater discharges would likely fall under these regulations.
Electronics recyclers generally do not have industrial wastewater streams.
Toxic Substances Control Act (TSCA). Under section 4 of TSCA, EPA can place restrictions on
the manufacture, processing, use, or disposal of certain chemicals to protect against
"unreasonable risk to human health or the environment." hi general, TSCA restrictions apply
more to manufacturers than to disposal companies, since many provisions have to do with the
contents of new products (e.g., lead-free paint). EPA has exercised TSCA authority over disposal
of a few chemicals, including lead, and is working on similar provisions for mercury-containing
products. However, RCRA is still the major regulatory framework governing waste management.
Note that TSCA does have very specific requirements for the handling and disposal of
polychlorinated biphenyls (PCBs), which an electronics recycler would probably only encounter
if handling appliances sold before the late-1970s ban on PCBs.
State regulations. Because the federal regulations described above generally only set minimum
standards, in many cases individual states are free to implement stricter controls. For example,
states may choose to:
Use lower thresholds in determining whether a facility must obtain permits.
Regulate solid waste from CESQGs, which are ordinarily excluded from RCRA.
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Implement universal waste regulations in excess of the federal regulation, which currently
does not include electronics.
Further restrict the use or disposal of certain chemicals.
Individual states control many of the permitting processes established by federal regulations (e.g.,
Title V), which allows them to integrate their own requirements and restrictions. New York is
one state that has specifically worked to highlight state regulations that may apply to the
electronics industry; with a grant from EPA Region 2, the state has published a guide to help the
industry understand and comply with the applicable state rules. See
http://www.epa.gov/Region2/p2/electron.pdf.
5.3 Industry and Other Activities Related to Environmental Management
hi the absence of federal standards for environmentally sound management in the electronics
recycling industry, organizations within the industry have developed some standards of their
own. Notable industry efforts include:
IAER certification. IAER, the major trade association for the electronics recycling industry, has
developed a certification process for its members. The IAER framework focuses on management
systems, including general business practices, environmental management (similar to ISO
14001), quality management (similar to ISO 9001), and health and safety. Through certification,
IAER aims to:
Support and promote high standards of environmental quality and regulatory compliance
in the electronics recycling industry.
Establish and maintain a formal process to certify that an electronics recycling company
is using high-quality business practices.
Provide a service to IAER member companies to help them improve their management
systems and gain recognition as high-quality electronics recyclers.
Recognize IAER member companies as "Certified Electronics Recyclers" if they are
found to meet the IAER certification criteria as a result of a formal, objective certification
process.
Promote the fact that organizations seeking to dispose of electronics equipment will be
able to have confidence in selecting Certified Electronics Recyclers as their service
providers of choice.
To gain certification, a company must undergo a thorough professional audit. IAER has
developed guidance to help member companies prepare for this audit. See http://www.iaer.org/.
ISRI standards. The Institute of Scrap Recycling Industries (ISRI), a trade organization
representing over 1,000 companies that process, broker, and consume scrap commodities, has
recently developed a set of environmental management standards for the industry. Called RIOS
(Recycling Industry Operating Standards), these ISO-style standards are designed to help guide
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companies' quality, environmental, health, and safety management programs. ISRI aims to make
RIOS an internationally recognized standard, as well as a domestic standard for certification. See
http://www.isri.org/.
EPA's Guidelines for Materials Management. Through the "Plug-In To eCycling" partnership,
EPA has worked with the electronics industry to develop general standards to:
Maximize reuse, refurbishment, and recycling over disposal and incineration.
Ensure that exported electronic products are being sent for legitimate reuse, recycling, or
refurbishment, and provide for special handling of components that may contain
substances of concern.
Make sure that collection, recycling, refurbishing, and disposal facilities follow
management practices that are consistent with the guidelines.
To be accepted as a partner in the "Plug-In" program, a company must demonstrate compliance
with these standards. Although EPA currently limits the partnership to manufacturers and
retailers (EPA has not yet developed standards to evaluate recyclers for membership), the
guidelines encourage any company working with electronic products to make environmentally
sound management decisions. See http://www.epa.gov/epaoswer/osw/conserve/plugin/guide.htm.
As an outcome of the EPA National Electronics Meeting in March 2005, EPA plans to convene a
multi-stakeholder group to work on developing standards and a certification scheme for
electronics recyclers.
