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Managing electronic waste: the California approach.


Recently there has been discussion among environmental health practitioners regarding the mounting volume of electronic waste (e-waste) entering the solid waste stream and the potential impacts on human health and the environment. Consisting of unwanted computers, monitors, televisions, and a variety of other devices, electronic waste frequently contains many toxic chemicals that when inappropriately managed may cause detrimental environmental exposure. For example, the cathode ray tube (CRT) of television sets and computer monitors contains lead. The lead levels in many CRTs exceed federal (and California) standards for hazardous waste. In a 1999 study conducted at the State University of Florida, researchers determined that color CRTs, when subjected to regulatory tests for hazardous waste, leached out 18.5 milligrams of lead per liter (Musson, Jang, Townsend & Chung, 1999), exceeding the 5 milligrams regulatory threshold for hazardous waste.

The primary concern is that if CRTs are exposed to conditions in local landfills, lead contamination of soil and groundwater may occur. Through emergency regulations finalized in February 2003, the California Environmental Protection Agency Department of Toxic Substances Control (DTSC) placed into regulatory guidance a complete ban on municipal landfill disposal of CRTs. This ban includes agents normally excluded from regulation, such as households and exempt generators. It was determined that e-waste more appropriately belonged in a world of reduced management standards addressed by the concept of "universal waste."

The Universal Waste Paradigm

Certain large-volume waste streams that technically meet the definition of hazardous waste have traditionally been disposed of in municipal landfills. These disposal sites are not designed to accept and store hazardous waste. In order to control the disposal of these wastes, on February 11, 1993, the U.S. Environmental Protection Agency (U.S. EPA) proposed new streamlined hazardous waste management regulations governing these materials (Standards for Universal Waste Management, 1995), which are known as universal waste. U.S. EPA believed that Resource Conservation and Recovery Act (RCRA) regulations for hazardous waste management would impede collection and recycling campaigns.

The Universal Waste Rule was intended to accomplish two main goals: first, to encourage recycling and discourage disposal of widely generated hazardous wastes, and second, to provide incentives for the collection of the unregulated portions of these waste streams and manage those unregulated positions using the same systems developed for the regulated portion, thereby removing these unregulated portions from municipal waste sites (Standards for Universal Waste Management, 1995).

In March 2000, the state of California adopted an Emergency Universal Waste Rule (Cal-UWR) (California Environmental Protection Agency Department of Toxic Substances Control, 2003). Prior to adoption of the Cal-UWR, wastes not included in the federal UWR had to be managed as fully hazardous waste. Hazardous waste designation forces the generator (unless exempt) to file for a U.S. EPA identification number, limits storage time, necessitates usage of a registered transporter, and restricts disposal to a permitted hazardous waste facility. These stringent rules can be burdensome and place a heavy financial load on generators of the waste.

In addition, these restrictive standards frequently do not foster proper, environmentally sound disposal practices among members of the general public. When faced with strict management controls on common items, people may resort to mismanagement through disposal in municipal-waste landfills or, worse, dumping of wastes by the side of the road. This practice may pose a threat to human health and the environment. With this concern in mind, the California Environmental Protection Agency Department of Toxic Substances Control promulgated UWR to control the disposal of CRTs in a less severe fashion.

Do CRTs Meet the Criteria for Universal-Waste Classification?

There are essentially two criteria for a waste stream to fit into the UW category. First, the waste stream must be large in volume and ubiquitous in dispersal. Second, the wastes need to contain chemicals that would typically place them in the hazardous waste classification, but in a form that when normally used presents little danger to human health or the environment.


Lead from electronic devices has been shown to be the second leading source of lead in municipal landfills, and the total national yearly tonnage has increased from just over 12,000 tons in 1970 to over 85,000 tons in the year 2000 (U.S. EPA, 1997), accounting for approximately 1 percent of the municipal solid waste stream (U.S. EPA, 2001a). The expectation is that these figures will increase as sales of personal computers increase (on average, 23 percent per year) (Boon, Isaacs, & Gupta, 2002) and as the computers then become obsolete. Finally, the annual national average total mass of lead used for CRTs has increased since 1972 from approximately 25,000 tons to 46,000 tons (Biviano, Sullivan, & Wagner, 1999).

Risk of Exposure

Although lead is known to cause human health problems, the likelihood of exposure is considered de minimus when the lead is contained in unbroken CRT glass, (U.S. EPA, 2001b). It can be assumed then that safe transport of computer monitors from a household to an appropriate recycling facility is possible.

Thus, it is clear that CRTs are a high-volume waste and are associated with a nominal risk of exposure when normally handled, making CRT placement in the universal-waste stream appropriate.


The state of California has been, historically, a leader in the early identification of environmental health issues. Electronic waste is no exception. As one of the first states to recognize the health concerns associated with the inappropriate disposal of this exceptionally large and growing waste stream, California has taken the initiative in promulgating regulations. In addition, California has recognized that overly restrictive laws might have negative environmental consequences and thus has placed this common waste in the more manageable category of universal waste, so that the appropriate path of recycling can be more fully achieved.


Biviano, M.B., Sullivan, D.E., & Wagner, L.A. (1999). Total materials consumption: An estimation methodology and example using lead-A materials flow analysis. U.S. Geological Survey Circular 1183, 1-26.

Boon, J.E., Isaacs, J.A. & Gupta, S.M. (2002). Economic sensitivity for end of life planning and processing of personal computers. Journal of Electronics Manufacturing, 11(1), 81-93.

California Environmental Protection Agency, Department of Toxic Substances Control. (2003). Universal waste rule: Final statement of reasons (Report No. R-97-08). Sacramento, CA: Author.

Musson, S.E., Jang, Y.C., Townsend, T.G. & Chung, I.H. (2000). Characterization of lead leachability from cathode ray tubes using the toxicity characteristic leaching procedure. Environmental Science & Technology, 34(20):4376-4381.

Standards for Universal Waste Management, 40 C.F.R. [section] 273 (1995).

U.S. Environmental Protection Agency, Office of Solid Waste. (1997). US/EPA Municipal Solid Waste Factbook 4.0. Washington, DC: Author.

U.S. Environmental Protection Agency, Office of Solid Waste and Emergency Response. (2001a). Electronics: A new opportunity for waste prevention, reuse, and recycling (EPA 530-F-01-006). Washington, DC: Author.

U.S. Environmental Protection Agency. (2001b). Life-cycle assessment of desktop computer displays: Summary of results (EPA 744-R-01-005). Washington, DC: Author.

Steven Korenstein, M.S., R.E.A., C.H.M.W.M.

Corresponding Author: Steven Korenstein, Hazardous Substances Scientist, Department of Toxic Substances Control, California Environmental Protection Agency, 18501 Brymer St., Northridge, CA 91326. E-mail:
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Article Details
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Title Annotation:Guest Commentary
Author:Korenstein, Steven
Publication:Journal of Environmental Health
Geographic Code:1U9CA
Date:Jan 1, 2005
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