Indiana Recycling Coalition

 

E-Scrap Action Program

 

Recommendations

 

For more than one and a half years the Indiana Recycling Coalition (IRC), a statewide 501 (c)(3) educational organization, has been developing the E-Scrap Action Program (ESAP).  ESAP is a project that targets electronics waste (e-scrap) as a major priority for waste management in the state of Indiana, because this waste stream can be hazardous to the environment and costly to manage.  

 

The initial phase of the E-Scrap Action Program brought together key stakeholders from across the state to discuss issues of concern and solutions for the future of e-scrap in Indiana.  Stakeholders represented solid waste districts, cities and towns, state associations (such as the Association of Indiana Solid Waste Districts, and the Indiana Association of Cities and Towns), private sector generators (such as Eli Lilly, Subaru, Chrysler, and Raytheon), state governments (Environmental Management, Commerce, and Administration), federal government (EPA), universities (such as Indiana University, Ball State and Purdue), representatives of the solid waste industry (Waste Management and Republic Services), private sector electronics recyclers, reuse organizations  and others.

 

This successful one-year process resulted in a series of preliminary recommendations from the multi-stakeholder group. The recommendations present ways in which the state can address the issue of e-scrap from policy, regulatory, legislative and educational perspectives. These recommendations are inter-related and the intent is that they will be considered as a comprehensive “package” and not individually. The recommendations fall into six interrelated areas:

 

Ř      Public education

Ř      Funding mechanisms

Ř      Landfill/incinerator disposal ban

Ř      Prison partnerships

Ř      Procurement

Ř      Asset management

 

 

Public Education

 

There has been very little education on e-scrap issues to date in Indiana. The need to educate Hoosiers about proper electronics management was identified in virtually every discussion that took place during the ESAP stakeholder process. There is a great need for information: many individuals and organizations need accurate information to make the right decisions about e-scrap management; the general public is unaware of potential hazards posed by e-scrap; many businesses are unaware of the regulations governing disposal of electronic equipment; and there is a general lack of awareness of the options available for managing e-scrap or for purchasing less toxic electronic devices.  Therefore, education becomes critical as a recommendation for action, and should also be considered an integral part of all other recommendations to follow.

 

Recommendation:

 

q       Indiana should develop and implement a comprehensive and coordinated education campaign with a central theme, using a multi-media approach, and targeting a wide range of audiences, such as businesses, schools, and consumers.

 

 

Funding Mechanisms

 

Stakeholders agreed that establishing ongoing e-scrap collection is essential; that state and local government cannot bear the entire cost of e-scrap management; and that state government will necessarily be involved in setting up and regulating the collection mechanism.

 

Recommendations:

 

q       Initially, Indiana should implement an Advanced Recovery Fee (ARF), a fee that is added at the time of purchase (much like the existing fee on tires).  This fee would help to cover the cost of managing current material and would support additional e-scrap programs at the local level.

q       Indiana should move towards “Extended Producer Responsibility” (EPR) through legislation that requires manufacturers to assume the responsibility for managing their equipment at the end of its useful life.  EPR  (1) pushes manufacturers to improve recyclability; and (2) provides lower operating costs for collection programs.

q       The Indiana Department of Commerce and Indiana Department of Environmental Management should make e-scrap a priority issue, and help fund start-up of e-scrap projects though existing state grant and loan programs. In particular, the Indiana Department of Commerce should work to develop funding for the private sector, specifically to encourage an electronics market development program.

q       Constituents of state funding programs should be surveyed on specific funding needs, and recommendations forwarded to the Indiana Department of Commerce and the Indiana Department of Environmental Management.

 

 

Landfill/Incinerator Disposal Ban

 

Most electronic equipment today is landfilled instead of recycled because it is currently the most economic and convenient method of management.  The high concentration of lead in cathode ray tubes (CRTs) in computer monitors and televisions, however, cause these items to fail the Toxic Characteristic Leaching Procedure (TCLP). The TCLP is the procedure recognized by the US Environmental Protection Agency for measuring the potential toxicity of waste materials, and materials failing the TCLP are regulated as a hazardous waste.  When incinerated, concerns arise over hazardous materials released into the air or exposure to hazardous materials from handling and residuals in the ash.  Although residential and other small quantities of these materials are technically exempt from hazardous waste regulations and current landfill leachate test do not show significant levels of lead, the stakeholders agreed that it is time to consider further regulation of CRTs, and to consider regulating other electronic equipment when appropriate.  For a successful CRT ban, adequate funding and an adequate infrastructure must be in place before a disposal ban is implemented.  While a consensus was reached in this issue, there is not unanimous acceptance of this recommendation. Landfill operators, in particular, may not support the disposal ban.

 

Recommendations:

 

q       Indiana should consider a statewide ban on final disposal of CRTs, and the ban should apply to residential as well as materials generated by businesses, schools and units of government.

q       A collection and funding infrastructure must be in place prior to implementation of a disposal ban

Indiana should consider adding other electronic equipment to the disposal ban after a CRT disposal ban is in effect, as TCLP results become available, and as collection infrastructure is developed.

 

 

Prison Partnerships

 

The use of prison labor in e-scrap management offers a number of potential benefits for collection programs, private sector recyclers, and the prison system. These partnerships would support private sector recyclers, not compete with them, by providing services that cannot be provide cost-effectively in the private sector—such as the de-manufacturing of computer monitors.  Prison partnerships could lower the cost for e-scrap management for Indiana communities, schools, businesses, and others.

 

However, the use of prison labor in other states has caused some controversy, such as competition with the private sector, or exposure to workplace hazards.  ESAP stakeholders agree that while there is no significant opposition to the prison partnership concept, as presented in the stakeholder discussions, it is essential to address any concerns that arise as partnerships develop, such as creating a level playing field among recyclers and properly training the workforce.

 

Recommendations:

 

q       Indiana should seriously consider, and continue to explore the feasibility of, developing prison partnerships in e-scrap management.

q       Partnerships should focus on providing service that cannot be provided cost effectively in the private sector.

 

Procurement

 

Electronic equipment is a problem at the end of its useful life because the disposal issues are not considered at the time of purchase.  If procurement officials considered potential hazards, or improved recyclability, disposal issues could be mitigated.  This recommendation also applies needed pressure to manufacturers of electronics equipment to manufacture and make available more environmentally sound products.

 

Recommendation:

 

q       Indiana should establish a program to educate local and state procurement agents on the hazards of electronics they are purchasing and provide them with tools to assist them in buying greener electronic equipment. 

 

 

Asset Management/Auctions

 

A significant amount of electronic equipment is “disposed” of through government or corporate auctions, through donations, etc. In these cases, the burden of final disposal is simply shifted to another party.  This is especially the case in bulk auction lots containing non-working or unwanted equipment, a common practice of government surplus programs.

 

Recommendations:

 

q       Indiana should adopt more responsible e-scrap management practices than are currently used under the auction system.

q       Local and state government agencies should be encouraged to bid for responsible e-scrap reuse/recycling services instead of relying on public auctions.

q       Local and state surplus agencies should be educated on the hazards of electronics and provided with information and tools to discourage public auction of e-scrap in bulk lots.

 

 

 

 

 

For more information, contact:

Indiana Recycling Coalition’s E-Scrap Action Program

PO Box 7108

Bloomington, Indiana 47407-7108

Phone: 812/988-9946; Fax: 812/988-9947

 

Revised August 25, 2004