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Section 6
Needs Identified by the Panelists
In the course of their discussion on the environmental impacts of electronics recycling, members
of the expert panel identified a number of needs that are currently unmet. Panelists offered
several suggestions on how to improve the level of information, collaboration, and coordination
between government and the recycling industry. Many of their suggestions include very clear
"next steps" to direct future efforts.
6.1 Research Needs
Panelists identified several key areas where more information is needed in order to characterize
potential human health and environmental impacts of electronics recycling. They specifically
suggested the following areas of inquiry:
Consolidate existing data and identify gaps. Many different groups have evaluated the health
effects of substances associated with electronics recycling; these include government agencies,
international organizations, and manufacturers. To a somewhat lesser extent, researchers have
also gathered information on exposures specifically related to electronics recycling processes. For
example, the National Jewish Medical and Research Center has assembled a great deal of data on
occupational exposures to beryllium.16 It would be useful to gather all relevant data, not only to
create a central information resource but also to show where data gaps remain. A particularly
important first step would be to contact major recyclers who have already gathered some
exposure data and ask if they will share what they have found.
Research to fill data saps related to health effects. Once the existing data have been evaluated,
future research should be directed toward filling key data gaps that remain. Risk assessors use
toxiciry benchmarks (e.g., RfDs, RfCs, cancer slope factors) to quantify both cancer risks and
non-cancer hazards associated with exposure to certain contaminants. Such benchmarks have not
been developed for some chemicals commonly found in electronic waste, such as BFRs.
Research to fill data saps related to exposures. Recognizing the importance of dose in
considering potential health effects, it is also critical to fill data gaps related to exposures in
electronics recycling. Suggested next steps include:
16 Newman, L.S., Maier, L.A., Martyny, J.W., Mroz, M.M., and Barker, E.A. 2003. Response of National Jewish
Medical and Research Center to OSHA Docket No. H005C, "Occupational Exposure to Beryllium: Request for
Information." Denver, CO: National Jewish Medical and Research Center. Online at
http://dockets.osha.gOV/vg001/V027B/OQ/78/61 .PDF.
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Gather occupational data from related sources. For example, CRT manufacturers may
have information about lead exposures among their employees; they may also have useful
insights about the most effective methods of monitoring occupational exposures.
Analyze the composition of materials being handled, as well as associated dusts. This
information will help identify substances that are a priority for air sampling. Include
sensitivity analyses that try to capture the potential impacts if certain components have
not been removed (e.g., if a battery or mercury bulb failed to be identified and removed).
Conduct area monitoring studies in recycling facilities. Sampling programs should be
based on an analysis of material composition, with chemicals of concern selected
according to toxicity and form (e.g., respirable).
If necessary, conduct personal breathing zone monitoring studies in recycling facilities.
As already stated, this type of study is generally preferred to assessing blood levels, since
blood tests do not screen out the effects of possible exposures outside the workplace.
If necessary, conduct stack testing or ambient air monitoring to evaluate potential ambient
air quality impacts from recycling facilities.
Conduct lysimeter tests on additional components to determine the extent to which
landfilling could lead to leaching and environmental contamination. Of particular interest
are inks and toners, which are often landfilled due to a lack of options for reuse.
Conduct additional research on processes and operations. It is not enough to evaluate exposures
in one facility, because different processes can lead to very different levels of exposure.
Researchers should familiarize themselves with common practices throughout the industry and
evaluate all possible points of exposure. Common processes expected to cause elevated
exposures should be thoroughly evaluated through air sampling and/or employee monitoring.
Panelists identified several processes of particular concern:
Processes for crushing CRT glass. Currently, the most common method of breaking
CRTs is the "gravity drop," which essentially entails dropping the unit on the floor. While
generally the most cost-effective technique, the gravity drop raises questions about dust
generation and should be studied accordingly.
Processes for handling mercury components, particularly the fluorescent backlight in
laptops, which is sometimes not removed before the laptop is shredded.
Processes that handle batteries. For example, it would be helpful to know what happens
to different types of batteries if they are not removed before shredding.
Processes that may expose workers to BFRs and other flame retardants commonly used in
electrical and electronic products. (Not all plastics in these products contain flame
retardants.)
