[House Hearing, 110 Congress]
[From the U.S. Government Publishing Office]
ELECTRONIC WASTE: CAN THE NATION
MANAGE MODERN REFUSE IN THE
DIGITAL AGE?
=======================================================================
HEARING
BEFORE THE
COMMITTEE ON SCIENCE AND TECHNOLOGY
HOUSE OF REPRESENTATIVES
ONE HUNDRED TENTH CONGRESS
SECOND SESSION
__________
APRIL 30, 2008
__________
Serial No. 110-98
__________
Printed for the use of the Committee on Science and Technology
Available via the World Wide Web: http://www.science.house.gov
---------
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COMMITTEE ON SCIENCE AND TECHNOLOGY
HON. BART GORDON, Tennessee, Chairman
JERRY F. COSTELLO, Illinois RALPH M. HALL, Texas
EDDIE BERNICE JOHNSON, Texas F. JAMES SENSENBRENNER JR.,
LYNN C. WOOLSEY, California Wisconsin
MARK UDALL, Colorado LAMAR S. SMITH, Texas
DAVID WU, Oregon DANA ROHRABACHER, California
BRIAN BAIRD, Washington ROSCOE G. BARTLETT, Maryland
BRAD MILLER, North Carolina VERNON J. EHLERS, Michigan
DANIEL LIPINSKI, Illinois FRANK D. LUCAS, Oklahoma
NICK LAMPSON, Texas JUDY BIGGERT, Illinois
GABRIELLE GIFFORDS, Arizona W. TODD AKIN, Missouri
JERRY MCNERNEY, California TOM FEENEY, Florida
LAURA RICHARDSON, California RANDY NEUGEBAUER, Texas
PAUL KANJORSKI, Pennsylvania BOB INGLIS, South Carolina
DARLENE HOOLEY, Oregon DAVID G. REICHERT, Washington
STEVEN R. ROTHMAN, New Jersey MICHAEL T. MCCAUL, Texas
JIM MATHESON, Utah MARIO DIAZ-BALART, Florida
MIKE ROSS, Arkansas PHIL GINGREY, Georgia
BEN CHANDLER, Kentucky BRIAN P. BILBRAY, California
RUSS CARNAHAN, Missouri ADRIAN SMITH, Nebraska
CHARLIE MELANCON, Louisiana PAUL C. BROUN, Georgia
BARON P. HILL, Indiana VACANCY
HARRY E. MITCHELL, Arizona
CHARLES A. WILSON, Ohio
C O N T E N T S
April 30, 2008
Page
Witness List..................................................... 2
Hearing Charter.................................................. 3
Opening Statements
Statement by Representative Bart Gordon, Chairman, Committee on
Science and Technology, U.S. House of Representatives.......... 6
Written Statement............................................ 7
Statement by Representative Ralph M. Hall, Minority Ranking
Member, Committee on Science and Technology, U.S. House of
Representatives................................................ 8
Written Statement............................................ 8
Prepared Statement by Representative Eddie Bernice Johnson,
Member, Committee on Science and Technology, U.S. House of
Representatives................................................ 9
Prepared Statement by Representative Russ Carnahan, Member,
Committee on Science and Technology, U.S. House of
Representatives................................................ 9
Prepared Statement by Representative Harry E. Mitchell, Member,
Committee on Science and Technology, U.S. House of
Representatives................................................ 10
Prepared Statement by the Hon. Mike Thompson (D-CA), Chairman, E-
Waste Caucus................................................... 58
Witnesses:
Mr. Eric D. Williams, Assistant Professor, Department of Civil
and Environmental Engineering and School of Sustainability,
Arizona State University
Oral Statement............................................... 10
Written Statement............................................ 12
Biography.................................................... 17
Mr. Gerardo N. Castro, Director of Environmental Services and
Contracts, Goodwill Industries of Southern California
Oral Statement............................................... 18
Written Statement............................................ 20
Biography.................................................... 22
Ms. Renee St. Denis, Director of Americas Product Take-Back and
Recycling, Hewlett-Packard Company
Oral Statement............................................... 22
Written Statement............................................ 23
Biography.................................................... 28
Mr. Eric Harris, Associate Counsel/Director of Government and
International Affairs, Institute of Scrap Recycling Industries
Oral Statement............................................... 29
Written Statement............................................ 31
Biography.................................................... 35
Mr. Ted Smith, Chair, Electronics TakeBack Coalition
Oral Statement............................................... 35
Written Statement............................................ 38
Biography.................................................... 50
Mr. Michael T. Williams, Executive Vice President and General
Counsel, Sony Electronics Inc.
