The Importance of Comprehensive Policy to Promote Safe CRT Recycling

By Angela G. Pack Zia
October 2007

The author presented this report to the Faculty of the Graduate School of the University of Texas at Austin, in partial fulfillment of the requirements for the degree of Master of Public Affairs, in August 2007.

Abstract
This paper addresses the effectiveness of policy in encouraging safe and proper recycling of residential electronic equipment with cathode ray tubes. The research measures policy effectiveness by addressing residential access to recycling and accountability by recyclers for material management practices throughout the recycling process. An empirical study is conducted for two specific policies: the federal Resource Conservation and Recovery Act (RCRA), and the Massachusetts’ set of policies concerning the disposal of cathode ray tubes. The study qualitatively analyzes the responses from surveys and follow-up interviews with recycling collection facilities to determine policy effectiveness. Policy implications are made and recommendations for further research are provided.

Table of Contents

1. Introduction

Purpose of the Research

Electronic equipment has become a mainstay in modern life. Therefore, as the world economy continues to expand, so will the growth in electronic equipment. Like all consumer goods, electronic equipment also reaches an end of life. With the fast pace in the change in technology, many electronic products are reaching end-of-life much sooner than ever before in the history of consumer electronic equipment. Yet, electronic equipment contains many toxic materials that can be detrimental to the human health and the environment if not handled and disposed of properly; and it also contains many valuable materials, many of which are nonrenewable.1 Today, electronic waste is the fastest growing waste in the waste stream.2 As a result, its disposal has become a topic of public concern.

The concern over electronic waste disposal has prompted government unions, countries, and local governments across the globe to find other solutions for managing the growing electronic waste. As such, this past decade has witnessed a number of proposed policies that are being implemented across the globe. These policies include hazardous waste management regulations, fee-subsidy policies, and policies based on the producer pays principle.3 The effectiveness and usefulness of these policies continue to be pored over in academic journals in fields ranging from environmental economics to environmental law. They are also passionately debated by stakeholders in the electronic industry, environmental organizations and other special interest groups; and continue to be mulled over by government agencies and legislators.

This paper builds on the previous studies on electronic recycling by incorporating the existing literature in the fields of Environmental Economics and Accountability to the electronic recycling industry and related policy. Existing research on electronic recycling reveals economic disadvantages and environmental and human safety concerns in not recycling electronic products. For example, the US Government Accountability Office, in its report, Electronic Waste: Strengthening the Role of the Federal Government addresses current inadequacies in federal policies promoting electronic recycling. This report highlights the economic loss of precious nonrenewable resources when electronic products are not recycled and the environmental and human safety hazards when the electronic material is improperly disposed such as in unprotected landfills, which are most common lesser developing countries.4 On the other hand, US based research that has focused on the success of recycling electronic products, especially electronic products with low recovery value such as cathode ray tubes (CRTs), attests to the economic value in exporting electronic products for reuse and recycling to secondary markets in developing countries.5 However, developing countries tend to lack enforceable or sufficient environmental and human safety regulations. As such, research shows that, while not all, many of the importing firms in developing countries use practices in material and product recovery that are harmful to both human health and the environment.6

The political debate surrounding many of the recently proposed recycling policies intended to encourage proper electronic recycling vary according to the affected stakeholder. Most policies are often criticized by different stakeholders for creating excessive barriers for recycling and/or excessive administrative burdens that increase transaction costs and, therefore, are too burdensome for targeted stakeholders. For example, producers which manufacture electronic products that contain a significant amount of high valued recyclable material for recovery are more likely to favor a policy that promotes producer responsibility in recycling than would a producer of electronic products which contains primarily low valued recyclable material. On the other hand, a producer with a vast array of electronic products may prefer a system that requires the consumers to pay an advanced recovery fee during the time of purchase and allow the state to properly allocate funds to recyclers when the product reaches its end of life.7

The Environmental Economics literature that deals with recycling is based on the premise that the production of a good creates both beneficial and negative externalities in society. Negative externalities are often not reflected in the price of the good because they are often a by product of either the production or the consumption of the good. When externalities are not accounted for in the price of the good, too much product may be produced, rendering harm to the society greater than the benefit received from the consumption of the good. To create an optimal limit of negative externalities, environmental economic theory demonstrates how either an optimal tax (known as a pigouvian tax) or perfect bargaining conditions (known as the Coase Theorem) can be used. A pigouvian tax may be a straight tax on the entity producing the externality or it may be devised through a combination of taxes and subsidies, depending on the constraints of the various stakeholders.8 Environmental Economic modeling for recycling reveals that policy for optimal material recycling must be driven by both producer design and consumer incentives to recycle. This revelation highlights the importance of policy to affect upstream inputs and design as well as downstream recycling by creating the right combination of incentives through taxes and subsidies on the various stakeholders.9 The ability to exercise the Coase Theorem in recycling is unlikely due to the large number of stakeholders involved in the bargaining process. On the other hand, implementing the optimal combination of tax and subsidies is not always practical due to high transaction costs and existing market distortions. In this case, Environmental Economic theory attempts to account for these distortions and costs by controlling for them and calculating second best options.10

A negative externality linked with the production or consumption of a good may not be apparent to the stakeholder because the stakeholder is uninformed about the cause of the negative externality, whereas the agent creating the negative externality may be fully aware of the cause but chooses to not disclose it to the stakeholder. This phenomenon is known as the problem of asymmetric information. Such asymmetric information creates market distortions for the reasons explained above. The literature in Accountability addresses the problem of asymmetric information by emphasizing the importance of creating a “mutual vulnerability” (or interdependent relationship) between a firm and its stakeholders to induce proper behavior and disclosure by firms. The idea behind this is that a firm will more likely disclose important information to the stakeholder if it is mutually dependent upon the stakeholder for its existence.11 The idea of accountability is relevant to all agents that may possibly engage in harmful behavior unbeknownst to stakeholders, ranging from large multinational corporations to small recycling firms. Policy is an important mechanism used to foster “mutual vulnerability” and thereby promoting accountability by a given firm.12

This paper adds to the policy debate because it asserts that policy should create the right incentives for all stakeholders in the electronics industry to function optimally according to the product’s life cycle. It analyzes various existing and proposed policies for electronics recycling by looking at stakeholder incentives as identified by environmental economic theory and market analysis; and it identifies two important outcomes of successful electronics recycling policy, accountability in material management and access to residential recycling. Additionally, it provides an empirical study that analyzes two established policies that govern recycling for Cathode Ray Tubes (CRTs), the federal Resource Conservation and Recovery Act (RCRA), and the Massachusetts’ policies concerning CRT disposal. The study evaluates the effectiveness of these policies in promoting CRT recycling by analyzing the two key outcomes identified in this paper. Lastly, this paper highlights areas in the electronics recycling debate that require further research.

Framework for Policy Evaluation

This research is based on the premise that improper disposal generates negative externalities that impact both current and future generations. Improper disposal includes the landfill and open land dumping as well as the use of crude and harmful recovery methods. The externalities generated are the loss of non-renewable materials and damage to both human health and the environment; and are a byproduct of economic disincentives for widespread safe and proper recycling of discarded electronic equipment Robin Ingenthron, President of American Retroworks, Inc., argues that recycling consumes less energy and generates less pollution than does the extraction of new materials in his published report, “Setting a Higher Standard: Establishing and Adhering to Best Practices Could Help Solve Export-Related Electronic Scrap Problems-Electronics Exporting.”13 According to the costs of funding remediation projects under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), it also appears that it would be less costly to recycle than it would be remediate environmental damage caused by improper disposal and mining of virgin materials.14 Because these externalities not only impact current generations but also future generations, it is reasonable to assume that the marginal external damages for improper disposal are greater than the marginal benefits gained from the use of the electronic equipment; thereby indicating the existence of market distortions in the electronics industry.15 As such, by applying key concepts in environmental economic theory, it is also reasonable to assume that promoting safe and proper electronics recycling reduces these externalities and restores more efficient use and allocation of resources to the market.16 This research holds that safe and proper recycling is the only viable option for disposal of electronic equipment and that recycling is an integral part of the natural life cycle of electronic equipment. The term ‘recycle’ in this paper includes all outputs generated by the electronics recycling industry, including the reuse of whole products and components.

Because the electronics recycling industry is intrinsically connected with all other stakeholders that impact the product’s life, this interdependency requires proper incentives for each stakeholder to operate with recycling at the end of life in mind. This paper identifies important incentives required by each stakeholder to promote a sustainable electronics recycling industry. However, because policy, both directly and indirectly, impacts stakeholders’ economic and regulatory incentives in the management of resources, policy is evaluated according to whether or not it promotes the right kind of incentives for each stakeholder.

Policy can also be evaluated by assessing policy outcomes. Two policy outcomes that result from creating the right incentives for stakeholders are identified in this research and are used to evaluate policy through an empirical study. These outcomes are consumer access to recycling and accountability in how material is managed throughout the recycling process. Access demonstrates that incentives are sufficient for market entry by electronics recyclers; and accountability demonstrates the proper flow of information so as to minimize external damages through material management practices in recycling.

Why Focus on Cathode Ray Tubes?

The focus on CRT products provides an opportunity to narrow the economic analysis on policy outcome for electronics recycling and helps identify key factors that create market distortions within the electronics recycling industry. The economic barriers in recycling CRT products, especially residential CRT products, represent many of the key challenges faced by other consumer electronic equipment. Yet, despite the economic challenges, the importance of recycling is evident. By focusing on CRTs, this research conveys how market distortions in the electronics recycling industry arise and creates a framework to evaluate policy designed to correct market distortions. For this reason, the findings in this research impact the entire electronics industry. Nevertheless, according to an interview with Mike Watson, Senior Compliance Manager, Global Asset Recovery Services for Dell, some stakeholders wish to distinguish policy for electronic items by separating electronic equipment that is considered to be information technology (IT) from those electronic products which are not. The rational behind this is from the fact that IT products tend to have more reusable components and/or more valuable material per weight; and, therefore, they are more economical to recycle.17 However, all electronic equipment varies across time according to market demand, technological requirements and design. As such, these requirements will continue to alter material content, product life, and ‘recyclability.’ Therefore, by promoting a coherent policy which provides the correct market incentives for all stakeholders as outlined in this research, the efficiency of material allocation and design for electronic equipment will continue to be maintained, regardless of product evolution.

CRT Product Information

CRT products include televisions and CRT monitors. Like other consumer electronic equipment, CRT products are wide spread and the number of obsolete products is increasing. According to a study in Massachusetts conducted in 2000, 99 percent of households had at least one television, (with 43 percent owning at least 3); and almost 60 percent of households had at least one computer.18 The estimated annual turnover rate is approximately 57 million; and that rate is expected to increase as more consumer convert to High Definition Television (HDTV) and other newer technologies.19 Additionally, previous research has found that a large amount of obsolete CRT products have been held in storage, creating a backlog of CRTs waiting to be sent into the waste stream.20 The U.S. Environmental Protection Agency report, Analysis of five Community Consumer/ Residential Collections of End-of-Life Electronics and Electrical Equipment by EcoBalance Incorporated, reported that CRT products make up the majority of discarded consumer electronic products in the electronic waste stream.21

A CRT product is bulky and heavy to transport, it contains a high amount of toxic materials, and most of its weight is in low valued materials for recycling (leaded glass and plastics).22 An average CRT monitor weights about 35 pounds.23 Approximately 60 percent of its weight is in leaded glass and approximately 18 percent is in plastics (from the encasement). Other materials include copper (9.1 percent), and steel, (11.4 percent).24 The leaded glass in a CRT is a composite of lead, silica and barium.25 Lead makes up approximately 8 percent of the CRT weight.26 It is an essential component in CRT glass because it shields consumers from harmful radiation emitted from the decelerating electrons which generate the images on the CRT screen.27 Nonetheless, lead, when in a volatile form, is known to be hazardous to humans and animal life if it is inhaled, ingested, or is absorbed by dermal contact.28

CRT Disposal Concerns

The disposal of CRTs in landfills causes both the loss of non-renewable resources and toxic contamination, which can leach into the soil and water supply if adequate protection and monitoring is not continually provided.29 According to a report by the Florida Center for Solid and Hazardous Waste Management, “CRTs’ lead content may represent as much as 80 percent of the toxic metals in discarded electronics.”30 Landfill disposal also increases environmental and social damages through the continued necessity of finding and extracting new virgin materials to replace that which is lost into the landfill.31 Extraction of virgin materials require more energy consumption than does the recycling of the electronic equipment; and it causes more environmental damage through the release of heavy materials into the environment.32 The improper recycling of CRTs also generates environmental and social damages; especially when recycling actually constitutes as dumping in the guise of recycling. For example, most US firms ship CRTs to be recycled or reused to firms in lesser developing countries with little or no enforceable environmental and/or human safety laws. Some of the receiving firms in these developing countries recycle only the most valuable material in the CRT, the copper yolk, by using unprotected human labor to break the CRT and retrieve the copper yolk and then discard the CRT leaded glass in an unprotected dump. The lead from the leaded glass then leaches into the soil and water supply, where it causes damage to the population, water and food resources.33 Unless an economic advantage exists for recyclers to engage in safe and proper electronic recycling, the electronics recycling industry may instead encourage poor disposal and recycling; and, thereby, contribute to the increase in external damages. Consequently, the only means by which these distortions can be mitigated and proper and safe recycling can take place is through the implementation of effective policy.

Empirical Study

This paper provides analysis for an empirical study conducted by sampling programs for CRT recycling in two geographical regions with differing policies. The two geographical regions compared are Texas and Massachusetts. The purpose of the study is to evaluate the effectiveness of the two policies by evaluating two main outcomes. The study evaluates the effectiveness of the federal Resourse Conservation and Recovery Act (RCRA) in Texas and the CRT related-policies in Massachusetts in promoting safe and proper residential CRT recycling. The two performance measure outcomes evaluated are residential access to CRT recycling and a demonstrated level of accountability in the material management practices for the recycling of collected equipment. The performance of the program in providing residential access to CRT recycling is a measure of the policies effectiveness in creating the right incentives for stakeholders to enter the market. Residential access to CRT recycling reflects the success of state programs in providing incentives for consumers to choose recycling over other forms of disposal. It also reflects the success of these programs in providing incentives for recyclers to offer consumers CRT recycling services in the market. A demonstrated level of accountability in material management measures the success of economic and regulatory programs to promote safe and proper recycling of the discarded equipment throughout each stage in the recycling process. A higher level of accountability corresponds to greater transparency of information about the material management process to all stakeholders; and thereby, promotes safe and proper practices because it reduces the problem of asymmetric information. On the other hand the problem of asymmetric information results when an agent (a recycler for example) working on behalf of the stakeholder (the public for example) has information unknown or non transparent to the stakeholder and therefore may have economic incentives to take actions that are not in the best interest of the stakeholder (such as improper disposal of hazardous materials and/or the use of unsafe methods of material recovery).

Because Massachusetts’ CRT policies were created as a concerted effort to increase consumer recycling of CRT products, the initial assumptions prior to the study were that access would be high under this set of policies. A review of the policies found no incentives that encouraged accountability by recyclers. However, until the study was conducted, it remained uncertain as to whether or not the policies promoted some level of accountability in the form of disclosure for material processing requirements, final output and destination. Alternatively, the federal RCRA policy has been criticized by stakeholders as being both too restrictive and too lenient in promoting electronics recycling for CRT products. Some stakeholders claim that RCRA discourages market access to residential CRT recycling because of the mandatory restrictions it imposes on CRT handling and disposal. On the other hand, other stakeholders argue that RCRA is too lenient on consumer disposal of electronic waste and on the export of hazardous waste and products for reuse and/or recycling. The latter argument claims that the RCRA export regulations encourage improper disposal and recycling by many electronics recyclers in the market. The initial review of the policy prior to the empirical study suggests that CRT recycling access would be limited. It also suggests significant loopholes that would discourage practices promoting accountability. The results of the study confirm initial assessment and principles of environmental economic and accountability. Accordingly, it highlights the importance of comprehensive policies that take into account the interdependent roles and functions of each stakeholder and incentives according to market forces in promoting a viable and sustainable electronics recycling industry.

Research Format

The second chapter provides an overview of the electronics recycling industry. It provides an understanding of how the electronics recycling industry operates. Importantly, by defining the roles by which each stakeholder supports electronics recycling, this chapter demonstrates the importance of recycling in context with the life cycle of the electronic equipment. Additionally, this chapter also attempts to illustrate the economic challenges for electronics recycling by relating them to the economic challenges in recycling CRT products and the lack of proper stakeholder incentives to make recycling the primary objective when the electronic equipment reaches its end of life.

The third chapter provides a critical overview of the various policies used to govern CRT recycling and/or the recycling of other types of electronic equipment. This chapter explains the rational for each policy and attempts to highlight positive attributes and disadvantages according to (1) stakeholder incentives as defined in Chapter 2, (2) previous research on a given policy, and (3) political debate among stakeholders. This chapter highlights two specific statutes for a case study. These statutes are the federal RCRA policy and the Massachusetts’ CRT disposal policies. The federal RCRA is an important policy to evaluate because it regulates electronic waste disposal in the majority of the states within the U.S. At the same time, it has also been a contentious policy. As a backlash to RCRA, several individual states have adopted new policies which they deem to be more effective in promoting electronics recycling. Massachusetts is one of the first states to adopt differing disposal/recycling policies for CRTs; which it implemented in the year 2000. The longevity of the policy makes it an attractive case study. On the other hand, many other state policies pursued have either only recently been implemented or have continued to evolve by the addition of new layers of related policy programs on top of existing ones; and therefore, making it difficult to adequately measure the success of specific programs. Nonetheless, the fundamental principles behind the policies being pursued are presented and evaluated.

Chapter 4 presents information from the empirical study concerning the two policies more thoroughly analyzed in Chapter 3, the federal RCRA policies and the Massachusetts’ CRT disposal policies. This chapter provides the methodology, the results and analysis of the empirical study. The study is based on measuring two key outcomes which are highlighted in Chapter 2 and Chapter 3. The results from the empirical study are compared with the policy analysis provided in Chapter 3. The results of the study not only confirm prior analysis but also raise awareness of questions for further study. Lastly, Chapter 4 summarizes the key findings from this research, and presents policy implications and suggests areas for further research.

The results of the empirical study reveal that neither of the policy programs for CRT recycling pursued in each geographical region were sufficient in creating incentives for safe and proper recycling. The policy programs pursued in Massachusetts created sufficient residential access to CRT recycling. They also were successful in creating a willingness by consumers to pay for CRT recycling. However, the policies pursued substantially lacks accountability measures in ensuring that the material collected is recycled in a safe and proper way. On the other hand, the federal RCRA policies as implemented in the state of Texas had limited access in creating residential access to CRT recycling. Only the large Metropolitan areas with more a population of more than one million consistently had outlets for residential CRT recycling. Surprisingly, the majority of the respondents in Texas that recycled CRT products did attempt to implement some level of accountability throughout the recycling process. The most common reason given was that it was good for public relations followed by the belief that the public demanded measures for accountability and that existing laws were insufficient. These responses highlight the value of the public as an important stakeholder in the recycling process. Nevertheless, no one standard in creating accountability for safe and proper recycling has been universally accepted. As such, the standards pursued by recycling collection facilities differ and disagreements exist among stakeholders as to their effectiveness.

In conclusion, this research reveals importance of policy programs not only for creating residential access for recycling, but also in promoting accountability in material management throughout the various stages in recycling. The theoretical research supports policies that create an interrelationship among all stakeholders in the recycling process. This interrelationship can be achieved by creating the right economic incentives for each stakeholder. To promote the optimal policy for sustainable CRT and/or electronic recycling, further research is necessary in defining universally accepted standards of accountability in material management practices and in creating environmental economic models that incorporate the various types of material outputs from the recycling process as well as all stakeholders.

2. The Electronics Recycling Industry

CRT recycling is an important subset to the electronics recycling industry. It has become fully integrated into the electronics recycling process. The challenges for CRT recycling are not unlike that of other electronic equipment. However, due to the specificity of CRT recycling and the large number of discarded CRTs, these challenges are magnified. As a result, CRT recycling both affects and is affected by the electronics recycling industry and the market in which it operates. For this reason, CRT recycling should be reviewed in context with the electronics recycling industry, rather than separately. This chapter provides an overview of the electronics recycling industry’s size, make up, and a description of how it operates. It also attempts to provide a basic understanding of market forces driving the industry. It identifies key stakeholders and their corresponding market roles for the creation of a viable and sustainable electronics recycling industry. Lastly, this chapter describes several key challenges that the electronics industry currently faces and connects those challenges with the prevailing economic forces. Through this broader understanding of the electronics recycling industry, the key industry issues concerning CRT recycling become more apparent.