Processes for handling plasma and LCD screens. Some of these processes are still being
developed; it is important to consider these new sources of potential exposure.
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6.2 Best Practices Guidance
Panelists expressed the need for a comprehensive set of updated best practice guidelines. There
are several potential benefits to establishing best practices, which could assist in:
Promoting practices that are most protective of worker health and safety.
Eliminating practices that pose unacceptable risks.
Establishing a more level playing field for the industry (by setting standards for
"compliance").
Facilitating information sharing.
Panelists suggested that best practices be established in three key areas: exposure monitoring;
technical processes; and auditing/verification.
Exposure monitoring. Panelists recommended that use of sampling and monitoring methods be
evaluated in order to determine a set of best practices. Government and recyclers would benefit if
they had clear guidance on determining when occupational exposure monitoring is required. If it
is required, they could use guidance on how to properly conduct the monitoring.
Technical processes. The electronics recycling industry could benefit from technical guidelines
for disassembly, shredding, and separation processes. In this case, best practices guidance would
be a logical outgrowth of the process-specific research suggested in Section 6.1. Each process
should be evaluated step by step to identify points that could generate hazardous forms of a
substance of concern. For example, research can identify processes most likely to release
beryllium from the beryllium-copper alloy. It is important to recognize that quality control of
incoming feedstocks can be an important step in ensuring safe and environmentally sound
recycling processing. Once processes have been evaluated, the results can be used to generate
guidelines on which processes should be used and what procedures need to be in place to ensure
that a given process will be safe (e.g., removal of batteries before a process that would liberate
battery contents). Ultimately, guidance on best operational practices could serve not only to
reduce risks to human health and the environment, but also to encourage a level playing field by
allowing "good" recyclers to justify higher costs in the name of worker safety and environmental
responsibility.
Auditing/verification. Although IAER has developed a general auditing system, it has yet to be
endorsed by any government agency or OEM organization, or by the electronic recycling industry
itself. Companies also could benefit from specific guidelines for auditing and verification
procedures, particularly procedures to evaluate processes, which the IAER audit does not cover
extensively. Best auditing practices could help recyclers whose clients (e.g., OEMs) require them
to vouch for downstream handlers. Currently, companies conducting their own audits must put a
lot of effort into developing and evaluating their own procedures. A set of guidelines would
streamline the process.
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6.3 Standardization
Companies in the electronics recycling industry need a clear understanding of the many state and
international regulations that affect electronics recycling. A clear, concise presentation of this
information could facilitate shared understanding, particularly in the complex areas of hazardous
waste handling and interstate and international transport. Panelists noted that federal regulation
could help standardize what is currently a fragmented regulatory landscape. A national effort to
regulate electronics recycling would provide more thorough and consistent coverage than current
state-by-state efforts.
6.4 Communication
Further effort by government and industry can facilitate communication in several key areas.
Members of the expert panel suggested a number of opportunities for improvement, including the
following:
Communication within the industry. As noted in previous sections, recyclers can contribute to the
overall state of knowledge within the industry by sharing data they have gathered on exposures,
processes, and monitoring methods. Greater communication will also help with developing best
practices for monitoring, processes, and auditing. Essentially, an improved forum for
communication can prevent everyone from having to "reinvent the wheel."
Communication with government. Industry and government should continue to work together to
address issues of human health and environmental impact. Collaboration will help all
stakeholders work toward a shared understanding and sustainable solutions.
Communication with OEMs. Recyclers and manufacturers can both benefit from improved two-
way communication. The following are just a few of the many ways in which better
communication between the two ends of the product lifespan can reduce potential hazards to
human health and the environment:
OEMs can provide recyclers with more information about the contents of their products.
For example, the recycler might like to know the concentration of beryllium in a product,
or whether a lithium battery is present. With the rising popularity of shredding, product-
level information has become increasingly important. The EU requirements will likely
give recyclers greater access to information about product contents, and the EPEAT
program is currently developing a declaration resource that will cover at least those
products that are EPEAT-certified. In the future, more extensive product information
databases could be developed to assist recyclers. Another area for future development is
the labeling of products or components, possibly with RFID tags that recyclers could scan
and match against a database.
OEMs can also provide recyclers with more detailed information about certain new or
uncommon chemicals found in their products; most notably, the mixtures used in plasma
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and LCD screens. Recyclers currently know little about the identity or health effects of
these chemicals.