Oral Statement............................................... 50
Written Statement............................................ 51
Biography.................................................... 54
Discussion....................................................... 54
Appendix 1: Answers to Post-Hearing Questions
Mr. Eric D. Williams, Assistant Professor, Department of Civil
and Environmental Engineering and School of Sustainability,
Arizona State University....................................... 62
Mr. Gerardo N. Castro, Director of Environmental Services and
Contracts, Goodwill Industries of Southern California.......... 69
Ms. Renee St. Denis, Director of Americas Product Take-Back and
Recycling, Hewlett-Packard Company............................. 72
Mr. Eric Harris, Associate Counsel/Director of Government and
International Affairs, Institute of Scrap Recycling Industries. 79
Mr. Ted Smith, Chair, Electronics TakeBack Coalition............. 85
Mr. Michael T. Williams, Executive Vice President and General
Counsel, Sony Electronics Inc.................................. 97
Appendix 2: Additional Material for the Record
Statement of Parker E. Brugge, Vice President, Environmental
Affairs and Corporate Sustainability, The Consumer Electronics
Association.................................................... 104
Statement of Meggan L. Ehret, Senior Counsel and Secretary,
Thomson Inc.................................................... 107
Statement of the Office of Solid Waste and Emergency Response,
U.S. Environmental Protection Agency........................... 109
Follow-up Questions for Written Submission by the Environmental
Protection Agency (EPA)........................................ 115
ELECTRONIC WASTE: CAN THE NATION MANAGE MODERN REFUSE IN THE DIGITAL
AGE?
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WEDNESDAY, APRIL 30, 2008
House of Representatives,
Committee on Science and Technology,
Washington, DC.
The Committee met, pursuant to call, at 10:00 a.m., in Room
2318 of the Rayburn House Office Building, Hon. Bart Gordon
[Chairman of the Committee] presiding.
[GRAPHIC(S) NOT AVAILABLE IN TIFF FORMAT]
hearing charter
COMMITTEE ON SCIENCE AND TECHNOLOGY
U.S. HOUSE OF REPRESENTATIVES
Electronic Waste: Can the Nation
Manage Modern Refuse in the
Digital Age?
wednesday, april 30, 2008
10:00 a.m.-12:00 p.m.
2318 rayburn house office building
Purpose
On April 30, 2008 the Committee on Science and Technology will hold
a hearing on the management of waste electronic equipment (e-waste) in
the United States. Witnesses will discuss industry practices for
recycling, refurbishment, re-sale and disposal of electronic products
and the challenges associated with end-of-life management of electronic
products.
The hearing will also examine the potential of research and
development in green design efforts to make recycling easier and
decrease the amount of toxic material used in electronic products, as
well as in creating frameworks for understanding the economic and
environmental impacts of reuse and recycling.
The Committee will hear testimony from six witnesses offering
perspectives from the electronics manufacturing sector, the recycling
industry, a non-profit service provider and academic research and
development.
Witnesses
Mr. Gerardo Castro is the Director of Contracts and
Environmental Services, Goodwill Industries of Southern
California, Los Angeles, California. Mr. Castro will discuss
the scope and magnitude of e-waste in this country, as well as
the volume of electronic products received by Goodwill
Industries annually and their product recycling, refurbishing,
and re-sale operations.