Electronics Recycling Industry Overview

The electronics recycling industry, while still a relatively young industry, has its roots in the old industry of scrap metal recycling, since the most valuable material recovered from electronic equipment has traditionally been its metal content.1 Today, the electronics recycling industry is a billion and a half dollar industry. According to the recent industry report by International Association of Electronics Recyclers (IAER), the industry doubled in size within the past three years, and it is expected to double again by 2010.2 Such market growth within the past three years has also yielded a 10 percent increase in the number of companies working in this industry.3 Yet, for the market size, this industry is comprised of a large number of small companies. According to the recent IAER Industry report, the electronics recycling industry is made up of approximately 500 companies. More than half of these companies operate in only one location; employ fewer than 20 employees; and generate less than $5 Million in annual revenue. As such, the industry is ripe for market consolidation through mergers and acquisitions, which it is now beginning to experience.4

Functions

To distinguish firms in the electronics recycling industry from those in other scrap recycling industries, the IAER study defines an electronics recycler as a company “with operations in one or more of the basic segments of the industry.”5 The IAER lists these basic segments as:

  1. Asset Management
  2. Broker
  3. De-Manufacturing
  4. Recovery of Parts and Subassemblies
  5. Materials Recovery and Recycling
  6. Materials Processing/Refining6

These segments construct a reverse logistics supply chain by which material is managed, sorted and processed. According the IAER report, Asset Management is the management over “inventory, disposition planning and the resale of product.”7 For discarded electronic equipment that also contains sensitive data, this function also includes data destruction.8 The term “Broker” describes the task of sale (or auction) of equipment for resale and export. Equipment for resale/auction includes whole working and non-working equipment which may be used “as-is”; refurbished to the original condition, or enhanced. Equipment that is not re-used or refurbished is de-manufactured. De-manufacturing is the disassembly of whole equipment to separate out parts by components and materials. “Recovery of Parts and Subassembly” is the process that determines whether or not components retrieved from the equipment are reusable or scrap. Reusable components can be sold for reuse into new or refurbished products. Non reusable components undergo “materials recovery and recycling” where they are further separated into like materials to prepare for the next process of “materials processing/refining.” In this last stage, the raw materials are recovered for reuse through processes that include “shredding, grinding, palletizing, and reefing.”9 Through the process of triage and recycling, the electronics recycling industry produces three types of outputs: whole units for resale, components for resale, and raw materials from scrap.

According to the IAER study, the electronics recycling industry currently processes 2.8 billion pounds of electronic equipment per year. Less than half of that amount (1.3 billion pounds) results in recycled material from scrap; and, over half of the equipment or its components are sold for reuse.10 One recycler commented that “you cannot understand the electronics recycling industry until you understand the secondary markets” where products are sold.11 This is because the market price for each type of output in each of these sectors impacts the revenue the electronics recycling industry can generate as well as the costs they incur.

Key Revenue Sources

Electronics recycling firms generate revenue from fees charged; through the resale of whole equipment and reusable components; and from metal recovery.12 The revenue from resale is a driving source of revenue for the industry. One study conducted by the Massachusetts Department of Environmental Protection showed that the resale value on whole products for 5 to 10 percent of the equipment collected was ten times greater than the remaining scrap material. Resale outputs also require significantly less processing, thereby, incurring fewer costs. The study revealed that the ability to resale is dependent upon the demand for the items in the secondary market. The study also noted that most of the secondary market is in the developing world, where they are less adverse to older technology and where labor for repair is significantly cheaper.13 Based on the conclusions of the 2006 IAER report, a report which has a broad US focus on the electronic recycling industry, “most of the equipment output from recycling operations was exported” and over half was exported as whole equipment. However, the actual amount of material that is eligible for resale is debatable and depends significantly on the type of equipment originally collected. For example, discarded residential equipment will have less resale opportunity than discarded equipment from a large corporation. This may be because residential products are likely to be older and closer to the end of the equipment’s life; whereas, a corporation may more likely discard working product as a result of a technology upgrade.14

On the other hand, a more narrowly focused study involving a small electronics recycling sample located only in California by Hai-Yong Kang and Julie M. Schoenung in their paper, “Economic Analysis of Electronic Waste Recycling: Modeling the Cost and Revenue of a Materials Recovery Facility in California”, reveals the recycling fee was the largest revenue source, followed by metal recovery, with revenue from resale generating the least. The authors noted that resale was limited in this study because the few working items that were received by the recycler being studied could only be “sold to regional repair shops.”15 The outcome from this study, therefore, may also reflect regional external pressures such as regional regulatory constraints and/or contractual agreements with consumers and suppliers which may limit exports to secondary markets in developing countries. It may also reflect technological limitations in identifying and easily repairing equipment or components for resale. Nevertheless, this study highlights the importance of fees as a key revenue generator; and underlines the vulnerability of the electronics recycling industry if material providers were not willing to pay them for recycling. Accordingly, fostering economic incentives to ensure that recyclers are paid appropriately for recycling is discussed in more detail in the next chapter.

Key Cost Factors

The more processing of material that must be done, the more costs a firm must also incur. Key cost factors that electronics recycling firms face include transportation costs, labor costs, CRT recycling costs and high up-front equipment costs.16 Of these, according to a study conducted by Kang and Schoenung, the costs associated with CRT recycling and labor account for approximately two thirds of the costs incurred by electronics recycling firms for material recovery.17

CRTs are expensive to recycle because:

  1. They are bulky and heavy.
  2. They require appropriate environmental conditions and handling due to their high lead content.
  3. They must undergo a significant amount of processing before they can be recycled into new glass.
  4. The material recovery value is very low.18

As with all electronic equipment, the recycling of a CRT product (monitor or television) begins with triage. A CRT has a life expectancy between 15 to 20 years, if not damaged by screen burn. However, a particular CRT product may have a shorter life expectancy due to non-CRT related electronic or mechanical problems.19 The estimated percentage of the number of CRTs collected that can qualify for resale is between 25 to 30 percent.20 If the CRT is not reusable, then the CRT glass is broken, sorted and cleaned to prepare it for glass-to-glass recycling or it is sent to a smelter where the lead is removed from the glass.21

Each CRT has two types of leaded glass, (the glass that makes up the panel and the glass that makes up the tube); and they differ in their composition of silicate and lead and differ visibly in color. Accordingly, before the glass can be recycled into new glass, the two different types of glass must be separated. This adds additional operational costs to an already costly process. A nation-wide study conducted by the U.S. Environmental Protection Agency (EPA) demonstrates the relative costs associated with CRT recycling in comparison to revenue from material recovery. It estimated an average cost of US$271 per ton for CRT collection, alone; and another US$192 per ton for a glass processor to receive it after it was already stripped down to the individual CRT unit. If the glass was broken with mixed leaded glass, then a hauler may incur an additional US$325 per ton to transfer it to a glass processor, where the processor would then have to separate the different types of glass for recycling. In contrast, the revenue recovered from recycling the CRT glass, once the glass had been sorted, cleaned and processed to specifications was estimated to be only US$175 per ton.22

The recycling of residential consumer electronic equipment exacerbates costs incurred by the electronics recycling industry because discarded consumer electronic equipment consists of a large number of CRT products (primarily televisions) and other equipment with little to no life expectancy. According to one EPA study, televisions make up the majority of discarded consumer electronic products.23 As such, according to the IAER report, the high number of televisions in the consumer electronic waste stream “usually resulted in a net loss when taken together with the recycling costs of transportation, packaging, and labor.”24

The current replacement rate for CRT products has been fairly constant in recent years. The IAER report estimates that the current replacement rate for consumer televisions are 20 million per year and 30 million per year for consumer computer monitors.25 These estimates also match closely with the EPA estimates which show a replacement rate of approximately 57 million for both consumer televisions and monitors combined per year.26 However, this replacement rate may likely increase due to the increasing adoption by consumers of newer technologies such as Digital and HDTV and Liquid Crystal Displays, which could further exacerbate potential costs.27

The other key cost factor is labor. Labor costs in the electronics recycling industry are estimated to be 28 percent of total costs according to a study conducted by Kang and Schoenung. Labor costs are significant because the disassembling of many unlike products and components is very labor intensive. The need to disassemble many dissimilar products for material recovery, since most of the equipment and components were never designed with disassembly in mind, makes automation substitution challenging.28 One way that companies reduce their labor costs is by exporting products to developing countries for disassembly and processing because labor there is significantly cheaper.29 Another way that cost of labor has been subsidized is through the use of community service labor30 and/or prison labor.31 Accordingly, the significance in labor costs has obviously impacted the way the industry has developed and how material is often managed.

Electronics Recycling Stakeholders

The stakeholders in the electronics recycling industry penetrate the entire life cycle of electronic goods. They include not only those companies that engage directly in electronics recycling, but also producers of electronic goods; regulatory agencies; manufacturers of electronic components; trade associations; consumer organizations; environmental organizations; retail and non-profit organizations; local governments; employees in the electronics recycling industry; and raw material producers (mining companies, scrap metal refineries, plastic manufacturers). Each stakeholder's role varies according to its financial and/or regulatory interest in the industry.

The diagram below demonstrates the relationship that key stakeholders (consumers, producers, electronic component manufacturers, raw material processors, and distribution channels) have with the recycling industry and with each other. The commercial and residential consumers both supply product directly to and purchase working used products from recyclers. The product that consumers send to recyclers is product that had originally been manufactured by producers of electronic goods. The inputs necessary to manufacture the electronic products come from both manufacturers of electronic components and raw material processors. Electronic components sold to producers are either made of material purchased from raw material processors, or retested used components recovered from recycling. Raw material processors depend on the supply of both virgin and recycled material. Various distribution channels such as retail stores, freight companies, and brokers transfer the material/product from one entity to the other.

Figure 1 Electronics Industry Interrelationship
Electronics Industry Interrelationship

Supply Base

Commercial industry has been the key economic force driving electronics recycling. The leading sectors in the commercial industry are: financial services, banking, telecommunications, and information technology.32 According to the IAER report, the market in discarded electronic equipment in the commercial sector is approximately four times the size of that of the residential sector. The recycling industry has been able to provide the commercial industry with solutions for their data security and destruction requirements; and for their regulatory requirements and associated costs for the disposal of electronic equipment due to the significant amounts of hazardous toxins they contain. Accordingly, many new entrants in the electronics recycling focus on data destruction services and other technical solutions geared toward the commercial industry’s needs.33

Nonetheless, the “rapidly increasing” residential consumer electronic waste stream and the increasing social demand to create a framework to recycle these products has forced the electronics recycling industry to take notice of the residential segment as well.34 Current estimates from the IAER report show that about 300 million consumer electronic products per year will “become potential scrap.” That estimate quickly increases to 400 million consumer electronic products per year for the remaining decade.35 Currently, only about 10 percent of consumer electronic products are being recycled, according to the IAER report.36 In accordance with these figures, the majority of the recycling firms interviewed for this research indicated that less than 1 percent of the products they processed were residential consumer products.37 Nevertheless, the increasing social demand to manage residential consumer electronic waste has lead the development of policy in many countries, driving individual states and local governments to create incentives for both consumers and electronics recyclers to recycle consumer electronics.

Customers versus Suppliers

Commercial industries and residential consumers serve the electronics recycling industry as not only suppliers of electronic equipment but also as customers. This is evident in the collection of fees for recycling. Accordingly, commercial industries and residential consumers act as customers in that they receive disposal services for hazardous materials and data destruction services from the recycler.

However, the electronics recycling industry also serves another customer base. This customer base is the output market for their reverse logistics supply chain. This customer base includes:

  1. Resellers in both the developed and developing markets,
  2. purchasers of electronic components for distribution channels in secondary markets, and
  3. purchasers of raw materials.

Accordingly, each of these principals represents an outlet option for each type of product output processed by the electronics recycling industry.

Greater revenue potential in one area over others can create strong economic incentives for electronics recyclers to also prefer one output method over another, such as resale over the recycling of low valued raw material such as leaded glass. The material directly supplied by the commercial and residential sector directly impacts potential revenue that an electronics recycler can generate from its downstream customer base. However, the commercial and residential sector has little to no influence on the re-use potential of products and components, the quality and/or quantity of the recoverable material, and the ease by which valuable materials and components can be retrieved Rather, the ability to influence these areas reside primarily in the producers of the electronic equipment who sold the equipment into the market in the first place.

Producers have a direct influence on the quality of the material transferred to the electronics recyclers primarily through their product design. A producer can improve the electronics recycler’s profitability through design by targeting specific areas crucial for lowering costs and maximizing revenue. One area is the challenge in demanufacturing/disassembly. A product can be originally designed for easy disassembly; thereby, substantially reducing labor costs for an electronics recycler.38 Another area is through potential resale of whole products and components. Producers can directly impact the resale potential by designing products with a longer life-span or by using key components which have long life. A third area is through the use of better recyclable materials over less recyclable, such as the use of easily recyclable plastics over plastics that contain certain brominated flame retardant chemicals, which may be difficult and/or hazardous to recycle.39 Lastly, producers can also impact market demand for recycled materials by requiring their supply chain to use more recycled materials in their components.

Despite the producer’s ability to directly impact the profitability of the electronics recycling industry through design choices, unless a producer has a direct economic incentive to improve ‘recyclability’ of its product, it will likely not incur an extra expense in operations and design to do so. As such, producers have become prominent stakeholders in the electronics recycling industry and many have taken active roles in addressing regulatory and logistical concerns in the industry.40 However, according to Joel Denbo, Chair of the Institute of Scrap Recycling Industries, Inc. (ISRI), in his testimony to the 109th Congress, “to date, voluntary calls by the recycling industry to motivate manufacturers to adopt a Design for Recycling philosophy have met with only a tepid response.”41 For this reason, some countries and states have passed legislation that attempts to better link producers with recyclers by creating regulatory and economic incentives to improve product ‘recyclability.’ The Extended Producer Responsibility (EPR) is an example of this type of legislation that has passed in various forms across Europe and in several states within the United States.

Distribution Channels

A key component in the supply chain is the creation of distribution channels from the supply base (primarily residential) to the electronics recyclers. The distribution channels for funneling discarded electronic equipment from these sectors to electronics recyclers are made up of various types of organizations/agencies. These organizations/agencies include: (1) municipal collection facilities/ transfer stations; (2) retail chains; (3) non-profit organizations; and (4) public or private waste haulers. The manner by which these organizations/facilities function as a distribution channel for electronics recyclers differs across local communities, regions, and states. Their capability to contribute to the collection and distribution of electronic equipment is mostly dependent upon how these facilities were set up to operate to begin with and the prevailing policies. Because residential electronic equipment must be centralized through clear distribution channels, these distribution channels can only operate effectively if economic incentives do not exist. According to a report by Northbridge Environmental Management Consultants on Massachusetts’ CRT recycling, economic incentives may be achieved by the use of government subsidies, or fees collected from residents.42 Alternatively, producers of electronic equipment may also subsidize recyclers, as is the case for several of Dell’s consumer recycling programs.43

Local municipalities may already run a transfer station and/or storage facility whereby it takes in other types of products that must be recycled, such as batteries and paints. Depending on the size, location, and available funds to safely monitor and store discarded electronic equipment, such a facility can also be used as a collection facility for electronics recyclers. Accordingly, private trash haulers that are already accustomed to sorting out dangerous materials for proper disposal may also be well equipped to add electronic equipment for diversion toward recycling.44

Retail chains already operate fairly sophisticated distribution networks; and are a key supplier of new consumer electronic equipment. Their association with consumer electronics, relationships with producers, and their knowledge of distribution networks have enabled some retailers to work with producers to offer either permanent collection facilities on site for specific types of electronic equipment (such as cellular telephones) or special recycling collection events (such as Best Buy has offered in certain stores across the nation).45

Most residents identify non-profit organizations such as Goodwill and the Salvation Army as organizations that accept discarded useful consumer goods that can be resold into the community; thereby creating jobs for those in need. Before consumer electronic equipment recycling became a topic of debate, these organizations had already been receiving these products for resale.46 According to a key study on CRT Recycling by Massachusetts Department of Environmental Protection (MassDEP), these organizations can be very useful in offering recycling access to residents and in providing electronics recyclers with a controllable, steady flow of electronic product.47 Accordingly, depending on access to and relationships with electronics recyclers, these organizations may accept (1) only working product; (2) working and non-working product free of charge; or (3) working product and non-working product for a fee.48 These organizations may also implement triage in their collection service. For example, Goodwill Industries in Central Texas, sponsored by the electronic equipment producer, Dell, incorporated electronics recycling triage into its model to provide both jobs and technical job training. This model is known as the Computer Works Program; and it allows the charity organization to directly benefit from the revenue on all items that can be resold in their Computer Works store. The remaining scrap is sent on to Dell approved downstream vendors for further processing.49

Special Interest Groups

Special interest groups serve as public advocates on behalf of the sector they represent. For this reason, trade associations within all aspects of the electronics industry and electronics recycling industry have taken positions in political, economical, and social debates regarding electronics recycling. Trade associations for the electronics recycling industry include the International Association of Electronics Recyclers (IAER), Institute of Scrap Recycling Industries, Inc.(ISRI), and Northeast Recycling Council (NERC). These organizations have been proactive in providing relevant information about the electronics recycling industry and advocating on its behalf. However, because environmental organizations and advocates of public health in the developing world are raising concerns about how material in the electronics industry is being handled with respect to its hazardous content, these stakeholders have also been proactive in trying to establish guidelines for best practices in material management for the industry. Accordingly, the IAER has developed a certification process which requires the implementation of specific material management practices.50 In addition, ISRI is currently negotiating with other industry stakeholders to develop universally accepted guidelines for material management in handling and processing electronic equipment.51

Other active trade associations and industry consortiums include those that are made up of or represent other key contributors to the electronics recycling industry, such as producers, consumers, electronic component manufacturers, and raw material processors. Examples of these organizations include iNEMI (International Electronic Manufacturing Initiative), CEA (Consumer Electronics Association), and EIA (Electronic Industries Alliance). iNEMI is involved in improving technology to promote best industry practices by electronic equipment manufacturers and their suppliers.52 The EIA, which represents electronic manufacturers in the United States, has also proactively set forth criteria for screening electronics recyclers according to its preferential materials management practices.53

The concern over how electronic equipment has been managed has much to do with the large amount that is exported and processed in developing countries with little to no enforceable environmental regulations. Because of the hazardous toxins that these products contain and the potential danger they pose to human health and the environment, environmental regulatory agencies, non-governmental environmental organizations, and labor groups have also become essential stakeholders in the electronics recycling industry. Environmental regulatory agencies include the federal Environmental Protection Agency (EPA), and individual state environmental agencies. These agencies are responsible for ensuring that the appropriate environmental regulations are in place and enforced according to legislative mandates.54 Labor groups and government agencies such as the Occupational Safety and Health Administration (OSHA) serve as advocates and regulatory agencies to protect workers and limit their exposure to such toxic materials.55

Non-governmental environmental organizations such as Basel Action Network (BAN) and the Silicon Valley Toxics Coalition have been instrumental in raising public concern over certain hazardous business practices.56 As Elizabeth Grossman reports in her book, High Tech Trash, such concerns have been primarily centered on the export of products for recycling and reuse to companies in developing countries that in turn may employ poor people to disassemble and recover materials and parts using rudimentary and crude methods without providing protection to laborers or the environment. The result of such practices have been a proliferation of toxic chemicals such as lead, mercury, and chromium into the water supply and soil and has had tremendous impact on the environment and on the health and development of both adults and children in these regions.57 Because easy access to markets in developing countries provides the electronics recycling industry with cheap labor, fewer environmental regulations and a high demand for the recovered materials; much of the material output from the electronics recycling industry is exported to these countries.58 While not all electronics recycling output exported to developing countries result in poor material management through unsafe recovery practices, the cost benefit and the ease of which it can be done has motivated nongovernmental agencies like BAN to raise general public concern over the material management practices conducted by the electronics recycling industry.

Examples of the external damages from crude methods of electronics recycling are well documented and reported. For example, on February 19, 2007, the NewsHour on the Public Broadcast System (PBS) aired a report called “Electronic Waste Adds to Pollution in India;” whereby, Thuppil Venkatesh from St. John’s Medical College claimed that as a result of crude methods in electronics recycling, “53 percent of children under 12 in India’s cities are lead-poisoned, meaning permanent brain damage that claims up to 20 percent of a child’s I.Q.”59 In an article titled “Firms Starting to Stem Wave of Toxic Tech Junk,” published in the Austin local newspaper, An article in the Austin American-Statesman dated March 5, 2007, states “a recent government report found that more than 80 percent of the children in this city [Guiyu, China, (a city that depends on recovering material from discarded electronic products)] of 133,000 have lead poisoning”.60 Reports from BAN confirm similar findings across the developing world.61 In essence, the electronics recycling industry is responsible for creating negative external social damage, which reflects market distortions within the industry. The environmental nongovernmental organizations act as a whistle blower to increase awareness of these externalities. However, it is the responsibility of the public, a critical stakeholder in promoting the well being of the environment and human health, to act upon available information to foster more effective policy. The public, like other stakeholder, must also have the proper economic and social incentive and tools to create effective and efficient change and demand accountability by companies, which in turn would create proper incentives for electronics recyclers to institute proper and safe methods for material recovery and handling through out the reverse logistics supply chain.

