Exporting a problem: is the U.S. exporting an environmental problem when it ships electronics scrap overseas? (Electronics Recycling).

For many environmental advocates, the recycling "triad" has included reduce, reuse and recycle, in that order, as the hierarchy of waste management options. When considering electronics, environmentalists are particularly concerned with avoiding disposal of these items, as they contain potential hazards.

Monitors and televisions contain cathode ray tubes (CRTs), which can contain up to six pounds of lead per unit -- the largest source of lead in municipal solid waste. The largest source of cadmium is found in rechargeable nickel-cadmium (NiCd) batteries, which are commonly found in laptop computers. Electronic waste is also a leading source of mercury in municipal waste.

Many of the plastics used to manufacture electronics contain brominated flame retardants. In addition, cabling and older casings contain polyvinyl chloride (PVC). All of these substances can be dangerous to human health if not handled appropriately. Clearly, we need to be careful in terms of disposal, but it is less clear whether these items should be reused or recycled -- and whether these activities should take place domestically or in other countries.

Reducing and Reusing

Reducing consumption is one solid waste management option, as it prevents disposal of materials, and conserves resources. Increasingly, however, more Americans own more computers, televisions and other home electronics.

Computers, in particular, are becoming obsolete more quickly than ever (the typical computer now has a life span of two to three years, down from five years in 1997). The U.S. Environmental Protection Agency (EPA) estimates in its June 2001 report, Electronics: A New Opportunity for Waste Prevention, Reuse, and Recycling, that 20 million computers became obsolete in 1998, while only 13 percent were reused or recycled.

The National Safety Council, Itasca, Ill., estimates that by 2005 as many as 60 million personal computers will become obsolete every year. Based on these statistics, it appears that we are not doing so well, collectively, in the "reduce" area when it comes to electronics. Perhaps this is not a realistic option.

In recent years, non-profits have become the "dumping grounds" for outdated electronics, according to one recycler, so they had to raise their standards. Most now will accept nothing less than a working Pentium 166, and many will not accept materials from the general public. The non-profits simply cannot absorb the computers that we try to donate for reuse. Some in the industry are also concerned that when businesses donate their computers to charity, they are removing them from a RCRA-covered waste stream (e.g., a business), to one that is not covered under RCRA regulations, and may therefore potentially be landfilled. Another concern is that non-profits and schools, often the recipients of donated computers, don't have the financial resources to properly dispose of these materials at the end of their lives.

In Eastern Europe, however, there is a huge demand for computers that are "outdated" by American standards. Similarly, Mexico is a vast market for old televisions, even black-and-white models. This is good news, right?

Some would say this is a step in the right direction. Others, however, would say shame on us, and suggest that we keep our electronic waste in our own country, and many are unsure what disposal alternative is the most beneficial and/or least detrimental.

One state DEP representative asserts that there is no way the U.S. market could absorb all of the electronics that are "recycled" each year. Furthermore, he asserts that many municipalities may be hiring recyclers that claim to keep the product and its components in the U.S., but that two links down the electronics food chain, at least some components are being shipped overseas. It is simply unrealistic, he says, for us to think that we can reuse and recycle all of our discarded electronics here, with our standards for electronics, as well as our cost of labor, being so high.

Another state Department of Environmental Protection (DEP) representative agrees, stating that, even if the computer and its components are processed in the U.S., materials will go overseas.

Bob Tonetti, senior environmental scientist at the U.S. EPA, states that the EPA supports reuse, for the aforementioned reasons, and because it offers great benefits in terms of computer literacy to those in developing nations. He states that the market for reusing electronics is limited here in America, not just because of our degree of electronic sophistication, but because of our mindset -- we, as a nation, do not like "used stuff." Furthermore, he states that "without foreign reuse and recycling efforts, we would have to shut down much of our collection efforts in the U.S."

Lauren Roman, vice president of electronics recycling firm United Recycling Industries, West Chicago, Ill., is in favor of exporting functioning computers for reuse.

David Wood, program director for Grass Roots Recycling Network (GRRN) of Athens, Ga., has mixed feelings about exporting computers for reuse. He acknowledges that resale of functioning computers helps fund the computer recycling industry, however, GRRN is against the export of electronic scrap. They are among those contending that it is irresponsible to send our electronics to developing nations, and that in doing so we are just exporting our hazardous waste, which will some day be improperly disposed in these developing nations -- possibly jeopardizing the health and safety of their citizens.

RECYCLING

If an item cannot be reused, then of course the last alternative to disposal is recycling. Most recyclers in the U.S. test for working components before they completely dismantle the items. What can be used is sold to re-manufacturers, and what cannot be reused is processed -- usually shredded or potentially dismantled by hand, to retrieve base metals (such as steel, aluminum and copper) and precious metals such as gold, silver and palladium.

Some recyclers ship components overseas for dismantling by hand, as labor is much less expensive in China, and hand dismantling results in less waste than shredding. Some large companies, however, have multi-million dollar shredders and can process the materials domestically. Canada also is a large export market for circuit boards, as many smelters are located there.

