1. RCRA Regulation of CRTs and
Other Computer Electronics
A business is updating its current
computer system with newer computer
models and is discarding its older
computers. Are these materials RCRA
hazardous wastes? How are the computers,
both monitors and processing units,
regulated when sent for disposal?
make hazardous waste determinations for
these materials by testing them or applying
their knowledge per 262.11. If generators
dispose of CRTs and other computer
equipment that are hazardous wastes, they
are subject to all the applicable RCRA
requirements when the materials are
Color computer monitors containing
cathode ray tubes (CRTs) are often RCRA
hazardous wastes, but there are no current
data suggesting that other pieces of
computer equipment, such as processing
units, are generally RCRA hazardous
wastes. Many color computer monitors
contain high amounts of lead in their CRTs,
which can make the monitors characteristic
hazardous wastes. The average
concentration of lead in leachate from
colored CRT glass generated through the
toxicity characteristic leaching procedure
(TCLP) is 22.2 milligrams per liter (mg/1),
which is considerably more than the toxicity
characteristic (TC) regulatory level of 5 mg/1
used to classify a waste as hazardous for
lead (40 CFR 261.24). Other hazardous
constituents such as mercury, cadmium, and
arsenic are sometimes present in CRT glass,
but these constituents are usually found in
very low concentrations unlikely to exceed
TC limits. As stated above, there are no
current data suggesting that other non-CRT
electronic materials from computers
generally exhibit any characteristics of
hazardous waste (67 FR 40508, 40510; June
12, 2002). However, generators of solid
waste CRTs and other computer equipment
who discard these materials are required to