In sum, each stakeholder has an important function in the development and the efficiency of the electronics recycling industry. The electronics recycling industry is not a traditional linear production industry whereby it uses a certain amount of inputs to produce a specific quantity of a particular good(s) according to a given price for resale to a particular customer base. But rather, it must rely on a number of external conditions for its material and product supply; and therefore must diversify its customer base to accommodate for variations in supply. Because of the hazardous materials contained in the electronic equipment, the industry should also be held accountable for its processing methods throughout the reverse logistics supply chain. Accordingly, each stakeholder plays an essential role in creating market base solutions to create a viable and sustainable industry. Therefore, a better understanding of each stakeholder’s connection with the electronics recycling industry combined with a better understanding of the prevailing market distortions that limit them from functioning properly is essential in developing proper economic incentives through policy such that each stakeholder operates more efficiently and effectively.

Market Distortions and Corresponding Challenges

The need to create proper economic incentives so that stakeholders operate efficiently and effectively is evidence of existing market distortions that impact the entire life cycle of the electronic equipment produced. Market distortions impede the proper allocation of resources by creating externalities.62 The economic challenges created in recycling residential consumer electronic product impedes the proper use of non-renewable resources and creates negative externalities through the improper disposal and/or handling of toxic materials. Accordingly, the immediate economic benefit encourages dumping and the use of harmful recovery methods, both of which create long lasting negative external damages. Lastly, lack of an interconnection between electronic equipment production and recycling creates incentives to use inefficient design and material allocation. Each of these market distortions impedes the development of a viable and sustainable electronics recycling industry. Accordingly, each of these market distortions translates into direct economic challenges identified by the electronics industry and stakeholders. These include challenges in:

  1. Designing recyclable product,63
  2. creating viable markets for output (especially for low-valued material such as plastics and leaded glass),
  3. developing better technology for more efficient processing,
  4. creating efficient logistical distribution networks for recycling residential consumer electronic equipment (especially for costly items such as CRTs),64 and
  5. creating accountability in material management processes throughout the reverse logistic supply chain.

However, efforts by individual states to curtail one or more of these market distortions by imposing their own policies have created non-uniformity in regulatory environments across the United States, which have created an additional challenge that impedes electronics recyclers from operating efficiently across borders and reaching efficient economies of scale. These challenges are highlighted in the IAER 2006 Industry report65 and in the transcripts from the 109th Congressional hearing, 1st session, titled, Electronic Waste: An Examination of Current Activity, Implications for Environmental Stewardship, and the Proper Federal Role, for the House Committee on Energy and Commerce on Environment and Hazardous Materials.66

The first four challenges listed above reflect the need to reduce operating and processing costs and improve revenue outlets so that the industry can effectively recycle the increasing amount of residential consumer electronic equipment.67 For example, the challenge to realize greater efficiencies in the logistical infrastructure is due to the challenge to more efficiently collect consumer/residential electronic products and to reduce transportation costs for bulky and costly consumer products like CRT products. Similarly, the need to improve techniques and technology in the recycling industry is important to remain competitive and profitable in the processing of low valued materials such as leaded glass and low grade plastics and in the demanufacturing of labor intensive equipment.68 However, the ability to create innovative technological solutions are hampered by the high upfront costs for research and development and the highly competitive global environment that stems from competing with cheaper labor markets, and with those companies that exploit the environment and labor through harmful recovery and/or virgin material extraction practices.69 Other obstacles for technological advancements stem from the lack of uniformity and technical challenges in product demanufacturing. This obstacle can be overcome with upfront design changes by producers to facilitate the recycling processes.

On the flip side to cost reductions is the need for greater demand for low valued materials. The development of markets can create more opportunities for the electronics recycling industry by generating more demand for its output at sustainable prices, especially for those materials like leaded glass that has low value and limited options for use as an input.70 Accordingly, market development can be achieved through technological innovations in material use and/or applications; regulatory requirements that promote the use of recycled material; and increased public demand for products that use recycled materials.

To date, little has been done by government(s) to promote the market demand of low value materials, such as leaded glass. Nonetheless, some producer-led initiatives have had an important impact on the marketability of some of the industry’s outputs. These initiatives include the adoption of materials that are easier to reuse and the increased use of recycled materials in its products. For example, Dell uses specific plastics that have more reuse potential instead of using plastics with harmful brominated flame retardants. Additionally, according to Ferris Segovia, President of Monitex LLC., many CRT producers use recycled leaded glass to make new CRT products.71 However, these initiatives have inherent limitations in accordance with basic laws of supply and demand for input materials and producer incentives to initiate useful design changes.72 Accordingly, producers have an important role in market development for the electronics recycling industry’s output. As such policy should provide producers with the right incentives to both design and use materials more efficiently in conjunction with recycling efforts.

Residential Consumer Access to Electronics Recycling

Consequently, the challenges faced by the electronics recycling industry in recycling consumer equipment discourage market entry without a guarantee that appropriate fees will be paid and/or a profit can be made from the output. As previously discussed, the use of recyclers by large commercial entities and their willingness to recycle for a fee has fueled the current industry growth.73 However, consumer electronic recycling, creates distribution logistic hurdles, operates on smaller economies of scale, contains primarily costly material to recycle, and competes with other alternatives for disposal. Therefore, access for residential consumer recycling requires that (1) consumer have incentives to recycle their end of life electronic equipment and (2) electronics recyclers have market incentives to make recycling a viable option for disposal. From this review of the industry, one key part of providing residential access for electronics recycling is the creation of proper incentives for each stakeholder through effective policy.

Accountability in Material Management Practices

The lack of sufficient employee safety and environmental laws in developing countries act as a subsidy to the true cost of electronics recycling. This creates distortions in the market place which promote the continued use of hazardous material recovery practices. These market distortions not only creates negative social externalities by causing harm to the environment and human health, but it also makes it more difficult for those firms that are incurring the costs of these social damages (both in the developed countries and in developing countries) to compete. This leads to greater market distortions and creates unsustainable business practices within the electronics recycling industry.

Various trade organizations, environmental groups, electronics recycling alliances, and the EPA have already published a number of recommended voluntary guidelines for best practices in material management for electronics recycling. Yet, the adoption of these guidelines appears to be limited. The IAER report shows that 60 percent of the electronics industry respondents supported some form of industrial certification program which incorporates specific material management practices. Nevertheless, at the time of the survey, the same number in percentage had not employed “any form of certification” that is already available, such as the IAER Certification or the ISO14001. However, only 5 percent of the respondents believed that “certification was not important.”74 Peter Muscanelli, President of IAER, stated in a telephone interview that one of the biggest hindrances in obtaining certification is the high costs to implement requirements.75 On the other hand, the IAER report showed that 30 percent of the respondents believed that it was not important to their customers for them to be certified.” This may indicate that while public demand for better management practices may have increased, it may not be sufficient to motivate widespread adoption by electronics recyclers. Additionally, because of the costs associated with implementing good material management practices, a company does not have an economic incentive to adopt them unless demanded by their key customer/supplier base.

As previously mentioned, many stakeholders are currently trying to devise a set of best practices in material management that would be acceptable to all stakeholders. If such a measure can be accepted and enforced, then the electronics recyclers would have a more level playing field in which to operate. Yet, with more than 500 recyclers, the majority of which are relatively very small, recyclers enjoy a great deal of public anonymity. Such anonymity may exploit the use of asymmetric information throughout the reverse logistics supply chain to engage in poor and unsafe material management practices, even if a recycler claims to adhere to widely accepted material management guidelines. Accordingly, without accountability measures in place, stakeholders have no proof that the recycler has incorporated good material management practices for itself and for its downstream venders. Robin Ingenthron, President of American Retroworks Inc., advises the use of legally binding contracts so that material suppliers have an effective legal tool to hold recyclers accountable.76 However, contractual obligations still require some tools such as independent audits to measure accountability. Additionally, it is not feasible for individual residents to enter contractual agreements with recyclers or collection facilities. Thus, residential consumers must rely on the recyclers and/or collection facilities to provide them with information regarding the contractual obligations over acceptable material management processes for its downstream vendors and enforcement measures. However, without public transparency of information, the public has no means to verify the accuracy of the information and market distortions may persist undetected.

Watts and Zimmerman, in their book titled, Positive Accounting Theory, explain that information about a company management practices is a public good.77 As such, without policy intervention, proper and adequate disclosure about material management practices will likely not prevail. Accordingly, in her report, “Trust, reputation and corporate accountability to stakeholders,” Tracy Swift states, “In an accountability framework, trust is not regarded as a sufficient condition for the effective social control of business behavior as managerial opportunism will always prevail.”78 Instead of pure regulatory policy, Swift advocates establishing an interdependent relationship based on a “mutual vulnerability and dialogue.”79 Concurrently, David Wheeler and John Elkington also stress the importance of fostering an interdependent relationship with companies to develop trust and proper and adequate disclosure.80 However, because many recyclers operate within a high degree of anonymity from the general public, creating “mutual vulnerability” for greater transparency will likely be difficult to achieve. As such, this paper recommends policy that reduces anonymity of recyclers by creating greater public transparency throughout the supply chain of recyclers used for each process by requiring mandatory disclosure of recycling companies used downstream for each process output along with their material management practices and the level of adherence to those practices. Concurrently, policy should also better inform the public about best downstream material management practices for each output process. This approach to policy is similar to the policy recommendations by Aris Solomon and Linda Lewis in their paper “Incentives and Disincentives for Corporate Environmental Disclosure.” Solomon and Lewis recommend an “education strategy” combined with a “regulatory strategy” to foster education on key areas necessary to keep stakeholders informed and regulatory requirements on companies to make such information available.81

Conclusion

The recycling industry creates three key types of market outputs. They are whole products, components, and raw material. Like any business, a recycler will seek to maximize profit by focusing on areas that offer the greatest amount of revenue relative to costs. The resale of whole products offers the greatest amount of revenue relative to cost; however, the electronic equipment available for resale depends on the material received from the supply base. The large number of old CRTs found in the residential consumer electronic waste stream makes residential consumer electronic equipment less desirable to recycle. Old CRTs are less likely to qualify for re-use because they tend to be near end of life. They are undesirable to recycle without additional fees because the total cost to recycle them into raw material is likely to be greater than the revenue generate from its output. Accordingly, these two aspects with CRT recycling create disincentives for electronics recyclers to recycle residential consumer electronic products, especially CRT products. As such, access for residential consumer electronics recycling may be severely limited without other market forces in place.

This chapter reviewed each stakeholder and its corresponding role in creating a viable and sustainable electronics recycling industry. A viable and sustainable electronics industry creates access to residential and commercial electronics recycling and fosters accountability in how material is managed throughout the entire reverse-logistics supply chain. Accordingly, each stakeholder requires appropriate incentives to operate optimally according to the life cycle of the product. This includes the economic incentives for consumers to seek recycling as an option and the economic incentives for recyclers to seek consumer electronic equipment for recycling. It also includes proper incentives to ensure that products are designed with recycling in mind and that material is being recycled according to safe and proper material management practices.

The lack of proper incentives necessary to foster a viable recycling industry reflects the market distortions that currently exist within the electronics industry. Wrong economic incentives lead to improper allocation of resources and create social externalities. As such, negative social externalities result from the loss of non-renewable resources when electronic equipment is not recycled, but rather dumped into a landfill. Moreover, negative social externalities also result from crude and harmful recycling methods that release significant amounts of toxic metals and other hazardous materials into the environment and harm both human health and the environment. Therefore, policy intervention is necessary to create proper incentives, when lacking, for each stakeholder in the life cycle of the product.

Each of the challenges to recycling consumer electronic equipment identified by electronics recycling industry leaders reflect the market distortions present in the electronic equipment industry. Governments of all forms have begun implementing policies with intentions to spur the correct incentives by stakeholders. However, the various policy approaches that have emerged across the globe and the United States have instead created an additional obstacle for the electronics industry. Recyclers now must navigate through a mélange of differing policies, depending on the state or local government it wishes to conduct business in. This impacts operational costs and limits economies of scale. As such, the electronics recycling industry supports one uniform national recycling policy. Such policy must create appropriate incentives, where lacking. The next chapter provides an overview of relevant recycling policies and evaluates them according to market incentives by stakeholders and accountability in material management practices.

3. Policy Overview

When effluents create social damage, such as hazardous waste, and that damage is not adequately accounted for in the price of the product, the markets become distorted.1 These distortions are realized in the overall challenges faced by the electronic recyclers in recycling low value electronic equipment, such as CRTs. Accordingly, the overarching areas of concern for policy with respect to the electronic recycling industry appear to be:

  1. How to provide adequate electronic recycling to residents without incurring economic loss?
  2. How to encourage the use of best practice in material management for all electronic recycling outputs in the reverse logistic supply chain?

The first question addresses overall access for residential electronic recycling and encompasses the willingness of the consumer to recycle over other disposal methods, and the willingness of the recycler to recycle consumer electronic equipment. The second question addresses accountability in managing material output from the recycling process.

Policy is often used as a means to correct market distortions by addressing the key questions of concern. However, policies are imperfect. They may tackle key causes of the market distortion inadequately or incompletely.2 They also may cause additional administrative and monitoring costs to the market and the policy, which could create distortions elsewhere.3

This chapter provides an overview of the federal policy, Resource Conservation and Recovery Act (RCRA) and an overview of its effectiveness and shortcomings in encouraging safe and proper recycling of CRT products. In addition, this chapter also looks at other policies that are being independently pursued by state and local governments and attempts to point out advantages and challenges inherent in each. Accordingly, this chapter also examines the effectiveness of the policies implemented in Massachusetts as a case study of one of the proposed recycling policies that has been established for at least a five year period. Each policy is evaluated by identifying the policy provisions and how they influence stakeholder incentives in comparison to what would be optimal as outlined in the previous chapter.

What is RCRA?

The Resource Conservation and Recovery Act (RCRA) was created in 1976. The federal government first began regulating solid waste disposal in 1965 with the Solid Waste Disposal Act (SWDA). This Act was amended in 1970 to become the Resource Recovery Act, RCRA’s precursor. RCRA gave statutory power to the EPA to regulate both hazardous and non-hazardous solid waste. Since its enactment, RCRA has been amended several times. Significant amendments include the Hazardous and Solid Waste Amendments (HSWA) of 1984, the Federal Facilities Compliance Act of 1992, and the Land Disposal Program Flexibility Act of 1996. The HSWA significantly expanded the Act’s role and regulatory obligations; whereas the Federal Facilities Act subjected federal facilities to more encompassing regulatory enforcement.4 The Land Disposal Program, one of the most recent amendments imposed significant changes to disposal programs for municipal and industrial non-hazardous waste.5

The key objectives for the RCRA according to the EPA are:

  1. “Protecting human health and the environment from potential hazards of waste disposal;
  2. Conserving energy and natural resources;
  3. Reducing amount of waste generated;
  4. Ensuring that wastes are managed in an environmentally sound manner”6

The provisions in the RCRA have been codified and are listed under Title 40 of the Code of Federal Regulations (CFR).7 The RCRA consists of ten subtitles, Subtitles A through J; however, Subtitle C and D are the most relevant for CRT disposal and recycling. Subtitle C is referenced in 40 CFR Parts 260 through 279.8 It governs the hazardous waste program from “cradle to grave” and deals with all aspects of handling and disposal of hazardous waste.9 This includes generation; transportation; treatment; storage and or disposal.10 Subtitle D governs the management of solid waste disposal and is referenced in 40 CFR Parts 239 through 259. One of the goals of Subtitle D is also to promote sound environmental practices and material recovery and reuse.11

Subtitle C

The provisions in this subtitle divides generators of hazardous waste by type according to the quantity of hazardous waste they generate.12 Large Quantity Generators (LQGs) produce more than 2200 pounds of hazardous material per month. LQGs are responsible for the generation of the majority of the hazardous waste produced; and therefore, are more stringently regulated. Small Quantity Generators (SQGs) each generate anywhere between 220 and 2200 pounds of hazardous materials per month. However, entities that generate below 220 pounds of hazardous material per month fall under a category known as Conditionally Exempt Small Quantity Generators (CESQGs) and are not subject to much regulation according to Subtitle C.13 Households and small businesses usually fall under this category and are, therefore, exempt from regulations under Subtitle C and fall under the regulatory provisions of Subtitle D.14

Subtitle C lays forth mandatory record keeping, labeling, permit requirements and financial responsibility standards for generators and treatment, storage and disposal facilities (also known as TSDFs).15 The EPA grants state agencies the power to oversee RCRA compliance; however, it also reserves the right to revoke this authority if it appears that state agencies are not providing adequate oversight.16 It requires that action be taken by those regulated to continue the reduction in the volume and toxicity of waste and in its exposure to humans and the environment through innovation and continued research and development.17 In accordance with mitigation of potential hazards, the Landfill Disposal Restrictions (LDR), included in Subtitle C, requires the adoption of technology and monitoring systems such as proper lining, leachate collection systems and leak detection systems and groundwater monitoring for landfills that contain large quantities of hazardous waste.18 In conjunction, a measure called Correction Action is included to require responsible parties to remediate any damage caused by hazardous waste as a result of poor waste management practices.19 The EPA shows that “50-70% of all TSDFs have some degree of environmental contamination requiring detailed investigation and perhaps cleanup. Accordingly, failure to take corrective action and/or remediation may lead to penalties (civil and/or criminal), violations, fines and/or imprisonment.20

Subtitle C allows firms to export hazardous waste to any country as long as specific requirements are followed. These requirements are:

Once hazardous waste is exported, it no longer is required to follow regulatory requirements under Subtitle C; but rather the regulatory requirements of the receiving country.

Subtitle C: Discussion

Because of the hazardous toxins in electronic equipment, their disposal by LQGs and SQGs are regulated under Subtitle C as hazardous waste. However, because equipment can be reused as commodities throughout the various output stages of recycling (reuse of whole products, components, and raw materials), the rigid regulations have also been effective in encouraging electronic recycling as an alternative disposal method.22 In effect, the material output from recycling becomes a compensatory factor by which LQGs and SQGs are able to offset disposal costs.

The determination of commodity over hazardous waste or vice versa has created a great deal of confusion in the recycling industry over the handling of CRTs. According to the EPA, the current regulations from Subtitle C are burdensome and confusing for entities who wish to engage in CRT recycling.23 The CRT’s lead content is the primary hazardous toxin found in CRTs. However, as a compound formed with silicate in a solid glass composite, it poses little risk of exposure or leaching given normal environmentally controlled conditions.24 As such, a CRT leaded glass can be reused and recycled under monitored and controlled conditions without increasing risk to human health or the environment.25 Additionally, reuse and recycling of CRTs reduce the demand for virgin material for the production of new CRTs; thereby, reducing energy consumption and the release of additional toxic pollutants that result from the extraction of virgin materials.26 Yet, Subtitle C treats the lead in the CRT as a separate composite of the glass that must be treated as hazardous waste when discarded. The result of which has lead to what some deem to be costly and unnecessary regulations that have hampered CRT recycling.27 Nevertheless, the existence of lead in CRT glass does pose a severe risk to human health and the environment if not handled and reused in an environmentally controlled manner with certain precautions in place; and therefore require some regulatory oversight through the processing and handling of it outputs.28

As discussed in the previous chapter, a relaxed export of whole products for reuse and recycling is a concern because of the incentive to engage in harmful recovery practices.29 Under Subtitle C, RCRA allows for the exportation of CRTs as hazardous waste to any receiving country provided that the receiving country agrees to receive it, no international agreements are violated, and the EPA has been properly informed. However, by labeling of the product as a commodity for reuse rather than hazardous waste, exporters of CRTs can evade the minimal RCRA export requirements on hazardous waste completely, thereby creating a regulatory loop hole. As such, any part of the original equipment, as explained by a president of a recycling company in the United States, whether it is the product itself, components and/or raw materials, can be considered to be shipped as a commodity for reuse.30 In either case, once the CRTs are exported, the receiving firms are free to handle the material in accordance to the regulatory oversight of the receiving country. A key difference, however in the two approaches is that because the receiving country must agree to accept the CRTs if labeled hazardous waste, the receiving country may or may not demand more regulatory oversight of the CRT material received than it would if the material entered the country as a commodity. If environmental and safety laws lack enforcement and/or are non-existent in the receiving country, then the two export approaches may not differ in how material is handled once it has been received and; therefore, labeling the CRTs as hazardous waste could be viewed by the exporter as an unnecessary a hurdle in the export process.