Ms. Renee St. Denis is the Director of America's
Product Take-Back and Recycling for Hewlett-Packard Company.
Ms. St. Denis will discuss the origin and history of HP's take-
back and recycling program and how it has influenced product
design. She will also discuss, from HP's perspective, the types
of innovations that are needed to promote electronic product
recyclability and the increased use of recycled materials.
Mr. Eric Harris is the Associate Counsel and Director
of Government and International Affairs for the Institute of
Scrap Recycling Industries (ISRI). Mr. Harris directs ISRI's
waste policy operations and will discuss the challenges faced
by e-waste recyclers as well as recycling best-practices. He
will also discuss the amount of e-waste that is recycled in the
U.S. versus the amount that is exported.
Mr. Ted Smith is the Chair of the Electronics Take-
Back Coalition. Mr. Smith will discuss the evolution of the e-
waste problem, the advantages and disadvantages to product
reuse, and the type of research and development initiative
needed to foster more environmentally-friendly electronic
products.
Mr. Michael Williams is the Executive Vice President
and General Counsel for Sony Electronics Incorporated. Mr.
Williams will discuss Sony's approach to the electronic waste
issue and whether their efforts in end-of-life management have
influenced product design. Mr. Williams will also discuss, from
Sony's perspective, the types of innovation needed to promote
electronic product recyclability and increased use of recycled
materials.
Dr. Eric Williams is an Assistant Professor of Civil
and Environmental Engineering at Arizona State University. His
research focus is industrial ecology, life cycle assessment,
and macro assessment of supply and demand. Dr. Williams will
discuss the environmental impacts associated with the
manufacturing of electronic products, the challenge in tracking
the reuse and recycling industry, and options for reducing the
environmental impacts of this industry.
Background
Electronic waste (e-waste) is the term used to describe electronic
products at the end of their useful lives. This includes: computers,
televisions, VCRs, stereos, printers, cell phones, fax machines,
copiers, and other commonly used electronic products. The use and
production of these products is integral to the digital age and our
economy. However, due to product failure or the desire to purchase more
advanced technology, the number of discarded electronic products is
rapidly increasing. Indeed the lifespan of some of this equipment is as
short as 18 to 24 months. The National Safety Council\1\ estimated that
over 499 million personal computers became obsolete between 1997 and
2004 and the Government Accountability Office estimates that 100
million televisions, computers, and monitors become obsolete each
year.\2\ With the fast rate of technology improvement and the rate that
many industrializing countries will soon also be discarding large
numbers of used electronics, the volume of e-waste globally stands to
grow substantially.
---------------------------------------------------------------------------
\1\ National Safety Council, Electronic Product Recovery and
Recycling Baseline Report: Recycling of Selected Electronic Products in
the United States, Stanford Resources, Inc. (1999).
\2\ Government Accountability Office, Electronic Waste:
Strengthening the Role of the Federal Government in Encouraging
Recycling and Reuse, November (2005).
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There currently is no specific federal law or regulation governing
the disposal of consumer electronic products in the United States. In
2000, the National Electronic Products Stewardship Initiative (NEPSI)
brought stakeholders together in an effort to create a consensus on the
shape of a national e-waste management framework. This process stalled
in 2004 when stakeholders could not agree on a financing mechanism for
a product take-back system. Due to the presence of toxic materials like
lead and mercury, several states now mandate end-of-life electronic
product management. The patchwork of State laws has many in industry
now turning to the Federal Government for a national framework that
will harmonize the different State laws.