OEMs and recyclers can work together to develop a consistent labeling scheme for
hazardous constituents. For example, all mercury-containing components or lithium
batteries could have a standard label or be color-coded for easy identification.
Recyclers can help OEMs design products that are safer and easier to recycle. With
improved communication, recyclers could make OEMs aware of difficulties that the latter
could try to alleviate in the product design phase.
6.5 Interagency Collaboration
To address the potential human health and environmental impacts of electronics recycling, EPA
should collaborate with other federal agencies whose work may be relevant to these issues, hi
particular, EPA should consider consulting or working with the following agencies:
NIOSH. This branch of the Centers for Disease Control and Prevention (CDC) is
responsible for conducting research and making recommendations for the prevention of
work-related illnesses and injuries. NIOSH may have useful information on processes and
exposures related to electronics handling. NIOSH also publishes its own set of chemical-
specific exposure thresholds.
OSHA. As noted in Section 5, OSHA has a number of general occupational health and
safety regulations that apply to electronics recyclers. OSHA may also be able to assist
with efforts to improve worker education, which panelists identified as a particular
concern. Educational materials should be clear, simple, and available in multiple
languages.
6.6 Informed Decisions
In general, members of the expert panel identified a need for informed decisions to move
electronics recycling forward. Specific suggestions are as follows:
Costs of data collection should be considered, and research efforts should be prioritized to
make the most effective use of available funding.
In promoting best practices, government and industry should ensure that recyclers can
continue to develop and apply new technologies where they make sense from an
environmental standpoint.
Government can work to find ways to provide incentives for improvement in technology
and environmental performance.
In general, the parties involved in this collaboration should be mindful of all the costs and
benefits of any proposed effort.
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Section 7
The Path Forward
If a single theme can be gleaned from the input provided by electronics recyclers, it is that their
industry is operating without standards and in a state of constant change. Product composition is
changing with advances in technology; new processes are constantly being developed; the
regulatory environment is growing more complex with every action by an individual state or
local government; and through all of this, the industry is growing - which means that from a
human health or environmental standpoint, the stakes are rising every day. Given the industry's
limited federal oversight, it is important that government and industry work together now to
anticipate and prevent dangers to human health and the environment.
Members of the expert panel convened by ORD identified several ways in which government and
industry can move forward to address the human health and environmental impacts of electronics
recycling; Section 7.1 presents a summary of these priorities for action. Section 7.2 outlines a
number of specific activities EPA can undertake to address these priorities.
7.1 Priorities
Considering what is currently known about the possible human health and environmental impacts
of electronics recycling, and considering the suggestions provided by various experts and
stakeholders, key priorities for action include the following:
Analyze product content and key recycling processes to identify substances and exposure
points of concern.
Make a comprehensive effort to gather and review all relevant toxicology, exposure, and
process-specific data from recyclers, federal agencies, and organizations in other
countries.
Conduct research to fill gaps in the existing data on effects, exposures, and processes, hi
particular, consider data needs for emerging chemicals, such as LCD mixtures. To
evaluate leaching potential, conduct lysimeter tests.
Work to develop best practices guidance for processes, exposure monitoring, and
auditing/verification.
Develop a widely recognized certification program for electronics recyclers to help
consumers of e-cycling services readily identify recyclers that are conducting activities in
an environmentally sound manner.
Ensure that existing protections are being enforced. For example, OSHA's lead standard
applies to all workplaces, including some electronics recyclers that may not have met
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their obligation to demonstrate compliance. Also, RCRA prohibits disposal of hazardous
waste in unpermitted facilities, yet panelists stated that they believe many recycling
companies still dispose of hazardous electronic components in unpermitted solid waste
landfills and incinerators.
Improve communication within the industry and with government. Work toward a shared
understanding and a shared vocabulary.
Improve communication between recyclers and OEMs, hi particular, find a way to give
recyclers and their employees more information about the products and chemicals they
are handling.
Although not specifically discussed at the meeting, individual panelists also suggested the
following:
Institute a nationwide solid waste disposal ban on e-scrap.
Institute a national hazardous waste exemption for e-scrap that is recycled in accordance
with environmentally sound management practices that are sanctioned by EPA.