The lack of regulatory oversight with respect to the transfer of ‘goods,’ (even those with hazardous toxins), is common within the constructs of the global economy. Accordingly, any trans-boundary shipment of electronic equipment includes the export/import of toxic materials. Additionally, to manufacture electronic equipment, the hazardous toxins that are used as inputs must be available within the country of production as a commodity to begin with. For example, a Chinese manufacturer of televisions sold in the United States first had to have access to the hazardous toxin, lead, and other materials to make the television in the first place. As such, the difference between hazardous waste and commodity is blurred. It is also a cause for a great deal of contention among stakeholders. According to Mike Watson, Senior Compliance Manager of the Global Asset Recovery Services for Dell, one of the biggest disagreements among stakeholder is the definition and term for hazardous waste.31 Accordingly, the use of hazardous toxins as an economic good may also provide insight to the U.S.’s approach in maintaining lenient trade in hazardous waste under RCRA. It may also help explain why the U.S. has not become a signatory to the Basel Convention Treaty, which restricts the export of such material to OECD countries only.32

On the other hand, free movement of hazardous materials into countries with little to no enforceable environmental and safety laws, without accountability mechanisms, creates incentives for poor material management practices. In recent years, voluntary initiatives have motivated more large corporations to release information to the public on their social/environmental impact. However, according to the literature review on corporate accountability, the number of corporations releasing such information still is relatively low and the information they release is deemed by stakeholders to not be adequate and/or creditable.33 The smaller the company, the less likely it will provide voluntary disclosure.34 As such, the lack of federal export control mechanisms highlights the accountability problem presented in the previous chapter regarding electronic recyclers.

From review, it appears that the lenient export policy of RCRA has done very little, if anything, to correct key areas contributing to market distortions in the electronics industry as a whole. Despite the fact that the majority of the external damages are being released outside the United States, the U.S. public still has a direct self-interest in correcting these market distortions. As mentioned in the previous chapter, the lack of enforceable regulations in the developing countries acts as a subsidy to the recycling costs, which impacts the creation of a sustainable electronic recycling industry in both the developed and developing countries. Secondly, human health and the environment in the United States and elsewhere are also negatively affected by trans-boundary pollution released into the atmosphere from harmful environmental practices.35 Additionally, the risk of consuming contaminated agricultural products imported from countries with little environmental regulations and controls has begun receiving increased public attention.36

The New 2007 CRT Rule

Some of the key areas of concern for recycling CRTs have been recently addressed in a change to regulations under Subtitle C. The change was signed in July 2006 and came into effect at the end of January, 2007.37 The change essentially deregulated CRTs, unbroken and broken, as hazardous waste under Subtitle C for collectors, transporters, and processors. On the other hand, CRTs which are stored by non-consumers for more than one year, stored in an environment which could volatilize the lead, labeled improperly, destined for disposal, or exported for recycling would be required to follow the regulations set under Subtitle C.38 The provision includes a one time notification requirement to the EPA for the export of CRTs destined for reuse. The purpose of deregulating CRTs is to make CRT recycling easier and less confusing. The change was deemed appropriate because of the low risk potential for harm to human health and the environment from leaded glass when handled in a controlled environment.39

The new regulation substantially reduces the liability and burden that is associated with handling CRTs. However, processing CRTs can still be hazardous to employees if certain provisions are not met.40 In the U.S., this area of concern is regulated under the Occupational Safety and Health Administration (OSHA); however, according to Peters-Michaud, John Katers and Jim Barry in their report published in Electronics and the Environment, OSHA only establishes limits on airborne contamination.41 Their study conducted on behalf of a recycler that de-manufactures electronic products showed that lead particles as a result of surface contamination from the work area can threaten employees’ health if particles become disturbed. If disturbed, these particles may tend to migrate into non-work related areas, where employees increase their risk of lead ingestion. However, with proper measures and active monitoring in place, such risk can be minimized substantially.42 Therefore, with more emphasis on CRT processing for reuse and recycling, it would be advisable for the EPA and OSHA to collaborate on a study on best practices for operational management of CRT processing to minimize health risks for employees in this field of work.

The new CRT rule does little to nothing to restrict recycling firms’ ability to export CRT products or outputs to firms in developing countries that may take advantage of the poor safety and environmental requirements. Firms exporting for “recycling” must adhere to the same requirements as listed under Subtitle C. Firms exporting for “reuse” simply must advise the EPA by providing a one-time written notification.43 Accordingly, the new CRT rule neglects to address the ambiguous loop-hole in the labeling of product for recycling or for reuse. Nor does it promote accountability in how material is processed once it is exported as it requires no formal qualification process concerning the material management practices of the importee.

Subtitle D

Subtitle D regulates non-hazardous waste and hazardous waste generated from CESQGs. CESQGs primarily include households and small businesses. Subtitle D also lays forth minimal provisions for landfill disposal and encourages material recovery for reuse through specific programs. Programs for material recovery include used oil and the Mercury-containing and Rechargeable Battery Management Act.44 Subtitle D also establishes minimum protective requirements such as liners and ground-water monitoring for landfills that would likely contain hazardous waste from households and other CESQGs.45 Subtitle D also promotes recycling programs by providing technical and financial assistance for such programs through local government and agencies.46

Under Subtitle D, residents can discard CRT products and other electronic equipment into any locally permitted landfill. Accordingly, Subtitle D does not require landfill operators to track the amount of electronic products such as CRTs that end up in their landfills.47 Nor does it require any local government or state agency to track how much product is being diverted from landfills through recycling initiatives.48 According to the EPA, over 200 million tons of municipal solid waste is generated across the United States each year. Within that amount, the EPA reports that each household contributes approximately 20 pounds on average of hazardous waste each year.49 The 2000 Census listed 105,480,101 occupied housing units.50 With 20 pounds per household, this number translates to almost 1 million tons of household hazardous waste dumped into local landfills per year. Discarded electronic waste is the fastest growing waste in the waste stream, increasing at a rate of approximately 3 to 5 percent per year.51 The U.S. Government Accountability Office (GAO) reports that local landfills are adequately protected to prevent toxic leachates from discarded electronic waste.52 However, according to a representative of the Texas Disposal System, the measures required for landfills under Subtitle D do not adequately protect the environment from large quantities of hazardous waste.53

When such product is dumped into landfills, we not only lose valuable resources, but we also increase the potential risk for soil and ground water contamination.54 The loss of non-renewable resources from the dumping of electronic equipment into the landfills creates a demand to mine for new non-renewable virgin materials, which leads to greater energy consumption and more environmental pollutants than would have occurred if the material was recycled instead.55 By allowing for landfill disposal of CRT products and other electronic equipment, the Subtitle D limits the economic incentive for CESQGs to recycle their product. The GAO report shows that states that do not have a landfill ban on CRTs demonstrate “drastically lower levels of recycling” than those states that have implemented a landfill ban on CRT products. The report confirms that with the continued allowance of the dumping of such waste into landfills, households and CESQGs have no incentive to do otherwise.56

Nonetheless, apart from implementing a landfill ban on CRT products, other factors may influence CESQGs to favor recycling over landfill disposal. For example, where landfill space is limited and costly to maintain, landfill cost may be just as expensive as recycling, thereby reducing the economic incentive for traditional disposal methods.57 Secondly, a growing public awareness over the concerns of landfill disposal has created a social incentive for some CESQGs to seek alternative disposal methods; whether it is a concern over possible toxics leaching into the soil and/or water supply, and/or over the loss in important non-renewable resources from landfill disposal.58

Today, many large cities now encourage electronic waste recycling by promoting local recyclers; offering recycling drop-off services; coordinating special electronic waste recycling events; or a combination of the three.59 Once this material is collected, the collecting agent becomes responsible for the material in accordance with subtitle C. Thus, a discarded electronic product that was previously exempt to regulation when in the possession of a household loses exemption status when product is combined and weighs more than 220 pounds in a given month.60 At such point, the issues regarding the assurance of proper reuse and recycling become both an issue for household consumers and commercial businesses alike.

Demand for National Recycling Legislation

The increasing amount of electronic equipment in the waste stream has been gaining attention worldwide. As such, various countries, intergovernmental unions, and individual states and local governments have already passed new legislation to deal with this issue. The most extensive measures passed are the European Union Waste Electronic and Electrical Equipment (WEEE) and the Restrictions on Hazardous Substances (RoHS) Directives. The WEEE Directive provides a framework for individual nation states in the European Union to implement recycling infrastructure based on the principle of Extended Producer Responsibility (EPR), whereby the producers of electronic products are responsible for financing the recycling of discarded electronic products. The EPR requires the producer to engage in a producer scheme that oversees monitoring and administrative duties. The producer may choose to coordinate the recycling of its own name-brand products directly or it may elect to join a pool of other producers that uses a recycling scheme to coordinate recycling. The retailers selling into the EU markets are required to participate in the collection of electronic waste from households and small businesses and direct it to the appropriate recycling schemes. A government administrative office oversees the appropriate collection and allocation of funds by producers to recyclers.61 The RoHS Directive is designed to work along with the WEEE Directive by limiting the hazardous materials that can be used in electronic equipment. The expectation for the RoHS Directive is that by limiting hazardous toxins, recycling would become easier and less hazardous; however, this directive is hampered by inherent technical limitations.62

In the United States, many states have decided to enact their own legislation to deal with this issue. To date, five states have enacted landfill bans for CRTs; these bans apply to all entities, including households. These states include Massachusetts, California, Minnesota, Maine and New Hampshire. Two states, Maine and Washington, have implemented their own version of legislation based on Extended Producer Responsibility. California has implemented its own version of the RoHS Directive and a recycling law based on an Advanced Recovery Fee (ARF) which includes a fee paid for by the consumer at the time of purchase and then allocated for the recycling of the product purchased.63

As discussed in the previous chapter, the concern over a “patchwork” of differing legislation across the nation has created increased confusion and costs for recyclers and other stakeholders, including consumers, producers and retailers.64 As a result, stakeholders have been pushing for a universal recycling scheme. However, stakeholders have been unable to agree upon which scheme is preferred because each scheme financially impacts each stakeholder differently. This is reflected in the breakdown in discussion among stakeholders through the National Electronics Product Stewardship Initiative (NEPSI), an organization formed in 2003 to bring stakeholders together in attempt to develop the best approach to address the recycling of electronic equipment.65 In current debate, most producers such as Dell and Hewlett-Packard that focus solely on information technology (IT) related products prefer Individual Producer Responsibility (a modified version of EPR) whereas producers that manufacture both IT products and consumer CRT products, such as Sony, prefer an ARF program.66 To date, this disagreement among stakeholders has created a significant stumbling block in the pursuit of new federal recycling legislation; despite the fact that recyclers prefer a unified national system, regardless of scheme, over the current trend.67

Policy Proposal Overview

Many of the proposed recycling policies have only recently begun to be implemented. The details of each policy proposal and how they are implemented differ from state to state. These factors create a challenge in conducting a detailed case study on many of the newly proposed policies. However, the existing literature and debate forums have sufficient information and research on each policy proposal so as to provide an overarching review and analysis of the key recycling policies currently being pursued. The prevailing recycling schemes/policies include ARF, EPR, landfill bans, restrictions on hazardous substances (RoHS), and subsidies for recycling, or a combination of two or more. The landfill ban is simply a regulatory measure that deters landfill disposal for electronic equipment. The ARF and EPR are schemes that incorporate a financing infrastructure for the recycling of consumer electronic equipment. Such financing infrastructure is intended to create the right incentives for all stakeholders so as to discourage dumping and encourage the development of a recycling infrastructure for the recycling of consumer electronic products. In each scheme, the consumer does ultimately pay something for the recycling; however, when, how, and how much the consumer pays differs according to the scheme. The RoHS initiative attempts to influence recycling costs by regulating the use of production inputs.68 Most policies are accompanied with regulatory oversight to ensure that the scheme is being followed. However, such regulatory oversight does not necessarily ensure safe and proper material management throughout the supply chain. Accordingly, additional requirements for the adherence of best practices in material processing may or may not also be incorporated into the implementation of each scheme.

A landfill ban fosters the demand for alternative means of disposal, especially by household and CESQGs, who traditionally have had little economic regulatory incentive to seek alternate forms of disposal. Yet, it, by itself, does not address the safety concerns about how material is managed once it is collected. Additionally, consumer CRT recycling incurs high transportation and processing costs while rendering low value material, resulting in a net loss.69 According to economic theory on waste, such high costs for disposal could create economic disincentives that could actually encourage dumping of the CRTs rather than recycling.70 As such, it may encourage dumping by consumers who are required to pay disposal fees to recyclers; or it may encourage dumping by recyclers who do not wish to incur high processing costs. Correspondingly, without accountability in material management practices, recyclers have an economic incentive to handsomely profit by collecting a fee while operating under harmful practices such as dumping in developing countries and/or employing crude and harmful recovery methods in those countries.

The ARF program establishes an upfront fee paid by the consumer at the time of purchase. The retailers selling the electronic equipment are responsible for collecting this fee and transferring it to the appropriate government agency. The funds are then diverted to recyclers for like products they recycle.71 If the price is set exactly to the cost incurred for recycling of the product, then, theoretically, this scheme functions like a tax-subsidy scheme whereby consumers would have an incentive to recycle.72 However, for such a scheme to work, economic theoretical modeling shows that (1) the recycling market must be a fully functioning market, and (2) the tax must convey the right incentives so that the producer uses the optimal amount of inputs.73 Accordingly, the ARF alone is insufficient at correcting the distortions in the market because it only impacts the downstream recycling and neglects the producers’ role upstream.74 The lack of upstream incentives in production and the use of direct subsidies to the electronic recycling industry also likely limits the industry’s ability to become a viable and efficient market and may hamper market development and technological innovations. Additionally, the ARF would likely add other market distortions because transaction costs for collecting and transferring the fees and the menu costs for changing fees according to product and ‘recyclability’ would keep consumer fees higher than the actual cost of recycling.75 Lastly, opponents of the ARF scheme criticize its reliance on the government to properly earmark fees collected. Some fear that in times of financial crisis, funds may be diverted.76 In sum, the ARF may be effective in creating economic incentives to increase residential access and distribution networks, but it appears to be insufficient at reducing negative externalities and creating a viable and sustainable electronic recycling industry.

Like the ARF scheme, the Extended Producer Responsibility scheme is designed to spur economic incentives for consumer electronic recycling. Yet, unlike the ARF scheme, the EPR requires the producers to be responsible for the cost of recycling end-of-life product. The main idea behind EPR is that by making producers responsible, consumers and recyclers will have an incentive to recycle consumer electronic equipment, and producers will have an incentive to design products easier and less costly to recycle through eco-design.77 However, EPR has inherent limitations in promoting eco-design. In joint producer schemes with fixed recycling costs for like products, a producer has an incentive to ‘free ride’ on the reduction of overall costs by another producer’s eco-design. Accordingly, the ‘free rider’ problem may limit short term incentives for eco-design.78 On the other hand, even if the ‘free rider’ problem is eliminated, eco-design is not necessarily a guaranteed outcome for producer responsibility. As such, eco-design may be limited as a result of prevailing market conditions and/or other distortions within the electronics industry. For example, the inelasticity of demand for product and market power whereby most of the cost of recycling can be directly passed on to the customer may limit a producer’s willingness to incorporate eco-design.79 Another limitation includes the actual cost of recycling relative to the total cost of production. If the recycling costs are a relatively small percent of the production costs, then that cost may be easily internalized and/or costs may be reduced elsewhere.80 The impact that EPR has on the electronic recycling industry in terms of market development and technological innovation is likely to be dependent upon prevailing market forces according to elasticity of demand and upon market distortions that impact stakeholder incentives. Other challenges to EPR are the cost for regulatory oversight and enforcement, and the management oversight and allocation of costs for recycling orphaned products.81

The inherent limitations in the EPR may be one reason why certain producers such as Dell, Inc. are working with the federal and state governments to support the use of Individual Producer Responsibility (IPR). IPR requires that individual producers be wholly responsible for the recycling of their own products.82 Theoretically, a producer that is directly responsible for the recycling of its own product will have an incentive to reduce costs through eco-design. Yet, eco-design incentives, like EPR, are likely to be dependent upon other market forces such as the inelasticity of demand, market share, and the costs of recycling relative to total production costs.83 And, while IPR limits the concern about ‘free riders,’ regulatory costs to enforce and oversee each producer may be very costly. Additionally, other concerns that need to be studied more closely are whether or not IPR can promote an efficient distribution channel for product and whether or not it would create undue barriers to market entry for smaller companies that would not be able to take advantage of economies of scale in both production and recycling.

Another example of a tax-subsidy program to encourage recycling of consumer electronic equipment is through the use of tax credits or direct subsidies to recyclers. An example of a tax credit provision is a bill sponsored by Senators Ron Wyden (D-Oregon) in the proposed Electronic Waste Recycling and Consumer Protection Act (S. 510).84 This scheme allows for the use of tax credits for both individuals and producers for products recycled.85 In essence, the use of subsidies gives both consumers and producers an economic incentive to recycle. However, like ARF and EPR, the upstream incentive for efficient use of resources in production is limited. It does not hold the producer responsible for improving ‘recyclability’ through design. Additionally, the subsidies must be paid for by a tax elsewhere. Because the tax is not directly related to the use of the product or input resources, it would likely exacerbate the distortion in resource allocation by encouraging more use of inputs than would be optimal.86 Accordingly, such distortions could increase electronic recycling costs in the long run and could impact sustainability of the program.

The RoHS policy often accompanies a financing policy and is used to improve product ‘recyclability’ by making it easier and safer to recycle. The central idea behind RoHS is that by reducing the toxic materials in electronic equipment, material management practices can be less restrictive and allow for greater flexibility in recycling methods.87 However, RoHS has several inherent limitations. One is the technological feasibility to reduce certain toxins from electronic products.88 For example, lead is a necessary component in CRTs so as to protect users from radiation.89 Secondly, even if a technical alternative exists, it may make the product either run less efficiently and/or reduce the life expectancy of the product.90 Thirdly, it could also lead to an increased demand in material extraction of the alternate material, which could lead to greater environmental degradation.91 In all three cases, the RoHS may actually induce greater inefficiencies in product design. However, RoHS may be beneficial in alleviating some external damages in cases where producers lack incentives to design products with recycling in mind and where recyclers lack accountability for their material management practices.

Each policy reviewed has inherent disadvantages. According to economic review, no single policy is sufficient by itself in spurring a viable and sustainable electronic industry. The economic literature advocates the use of multiple policies to ensure optimal use of resources and the reduction in negative externalities. Accordingly, optimal mixture of policies must address the negative externalities across the entire life cycle of the product. As such, policies should also include ensuring safe and proper recycling within the electronic recycling industry through mechanisms that also promote accountability for material management practices.

Most of the policies reviewed have only recently been implemented in certain states across the United States; and thus, insufficient time has passed to conduct an empirical study on their outcome. However, Massachusetts implemented its consumer CRT recycling policies over 6 years ago. Accordingly, Massachusetts provides an interesting case study on the results of a landfill ban on CRTs in conjunction with temporary subsidies to encourage CRT recycling from policy and the deregulation of CRT products as a hazardous waste.

Massachusetts’ CRT Recycling Policy

In April, 2000, Massachusetts established a landfill ban on CRTs. At the same time, the state also promoted a residential recycling infrastructure by establishing state contracts with recycling companies and by offering grants to help municipalities establish a drop-off recycling service.92 Massachusetts promoted a voluntary recycling program rather than a mandatory recycling infrastructure due to concerns over inflexibility and costs of the latter.93 To help create a recycling infrastructure accessible to residents, Massachusetts received a waiver from the RCRA, Subtitle D for all unbroken CRTs. The details of the waiver served as a precursor to the new CRT rule recently implemented by federal legislation.94 By reducing obligatory permits and other regulatory barriers, more participants were able to enter the CRT recycling market as collectors, storage facilities, and transporters.95 Concurrently, Massachusetts also provided subsidies in the form of grants to encourage “the establishment of a collection and recovery system to serve the residential market.”96 The grants enabled municipalities and other government organizations to cover processing costs for a period of time. A state negotiated contracted with CRT recycling venders also provided government organizations with access to established recycling prices.97

If a facility run by a municipality or government agency received grants, then that agency was obligated to report the amount of material collected and recycled. Otherwise, according to John Crisley of the Massachusetts Department of Environmental Protection, no reporting was necessary. However, the Massachusetts Department of Environmental Protection (MassDEP) discontinued CRT recycling grants between 2002 and 2003. Today, no municipality is now obligated to report on the amount of material collected for recycling.98 Nonetheless, a municipality or other government agency can still engage with state contracted CRT recyclers and receive negotiated pricing; however, this, too, is not obligatory.99 In sum, the only legal requirement imposed on a collection facility or CRT recycler not contracted with the state is that they adhere to the landfill ban and any pertinent requirements for establishing a collection facility.

