Electronic and Universal Waste Regulations

Transcription

1 Electronic and Universal Waste Regulations Derek Boer Colorado Department of Public Health and Environment Hazardous Materials and Waste Management Division

2 Regulatory Scope E-waste is regulated as both a solid waste and a hazardous waste Exemptions for generators when e-waste is recycled and managed appropriately Solid waste: Non-hazardous Household hazardous Recycling and beneficial use Hazardous waste: Hazardous Commercial/government & co-mingled w/ household Under Universal Waste regulations, or under full Hazardous Waste regulations Typically recycler makes the waste determination

3 Under Solid Waste recyclable material Section 8.2 as recyclable material generators Exempt from registration and reporting requirements if material is sent to a registered recycling facility in Colorado Register and annual report if material goes out-of-state Recyclable material collected and managed at a rate to prevent an overflow from containers

4 Solid Waste Minimize the potential for release of ground water contaminants, dust, odors, or nuisance conditions Compliance with health laws and regulations, Water and Air quality control, and local laws Facilities must be fenced or secured Closure requirements

5 Universal vs Hazardous Waste Universal waste is hazardous waste Universal waste is less stringent set of regulations Q: Is all electronic waste considered universal waste? A: No, if it s not hazardous then it s a it s solid waste. Solid waste Hazardous Waste Universal Waste

6 As a Hazardous Waste What is e-waste? Desktop towers CRT monitors Laptops Computer peripherals Cell phones Printers Terminals Mainframes Keyboards/mice Televisions

7 What is Hazardous E-Waste? Electronic equipment or components that contain circuit boards or other complex circuitry Fails TCLP analytical test = a hazardous waste (Toxicity Characteristic Leaching Procedure) TCLP test simulates conditions in MSW landfill, and tests for 8 metals For electronics - lead, mercury, cadmium, and chromium are the drivers

8 Generator knowledge to make the call You can use generator knowledge of a waste, you don t have to run TCLP on every device Generators and handlers often make assumption that electronics are hazardous Cheaper, easier, more efficient Doesn t change where the material goes Doesn t add a great regulatory burden

9 Role of Recycler in Determination Device must first be a waste to be regulated as a universal waste Electronics that will be refurbished, resold, or reused are still a product Usually the recycler makes the call

10 Sham Product Argument Stored in lieu of disposal Is it being managed as a product? That has value?

11 Universal Waste Handlers Any facility that generates or manages universal wastes is called a handler Small quantity handler <5,000 kg universal wastes onsite at one time Large quantity handler 5,000 kg universal waste onsite at one time

12 Requirements for Handlers Same for both handler classifications except LQHs must also: Notify and obtain EPA ID # Keep records of universal waste shipped to/from facility

13 Requirements for Handlers No onsite disposal No disposal to trash No treatment/processing except as provided in the universal waste rules Universal waste remains subject to full hazardous waste regulations

14 Requirements for Handlers These requirements also apply to 5 other universal wastes*: 1. Batteries (NiCad, lithium, silver-oxide, mercury-oxide) 2. Lamps (fluorescent, CFLs, HID contain mercury/reactive) 3. Aerosol cans (that contain hazardous contents) 4. Mercury-containing devices (switches, barometers) 5. Some pesticides (recalled or collected through program) * there are minor differences in the requirements

15 Requirements for All Handlers Manage material in a way that prevents release to the environment Accumulation time - one year Immediately contain all releases and residues from universal wastes.

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17 Containers Must contain devices, or components in containers Structurally sound, adequate to prevent breakage, and compatible No leakage or spillage Immediately clean up broken components, containerize Do not have to be closed (only e-waste)

18 Apply to All Handlers Labels Used - material type, Waste - material type, or Universal Waste - material type Label individual wastes or accumulation container

19 Apply to all Handlers Limited treatment allowed Disassembly of electronic devices Shredding hard drives For other UW puncturing aerosols and crushing lamps

20 Treatment Requirements Develop a written procedure, train staff to follow it Operation and maintenance Precautions to protect workers Waste management and disposal Transfer waste to a proper container Prevent releases, maintain appropriate spill kit and know how/when to use

21 Training All employees are thoroughly familiar with proper waste handling and emergency procedures, relative to their responsibilities during normal facility operations and emergencies. Suggest documentation

22 Apply to All Handlers Must ship to another universal waste handler or to destination facility Destination facility = treatment, disposal or recycling facility Subject to hazardous waste permitting requirements, and SW recycling regulations Receiving handler must agree to receive shipment prior to shipping

23 Universal Waste Transporters Requirements apply to anyone who transports regulated universal waste No onsite disposal No disposal to trash Comply with DOT requirements (49 CFR ) No treatment or diluting 10-day transfer Contain/clean-up releases

24 Department of Transportation Universal wastes are usually not DOT hazardous materials Hazardous material shipper requirements: Identify shipping name, class/division, ID number, hazard warning label Packaging requirements Employee Training Shipping Papers Emergency Response Information Certification Placarding Security Plan Incident Plan

25 Universal Waste Exports If ship to non-oecd countries Notification of intent to export to EPA Annual report to EPA Recordkeeping copies of each Notification of intent, EPA Acknowledgment of Consent, each confirmation of delivery, and each annual report for 3 years Export only upon consent of receiving country and in conformance with EPA Acknowledgment of Consent Provide EPA Acknowledgment of Consent to transporter

26 Large Quantity Handlers Notify Department and obtain an EPA ID # No fee with notifying One time

27 Large Quantity Handlers Tracking Keep record of each shipment of UW received/sent Log, invoice, manifest, bill of lading, or other shipping document Name, address, quantity of each waste, date Keep records for three years from shipment date

28 Benefits Over HW Regulations Less stringent requirements Not required to count UW toward monthly HW generator total Not required to use hazardous waste manifest Not required to use hazardous waste transporter

29 Industry and certifications e-stewarts Certification started by Basel Action Network (BAN) R2 Solutions sponsored by the EPA