Maintain support for integrated resource management where different resource recovery
technologies (i.e., mechanical, chemical, and thermal) are available to electronics
recyclers to ensure that materials that cannot be recycled can be landfilled in an
environmentally and economically sound manner.
7.2 Roles EPA is Well Positioned to Play
EPA is well positioned to play a key role in the ongoing effort to address the potential human
health and environmental impacts of electronics recycling. There are several specific ways in
which EPA could assist the industry in achieving some of the action priorities outlined in the
previous section:
Investigating the potential levels of occupational and environmental exposure to heavy
metals.
Evaluating the potential human health effects of flame retardants where the existing data
are deficient. ORD has expertise in establishing toxicity benchmarks (e.g., RfDs, RfCs,
cancer slope factors).
Encouraging recyclers to share data they have gathered on processes and exposures.
Leading the effort to develop best practices guidelines, including possible standards for
"compliance." In October 2005, EPA will "kick off an effort to convene and facilitate a
stakeholder process to develop a standard for environmentally responsible electronics
recycling, as well as a system for certifying and verifying recyclers against this standard.
Facilitating communication, particularly between OEMs and recyclers. EPA could
conceivably provide an interface for product declaration, perhaps similar to the provisions
in EPEAT, but with broader applications.
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Working with OSHA, the recycling industry, and other relevant parties to develop tools
for worker education.
Conducting research using TCLP and other approaches on e-scrap to determine what is
and is not hazardous waste.
Standardizing and enforcing regulations affecting electronics waste recycling.
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Section 8
Participants and Attendees
The following individuals served as members of the expert panel on May 19, 2005:
Name
Lauren Roman
Craig Boswell
Michael Fisher
Dale Johnson
Cindy Thomas
Tim Townsend
John Wilhelmi
Affiliation
MaSeR Corporation
Hobi International
American Plastics Council
MaSeR Corporation
Noranda Recycling
University of Florida
ERG
Expertise
Industry expert
Electronics demanufacturing
Value of recovered plastics in computers
Material separation and recovery
Material shredding and smelting
TCLP testing and landfills
Risk and exposure assessment
The session was moderated by Lauren Roman of MaSeR Corporation. Jeff van Ee of EPA-ORD
coordinated the session and provided an introduction to EPA's objectives.
The panel session was conducted in front of an audience that included representatives from the
electronics recycling industry, electronics manufacturers, and government. Several attendees
provided valuable comments and suggestions, many of which have been included in this report.
A list of attendees is provided in Appendix A.
Some of the content in this report, particularly the background information in Section 2 and the
description of current voluntary and regulatory actions and controls in Section 5, may not have
been specifically discussed during the session, but is provided as supplemental information.
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Section 9
Additional Resources
American Plastics Council (APC). 2000. Plastics from Residential Electronics Recycling: Report
2000. Arlington, VA: APC. Online at
http://americanplasticscouncil.org/apcorg/newsroom/technical_reports/plastic_electronics.pdf.
Damerud, P., Atuma, S., Aune, M., Cnattingius, S., Wernroth, M., Wicklund-Glynn, A. 1998.
"Polybrominated diphenyl ethers (PBDEs) in breast milk from primiparous women in Uppsala
County, Sweden." Organohalogen Compounds 35: 411-414.
Electronics Product Stewardship Canada (EPSC). 2005. EPSC Annual Review: May 2005.
Online at http://www.epsc.ca/pdfs/Ann%20Review%202005%20Final.pdf. See also
http://www.epsc.ca/.
Institute of Scrap Recycling Industries, Inc. (ISRI). 2004. ISRI Web site. Washington, DC: ISRI.
Online at http://www.isri.org.
International Association of Electronics Recyclers (LAER). 2003. IAER Electronics Recycling
Industry Report: 2003. Albany, NY: IAER.
International Association of Electronics Recyclers (IAER). 2005. IAER Certification. Albany,
NY: IAER. Online at http://www.iaer.org/communications/certification.htm.
International Association of Electronics Recyclers (IAER). 2005. IAER Web site. Albany, NY:
IAER. Online at http://www.iaer.org/.
Jakobsson, K., Thurreson, K., Rylander, L., Sjodin, A., Hagmar, L., and Bergman, A. 2002.
"Exposure to polybrominated diphenyl ethers and tetrabromobisphenol among computer
technicians." Chemosphere 46: 709-716.