If a facility uses a state contractor, that state contractor is obligated to provide the facility with a certification that states that all material was processed in accordance with the state contract and the amount processed. Accordingly, the state contract specifies that the contractor must provide the Operations Services Division (OSD) of the MassDEP the following:

  1. “Detailed description of their process, including what materials get recycled, what residues remain and how those residues are managed.”
  2. “Information on ultimate destination(s) of all products recycled or reused.”
  3. “Saleable end product(s) and all end markets that will be utilized.”100

The state does not impose export restrictions of products for recycling or reuse. On the contrary, it appears that the state supports the export of CRTs. Both the report conducted by Northbridge Environmental Management Consultants titled, “Characteristics of Massachusetts’ CRT Recycling Program”, and the report conducted by MassDEP on CRT Recycling reference the importance of exporting material for reuse and recycling due to the high market demand for product overseas and the lower costs that developing countries face in disassembly, repair, and recycling. However, neither report discusses the harmful recovery methods that may be used by importing firms, nor do they provide a means to qualify the material management practices of the receiving firm.101

Many collections facilities in Massachusetts charge residents to recycle their CRTs. This would appear to create an economic disincentive for residents to recycle their CRTs. However, the Northbridge Environmental Management Consultants report found that charging for CRT recycling “does not appear to have an impact on cost or effectiveness.”102 Accordingly, the report stated that “drop-off programs that charged fees were actually somewhat more effective, measured in pounds recovered per resident.”103 One explanation given in the report is that those facilities which charge fees can afford to develop and promote sophisticated programs that also enable them to run more efficiently in larger economies of scale.104 Nonetheless, the willingness of consumers to pay a fee for recycling runs counterintuitive to economic theory unless the probability of a fine for improper disposal was substantial and/or the transportation cost incurred to take the CRT to another recycler that does charge a fee was greater than the fee charged by the more conveniently located recycler. Further research in this area is needed to be able to make a more definitive conclusion as to why consumers’ are willing to pay a fee for recycling.

Overall, the policy appears to be very successful in creating residential access to CRT recycling facilities. By 2002, according a report conducted by Northbridge Environmental Management Consultants, “94 percent of Massachusetts residents lived in communities with a CRT recycling program in place.”105 Many of these residents had a variety of options for CRT recycling.106 These options included a municipal drop-off facility (the most common means of access), private companies (waste haulers or recyclers), charity drop-off locations, and curbside collection (most common in larger cities).107 However, based on the policy overview, it does not appear that CRT recyclers have a clear incentive to incorporate best practices in material management to ensure safe reuse and processing of discarded CRTs.

Conclusion

The natural market distortions that occur when the cost of external damages from disposal are not incorporated into the production costs of the product result in distorted economic incentives; thereby creating inefficiencies in the disposal and recycling of product. Policy can be an effective tool in reducing these distortions and creating the appropriate economic incentives for greater efficiencies. However, policies are inherently limited according to policy focus and administrative and enforcement costs.108 The policies varied according to consumer access to recycling and producer’s responsibility in recycling. Nonetheless, it appears that none of the policies evaluated addressed concerns over accountability in material management practices, despite the increased public attention on harmful practices.

The current RCRA policy appears to be insufficient in creating economic incentives to promote the recycling of residential consumer electronic equipment. Because RCRA exempts households and small businesses from adhering to Subtitle C, they are free to place their electronic equipment in landfills along with other municipal waste. RCRA also does not provide necessary economic incentives to encourage recyclers to collect and recycle residential electronic product (the EPA does promote recycling through its E-plug-in initiative; however, it is completely voluntary and does not affect current regulatory policy).109 Accordingly, the assessment of the current policy and related data reveals that it is insufficient in promoting efficient recycling of residential electronic equipment.

RCRA also does not encourage the accountability and transparency that is necessary to promote the use of best practices in material management. The export policies on hazardous waste are lenient and do not restrict how the material is handled once it leaves the country. The policies governing the export of electronic equipment for reuse are almost non-existent. Such lenient export policies may be based on open market principles for the global production and demand of goods. However, the anonymity of small electronic recyclers combined with the market distortions that encourage crude recycling methods in countries with little or no enforceable labor and environmental regulations promote external damages that could both limit the ability to create sustainable electronic recycling in the US and could negatively impact human health and the environment both in the US and abroad.

Most of the proposed policies pursued by a number of states appear to focus on creating greater access to recycling electronic equipment through a financing scheme so that recyclers have an economic incentive to recycle low valued electronic, equipment like CRT products, which would otherwise result in a net loss in revenue. Theoretically, each approach creates economic incentives necessary to promote residential electronic recycling; however, it does so at the expense of neglecting to establish important incentives necessary for other stakeholders. Subsidies such as tax credits and grants do not allocate the true cost of recycling appropriately, which could lead to further market distortions. Both subsidies and ARF appear to neglect the importance of creating incentives that encourage the producer to design products that are more beneficial to electronic recycling; whereas the EPR only does so if the producer is directly responsible for the cost of recycling its own product. The RoHS can be used in conjunction with a financing policy to provide incentives to improve eco-design; however, it may do so at the expense of creating more optimal designs and could create additional market distortions. Accordingly, each policy has inherent limitations and challenges to implement, enforce, and monitor without creating significant distortions elsewhere. Additionally, none of these policies intrinsically address accountability in material management to encourage safe and proper recycling of electronic equipment collected.

The review of Massachusetts as a case study revealed that a landfill ban on low value residential electronic products, such as CRTs, and temporary subsidies can improve access by creating incentives for both residents and recyclers. With an enforced landfill ban and access to CRT collection facilities, residents face both a regulatory and economic incentive to choose recycling over landfill disposal. On the other hand, recyclers receive an economic incentive to recycle residential CRTs from (1) the use of recycling fees, (2) temporary subsidies used to establish distribution networks, (3) lower costs in material handling from deregulation, and (4) opportunity to take advantage of high demand for CRT output in export markets. Accordingly, one report showed that the collection facilities that charged for recycling were both more effective and more efficient.110 However, the policy appears to do very little, if anything, to address the material management concerns in CRT handling and processing. CRT handling and processing does not pose a threat to human health and the environment if done in a controlled environment. However, according to research, the policy does not establish such conditions. Nor is criteria established on the export of CRT output, despite the fact that a few key market studies on the Massachusetts CRT recycling reveal the importance of the export markets in the developing world for CRT output.

In conclusion, policies which focus on improving access to residential electronic recycling without correcting market dynamics that discourage proper material management could result in increased dumping and/or greater proliferation of harmful recovery methods. These market distortions are due to the lack of enforceable labor and environmental policies in much of the developing world, combined with a sense of public anonymity among many recyclers in the recovery methods employed downstream, and competition with the mining and production of virgin material, (which in many developing countries can also be very exploitative of the environment and human health). Failure to address these market distortions could impact the ability to develop a long term competitive and efficient electronic recycling industry. It could also continue to impact the environment and the health of current and future generations more severely.

4. Empirical Study

According to the policy overview from the previous chapter, the current RCRA policy has been ineffective in creating consumer access to electronic recycling and in establishing mechanisms for accountability in material management practices for the recycling of electronic equipment once it is exported. The various policies being implemented in several states appear to focus primarily on access, with limited incentives to improve eco-design. As such, the policy review on Massachusetts’ CRT recycling reveals that the policy has been effective in addressing access but has neglected accountability for material management. In attempt to validate these assertions, an empirical study was conducted to look at how both areas, residential access and accountability, are impacted by differing policies: RCRA and the CRT disposal policies pursued by Massachusetts.

After having laid forth a critical review of existing policies and the infrastructure of the recycling industry, this chapter measures the success of the programs in creating residential access and accountability in material management practices in CRT recycling. To measures the success of each outcome in each of the aforementioned policy initiatives, this research identifies and analyzes key measurable indicators important for the success of each outcome. This research highlights the key difference in the outcomes from each policy and attempts to explain these differences. This chapter presents the methodology behind the comparative study of CRT disposal. This chapter explains why the two policies were chosen, what indicators were chosen and why they were used, and how the comparative study was conducted. It lays forth the results of the study and provides comparative analysis of the results. Finally, this chapter closes with an overview of the key points from the research and highlights key areas for further research.

Methodology

State Policies Researched

The study uses Texas as a representative sample of the outcome from policies implemented by the RCRA. The Texas state agency that is responsible for implementing and overseeing RCRA regulatory programs is the Texas Commission on Environmental Quality.225 Using the result of one state’s implementation of the federal government policies rather than that of many states reduces variation in implementation that could make analysis more challenging. Additionally, Texas is useful for study because it is a large and populous state that covers many demographic and geographic areas. Its total population is approximately 23,507,783, roughly 7.8 percent of the total U.S.population.226 Twelve of the Metropolitan Statistical Areas have a population of 200,000 or more; four of which have a population of more than a million.227 The demographic population by race and ethnicity for comparison between Texas and the United States are as follows:

Race/EthnicityTexasUSA228
White Non-Hispanic49.2%66.9%
Hispanic or Latino Origin35.1%14.4%
Black/ African American11.7%12.8%
Asian3.3%4.3%
American Indian0.7%1.0%
Persons of 2 or more races1.1%1.5%

By focusing on a large geographic/demographic region with a diverse population and with little to no change in many years to its regulatory policies concerning the handling and disposal of CRTs, the data gathered should give an adequate picture on the varying effects of RCRA without any significant bias. However, it is important to note that the Texas environmental policies pertaining to CRTs differ from that of the federal EPA in that it treats CRTs as hazardous waste whereas federal legislation does not.229 However, this should not impact the data since RCRA laws governing CRT disposal before 2007 were more stringent than universal waste laws; in such case, the state must cede to federal laws. Only since the new CRT rule has come into effect in January of 2007 has policies in Texas differ from federal policy, in which case, Texas policy is more stringent.230 As such, the recent policy difference is likely to have no impact on data received from surveys.

Massachusetts was chosen as a geographic area for data sampling due to its long-term paradigm shift in policies toward landfill and incinerator disposal of CRTs. Such policies in Massachusetts first began in 1991 with the landfill and incinerator ban on white goods; and in April 1, 2000, this policy was extended to include a ban on CRTs from landfills and incinerators.231 As discussed in the previous chapter, in conjunction with the landfill disposal ban, the state promoted the development of a recycling infrastructure for municipalities and local governments across the state.232 Because this program and ban has been in effect for more than 6 years, the current data should accurately reflect the outcome of this policy without any significant bias.

Due to the recent implementation of new policies and the addition of new policies in conjunction with existing policies in several of the aforementioned states, it is believed that data collected from these states would likely be substantially biased as a result of an overlap of new programs over existing and insufficient time for current programs to be fully implemented. Consequently, state policies such as Maine and Maryland’s EPR policies and California’s ARF and RoHS policies were omitted from the study. Sweden also had originally been considered as a case study due to its long-term policies toward electronic waste recycling and the creation of a collective state-run recycling program.233 However, due to possible bias in recent data as a result of recent implementation of the European Union’s WEEE and RoHS Directives across Europe as well the perceived difficulty in obtaining data within an appropriate time frame due to language and geographical barriers, Sweden was also excluded from the study.

Focus Area of Study

The study primarily focuses on how the policies impact the disposal of residential CRTs. The focus on residential CRT disposal is due to the fact that this group is classified under RCRA as exempt from the stringent disposal methods; and therefore, is allowed to place CRTs in permitted landfills under Subtitle D.234 Moreover, the recycling of residential CRTs poses significant challenges for electronic recyclers. As presented in the report by the U.S. Government Accountability Office, Electronic Waste: Strengthening the Role of the Federal Government, these two aspects combined with the CRTs’ high levels of toxicity and their growing numbers in the solid waste stream heighten the need for policy to create incentives which encourage safe alternative methods for disposal.235

While this study does focus on exempt small generators, it does not ignore the importance of non-exempt generators within the scope of the research. Non–exempt generators, due to their required compliance with RCRA, have traditionally had an economic incentive to find alternative methods of disposal. Because of the high value content in their electronic products and due to the storage of sensitive data on hard drives, reuse, refurbishment and recycling have become preferable to such generators for economic and data security reasons. Therefore, these generators collectively have become a key driving force in the development and growth in the recycling industry.236 As such, they also have been drivers in standards concerning transparency and accountability in how material processed downstream is managed. It is in this context through interviews and research that non-exempt generators are included in the overall analysis of the policies.

Key Indicators

To ascertain how policy influences residential CRT recycling and whether or not CRTs are recycled in a proper and safe manner, the research attempts to address accessibility to CRT recycling and the degree by which accountability measures are imposed on individual collection facilities and on their downstream venders. Accessibility to CRT recycling includes public knowledge of available alternative disposal options, their access to these options and their use of these options. The level of accountability for material management practices throughout the reverse logistics supply chain is reflected in the required record keeping of specific information that the facility imposes on itself as well as on its downstream venders. Therefore, the study addresses requirements for material management practices imposed on downstream venders; the level of detail in record keeping for equipment received and diverted through venders, and the final material output from recycling.

Resources for Research

Data is gathered from federal, state and local agencies, trade organizations, local collection agencies, recycling companies, and other selected recycling institutions by use of interviews, email correspondence, online research, and surveys. All data collected addresses either policy implementation or information regarding access and accountability in material management. To organize the local data sample, the research focuses on a survey targeting local CRT collection facilities located in only the key cities/counties in Texas and Massachusetts’ Metropolitan areas with a population of 200,000 or more as defined by the Census Bureau of 2000. This sample selection size represents a significant portion of the entire population that would most likely warrant alternative options for CRT disposal for exempt small generators. By using a Metropolitan area with a population of 200,000 or more, only rural areas supported by a sizeable urban core are represented. The rational behind this approach is based on previous studies that show that recycling options in rural areas, in general, tend to be more problematic.237

Sample Selection

To find collection facilities to target for surveys and follow-up questions, municipal and county web sites were first perused for information on agencies and/or companies within the targeted areas that provided recycling collection services either for CRT products only or for multiple residential electronic equipment, including CRT products. Because local governments have traditionally offered waste management services to residents and small businesses, either directly or through contracted private companies; it was deemed logical that local governments would be a first point of contact for information on alternative methods of disposal. If no information was provided for by the local governments, a second review of consumer electronic recycling services was conducted via the local yellow pages for the targeted local governments. If no collection facility was found by those two means, then it was assumed that residents/consumers did not have proper access to electronic recycling collection facilities in the targeted area.238 In Massachusetts, research discovered that a large waste hauler is also a predominant recycling collection agency for CRTs that service many local municipalities. Therefore, in addition to local government recycling collection services, a survey also went to the Massachusetts headquarters for this particular waste hauler in reference to their collection of CRTs for recycling in targeted communities. In Texas, Dell was contacted as a key organizer for the collection of discarded computers and other related peripherals for the purpose of reuse, refurbishment and recycling. In communities with a number of CRT recycling providers, often two were chosen randomly.

Survey for Purpose of Analysis

The survey used in this research was submitted to the various recycling collection facilities. Input from various interviews with officials in state environmental protection agencies, collection facilities, recyclers, and other industry affiliates was helpful in determining what information to request from collection facilities such that responses from surveys could be conducted in a timely manner. The questions in the survey had to address consumers’ accessibility to recycling options and the degree of accountability demonstrated in material management. The surveys were sent to targeted facilities in February and March of 2007. Please see Appendix A for a copy of the survey used for the research.

Questions one through four from the survey are useful in providing insight on the accessibility of alternative disposal methods for CRTs. The question about the program start date indicates how long the facility has been available for public use, while the question about residential use establishes the facilities targeted audience. The question about recycling tons over time indicates whether or not the recycling of products is increasing over time as should be expected if more residents are increasingly choosing recycling over landfill or storage. The inquiry about fees charged for CRTs may be seen as an economic deterrent for CRT recycling, which could reduce residential access.

To assess the level of accountability in proper material management practices, several assumptions were made.

  1. No one recognized guide for best practices in material management was considered to be better than the other.
  2. Contractual agreements were considered to be a better measure of accountability than criteria alone since contractual agreements may be legally enforced.239
  3. Having measures in place to track information on disposal methods and practices for downstream venders is considered better than having none.
  4. Information on final destination by percentage represents knowledge on downstream venders’ outputs and whether or not those percentages are in line with what one could expect according to the literature review.

As a result, most of the analysis requires reviewing certain question in context of the answers from other questions. For example, the analysis to the response as to whether or not the facility charges a CRT fee has a lot to with whether or not the majority of the product delivered is from residents or from commercial industries. Below is a table that describes how the questions from the survey are analyzed both separately and together with other questions and what information they convey.

Survey Material Management Information

Table 1 · Summary of Rational Behind Survey Questions
(2) Residential? Is the facility actually keeping track of where they get their material? If so, this demonstrates some level of accountability in record keeping.
(2) Residential? + (3) CRT fee? How much of their program relies on consumers products affect the reuse/refurbishment value and thus a collection agency may have more incentives to seek undesirable outlets unless it can recover some costs through the use of fees.
(4) Amount recycling by tons over time? The recording of tonnage collected demonstrates some level of accountability for material received. It also demonstrates whether or not the amount is increasing or decreasing over time.
(5) Percent Reused? + (6) Percent refurbished? + (7) Percent Recycled? By tracking the end use of products received demonstrates a level of accountability of how product is used and/or disposed of through their downstream venders.
(5) Percent Reused? + (6) Percent Refurbished? The amount of product that can be reused or refurbished for reuse depends on the source of the products. Residential products have less reusable product than do commercial products. See Chapter 3 for more information. A red flag would arise if high percent of product is said to be reused while the majority of product is residential.240
(3) CRT fee? + (7) Percent Recycled? + (8) Criteria? + (9) Contract? A 90% ~ 100% recycled would likely be a signal for care in proper and safe disposal only if a fee is charged for CRTs and the facility has established a contract that require downstream venders to adhere to material management guidelines. Otherwise, it could indicate that the facility is not properly tracking how the downstream venders dispose of the products.241
(8) Criteria? If other criteria are chosen apart from just price, then we can assume that the facility is attempting to some extent to implement proper material management practices in the downstream vender chain.
(9) Contract? Selecting criterion alone is not sufficient to ensure actual proper material management as it is not legally binding and difficult to maintain. A contract with stipulations involving one or more of the aforementioned criteria other than price demonstrates a more concerted effort in controlling material management practices for material downstream.242
(10) Tracking requirements? Demonstrates the degree of thoroughness in tracking downstream venders.
(10) Tracking requirements? + (5) ~ (7) Percent Reused and Refurbished and recycled? + (8) Criteria? + (9) Contract? This descriptive overview of downstream tracking is reviewed in context with previous answers to check for consistency and how thorough material management practices are for downstream venders.
(11) Tier? Record keeping without looking at more than one or two tiers may not be sufficient in determining how material was disposed. Therefore, proper material management will track material downstream through multiple tiers in the reverse logistics supply chain.243

Limitations

The research has several limitations that must be considered with respect to the data sample and the questions in determining access and accountability in material management practices. First, the small sample size for data may create some bias. Additionally, despite offering anonymity to facilities responding to the survey, the nature of the questions may create a self-selection bias for those companies not wanting to divulge what they deem sensitive information. Per several interviews with recyclers, the research revealed that many recyclers were often distrustful on how this information may be used.244

The ability to measure residential access to recycling facilities is fundamentally limited. This survey recognizes access as to whether or not an option for recycling exists within a major community in the Metropolitan region by information made available from local government websites and/or the local yellow pages. It does not look at access in terms of convenience for residents in measures such as distance and hours of operations. Nor does this information indicate how much material was diverted from landfills and storage. Additionally, the request for the amount of electronic waste received in tonnage is not a clear indicator of access, especially in large metropolitan areas where residents have multiple choices for residential collection facilities; and where types of material accepted for certain drop-off may be restricted to specific items.

Another limitation inherent in the request for tonnage is based on the differences between the two states in what CRT collection facilities accept for recycling. Many collection facilities in Massachusetts focus on accepting only CRTs and not other electronic equipment. On the other hand, in Texas, some collection facilities accept only computer related equipment, including CRT monitors, but will not accept other CRTs such as televisions. These differences reflect the differences in the prevailing policies in each state. Nonetheless, such differences in type of electronic products collected hinder comparative regional analysis according to collected tonnage.

The questions in the survey that probe into accountability measures for material management practices are also limited. The purpose of the survey is to determine collection facilities’ intent to incorporate publicly recognized material management practices; not whether or not these facilities have been successful in ensuring that these practices are actually adhered to by downstream venders. Additionally, this research does not attempt to qualitatively judge one preferred guideline for material management practices over another. Instead, it assumes that any of the options other than just pricing are better than none, which may or may not be accurate.

The overlap and contextual reference of the questions create autocorrelation in the data. The questions concerning the percentage of electronic equipment reused, refurbished, and recycled must be viewed in context with other material management questions. For example, a facility that requires all products sent downstream to be recycled will likely claim that 100 percent of the products received are recycled. On the other hand, a company that does not track how electronic products are managed through the supply chain may also claim that 100 percent was recycled. In such cases, a review of how much is recycled versus reused and/or refurbished alone does not indicate whether or not a facility is employing additional material management practices.