Thirteen states have e-waste laws. California implemented a program
in 2005. Maine, Washington and Minnesota implemented e-waste programs
in 2007, and other states with legislatively mandated programs will
bring those programs online in the near future. Many electronics
producers and retailers now offer some type of product take-back
service. Despite this progress, the EPA estimates that at most only 15
percent of products at the end of their useful lives reach a recycling
or reuse program. Cell phone producers, who have one of the most
established take-back programs and whose product is easy for the
consumer to return, only recapture a fraction of the phones they sell.
According to the EPA, about two million tons of unwanted electronics
end up in landfills or incinerators on average, while only 345,000 tons
were ``recycled.'' \3\ Many producers, recyclers, and experts site
consumer behavior and the logistics of gathering large volumes of waste
as a major hurdle to cost-effective recycling.
---------------------------------------------------------------------------
\3\ Environmental Protection Agency, Management of Electronic
Wastes in the United States, November 2007. http://www.epa.gov/
ecycling/
Waste Management Issues
When properly handled, used electronic products can be a valuable
source for reusable equipment or secondary feedstock. However, when not
properly handled, studies show that the components of these items can
be sources of toxins and carcinogens. Cathode ray tubes (CRTs), the
glass picture tubes found in some televisions and computer monitors,
contain approximately five to eight pounds of lead, chromium, nickel,
and zinc. Circuit boards also contain considerable quantities of lead-
tin solders and are likely to leach into groundwater or be emitted in
gaseous form if destroyed in an incinerator. Up to thirty-eight
separate chemical elements are incorporated into electronic waste
items.
In addition to concerns about pollution and volume regarding
disposal of these products in landfills, electronic equipment also
contains valuable resources. The U.S. Geological Survey estimates that
scrap electronics contain significantly higher concentrations of
copper, gold, and other metals than an equivalent weight of a typical
ore. The recovery of the metals in e-waste decreases the need for
virgin materials and lessens the impact on the environment that
extraction of those materials represents.
It is also important to consider that even with an increased
content of recovered materials, the production of electronic products
carries a significant environmental footprint. Rapidly changing
production methods and a scarcity of current data make accurately
assessing product life cycle difficult. Microchip fabrication, circuit
board and component manufacturing, and the production of plastics,
metals, glass, and the specialized chemicals used in the electronics
industry have high energy and water requirements and require the use of
chemicals that are harmful to human health and the environment. Many
producers have made strides in increasing the efficiency and lessening
the impact of manufacturing, but the entire life cycle of electronics
still has a significant environmental footprint.
Obsolete devices from industrialized countries can find their way
to developing countries, where old computers and cell phones are often
used for a few more years or processed for disposal. High disposal
costs and landfill fees in the developed world have conspired with low
labor costs and lenient health and environmental regulations in the
developing world to create an incentive to export used electronic
products to nations like China and Nigeria. Some of these products are
received for legitimate refurbishment and reuse, but an overwhelming
quantity has no reuse value and is improperly and unsafely recycled or
landfilled. Primitive recycling creates health hazards for the laborers
and environmental problems for their communities. According to the
Basel Action Network (BAN), approximately 80 percent of the e-waste
directed to recycling in the U.S. is not recycled, and instead finds
its way overseas. There is no universally accepted standard to qualify
a product for reuse.
Many recyclers are environmentally responsible and health and
safety conscious, but there are still numerous ``sham'' recycling
operations that engage in harmful practices, particularly with regards
to export. Stakeholders are working with the EPA to create a set of
best practices for environmental management in electronics recycling,
but there currently is no one universally accepted standard for
electronics recycling. Electronics ``recycling'' can also be a
misleading characterization of practices, since most of the material
recovered from the product, in particular the plastics and the glass,
is not reused directly in the electronics industry, and much is fated
for incineration (i.e., fuel for smelters and furnaces).