Kuehr, R. and Williams, E., Eds. 2003. Computers and the Environment. Dordrecht, The
Netherlands: Kluwer Academic Publishers.
Lewis, C.A. and Thunder, J.M. 1997. Federal Chemical Regulation: TSCA, EPCRA, and the
Pollution Prevention Act. Washington, DC: The Bureau of National Affairs, Inc.
Newman, L.S., Maier, L.A., Martyny, J.W., Mroz, M.M., and Barker, E.A. 2003. Response of
NationalJewish Medical and Research Center to OSHA Docket No. H005C, "Occupational
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Exposure to Beryllium: Request for Information. " Denver, CO: National Jewish Medical and
Research Center. Online at http://dockets.osha.gov/vg001/V027B/00/78/61.PDF.
New York State Department of Environmental Conservation. 1999. Environmental Compliance
and Pollution Prevention Guide for the Electronics and Computer Industry. Albany, NY:
New York State Department of Environmental Conservation, Pollution Prevention Unit.
Online at http://www.epa.gov/Region2/p2/electron.pdf.
Noranda, Inc. 2004. Sustainable Development Reports: 1999-2004. Online at
http://mv.noranda.com/Noranda/Corporate/Sustainable+Development/Default.htm.
O'Brien, J. 2005. "Recent studies indicate minimal heavy metal releases from MSW landfills: A
summary of the SWANA Applied Research Foundation's findings." MSW Management 15(3).
Online at http://www.mswmanagement.com/mw_0505 recent.html.
Roe, S. 2001. "Deadly metal's use endangers workers: Employers often don't warn about risks
from beryllium." Chicago Tribune. 29 July, 2001.
Ryan, J., and Patri, B. 2000. "Determination of brominated diphenyl ethers (BDEs) and levels in
Canadian human milk." Organohalogen Compounds 47: 57-60.
She, J., Winkler, J., Visita, P., McKinney, M., and Patreus, M. 2000. "Analysis of PBDEs in seal
blubber and human breast adipose tissue samples." Organohalogen Compounds 47: 53-56.
Tinkle, S.S., Antonini, J.M., Rich, B.A., Roberts, J.R., Salmen, R., DePree, K., and Adkins, E.J.
2003. "Skin as a route of exposure and sensitization in chronic beryllium disease."
Environmental Health Perspectives 111(9): 1202-1208.
U.S. EPA. 2003. Municipal Solid Waste in the United States: 2001 Facts and Figures. EPA530-
R-03-011. Washington, DC: U.S. Environmental Protection Agency, Office of Solid Waste
and Emergency Response.
U.S. EPA. 2004. Recycling Electronics and Asset Disposition (READ) Services: An EPA
Government Wide Acquisition Contract. Washington, DC: U.S. Environmental Protection
Agency. Online at http://www.epa. gov/oam/read.
U.S. EPA. 2005. Design for the Environment. Washington, DC: U.S. Environmental Protection
Agency. Online at http://www.epa.gov/dfe/.
U.S. EPA. 2005. Integrated Risk Information System (IRIS). Washington, DC: U.S.
Environmental Protection Agency. Online at http://www.epa.gov/iris/.
U.S. EPA. 2005. Plug-In To eCycling. Washington, DC: U.S. Environmental Protection Agency.
Online at http://www.plugmtoecvcling.org/.
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U.S. EPA. 2005. Plug-In To eCycling: Guidelines for Materials Management. Washington, DC:
U.S. Environmental Protection Agency. Online at
http://www.epa.gov/epaoswer/osw/conserve/plugin/guide.htm.
U.S. EPA. 2005. RCRA Orientation Manual. Washington, DC: U.S. Environmental Protection
Agency, Office of Solid Waste. Online at http://www.epa.gov/epaoswer/general/orientat/.
Zero Waste Alliance (ZWA). 2005. Electronic Product Environmental Assessment Tool
(EPEAT). Online at http://www.epeat.net/.
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Appendix A
Participant List
* Panelist
** Moderator
Michael Alexander
National Recycling Coalition
P.O. Box 97
Brattleboro, VT 05301
802-254-3338
Email: michaela@nrc-recvcle.org
Ian Bain
Citirya Inc./EWS USA
106 East Old Settlers Boulevard
Round Rock, TX 78664
512-238-1911
Fax: 512 238 1931
Email: ian.bain@citiraya-inc.com
*Craig Boswell
HOBI International, Inc.