The research does not account for the proportional differences in the geographical distances in each state. Massachusetts is a much smaller state with a much denser population than Texas (809.8 people per square mile versus 79.6 people per square mile).245 The greater density is more favorable in developing logistical distribution networks at lower costs. Therefore, what may appear to be the outcome of policy could also be the result of having a relatively dense population distributed over a small region.

Survey Findings

Respondents

The response rate for collection facilities in Massachusetts was slightly higher than that for collection facilities in Texas; 62.5 percent compared with 59 percent. Please refer to Appendix B for number of respondents. The main respondents in both states that completed the survey were either municipal/county drop-off locations or charity organizations. None of the selected electronic recyclers and none of the private waste management companies responded to the survey. Several of the electronic recyclers in Texas did provide useful follow-up information via telephone and personal interviews instead of completing the survey. Likewise, the Global Asset Recovery Systems division of Dell also provided useful information via an interview rather than respond to the survey. Such interviews were incorporated into survey responses where applicable. Additionally, information found on available web sites also served as a supplement and/or complement to the survey when necessary.

Access

In accordance to the policy review in Chapter 3, Massachusetts’ collection facilities appear to be more accessible to residents than do collection facilities located in Texas. At least one collection facility was located in a prominent town within a Metropolitan Statistical Area with a population of 200,000 or more in Massachusetts. In Texas, only half of all Metropolitan Statistical Areas with a population of 200,000 or more had at least one identifiable electronic recycling collection facility within a prominent local government. All Metropolitan Statistical Areas in Texas with a population over a million had multiple options for residential electronic equipment drop-offs. However, only one of the two areas with a population between 500,000 and 600,000 had an identifiable electronic recycling collection facility. Of the six Metropolitan Areas with a population between 200,000 and 499,999, only one area had an identifiable electronic recycling collection facility. Please refer to Appendix B for more detailed information.

In terms of how long existing facilities have been available to residents, facilities in Massachusetts shows the year 2001 as a median commencement date, which is only one year after the landfill ban. In contrast, the facilities in Texas show mid 2003 as a median commencement date. (Please refer to Appendix C for a complete summary of data from respondents). Thus, half of the facilities that have responded in Massachusetts were in place by 2001; whereas half of facilities in Texas were established by mid 2003, despite approximately 30 years of RCRA (with approximately 10 years of imposing more stringent controls on local landfills).

According to a few collection facilities surveyed, access to CRT recycling in Texas depends on whether it is in the form of a monitor or television. Accordingly, 2 out of 11 respondents do not accept televisions. However, the majority of the collection facilities in Texas do not charge for CRT recycling; in contrast to those in Massachusetts, where 4 out 6 charged for CRT recycling (See Appendix C for detailed summary). Correspondingly, we might assume that residents who may be adverse to the charge may seek other options such as placing product into storage, dumping, or giving product away rather than pay. Nonetheless, based on the aggregate data from respondents, collected tonnage of residential CRTs in Massachusetts has continued to increase year over year. The same is true for overall electronic waste collected by facilities in Texas.

The charity organizations that were included in the survey reported the highest amounts in collected electronic equipment; both of which were located in Texas. Neither of the charities surveyed charged a CRT fee. Only the charity organizations that actively support electronic recycling were included in the survey; nonetheless, it corroborates with a previous research study which showed that charity organizations can be an important distribution channel for funneling residential electronic equipment to electronic recyclers.246

In summary, Massachusetts has a much higher overall level of residential access for CRT recycling than does Texas, despite the facilities in Massachusetts being more likely to charge for CRT recycling. In Texas, a large disparity in access to residential CRT recycling exists between Metropolitan Areas with populations over 1 million and under 1 million. While the majority of the collection facilities also accept televisions, the fact that approximately 18 percent of the respondents do not accept televisions indicates residential limitations in access for CRT recycling.

The results of this study concur with the assessment in the previous chapter. Despite the longevity of regulations under RCRA, residential access to CRT recycling has only recently began to be realized; and primarily in large metropolitan areas that are likely to have better access to electronic recyclers serving larger firms. The economic costs associated with residential CRT recycling are reflected in the lack of access in small to medium Metropolitan areas; and in the limitation in large Metropolitan areas to provide residential recycling for televisions. On the other hand, it appears that most of the residential CRT recycling began soon after MassDep implemented the landfill ban and promoted CRT recycling infrastructure through the use of grant subsidies and deregulation of CRT handling under RCRA. Most facilities required a fee to recycle CRTs; nonetheless, accumulated amounts of CRTs collected for recycling appear to continue to increase. In accordance with the Northbridge study, this research demonstrates that the policy creates sufficient incentives to encourage residences to pay for CRT recycling rather than storing or dumping the CRT. These results also have significance in creating access to residential recycling in areas where landfill use may be costly or inconvenient.

Interestingly, with CRT as the main electronic equipment that is banned from landfills, access to recycling for other types of electronic equipment is questionable. For example, Boston’s solid waste management website directed residents to discard computers in municipal waste by claiming that computers are not hazardous waste.247 This runs contrary to current research on electronic waste. Other facilities questioned did not accept other electronic equipment beyond CRTs. While this study focuses on CRTs, it is important to note the narrow focus of the Massachusetts’ policy and its implications. As such, research in electronic waste finds that landfill disposal and/or the improper recycling of electronic equipment in general create external damages in lost resources and environmental damages from toxic materials.

Accountability in Material Management

According to the survey results from both states, it appears that collection facilities in Texas are much more likely to impose additional criteria and contractual material management requirements on their downstream venders than do facilities in Massachusetts. Texas facilities are also more likely to track information not required of them by law. In Texas, the majority of the respondents provided data collection information and provided information on the final use (output via reuse, refurbishment, or recycled) of the electronic equipment collected. In contrast, the majority of collection facilities in Massachusetts (4 out of 5 respondents to the surveys) did not provide any information on final use/output (See Appendix C for details).

According to the responses received from and interviews conducted with the Texas collection facilities, 8 of the 11 respondents indicated that they impose criteria on their downstream venders other than price; 7 of which indicated criteria not legally required under RCRA or state law. Likewise, 7 Texas respondents indicated that one or more of the criteria besides price, are also written as a contractual agreement; and 6 Texas respondents instituted tracking requirements for their downstream venders (See Appendix C for a detailed summary). In contrast to the responses from Texas collection facilities, only 1 facility in Massachusetts required a detailed accounting of inventory; and 1 facility required a certification that material was processed in accordance with local, state and federal law along with total weight. Accordingly, the information provided by collection facilities was limited and the vast majority required no more than what was legally required by state or federal law.

The high number of respondents in Texas that impose criteria, contractual and tracking requirements demonstrates an attempt to increase accountability and transparency over how material is managed. To better understand the rational behind the imposition of additional requirements, a follow-up question was submitted to all 7 respondents. The question listed the criteria and/or requirements that were submitted in the survey. It then asked the respondents to check all reasons why the facility imposed the listed criteria/requirements. The optional responses were:

  1. Required by law
  2. Public Demand
  3. Belief that existing law was insufficient
  4. Good for Public Relations
  5. Other

The response rate for the follow-up question was 5 out the 7 respondents (See Appendix C for detailed summary). The most unanimous answer (4 out of 5) was that the facilities thought the criteria/requirements were good for public relations. This response concurs with other empirical evidence which links corporate responsibility as a product of corporate public image. This may also create concern over how diligently these accountability measures are being enforced.248 On the other hand, respondents also answered 3 out of 5 that reasons for imposing criteria/requirements also include the belief that existing law was insufficient and a belief that the public demanded it. One respondent added that “the few in the public who care about it [material management practices downstream] care a lot”; as such, the facility “considers their view as that of the majority.”249 According to Accountability literature, this may reflect a certain level of mutual responsibility between the collection facilities and the public.250 Such may be the case since most of these respondents are either a collection facility operated by the local government or a local charity organization. This finding highlights the importance of an informed and educated public for creating accountability measures in the electronic recycling industry.

In contrast, the vast majority of the facilities in Massachusetts did not impose any additional criteria than what was required by law. This suggests that the public concern about material management downstream is significantly less than it is in Texas. This could be because much of the recent public debate on material management has been centered on the prevailing RCRA policy. Accordingly, the population in Massachusetts may view the overall national policy debate concerning material management practices as one that is not relevant to their policy practices. If this is the case, then, the policy focus on access without addressing accountability in proper material management practices may further encourage poor material management practices and could result in a non-sustainable solution for electronic recycling. Nonetheless, this is an area that must be explored through further research.

The most cited criteria and contractual obligations for material management practices were ‘Detailed accounting of inventory/parts and its final destination’ and ‘Zero Export Policy’ (See Appendix C for detailed summary). The former received the most responses with 5 responses claiming that that is part of their downstream vender criteria and with the same number claiming that that is part of the downstream venders’ contractual obligations. The latter received 3 responses in both criteria and contractual obligations. The first response reflects public concern as to where this material finally ends up. The latter may reflect a degree of public concern over the lack of regulation in developing countries to ensure that harmful recovery practices are not used. As such, a ‘No export policy’ may provide a level of assurance to concerned members that harmful recovery practices will not occur.

The survey did not reveal a correlation between a charge for CRT recycling and good material management practices, as had been expected. In Texas, because the majority of the collection facilities are located in large Metropolitan areas with a population of more than a million, it could be that large electronics recycling companies located in the area that service the commercial recycling also extend their service to recycling residential electronic equipment, especially if it represents a very small percentage of the recycling company’s business. As such, a recycler may benefit from offering residential recycling through increased recognition and prestige. Additionally, municipal subsidies and/or other measures not addressed in this survey may also contribute to the absence of fees paid by consumers for residential CRT recycling. Nonetheless, understanding all means by which the costs of CRTs recycling are currently being incurred is important for further policy analysis.

The lack of survey responses in both states from waste haulers and recyclers that also offer residential collection service raises questions about the lack of available information and transparency to the general public. The web sites for the majority of the targeted recyclers assert that the recyclers provide environmentally safe recycling. Nevertheless, interviews with recyclers revealed a high degree of public non-disclosure for downstream venders and a general reluctance to provide specific information on their practices regardless of the recovery methods used downstream. The main rational for the secrecy was due to the highly competitive environment in the industry. Accordingly, those companies that discovered environmentally sound productive methods at competitive pricing guarded their downstream venders as part of their trade secret. On the other hand, those which were less environmentally conscientious appeared to fear public scrutiny for their material management practices, and thus, were also reluctant to reveal much information. Nonetheless, the level of public secrecy and non-disclosure regarding downstream venders and material management practices increases the level of anonymity enjoyed by recyclers throughout the reverse logistics supply chain. Such anonymity limits the level of public scrutiny that can be targeted at any individual recycler and raises significant questions about transparency and accountability that are important for maintaining appropriate checks and balances necessary to ensure proper material management practices.

Closing Discussion

This research has focused on the recycling of residential CRT products as a proxy for the challenges facing the electronics recycling industry. External damages are created throughout the entire life cycle of the product, including disposal. Residential CRTs contain significant amounts of hazardous materials, primarily lead, which must be disposed of or recycled properly.251 If disposed of into landfills, valuable and non-renewable material is lost for good; virgin material must be found and extracted, consuming more energy and releasing more harmful contaminants into the environment. The hazardous materials in the CRTs can build up in the landfill and potentially leach into soil and the water supply, depending on the precautionary measures taken by the landfill. Such precautionary measures are practically nonexistent in most of the developing world.252 Additionally, recycled material requires less energy to recover into raw material and has less environmental impact than does the extraction of virgin material.253 As such, safe and proper recycling is critical in reducing external damages caused by improper disposal and by the extraction of virgin material. However, if not recycled properly, CRTs can cause significant harm to human health and the environment by the release of lead.254 Yet, proper recycling of CRT products is expensive because their material output value is low relative to their collection and processing costs. This breakdown in market forces to efficiently allocate material reflects the market distortions inherent in the electronics industry and impacts the product throughout its entire life cycle. As a result, the damage caused by the production, consumption, and disposal of these products is greater than the benefits received, and markets become distorted.255 Therefore, policy becomes an important tool to reduce the external damages by reducing market distortions throughout the entire life cycle of the product.

By looking at the challenges in recycling CRT products (and other low value electronic equipment) and by identifying the role that each stakeholder has on the entire life cycle of the product, this research identifies key incentives that each stakeholder must have to reduce existing market distortions and to create a viable and sustainable electronic recycling industry. These incentives may be economic, social or regulatory. Accordingly, producers require incentives to use the right allocation of inputs and to design the most efficient product. Consumers require incentives to buy the right amount of product and recycle the product once it has been consumed. Recyclers require an economic incentive to offer its services to both commercial and residential consumers. They also require incentives to properly process material. Lastly, recycling outputs require proper market incentives to encourage optimal material output from the recycling industry.

If proper incentives are in place, then the outcome should include residential access to CRT and other electronic recycling and a high level of accountability in material management practices throughout the reverse logistics supply chain. This research evaluated both accessibility and accountability in material management practices for CRT recycling as outcomes of two policies, the federal RCRA policy and the Massachusetts’ policy for CRT recycling. The study revealed that Massachusetts’ policy was successful at creating access but not accountability in material management practices. On the other hand, RCRA policy was not successful in creating access in medium to small Metropolitan areas. However, as a backlash to the leniency in RCRA, a level of public awareness on the hazards of improper material management practices has produced some level of accountability in material management practices by those collection facilities most closely connected to the general public. Nonetheless, the high degree of secrecy in material management practices displayed by many recyclers and waste haulers demonstrate a general lack of accountability to the public for the industry’s actions.

These findings reveal that without adequate policy, accountability becomes dependent upon the structural make-up of the electronic recycling industry, the degree by which the public is informed about material management practices, and how responsive the recycler is to public opinion. Accordingly, the findings reveal that public accountability by recyclers and waste haulers is significantly deficient. These findings also reveal that policies that promote access to recycling do not necessarily promote safe and proper recycling. Without the latter, the long-term sustainability of the recycling under such policy is questionable since it subsidizes the industry by allowing it to engage in cheaper but more harmful recovery methods.

Further Research

This research looked at accountability in materials management practices in accordance with identifiable practices and guidelines which are meant to reduce harmful recovery practices. This research does not validate that these practices are being followed nor does it qualify their usefulness. For example, the ‘no export policy’ may not qualify as good management practices. As Robin Ingenthron, President of American Retroworks, had pointed out in a telephone interview, material has to be exported at some point throughout the process because the manufacturing companies using the outputs are primarily located in developing countries.256 Many processing of scrap into raw material also takes place in developing country. One manager of a collection facility was very disappointed when he learned that despite a ‘no export policy’ with his venders, the leaded glass was still being shipped for processing overseas because no company in the U.S. processed leaded glass into new glass.257 Robin Ingenthron also argues that the promotion of reuse, even if the product is reused in developing countries, reduces the environmental impact because it reduces the overall amount of electronic equipment produced; thereby reducing the extraction of virgin material and energy consumption required to produce new product.258

Many stakeholders are currently working together to develop a set of best practices that can be widely accepted.259 However, what has not been observed is whether or not material management practices are being defined according to the various processes for each product output. Nor, is it clear how such an agreement concerning material management practices can be enforced, if enforced at all. More specialized research is needed in this area to ensure both accountability and best practices for each process in the electronic recycling industry.

Additionally, more environmental economic modeling is needed to better evaluate policy options for reducing market distortions when multiple outputs can emerge from recycling. Traditionally, economic models viewed recycling output as raw material, only. This paper identified three main outputs in recycling: whole equipment, components, raw material. Each output has cyclical repercussions on how and how many products are produced. Accordingly, the modeling of these three outputs into the optimal utility models could impact the optimal outcome of product design, longevity, and material inputs, especially where there might be trade offs. For example, longer, more durable products may require the use of more hazardous material and may require design that is less conducive to recycling; whereas, products that are designed to be easier to recycle may use less hazardous material, but may not be as durable.

Policy Implications

In accordance with the findings in economic literature on recycling, this research highlights the importance of multiple comprehensive policies to address the market distortions that impede electronic recycling of low valued material. Policies must determine the optimal roles for each stakeholder throughout the life cycle of the product and create appropriate incentives accordingly. Conversely, policies which focus on only the role of a few stakeholders in the recycling process may create access that is not sustainable, and may exacerbate existing market distortions or create more elsewhere. As such, policy should include:

  1. Producers’ incentive to design product with ‘recyclability’ in mind such that the output from recycling maximizes resource use and allocation,
  2. consumers’ incentive to choose safe and proper forms of recycling rather than alternative forms of disposal,
  3. electronics recyclers’ incentive to recycle in a safe and proper manner by creating a mechanism to hold recyclers accountable for material management practices through out the reverse logistic supply chain
  4. proper incentives such that output markets value and utilize outputs as a result of proper recycling over other methods that create negative externalities.

In sum, by fostering proper incentives for each stakeholder throughout the electronics industry, policy can encourage access for electronic recycling for what is currently deemed undesirable to recycle. However, to be sustainable, policy must also ensure stakeholder accountability in material management practices.

Appendix

Appendix A. Survey for Electronic Recycling Centers

Electronic Recycling Program

  1. When did the program begin?
  2. Is the program exclusively for residents?
    • If not, what other entities can drop off their electronic waste at the recycling center/s.
    • What percent of the E-waste dropped-off from residents?
  3. Does the program charge a fee for CRT drop offs?

Electronic Recycling Program Usage

  1. How many tons of E-waste does the recycling center collect each year since it has become into existence? (please list all that apply)
    • 2006
    • 2005
    • 2004
    • 2003
    • 2002
    • 2001
    • 2000
  2. What percentage of the E-waste received by your program is reused?
  3. What percentage is refurbished?
  4. What percentage is completely recycled?

Key Criteria for Establishing Downward Venders

  1. What are the criteria for handling CRTs required in selecting electronic recycling downstream venders? (choose all that apply)
    • EPA Plug-In to E-Cycling Material Management Guidelines
    • TEST Pledge
    • Environmental Management System (EMS)
    • BAN Pledge
    • IAER Certificate
    • Price
    • Detailed accounting of inventory/parts and its final destination
    • Zero Export Policy
    • WR3A CRT Test
    • Other
  2. Are any of these criteria written into a contract with your downstream venders?
    If yes, please indicate:
    • EPA Plug-In to E-Cycling Material Management Guidelines
    • TEST Pledge
    • Environmental Management System
    • BAN Pledge
    • IAER Certificate
    • Price
    • Detailed accounting of inventory/parts and its final destination
    • Zero Export Policy
    • WR3A CRT Test
    • Other
  3. Please describe what you require your downstream venders to track with respect to CRTs.
  4. To what tier must they track the material?

