Responsibly Retiring IT Assets, Medical or Laboratory Equipment

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1 Responsibly Retiring IT Assets, Medical or Laboratory Equipment

2 Agenda Introductions David Zimet, President, Hesstech, LLC Industry Overview Key Issues When Retiring Electronic Equipment Data Security & Protection Supplier Qualifications & Approvals Equipment Decontamination Custody Tracking and Ownership Transfer Remarketing Reusable Equipment Industry Service Options Individual verses Bundled Services Choosing the Right Supplier Acceptable Materials Appendix Asset Recovery & Recycling Process Destruction by Shredding Recent Federal Agency Enforcement Action USEPA endorsed Best Management Practices

3 The Industry The electronics asset recovery & recycling industry has grown to over $9 billion due to increasing corporate requirements for: Risk Management Data security certified data destruction Evolving electronic waste disposal compliance issues Mitigating health, safety, and disposal liabilities Compliance issues (FDA, OSHA, RCRA, DOT, GLB, SOX, HIPAA, etc.) Lowering Total Cost of Ownership ( TCO ) Extend the useful life of equipment Recover asset value from equipment remarketing Environmental Stewardship Reduce the proliferation of electronic waste in landfills

4 Key Issues when Retiring Electronic Assets Data Security & Protection Erasing hard drives is not the only risk that needs to be mitigated Printers, fax machines, copiers, phones, PDAs, etc. Secure handling for computers and storage devices connected to laboratory or medical test equipment Avoiding unauthorized employee access or theft Client site data protection policies Decide: data erasure on-site or at electronics processor Supplier Site Security & Technical Capabilities Facility Surveillance 24/7 Visitor and employee egress control Employee background checks Transparent tracking system for materials processed Validated Data Erasure Process see next slide

5 Key Issues when Retiring Electronic Assets Issues Surrounding Data Destruction There is a lot of inaccurate information circulating around the industry about DOD Approved Software that does not exist. The DOD may approve a methods of destroying data where many software programs will be suitable. The key issue is the user applying the necessary multi-step process with a strong QC procedures to assure data is removed. Data Destruction Options: If data is removed by client supplier should be capable of verifying data is removed prior to resale Hard Drive Destruction Options Degaussing renders drive useless for reuse and destruction cannot be confirmed Overwriting Drives Must have appropriate commercial software with Individual drive erasure reporting system Shredding End of the road

6 Key Issues when Retiring Electronic Assets Supplier Qualifications & Approvals Verify Applicable Supplier Employee Training Programs 40 Hour OSHA Hazwoper Hazardous Waste Worker REACTIVE Chemical Properties Training OSAH Emergency Response Awareness/Operations OSAH Hazardous Communications DOT HM 181/126F OSHA Hazwoper Refresher OSAH Bloodborne Pathogens Red Cross CPR/Safety Chemical Hygiene Verify Supplier has Appropriate Approvals and Licenses DOT and State HAZMAT Transporter Authorization TSDF if materials are consolidated and transferred Universal Waste Approvals or Permitting varies by State Data Destruction software often requires a per unit or site license

7 Key Issues when Retiring Electronic Assets Equipment Decontamination Proper Decontamination for End-of-Life or Reusable Equipment Mitigate health & safety risks & ensure proper disposal of HAZ MAT Decide: In-house personnel or outsourced services If in-house or outsourced by generator, electronics processor may need to approve procedures Outsourcing to the electronics processor can often reduce costs and streamline indemnification and liability transfer Secondary Deep Cleaning Needed Prior to Recycling Unknown hazardous or inaccessible surfaces are often uncovered during the dismantling or recycling process An electronics processor should have demonstrated capabilities to perform these services Residual Downstream Markets for Contaminants Processor must have transparent credible downstream channels Records showing history of shipments are paramount

8 Key Issues when Retiring Electronic Assets Custody Tracking and Ownership Transfer Determine Custody Tracking Requirements List of retired IT assets is often a mystery is an inventory needed Laboratory and Medical Test Equipment more often requires maintenance and records are available Do FDA or other requirements dictate custody needs to be tracked until item is destroyed Are there specific requirements when tracking materials from the point of origin to final destination Record Keeping and Regulatory Compliance The members of the custody chain should demonstrate secure and data is recoverable in the event of a catastrophe Web based reporting or otherwise transparent reporting should be required Domestic : FDA, RCRA, DOT, TSCA, SOX. GLB, HIPAA, International: Basel Treaty, WEEE, Import Restrictions

9 Key Issues when Retiring Electronic Assets Remarketing Reusable Equipment Mitigate Risks Selling Equipment Ensure proper decontamination is performed as necessary Ensure transfer of ownership documentation is compliant with FDA and other applicable regulations Prohibit exporting of obsolete or non-repairable items and require verifiable destruction Verify title transfer and indemnification documentation is secure and recoverable in the event of a catastrophe Remarketing Options (1) Buyouts (2) Revenue sharing targeted resale (3) Auction liquidations When materials are removed and remarketed at supplier site Free up storage space and avoid managing buyer inspections More time to maximize revenues generated from buyers Equipment is remarketed from client site Client typically manages access to buyers Staging and storage can be an issue

10 Key Issues when Retiring Electronic Assets Industry Service Options Optional Services Retiring IT, Laboratory, or Medical Equipment Equipment Deinstallation On-site Lab Pack and Packing and removal On-site Waste Management Internal Redeployment Equipment Remarketing Hazardous Waste Disposal & Transportation Non-Hazardous & Universal Waste Disposal & Recycling

11 Key Issues when Retiring Electronic Assets Choosing the right Supplier Using Multiple Unlinked Suppliers Multiple suppliers can increase qualification time and costs Compatibility issues may arise between suppliers if they participate in a single product custody chain Exposure to liabilities typically increase with multiple suppliers Bundled HAZMAT, Universal Waste, and Logistics Services Suppliers who engage in full lifecycle management consolidate reduce qualification time and expenses Reduce Logistics Costs by minimizing the number of pick-ups Maintain smaller storage areas for accumulating equipment

12 Key Issues when Retiring Electronic Assets Acceptable Items for a Full Service Supplier

13 Appendix The Asset Recovery & Recycling Process The Shredding Process In the News

14 The Asset Recovery & Recycling Process

15 The Shredding Process for Electronics Preparation Delamination Separation and Recovery

16 Preparation Stage

17 Delamination stage

18 Separation and recovery stage

19 Example of a recovered fractions: Red metals (Cu and PM)

20 In the News

21 Recent News and USEPA Enforcement Action

22 USEPA Announces Industry Guidelines 9ba852574f3004f0af6!OpenDocument

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