7601 Ambassador Row
Dallas, TX 75247
214-951-0143
Fax:214-951-0144
Email: cboswell@hobi.com
Robert Busbice
U.S. Department of Defense
8900 Savage Road
Fort Meade, MD 20775
John Cianciarulo
Noranda Recycling, Inc.
80 Commercial Way
E. Providence, RI 02914
401-438-9220
Fax: 401-438-1237
Email: cianciai (Slsampling.noranda.com
Jeffrey Dahmus
Massachusetts Institute of Technology
77 Massachusetts Avenue - Room 35-005
Cambridge, MA 02139
617-253-7530
Fax: 617-253-1556
Email: j dahmus@mit.edu
Joseph DeLorme
GE Advanced Materials
1 Plastics Avenue
Pittsfield, MA 01201
413-448-7491
Fax: 866-286-6625
Email: joseph.delorme@ge.com
Shashank Dubey
Teradyne, Inc.
44 Simon Street
Nashua, NH 03062
603-879-3788
Fax: 603-879-2788
Email: shashank.dubey@teradvne.com
Matthew Fischer
Gannon & Scott
33 Kenney Drive
Cranston, RI 02920
401-463-5550
Fax: 401-463-5971
Email: mattFischer@gannon-scott.com
A-l
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*Michael Fisher
American Plastics Council
1300 Wilson Boulevard
Arlington, VA 22209
703-741-5599
Fax: 703-741-6599
Email: mike fisher@plastics.org
Staci Gatica
U.S. Environmental Protection Agency
1200 Pennsylvania Avenue, NW
Washington, DC 20460
202-564-2321
Email: gatica-hebert.staci@epa.gov
Kate Geraghty
Rohm and Haas
Herald Way
Coventry CV3 2RQ
United Kingdom
+44-(0)-247-665-4459
Fax: +44-(0)-247-644-8014
Email: kgeraghty@rohmhaas.com
Alfred Hambsch
Cable Recycling
220 John Street
Barrie, ON L4N 2L2
Canada
705-725-1919
Fax: 705-725-1920
Email: ahambsch@barriemetals.com
Joe Hennigan
U.S. Department of Defense
8900 Savage Road
Fort Meade, MD 20775
Lee Herriges
GE Healthcare
P.O. Box414(ED-91)
Milwaukee, WI 53129
414-747-6997
Fax: 414-747-6855
Email: lee.herriges@med.ge.com
Lloyd Hicks
INFORM
120 Wall Street - 14th Floor
New York, NY 10005
212-361-2400
Fax:212-361-2412
Email: hicks@informinc.org
Jaco Huisman
Design Production & Contraction
TU Delft
Landbergstraat 15
Delft 2628CE
The Netherlands
+31-15-278-2738
Fax:+31-15-278-2756
Email: j .huisman@io.rudelft.nl
*Dale Johnson
MaSeR Corporation
14 Schooner Ridge - Suite 200
Marblehead, MA 01945
617-290-2276
Fax:617-687-9187
Email: djohnson@masercoi-p.com
Sandy Jones
U.S. General Services
401 West Peachtree Street - Suite 2300
Atlanta, GA 30308
404-331-1941
Fax: 404-730-9723
Email: sandy.jones@gsa.gov
Katharine Kaplan Osdoba
U.S. Environmental Protection Agency
1200 Pennsylvania Avenue, NW (5306W)
Washington, DC 20460
703-308-8659
Fax: 703-308-8686
Email: osdoba.katharine@epa.gov
Lynn Knight
Eastern Research Group, Inc.
110 Hartwell Avenue
Lexington, MA 02421
781-6747313
Fax:781-674-2851
Email: lynn.knight@erg.com
A-2
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Jim Kozinski
GE HealthCare RR
2200 East College Avenue
Cudahy,WI 53110
414-747-6997
Fax: 414-747-6855
Email: iames.kozinski@med.ge.com
Chris Lamie
Eastern Research Group, Inc.
110 Hartwell Avenue
Lexington, MA 02421
781-674-7247
Fax: 781-674-2851
Email: chris.lamie(a),erg.com
Jim Lynch
CompuMentor
1352 Acton Street
Berkeley, CA 94706
415-633-9308
Fax: 415-633-9400
Email: i imlynch@cornpumentor.org
Robert McKechnie
Citiraya Inc.