Appendix B. Research Target Areas and Response Rate

Table 2 · Targeted Metropolitan Statistical Areas
Massachusetts Metropolitan Statistical Areas Populations Available CRT Recycling
Barnstable Town, MA 222,230 Y
Boston-Cambridge-Quincy, MA-NH 4,391,344 Y
Springfield, MA 680,014 Y
Worcester, MA 750,963 Y
Texas Metropolitan Statistical Areas Populations Available CRT Recycling
Waco, TX 213,517 N
Amarillo, TX 226,522 Y
Lubbock, TX 249,700 N
Brownsville-Harlingen, TX 335,227 N
Beaumont-Port Arthur, TX 385,090 N
Corpus Christi, TX 403,280 N
McAllen-Edinburgh-Pharr, TX 569,463 Y
El Paso, TX 679,622 N
Austin-Round Rock, TX 1,249,763 Y
San Antonio, TX 1,711,703 Y
Houston-Baytown-Sugar Land, TX 4,715,407 Y
Dallas-Fort Worth-Arlington, TX 5,161,544 Y
Table 3 · Collection Facility Response Summary
Massachusetts Collection Facilities Summary Targeted for Survey Responded to Survey
Local Government Collection Facilities 6 5
Private Waste Hauler 1 0
Private Recycler 1 0
Non-Profit Organization 0 0
Texas Collection Facilities Summary Targeted for Survey Responded to Survey
Local Government Collection Facilities 6 6
Private Waste Hauler 2 0
Private Recycler 5 0
Non-Profit Organization 3 2

Appendix C. Research Data

Table 4 · Texas Data Summary I - Texas Respondents
When program began? Residents only? Charge CRT fee? Percent Reused? Percent Refurbished? Percent Recycled? (recovered into raw material) Required Criteria for Selecting Recycler? Required Criteria in Contract (excluding price)? Downstream Tracking Requirements? Tier level for tracking?
2004 N (80%) N 0% 0% 100% Y Y Y Y
2005 Y N NA Y NA NA
2001 Y N Y Y Y NA
2003 Y Y < 5% 10% 80% Y Y Y Y
2002 Y Y (2006) 0% 0% 100% Y Y Y Y
2005 (2001 for annual event) Y N 10% 30% 60% NA NA NA
2005 N (90%) N 5% 15% 80% Y N Y Y
N (<1/2%) X 100% NA Y
N X X 98-99%
1997 N (95%) N 20-40% 60-80% Y Y Y Y
N Y X Y Y Y
Table 5 · Texas Data Summary II - Texas Respondents
Criteria for Recyclers Criteria listed in Contracts Downstream Tracking Requirements Tier Level for Tracking
EPA Plug-In; EMS; Detailed Accounting of Inventory & Final Destination; Zero Export; RCRA; CIWMB; DTSB EPA Plug-In; EMS; Detailed Accounting of Inventory & Final Destination; Zero Export; RCRA; CIWMB; DTSB Reuse, Recovery, hazardous waste disposal 6 tier process from reuse to smelting
NA Detailed Accounting of Inventory & Final Destination NA NA
Detailed Accounting of Inventory & Final Destination Detailed Accounting of Inventory & Final Destination Final Destination NA
Detailed Accounting of Inventory & Final Destination; Zero Export Detailed Accounting of Inventory & Final Destination; Zero Export Final Destination/ Disposition Disposition point; hazardous landfill; and amount for each
TEST Pledge; BAN Pledge; Price; Detailed Accounting of Inventory & Final Destination; Zero Export Test Pledge/Standards; Detailed Accounting of Inventory & Final Destination; Zero Export; 100% recycle-no refurbish Weight of whole units; certificate of destruction of whole units Internal auditor for downstream vendors provides documentation of regulatory compliance and responsible recycling and disposal of hazardous and non-hazardous materials upon request.
All applicable local, state, & federal laws NA NA NA
EMS; BAN; IAER Certificate; Detailed Accounting of Inventory and Final Destination NA No export of whole units; clear understanding of downstream destruction End use or final dismantle
NA Export location
NA
Dell’s Material Management Criteria Dell’s Material Management Criteria Annual Audit 4 tiers
Dell’s Material Management Criteria Dell’s Material Management Criteria Annual Audit
Table 6 · Texas Response Summary of Criteria - Texas Responses for Criteria Selected
EPA Plug-In Material Management Guidelines TEST Pledge/Standards Environmental Management System (EMS) BAN Pledge IAER Certificate Detailed Accounting of Inventory & Final Destination Zero Export Policy WR3A CRT Test Other
Criteria For Recyclers 1 1 2 2 1 6 3 0 4
Criteria Listed in Contracts 1 1 1 0 0 5 3 0 5
Table 7 · Massachusetts Data Summary I - Massachusetts Respondents
When program began? Residents only? Charge CRT fee? Percent Reused? Percent Refurbished? Percent Recycled? (recovered into raw material) Required Criteria for Selecting Recycler? Required Criteria in Contract (excluding price)? Downstream Tracking Requirements? Tier level for tracking?
2000 Y N NA NA NA Y NA NA NA
2002 N (95%) Y NA NA NA Y NA Y NA
2001 Y Y NA NA NA NA NA NA NA
2000 N (~99%) Y NA NA 100% Y NA NA Y
2001 Y N NA NA NA NA NA NA NA
N Y
Table 8 · Massachusetts Data Summary II - Massachusetts Respondents
Criteria for Recyclers Criteria listed in Contracts Downstream Tracking Requirements Tier Level for Tracking
Detailed Accounting of Inventory & Final Destination NA NA NA
Certification that materials have been processed in accordance to local, state & federal law NA Total weight & certificate of recycling/destruction Unknown
NA NA NA NA
State Approved Recycler NA NA State report
NA NA NA NA

Appendix D - Acronyms

ARF : Advanced Recovery Fee
BAN: Basel Action Network
CEA: Consumer Electronics Association
CFR: Code of Federal Regulation
CERCLA: Comprehensive Environmental Response, Compensation and Liability Act
CESQGs: Conditionally Exempt Small Quantity Generators
CRT: Cathode Ray Tube
EIA: Electronic Industries Alliance
EPA: U.S. Environmental Protection Agency
EPR: Extended Producer Responsibility
GAO: Government Accountability Office
HDTV: High Definition Television
HSWA: Hazardous and Solid Waste Amendments
IAER: International Association of Electronics Recyclers
iNEMI: International Electronic Manufacturing Initiative
IPR: Individual Producer Responsibility
ISRI: Institute of Scrap Recycling Industries, Inc.
IT: Information Technology
LDR: Landfill Disposal Restriction
LQGs: Large Quantity Generators
MassDEP: Massachusetts Department of Environmental Protection
NEPSI: National Electronics Product Stewardship Initiative
OSD: Operations Services Division of MassDEP
OSHA: Occupational Safety and Health Administration
PBS: Public Broadcast System
RCRA: Resource Conservation and Recovery Act
RoHS: Restrictions on Hazardous Substances
SQGs: Small Quantity Generators
SWDA: Solid Waste Disposal Act
TSDFs: Treatment, storage and disposal facilities
WEEE: Waste Electronic and Electrical Equipment

Appendix E - Bibliography

Government Publications

Books

Articles

Internet Articles

Reports

Interviews and Emails

Brochures and Pamphlets

WebPages

Notes

Notes - Chapter I

  1. U.S. Geological Survey, Obsolete Computers, “Gold Mine,” or High-Tech Trash? Resource Recovery from Recycling, USGS Fact Sheet FS-060-01, (July 2001). Online. Available: pubs.usgs.gov/fs/fs060-01/fs060-01.pdf. Accessed: March 31, 2007.
  2. weee-recycle.com. Online. Available: www.weee-recycle.com/home.html. Accessed: November 11, 2007.
  3. Master of Public Administration Program in Environmental Science and Policy, Columbia University, S510: Electronic Waste Recycling Promotion and Consumer Protection Act; Final Report, The Workshop in Applied Earth Systems Management II, (December 9, 2006), pp.12.
  4. U.S. Government Accountability Office, Electronic Waste: Strengthening the Role of the Federal Government, GAO-06-47, (November 2005), p.1-23. Online. Available: www.gao.gov/new.items/d0647.pdf. Accessed: October 27, 2006.
  5. Massachusetts Department of Environmental Protection, “Electronics Re-Use and Recycling Infrastructure Development in Massachusetts,” under the United States Environmental Protection Agency’s Municipal and Industrial Solid Waste Division for the Jobs Through Recycling Program, September 2000, pp.13-14.
  6. Robin Ingenthron, “Setting a Higher Standard: Establishing and Adhering to Best Practices Could Help Solve Export-Related Electronic Scrap Problems-Electronics Exporting,” Recycling Today, (Jun, 2002). Online. Available: findarticles.com/p/articles/mi_m0KWH/is_6_40/ai_87857754. Accessed: January 17, 2007.
  7. U.S. Congress, House Committee on Energy and Commerce on Environment and Hazardous Materials, Electronic Waste: An Examination of Current Activity, Implications for Environmental Stewardship, and the Proper Federal Role, 109 Congress, 1 Session (September 8, 2005). Online. Available: Lexis-Nexis Academic Universe, web.lexis-nexis.com/universe. Accessed: September 26, 2006.
  8. Don Fullerton, “A Framework to Compare Environmental Policies,” Southern Economic Journal, vol.68, no.2, (2001), pp.224-247; Don Fullerton and Thomas C. Kinnaman, “Garbage, Recycling and Illicit Burning or Dumping,” Journal of Environmental Economics and Management, vol. 29, (1995), pp.78-89.
  9. Margaret Walls & Karen Palmer “Upstream Pollution, Downstream Waste Disposal, and the Design of Comprehensive Environmental Policies,” Journal of Environmental Economics and Management, vol. 41, (2001), pp.95-107; Paul Calcott & Margaret Walls, “Waste, recycling, and ‘Design for Environment’: Roles for markets and policy instruments,” Resource and Energy Economics, vol.27, (2005), pp.287-305.
  10. Calcott, “Waste, recycling, and ‘Design for the Environment,” pp. 287-305.
  11. Tracy Swift, “Trust, Reputation and Corporate Accountability to Stakeholders,” Business Ethics, A European Review, vol. 10, no.1 (January 2001), pp. 1-24; Aris Solomon and Linda Lewis, “Incentives and Disincentives for Corporate Environmental Disclosure,” Business Strategy and the Environment, vol. 11 (2002), pp.166-167.
  12. Ibid.
  13. Ingenthron, “Setting a Higher Standard.”
  14. Lyndon B. Johnson School of Public Affairs, Economic Impact of Rural Military Base Realignment and Closure, Policy Research Project Report Series, no. EIR (Austin, Texas, 2006), pp. 53-73.
  15. Fullerton, “A Framework to Compare,” pp.224-247.
  16. Fullerton, “Garbage, Recycling,” pp.78-89.
  17. Interview with Mike Watson, Senior Compliance Manager, Global Asset Recovery Services, Dell, Austin, Texas, February 16, 2007.
  18. MassDEP, “Electronics Re-Use and Recycling,” pp.13-14.
  19. U.S. Environmental Protection Agency, Resource Conservation Challenge (RCC) CRT Recycling Made Easy. Online. Available: www.epa.gov/RCC/2006news/09-crt.htm. Accessed: March 14, 2007.
  20. MassDEP, “Electronics Re-Use and Recycling,” pp.13-14.
  21. U.S. Environmental Protection Agency, Analysis of five Community Consumer/ Residential Collections of End-of-Life Electronics and Electrical Equipment, by EcoBalance Incorporated., (Bethesda, Maryland, April 1999), pp. 3, 38. Online. Available: www.p2pays.org/ref/12/11889.pdf. Accessed: March 14, 2007.
  22. International Association of Electronics Recyclers, IAER Electronics Recycling Industry Report 2006, p.6.
  23. U.S. Environmental Protection Agency, Office of Solid Waste, Economic Analysis of Cathode Ray Tube Management, Notice of Proposed Rulemaking, (Washington, D.C., February 15, 2002), p.28. Online. Available: www.epa.gov/epaoswer/hazwaste/recycle/electron/econ-crt.pdf. Accessed: January 3, 2007.
  24. Hai-Yong Kang and Julie M. Schoenung, “Economic Analysis of Electronic Waste Recycling: Modeling the Cost & Revenue of a Materials Recovery Facility in California.” Environmental Science Technology, vol.40, no.5 (2006), pp.1681.
  25. World Reuse, Repair, Recycling Association (WR3A), “The CRT Glass Recycling Test.” Online. Available: www.wr3a.org/docs/CRTGlassTest_final.PDF. Accessed: January 3, 2007.
  26. U.S. Environmental Protection Agency, Design for the Environment: Life-Cycle Assessment of Desktop Computer Displays: Summary of Results. Online. Available: www.epa.gov/oppt/dfe/pubs/comp-dic/lca-sum/. Accessed: April 2, 2007.
  27. Florida Center for Solid and Hazardous Waste Management, Characterization of Lead Leachability From Cathode Ray Tubes Using The Toxicity Characteristic Leaching Procedure, State University System of Florida, Report 99-5 (Gainesville, Florida, December, 1999), pp.3-4.
  28. EPA, Design for the Environment.
  29. GAO, Strengthening the Role of the Federal Government, p.3.
  30. Florida Center, Characterization of Lead Leachability, p.5.
  31. Ingenthron, “Setting a Higher Standard.”
  32. Ibid.
  33. GAO, Electronic Waste: Strengthening the Role, pp.2-3.

Notes - Chapter II

  1. Institute of Scrap Recycling Industries, Electronics Recycling. Online. Available: www.isri.org/AM/Template.cfm ?Section=Electronics1 &Template=/TaggedPage/TaggedPageDisplay.cfm &TPLID=109 &ContentID=6844. Accessed: December 21, 2006.
  2. International Association of Electronics Recyclers , IAER Electronics Recycling Industry Report 2006, p.7, 26.
  3. Ibid. p.10.
  4. Ibid., p.7, 10-13.
  5. Ibid., p.11.
  6. Ibid., p. 4.
  7. Ibid., p. 4.
  8. Interview with Robyn Llewelyn, Electronic Recycling Manager, Goodwill Industries of Central Texas, Austin, Texas, January 12,2007; IAER, IAER Report, p. 44.
  9. Ibid. p. 4.
  10. Ibid., pp. 7, 15.
  11. Telephone interview by Angela Pack Zia with Willy Medina, Operations Manager, Partner, Cinco Electronics Recycling, Austin, Texas, January 3, 2007.
  12. Hai-Yong Kang and Julie M. Schoenung, “Economic Analysis of Electronic Waste Recycling: Modeling the Cost & Revenue of a Materials Recovery Facility in California.” Environmental Science Technology, vol.40, no.5, (2006), pp. 1672-1680.
  13. Massachusetts Department of Environmental Protection, “Electronics Re-Use and Recycling Infrastructure Development in Massachusetts,” under the United States Environmental Protection Agency’s Municipal and Industrial Solid Waste Division for the Jobs Through Recycling Program, September 2000, pp.8-12.
  14. IAER, IAER Report, pp. 18-19.
  15. Kang, “Economic Analysis,” p. 1678.
  16. Ibid. p. 1677
  17. Ibid.
  18. Ibid.
  19. Interview with Ferris Segovia, President, Monitex LLC., Grand Prairie, Texas, March 7, 2007.
  20. World Reuse, Repair, Recycling Association, “The CRT Glass Recycling Test.” Online. Available: www.wr3a.org/docs/CRTGlassTest_final.PDF. Accessed: January 3, 2007.
  21. U.S. Environmental Protection Agency, Office of Solid Waste, Economic Analysis of Cathode Ray Tube Management, Notice of Proposed Rulemaking, (Washington, D.C., February 15, 2002), pp.25-33. Online. Avalaible: www.epa.gov/epaoswer/hazwaste/recycle/electron/econ-crt.pdf. Accessed: January 3, 2007.
  22. Ibid.,p.33.
  23. U.S. Environmental Protection Agency, Analysis of five Community Consumer/ Residential Collections of End-of-Life Electronics and Electrical Equipment, by EcoBalance Incorporated., (Bethesda, Maryland, April 1999), pp. 3, 38. Online. Available: www.p2pays.org/ref/12/11889.pdf. Accessed: March 14, 2007.
  24. IAER, IAER Report, p.31.
  25. Ibid.
  26. U.S. Environmental Protection Agency, Resource Conservation Challenge (RCC): CRT Recycling Made Easy. Online. Available: www.epa.gov/RCC/2006news/09-crt.htm. Accessed: March 14, 2007.
  27. IAER, IAER Report, pp. 22, 26.
  28. U.S. Congress, House Committee on Energy and Commerce on Environment and Hazardous Materials, “Electronic Waste: An Examination of Current Activity, Implications for Environmental Stewardship, and the Proper Federal Role,” testimony by Joel Denbo, Chair, Institute of Scrap Recycling Industries, Inc., September 8, 2005. Online. Available: Lexis-Nexis Academic Universe, web.lexis-nexis.com/universe. Accessed: September 26, 2006.
  29. MassDEP, “Electronics Re-Use and Recycling,” pp. 8-12.
  30. Llewelyn interview.
  31. Elizabeth Grossman, High Tech Trash, Digital Devices, Hidden Toxics, and Human Health,(Washington, D.C.: Island Press/Shearwater Books, 2006), pp. 191, 246-252.
  32. IAER, IAER Report, p. 19.
  33. Ibid, p.19, 44.
  34. U.S. Congress, House Committee on Energy and Commerce on Environment and Hazardous Materials, “Electronic Waste: An Examination of Current Activity, Implications for Environmental Stewardship, and the Proper Federal Role,” testimony by Gerald L. Davis, President and CEO, Goodwill Industries International, September 8, 2005. Online. Available: Lexis-Nexis Academic Universe, web.lexis-nexis.com/universe. Accessed: September 26, 2006.
  35. IAER, IAER Report, pp.25-26.
  36. Ibid., p.27.
  37. All interviews with electronic recycling companies revealed that residential electronic equipment make up less than 1 percent of the equipment that each company receives for demanufacturing and processing.
  38. U.S. Congress, House Committee on Energy and Commerce, “Electronic Waste,” testimony by Denbo.
  39. Dell, Environment, Online. Available: www.dell.com/content/topics/global.aspx/corp/environment/en/index?c=us&l=en&s=corp. Accessed: September 28, 2006.
  40. This is evident is the number of manufacturers’ representatives who spoke at the U.S. Congress hearing for the House Committee on Energy and Commerce on Environment and Hazardous Materials during the 109 Congress, 1 Session (September 8, 2005). Citation: U.S. Congress, House Committee on Energy and Commerce on Environment and Hazardous Materials, Electronic Waste: An Examination of Current Activity, Implications for Environmental Stewardship, and the Proper Federal Role, 109 Congress, 1 Session (September 8, 2005). Online. Available: Lexis-Nexis Academic Universe, web.lexis-nexis.com/universe. Accessed: September 26, 2006.
  41. U.S. Congress, House Committee on Energy and Commerce, “Electronic Waste,” testimony by Denbo.
  42. Northbridge Environmental Management Consultants, Characteristics of Massachusetts’ CRT Recycling Program, Prepared for Electronic Industries Alliance (Westford, Massachusetts, October 21, 2002), pp. 2-2, 2-3. Online. Available: mass.gov/dep/recycle/priorities/macrteia.doc. Accessed: March 22, 2007.
  43. Interview with Mike Watson, Senior Compliance Manager, Global Asset Recovery Services, Dell, Austin, Texas, February 16, 2007.
  44. Northbridge, Massachusetts’ CRT Recycling Program, p.3-3.
  45. U.S. Congress, House Committee on Energy and Commerce on Environment and Hazardous Materials, Electronic Waste: An Examination of Current Activity, Implications for Environmental Stewardship, and the Proper Federal Role, 109 Congress, 1 Session (September 8, 2005). Online. Available: Lexis-Nexis Academic Universe, web.lexis-nexis.com/universe. Accessed: September 26, 2006.
  46. U.S. Congress, House Committee on Energy and Commerce, “Electronic Waste,” testimony by Davis.
  47. MassDep, “Electronics Re-Use and Recycling”, p.19.
  48. Northbridge, Massachusetts’ CRT Recycling Program, p.3-3.
  49. Llewelyn interview.
  50. International Association of Electronics Recyclers, IAER Certification. Online. Available: www.iaer.org/communications/certification.htm. Accessed: December 10, 2006.
  51. Watson interview.
  52. International Electronics Manufacturing Initiative. Online. Available: www.inemi.org. Accessed: October 2, 2006.
  53. Electronics Industry Alliance. Online. Available: www.aiae.org. Accessed: February 8, 2007.
  54. U.S. Environmental Protection Agency, About EPA. Online. Available: www.epa.gov/epahome/aboutepa.htm. Accessed: January 23, 2007.
  55. U.S. Department of Labor, Occupational Safety and Health Administration, Lead. - 1910.1025. Online. Available: www.osha.gov/pls/oshaweb/owadisp.show_document? p_table=STANDARDS&p_id=10030. Accessed: February 14, 2007.
  56. Grossman, High Tech Trash, pp. 156-157, 185-187.
  57. Grossman, High Tech Trash, pp. 182-209.
  58. U.S. Government Accountability Office, Electronic Waste: Strengthening the Role of the Federal Government, GAO-06-47, (November 2005), pp. 20-23. Online. Available: www.gao.gov/new.items/d0647.pdf. Accessed: October 27, 2006.
  59. “Electronic Waste Adds to Pollution in India,” NewsHour, (February 19, 2007). Online. Available: www.pbs.org/newshour/bb/science/jan-june07/ewaste_02-19.html. Accessed: March 5, 2007.
  60. “Firms Starting to Stem Wave of Toxic Tech Junk,” Austin American-Statesman,(March 5, 2007), p. D-1.
  61. Basel Action Network (BAN), About the Basel Action Network-BAN. Online. Available: www.ban.org/main/about_BAN.html. Accessed: January 9, 2007.
  62. Don Fullerton, “A Framework to Compare Environmental Policies,” Southern Economic Journal, vol. 68, no.2, (2001), pp.227-230.
  63. U.S. Congress, House Committee on Energy and Commerce, “Electronic Waste,” testimony by Denbo.
  64. IAER, IAER Report, pp. 6, 25.
  65. U.S. Congress, House Committee on Energy and Commerce, “Electronic Waste,” testimony by Denbo.
  66. IAER, IAER Report, p. 6.
  67. Ibid, pp. 25-32.
  68. U.S. Congress, House Committee on Energy and Commerce, “Electronic Waste,” testimony by Denbo.
  69. GAO, Electronic Waste: Strengthening the Role, pp. 20-24.
  70. U.S. Congress, House Committee on Energy and Commerce, “Electronic Waste,” testimony by Denbo.
  71. Segovia Interview.
  72. U.S. Congress, House Committee on Energy and Commerce, “Electronic Waste,” testimony by Denbo.
  73. IAER, IAER Report, p. 19
  74. IAER, IAER Report, p.18.
  75. Telephone interview by Angela Pack Zia with Peter R. Muscanelli, President, International Association of Electronics Recyclers (IAER), Albany, New York, January 2, 2007.
  76. Telephone interview by Angela Pack Zia with Robin Ingenthron, President, American Retroworks, Inc., Middlebury, Vermont, January 15, 2007.
  77. Ross L. Watts and Jerold L. Zimmerman, Positive Accounting Theory, (Prentice-Hall: London, 1986).
  78. Tracy Swift, “Trust, Reputation and Corporate Accountability to Stakeholders,” Business Ethics, A European Review, vol. 10, no.1 (January 2001), p. 24.
  79. Ibid.
  80. David Wheeler and John Elkington, “The End of Corporate Environment Report? Or the Advent of Cybernetic Sustainability Reporting and Communication,” Business Strategy and the Environment, vol.10 (2001), pp.1-14.
  81. Aris Solomon and Linda Lewis, “Incentives and Disincentives for Corporate Environmental Disclosure,” Business Strategy and the Environment, vol. 11 (2002), pp.166-167.