One Midwestern recycler says that he does not depend upon foreign markets for the dismantling and recycling of electronics. His employees dismantle by hand, although the circuit boards might be sent to smelters who have shredders, because the company charges a per-pound fee to recycle electronics, the dismantling is a financially viable business. When it comes to reuse, because of technological advances, the bar keeps being raised, and, although he still sees a strong demand for Pentium 133s, anything less is likely being purchased by dealers who send the computers to third-world nations. Many municipalities implementing electronics reuse and recycling programs refuse to hire recyclers who ship electronics or electronics parts overseas. They are concerned that environmental regulations are less stringent than they are in the U.S., and that hazardous materials in the electronics will be landfilled or incinerated. When buried, these materials can leach into the soil, infiltrating water systems. When burned, they are released into the air as toxins.

The main issue, according to Roman, is the export of scrap to poor countries. China may be tightening its rules on importing electronics scrap, but other poor countries will be willing to accept these materials. Pakistan, for example, is an increasing market for electronic scrap. Ironically, many municipalities and non-profits are pressured to accept low bids for recycling programs, which may not always result in the most responsible disposition of materials.

What if they are reused for a few years -- what is the fate of the item beyond that "second life?" Do we have to temper the positive feelings from donating computers with worry that the computer will some day be improperly disposed? Are we responsible for the entire life of the product, from store to grave, or just for the useful life that we use? The EPA's position is that, if at any point in the processing of these materials hazardous waste is generated, then the processor is responsible for the safe disposition of these elements.

Under RCRA, businesses and institutions that do not have their CRTs reused or recycled at the end of their useful life, but instead send them to a landfill or incinerator, are required to handle the material as a hazardous waste.

A new EPA rule, which will clarify RCRA, is expected to be proposed this spring. The new rule will likely ease restrictions that have caused many municipalities and recyclers to shy away from recycling CRTs. The rule excludes intact CRTs from being covered under RCRA as a hazardous waste -- stating that usable CRTs are products, not a waste, until they are disposed of or reach the final stage at the final recycler. Furthermore, it clarifies that commercial generators who send their used CRTs to disposal, rather than recycling, will be subjected to full hazardous waste requirements, which increases their disposal cost as well as their liability.

IS CHANGE IMMINENT?

The challenge of developing a successful framework for electronics reuse, recycling and disposal is a task that should involve all nations. Reusing and recycling electronics are activities that perhaps cannot be realistically contained within our borders, yet we cannot mandate what other nations do with their solid waste. Other nations are taking a look at how to handle electronics in their recycling and waste streams, and manufacturers are also involved.

The Organization for Economic Cooperation and Development (OECD), a group of 30 member nations including Canada, Mexico, the U.S., many Western European nations, Japan and others, began examining this issue about two years ago. The OECD Working Group on Waste Prevention and Recycling is developing a program to give greater assurance of proper management of recyclables being exported. The delegates are taking a close look at the proper management of electronics recycling. The group will most likely devise guidelines for members that will rely on third party auditing to ensure that hazardous materials retrieved from recyclables are handled in an appropriate, safe manner. The OECD's program will educate nations on the issue, providing member nations with the opportunity to use tools and guidelines being developed.

The Basel Action Network is also working toward developing guidelines to stop the export of hazardous wastes. Other groups actively participating in efforts include the Silicon Valley Toxics Coalition and the GRRN. The GRRN is advocating a framework for producer takeback programs, where manufacturers would be responsible for taking back electronics at the end of their useful life.

The U.S. EPA admits that the OECD program will take some time to implement, so in the interim they are considering making information available to municipalities on a Web site. Information could include lists of foreign recyclers who are sanctioned by their nation, which would help municipalities and recyclers make decisions about their programs by ensuring that the recipient of their electronics and electronics components is legitimate and properly authorized by the country.

A photo of a CRT washed up on an otherwise beautiful South Pacific beach, brand name clearly marked, could be a public relations fiasco for a CRT manufacturer. The threat of just such a thing, as well as perhaps manufacturers' genuine concern for the environment, and possible legislation--such as the European Union's pending Waste Electrical and Electronic Equipment (WEEE) Directive -- keeps many original equipment manufacturers (OEMs) in the recycling loop. The WEEE Directive states that manufacturers will have the responsibility for recycling their products when they are discarded.

In the U.S., some manufacturers and retailers have helped states and municipalities sponsor electronics recycling programs. Manufacturers are also being encouraged, through the European Union's Restriction of Hazardous Substances (RoHS) Directive, to design electronics with fewer hazardous elements.

In the U.S., some states have enacted legislation to place restrictions on the disposal of products containing hazardous material, which may also encourage manufacturers to reduce the use of certain materials.

Susan Bush is an analyst with R. W. Beck in Rhode Island. She can be reached at [e-mail] or at [phone].