106 Old Settlers Boulevard
Round Rock, TX 78664
512-238-1911
Fax:512-238-1931
Email: robert.mckechnie@citiraya-inc.com
Wayne Rifer
Rifer Environmental
1975 NW 113th Avenue
Portland, OR 97229
503-644-0294
Fax: 503-643-9705
Email: wrifer@concentric.net
**Lauren Roman
MaSeR Corporation
22 Hatakawanna
BuddLake,NJ 07828
973-426-0406
Fax: 973-426-0866
Email: Lroman@masercorp.com
Matthew Russell
Lexmark
740 New Circle Road
Lexington, KY 40511
859-232-7176
Fax: 859-232-3039
Email: mrussell@jexmark.com
Chris Ryan
Metech International
120 Mapleville Main Street
P.O. Box 500
Mapleville, RI 02839
978-772-4897
Fax: 978-772-5440
Email: cryan@metech-arm.com
Mark Sajbel
U.S. General Services Administration
7* and D Street
Washington, DC 20407
Email: mark.sajbel@gsa.gov
Greg Sampson
Earth Protection Services, Inc.
107 East Historic Columbia River Highway -
Suite 208
Troutdale, OR 97060
503-667-1004
Fax: 503-667-1008
Email: g.sampson@earthpro.com
David Sanders
Great Lakes Chemical
1 Great Lakes Boulevard
West Lafayette, IN 47906
765-497-6319
Fax:765-497-5411
Email: dsanders@glcc.com
Karsten Schischke
Fraunhofer IZM
Gustav-Meyer-Allee 25
Berlin 13355
Germany
+49-30-46403-156
Fax:+49-30-46403-131
Email: schischke@izm.fhg.de
A-3
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J.M. Gideon Schroeder
Cisco Systems, Inc.
170 Tasman Drive
San Jose, CA 95134
773-444-5054
Email: gschroed@cisco.com
Douglas J Sellick
Industry Canada
155 Queen, 423
Ottawa, ON K1A OH5
Canada
613-957-2857
Fax: 613-957-1201
Email: sellick.doug@ic.gc.ca
Sandford J. Selman
Asia West LLC
121 Post Road East
P.O. Box 5213
Westport, CT 06881
203-221-7455
Fax: 203-221-7457
Email: sandy@aswiawestrunds.com
Ingrid Sinclair
Noranda Recycling
3160 Vera Valley Road
Franklin, TN 37064
615-287-5945
Fax: 615-793-9959
Email: ingrid.sinclair@norandarecycling.com
Jorgen Svensson
Sony Ericsson
Torshamnsgatan 27
P.O. Box 64
KistaSE-16494
Sweden
+46-8-404-2425
Fax: +46-8-404-8570
Email: jorgen.svensson@sonyericsson.com
*Cindy Thomas
Noranda
Canada
905-874-6835
Email: cindv.thomas@toronto.norfalc.com
*Timothy Townsend
University of Florida
352-392-0846
Email: ttown@ufl.edu
Dani Tsuda
WSP Environmental
405 Howard Street - Suite 500
San Francisco, CA 94105
415-298-0604
Email: dani.tsuda@wspgroup.com
Chris Turner
Sony Ericsson
7001 Development Drive
P.O. Box 13969
Research Triangle Park, NC 27709
919-472-6997
Fax: 919-472-1380
Email: chris.turner@sonyericsson.com
Jeff van Ee
U.S. Environmental Protection Agency
P.O. Box 93478
Las Vegas, NV 89119
702-798-2367
Fax: 702-798-2107
Email: vanee.jeff@epa.gov
Michael Vanderpol
Environment Canada
351 St Joseph Boulevard
Gatineau, QCJ9J1J5
Canada
819-953-9246
Email: michael.vanderpol@ec.gc.ca
*John Wilhelmi
Eastern Research Group, Inc.
110 Hartwell Avenue
Lexington, MA 02421
781-674-7312
Fax:781-674-2851
Email: iohn.wilhelmi (aierg.com
A-4
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Michael Williams
Inert Corporation
16 Swampscott Street
P.O. 146
Newfields,NH 03856
603-772-7236
Fax: 603-773-5643
A-5
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