Notes - Chapter III

  1. Don Fullerton, “A Framework to Compare Environmental Policies,” Southern Economic Journal, vol.68, no.2, (2001), pp.224-247.
  2. Margaret Walls & Karen Palmer “Upstream Pollution, Downstream Waste Disposal, and the Design of Comprehensive Environmental Policies,” Journal of Environmental Economics and Management, vol. 41, (2001), pp.95-107.
  3. Fullerton, “A Framework to Compare,” pp.224-247
  4. U.S. Environmental Protection Agency, RCRA Statutory Overview, prepared by Booz Allen & Hamilton Incorporated, (EPA530-R-99-063, PB2000-101 903), pp.2-4. Online. Available: www.epa.gov/epaoswer/hotline/training/statov.txt. Accessed: March 14, 2007.
  5. U.S. Environmental Protection Agency, Waste: Laws & Regulations, Online. Available: www.epa.gov/epaoswer/osw/laws-reg.htm. Accessed: March 14, 2007.
  6. Ibid.
  7. EPA, RCRA Statutory Overview, p. 2.
  8. EPA, RCRA Statutory Overview, pp. 3, 5-6.
  9. EPA, Waste: Laws & Regulations.
  10. U.S. Environmental Protection Agency, Region 2 Waste: Hazardous Waste; RCRA Subtitle C, Online. Available: www.epa.gov/region02/waste/csummary.htm. Accessed: March 14, 2007.
  11. EPA, RCRA Statutory Overview, pp. 15-16.
  12. Ibid., p. 7.
  13. U.S. Environmental Protection Agency, RCRA, Reducing Risk from Waste, (Washington, D.C., EPA530-K-97-004, September, 1997), pp.10-11. Online. Available: www.epa.gov/epaoswer/osw/laws-re.htm. Accessed: March 14, 2007.
  14. EPA, RCRA Statutory Overview, pp. 15-16.
  15. EPA, Region 2 Waste: Hazardous Waste.
  16. Ibid., p.12.
  17. Ibid., p.11-12.
  18. Ibid., p.9-10.
  19. EPA, Region 2 Waste: Hazardous Waste.
  20. EPA, RCRA, Reducing Risk from Waste, p.29.
  21. EPA, RCRA Statutory Overview, p.14.
  22. International Association of Electronics Recyclers, IAER Electronics Recycling Industry Report 2006, p. 18-19.
  23. U.S. Environmental Protection Agency, Resource Conservation Challenge (RCC) CRT Recycling Made Easy. Online. Available: www.epa.gov/RCC/2006news/09-crt.htm. Accessed: March 14, 2007.
  24. Interview with Ferris Segovia, President, Monitex LLC., Grand Prairie, Texas, March 7, 2007..
  25. Neil Peters-Michaud, John Katers, and Jim Barry, “Occupational Risks Associated with Electronics Demanufacturing and CRT Glass Processing Operations and the Impact of Mitigation Activities on Employee Safety and Health,Electronics and the Environment, vol. 19-22, (May 2003), pp.325-328.
  26. U.S. Geological Survey, Obsolete Computers, “Gold Mine,” or High-Tech Trash? Resource Recovery from Recycling, USGS Fact Sheet FS-060-01, (Juy 2001). Online. Available: pubs.usgs.gov/fs/fs060-01/fs060-01.pdf. Accessed: March 31, 2007.
  27. U.S. Environmental Protection Agency , Office of Solid Waste, Economic Analysis of Cathode Ray Tube Management, Notice of Proposed Rulemaking, (Washington, D.C., February 15, 2002), pp.1-2. Online. Available: www.epa.gov/epaoswer/hazwaste/recycle/electron/econ-crt.pdf. Accessed: January 3, 2007.
  28. Florida Center for Solid and Hazardous Waste Management, Characterization of Lead Leachability From Cathode Ray Tubes Using The Toxicity Characteristic Leaching Procedure, by Timothy G. Townsend, Stephen Musson, Yong-Chul Jang, Il-Hyan Chung, State University System of Florida, Report 99-5 (Gainesville, Florida, December, 1999), pp.1-15.
  29. Basel Action Network, About the Basel Action Network-BAN. Online. Available: www.ban.org/main/about_BAN.html. Accessed: January 9, 2007.
  30. Telephone interview by Angela Pack Zia with electronics recycling facility worker, March 19, 2007. Telephone interview was conducted in confidentiality, and the names of interviewee is withheld by mutual agreement.
  31. Interview with Mike Watson, Senior Compliance Manager, Global Asset Recovery Services, Dell, Austin, Texas, February 16, 2007.
  32. Basel Action Network, What is the Basel Convention. Online. Available: www.ban.org/main/about_basel_conv.html. Accessed: January 9, 2007.
  33. This information was found in many accountability articles reviewed including articles sited in bibliography by Carol Ann Tilt, “The Influence of External Pressure Groups on Corporate Social Disclosure: Some Empirical Evidence” in the journal, Accounting, Auditing & Accountability Journal, and by Aris Solomon and Linda Lewis, “Incentives and Disincentives for Corporate Environmental Disclosure” in the journal, Business Strategy and the Environment.
  34. Ibid.
  35. John J. Fialka, “How Mercury Rules Designed for Safety End Up Polluting,” The Wall Street Journal, (April 20, 2006). Online. Available: Available: online.wsj.com/article/PA2VJBNA4R/SB114549461628630674-search.html. Accessed: December 12, 2006.
  36. This issue of concern was raised in Elizabeth Grossman’s book, High Tech Trash. It has also gained increased attention in the mainstream media. See bibliography citations for articles, “China: Polluted Land Threatens Food,” MSN Money, and Walt Bogdanich and Jake Hooker, “From China to Panama, a Trail of Poisoned Medicine,” The New York Times.
  37. EPA, Resource Conservation Challenge (RCC).
  38. Ibid.
  39. U.S. Environmental Protection Agency, Fact Sheet: Easier Recycling of Cathode Ray Tubes. Online. Available: www.epa.gov/epaoswer/hazwaste/recycle/electron/crt-fs06.htm. Accessed: March 14, 2007.
  40. Peters-Michaud, “Occupational Risks,” pp.326-328.
  41. Ibid., p.326.
  42. Ibid., pp. 326-328.
  43. EPA, Fact Sheet.
  44. EPA, RCRA Statutory Overview, pp.15-16, 22.
  45. Ibid., pp.15-16.
  46. EPA, RCRA Statutory Overview, pp.15-16.
  47. Ibid.
  48. Telephone interview by Angela Pack Zia with Alan Watts, Recycling Marketing Specialist, Small Business and Environmental Assistance Division, Texas Commission on Environmental Quality, Austin, Texas, January 29, 2007.
  49. EPA, RCRA, Reducing Risk from Waste, pp.25-27.
  50. U.S. Department of Commerce, Bureau of the Census, United States Census 2000. Online. Available: www.census.gov/census2000/states/us.html. Accessed March 19, 2007
  51. weee-recycle.com. Online. Available: www.weee-recycle.com/home.html. Accessed: November 11, 2007.
  52. U.S. Government Accountability Office, Electronic Waste: Strengthening the Role of the Federal Government, GAO-06-47, (November 2005), p.3. Online. Available: www.gao.gov/new.items/d0647.pdf. Accessed: October 27, 2006.
  53. Telephone interview by Angela Pack Zia with Gary Newton, Attorney, Texas Disposal Systems, Creedmoor, Texas, January 15,2007.
  54. Ibid.
  55. Robin Ingenthron, “Setting a Higher Standard: Establishing and Adhering to Best Practices Could Help Solve Export-Related Electronic Scrap Problems-Electronics Exporting,” Recycling Today, (Jun, 2002). Online. Available: findarticles.com/p/articles/mi_m0KWH/is_6_40/ai_87857754. Accessed: January 17, 2007.
  56. GAO, Electronic Waste: Strengthening the Role, pp. 4-5.
  57. Dina Cappiello, “Town Turns Trash into Cash,” Houston Chronicle, (August 11, 2003). Online. Available: www.chron.com/disp/story.mpl/special/03/recycle/2041121.html. Accessed: January 18, 2007.
  58. GAO, Electronic Waste: Strengthening the Role, pp.15-16.
  59. Ibid.
  60. EPA, RCRA Statutory Overview, pp.15-16.
  61. England Department of Trade and Industry, “WEEE Consultation, Part II: Draft Guidance to the Waste Electrical and Electronic Equipment Regulations,” (July 2006), pp.24-45.
  62. RoHS. Online: www.rohs.gov.uk. Accessed: November 11, 2006.
  63. U.S. Congress, House Committee on Energy and Commerce on Environment and Hazardous Materials, “Electronic Waste: An Examination of Current Activity, Implications for Environmental Stewardship, and the Proper Federal Role,” testimony by Renee St. Denis, Director, Americas Product Take Back, Hewlett-Packard Company, September 8, 2005. Online. Available: Lexis-Nexis Academic Universe, web.lexis-nexis.com/universe. Accessed: September 26, 2006.
  64. IAER, p. 6.
  65. Elizabeth Grossman, High Tech Trash, Digital Devices, Hidden Toxics, and Human Health,(Washington, D.C.: Island Press/Shearwater Books, 2006), pp.166-168.
  66. Watson interview.
  67. U.S. Congress, House Committee on Energy and Commerce on Environment and Hazardous Materials, “Electronic Waste: An Examination of Current Activity, Implications for Environmental Stewardship, and the Proper Federal Role,” testimony by Joel Denbo, Chair, Institute of Scrap Recycling Industries, Inc., September 8, 2005. Online. Available: Lexis-Nexis Academic Universe, web.lexis-nexis.com/universe. Accessed: September 26, 2006.
  68. RoHS
  69. IAER, p.31.
  70. Don Fullerton and Thomas C. Kinnaman, “Garbage, Recycling and Illicit Burning or Dumping,” Journal of Environmental Economics and Management, vol. 29, (1995), pp.78-89.
  71. U.S. Congress, House Committee on Energy and Commerce on Environment and Hazardous Materials, “Electronic Waste: An Examination of Current Activity, Implications for Environmental Stewardship, and the Proper Federal Role,” testimony by David A. Thompson, Director, Corporate Environmental Department, Panasonic Corporation of North America, September 8, 2005. Online. Available: Lexis-Nexis Academic Universe, web.lexis-nexis.com/universe. Accessed: September 26, 2006.
  72. Fullerton, “Garbage, Recycling ,” pp.78-89.
  73. Fullerton, “A Framework to Compare,” pp.224-247.
  74. Paul Calcott & Margaret Walls, “Waste, recycling, and ‘Design for Environment’: Roles for markets and policy instruments,” Resource and Energy Economics, vol.27, (2005), pp.287-305.
  75. U.S. Congress, House Committee on Energy and Commerce, “Electronic Waste,” testimony by Denis.
  76. Ibid.
  77. Don Fullerton and Wenbo Wu, “Policies for Green Design,” Journal of Environmental Economics and Management, vol.36, (1998), pp.131-146.
  78. Annika Gottberg, et.al., “Producer Responsibility, Waste Minimization and the WEEE Directive: Case Studies in Eco-design from the European Lighting Sector,” Science of the Total Environment, vol. 359 (2006), p.42.
  79. Ibid., pp. 43-49.
  80. Ibid.
  81. U.S. Congress, House Committee on Energy and Commerce on Environment and Hazardous Materials, “Electronic Waste: An Examination of Current Activity, Implications for Environmental Stewardship, and the Proper Federal Role,” testimony by Dave McCurdy, President and CEO, Electronic Industries Alliance, September 8, 2005. Online. Available: Lexis-Nexis Academic Universe, web.lexis-nexis.com/universe. Accessed: September 26, 2006.
  82. Watson interview.
  83. Gottberg, “Producer Responsibility,” pp. 43-49.
  84. U.S. Congress, Senate, Electronic Waste Recycling and Consumer Protection Act, Senate Bill 510, 109 Congress, 1 Session (2005).
  85. Master of Public Administration Program in Environmental Science and Policy, Columbia University, S510: Electronic Waste Recycling Promotion and Consumer Protection Act; Final Report, The Workshop in Applied Earth Systems Management II, (December 9, 2006), pp.18-20.
  86. Fullerton, “A Framework to Compare,” pp.224-247.
  87. RoHS.
  88. RoHS.
  89. Florida Center, Characterization of Lead Leachability, pp.3-4.
  90. SEMI®, Frequently Asked Questions (FAQ) about the European Union’s WEEE & RoHS Directives, (January 2006).
  91. Telephone interview by Angela Pack Zia with Robin Ingenthron, President, American Retroworks, Inc., Middlebury, Vermont, January 15, 2007..
  92. Telephone interview by Angela Pack Zia with John Crisley, Manager, Municipal Waste Reduction Program, Massachusetts Department of Environmental Protection, Boston, Massachusetts, January 3, 2007.
  93. Northbridge Environmental Management Consultants, Characteristics of Massachusetts’ CRT Recycling Program, Prepared for Electronic Industries Alliance (Westford, Massachusetts, October 21, 2002), pp.2-1,2-2. Online. Available: mass.gov/dep/recycle/priorities/macrteia.doc. Accessed: March 22, 2007.
  94. U.S. Environmental Protection Agency, Resource Conservation Challenge (RCC).
  95. Northbridge, Characteristics of Massachusetts’ CRT Recycling Program, p. 2-2.
  96. Ibid.
  97. Northbridge, Characteristics of Massachusetts’ CRT Recycling Program, pp. 2-2,3.
  98. Crisley interview.
  99. Email from John Crisley, Manager, Municipal Waste Reduction Program, Massachusetts Department of Environmental Protection, “REPLY: Research Questions,” to Angela Pack Zia, March, 26, 2007.
  100. Email from John Crisley.
  101. Northbridge, Characteristics of Massachusetts’ CRT Recycling Program; Massachusetts Department of Environmental Protection, “Electronics Re-Use and Recycling Infrastructure Development in Massachusetts,” under the United States Environmental Protection Agency’s Municipal and Industrial Solid Waste Division for the Jobs Through Recycling Program, September 2000.
  102. Northbridge, Characteristics of Massachusetts’ CRT Recycling Program, p. ES-2.
  103. Ibid.
  104. Ibid., p. 3-18.
  105. Ibid., p. ES-1.
  106. Ibid., p. 3-5.
  107. Ibid., 3-3,4.
  108. Fullerton, “A Framework to Compare,” pp.224-247.
  109. U.S. Environmental Protection Agency, Plug-In to Ecycling. Online. Available: www.epa.gov/epaoswer/osw/conserve/plugin/. Accessed: January 23, 2006.
  110. Northbridge, Characteristics of Massachusetts’ CRT Recycling Program, p. ES-2

Notes

  1. Texas Commission on Environmental Quality. Online. Available: www.tceq.state.tx.us. Accessed: October 21, 2006.
  2. U.S. Department of Commerce, Bureau of the Census, State and County Quickfacts. Online. Available: quickfacts.census.gov/qfd/states/48000.html. Accessed March 19, 2007.
  3. U.S. Department of Commerce, Bureau of the Census, Metropolitan and Micropolitan Statistical Area. Online. Available: www.census.gov/population/www/estimates/metroarea.html. Accessed: January 3, 2007.
  4. Census Bureau, State and County Quickfacts.
  5. Texas Commission on Environmental Quality, Small Business Local Government Assistance, McCoy RCRA review, vol. 5, (August 8, 2006), pp.1-3 (newsletter).
  6. Ibid.
  7. Massachusetts Department of Environmental Protection, 310 CMR 19.017: Waste Disposal Ban Regulation. Online. Available: www.mass.gov/dep/recycle/laws/bansreg.htm. Accessed: December 19, 2006.
  8. Telephone interview by Angela Pack Zia with John Crisley, Manager, Municipal Waste Reduction Program, Massachusetts Department of Environmental Protection, Boston, Massachusetts, January 3, 2007.
  9. Scandinavica.com. Online. Available: www.scandinavica.com/culture/nature/recycle.htm. Accessed: December 3, 2006.
  10. U.S. Environmental Protection Agency, RCRA Statutory Overview, prepared by Booz Allen & Hamilton Incorporated, (EPA530-R-99-063, PB2000-101 903), pp.15-16. Online. Available: www.epa.gov/epaoswer/hotline/training/statov.txt. Accessed: March 14, 2007.
  11. U.S. Government Accountability Office, Electronic Waste: Strengthening the Role of the Federal Government, GAO-06-47, (November 2005), pp. 3-33. Online. Available: www.gao.gov/new.items/d0647.pdf. Accessed: October 27, 2006.
  12. International Association of Electronics Recyclers, IAER Electronics Recycling Industry Report 2006, p. 18-19.
  13. Jean-Daniel M. Saphores, et. al., “Household Willingness to Recycle Electronic Waste; An Application to California,” Environment and Behavior, vol.38, no.2, (March, 2006), pp.183-205.
  14. Interview with Mike Watson, Senior Compliance Manager, Global Asset Recovery Services, Dell, Austin, Texas, February 16, 2007.
  15. Telephone interview by Angela Pack Zia with Robin Ingenthron, President, American Retroworks, Incorporated, Middlebury, Vermont, January 15, 2007.
  16. World Reuse, Repair, Recycling Association (WR3A), “The CRT Glass Recycling Test.” Online. Available: www.wr3a.org/docs/CRTGlassTest_final.PDF. Accessed: January 3, 2007.
  17. Ibid.
  18. Email from Robin Ingenthron, President, American Retroworks, Incorporated, “Re: Contact Us - from WR3A.org” to Angela Pack Zia, January 11,2007.
  19. Watson interview.
  20. This issue was raised by almost all recyclers who were interviewed.
  21. Census Bureau, State and County Quickfacts.
  22. Massachusetts Department of Environmental Protection, “Electronics Re-Use and Recycling Infrastructure Development in Massachusetts,” under the United States Environmental Protection Agency’s Municipal and Industrial Solid Waste Division for the Jobs Through Recycling Program, September 2000, pp.7-8.
  23. City of Boston, Public Works, Recycling: Frequently Asked Questions. Online. Available: www.cityofboston.gov/publicworks/recycling/recfaq.asp. Accessed: March 5, 2007.
  24. Tracy Swift, “Trust, Reputation and Corporate Accountability to Stakeholders,” Business Ethics, A European Review, vol. 10, no.1 (January 2001), p. 18.
  25. Email from collection facility manager, “Re: E-waste Survey Follow-up Question” to Angela Pack Zia, April 3, 2007. Email sent in confidentiality, and the name of sender is withheld by mutual agreement.
  26. Swift, “Trust, reputation and corporate accountability;” David Wheeler and John Elkington,“The End of Corporate Environment Report? Or the Advent of Cybernetic Sustainability Reporting and Communication,” Business Strategy and the Environment, vol.10 (2001), pp.1-14.
  27. EPA, Design for the Environment.
  28. Florida Center for Solid and Hazardous Waste Management, Characterization of Lead Leachability From Cathode Ray Tubes Using The Toxicity Characteristic Leaching Procedure, by Timothy G. Townsend, Stephen Musson, Yong-Chul Jang, Il-Hyan Chung, State University System of Florida, Report 99-5 (Gainesville, Florida, December, 1999), pp.1-16.
  29. U.S. Geological Survey, Obsolete Computers, “Gold Mine,” or High-Tech Trash? Resource Recovery from Recycling, USGS Fact Sheet FS-060-01, (Juy 2001). Online. Available: pubs.usgs.gov/fs/fs060-01/fs060-01.pdf. Accessed: March 31, 2007.
  30. Florida Center, Characterization of Lead Leachability, pp.1-16.
  31. Don Fullerton, “A Framework to Compare Environmental Policies,” Southern Economic Journal, vol.68, no.2, (2001), pp.224-247.
  32. Ingenthron interview.
  33. Email from collection facility manager, “CRT Landfill Info” to Angela Pack Zia, February 16, 2007. Email sent in confidentiality, and the name of sender is withheld by mutual agreement.
  34. Ingenthron interview.
  35. Watson interview.

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