The U.S. is behind many other countries in confronting the e-waste
challenge. The European Union (EU) took action in 2000 by passing the
Waste Electrical and Electronic Equipment Directive (WEEE), which bans
the disposal of e-waste in landfills and requires electronics producers
to take back their used products. The WEEE Directive imposes the
responsibility for the disposal of e-waste on the manufacturers. Part
of the impetus for this policy was the theory that giving the producers
the responsibility of recycling their own products would encourage them
toward greener designs and products that are more easily recycled. It
is too soon to assess whether these disposal laws have motivated
producers to adopt greener designs. However, the EU Restriction of
Hazardous Substance (RoHS) Directive banning the import of electronics
with toxics like lead and cadmium has motivated the use of greener
materials in electronics sold around the world.
Recognizing the need to find better end-of-life management for
these products, the EPA and many producers, retailers, State and local
governments have been working to improve the awareness of the need for
recovery of electronics and access to safe reuse or recycling options.
This is a national problem and there is a need for standards and
safeguards for environmentally sound disposal practices that strike a
balance between manufacturer and consumer responsibility.
Chairman Gordon. This hearing will come to order. Good
morning and welcome to today's hearing entitled ``Electronic
Waste: Can the Nation Manage Modern Refuse in the Digital
Age?''
I would like to welcome our panelists, who will share with
us their views on the end-of-life management of the electronics
that we all use and enjoy every day.
Let me also point out that it appears we are going to have
a joint session later on, which is going to unfortunately make
us either have to finish up before or come back after, so we
hope--I want you all to know that this is the start of this
very important process and we will deal with it when the time
comes.
This nation started on the path that brings us here today
in the 1940s when we began producing and buying televisions. By
the 1960s, about 60 million American homes had TV sets. By last
year, we were over 250 million. In the 1980s we began to
acquire home computers and businesses, universities and schools
invested in personal computers. Between 1986 and 1990, around
28 million personal computers were sold in the United States
and by 2000 that number had more than doubled.
We all own and use these electronic products--TVs,
computers, cell phones, MP3 and DVD players, but we rarely stop
to think about what happens to all these products once we are
finished with them.
Today the amount we have to dispose of is in the billions.
We know that many of these products end up in our landfills or
are sitting in our attics and storage closets because we aren't
sure what to do with them. Innovation in the electronics
industry has produced staggering advances and I don't think
anybody would want to turn back the clock on this progress. But
if we could turn the clock back on something else, we would
want to ask the engineers who began using lead in televisions
to shield viewers from the X-rays and ask, ``How can we come up
with something better?''
Because now in 2008, with the transition to digital TV
signals fast approaching and better technology on the market,
we have millions of televisions and monitors with untold tons
of lead heading to the landfills. And these old products also
contain toxins like mercury and cadmium.
Fortunately, there is a growing awareness of recycling and
going green. As we will hear today, e-waste is not just trash.
These products contain precious materials like gold and copper,
and it doesn't make sense to put gold in a dump.
Over a dozen states now have legislation mandating proper
e-waste disposal and many electronic producers now offer take-
back services. However, it is estimated that only 10 to 15
percent of these products reach recyclers. Clearly, much needs
to be done to educate consumers about recycling and to make
sure everyone has access to recycling.
But raising awareness is not the only thing that can be
done to tackle our growing pile of e-waste. Today we will also
hear about opportunities to design products to avoid end-of-
life problems and to make product recycling more efficient and
economically attractive. We must seriously look at the issue of
reuse and help find ways to safeguard against its downstream
problems.
We must also develop methods to adequately access the
economic and environmental impacts of e-waste and policies to
manage it.
This is a problem of global proportions. Technology and
innovation have as much a role to play in solving it as they
did in creating it. We don't want to stifle the innovation that
has put the computing power of a room-sized mainframe into the
palm of our hand, but we want to go forward with enough
information and foresight to ensure that these modern marvels
are not modern environmental problems.
[The prepared statement of Chairman Gordon follows:]
Prepared Statement of Chairman Bart Gordon
Good morning and welcome to today's hearing on electronic equipment
waste (e-waste) in the United States.
I would like to welcome our panelists who will share with us their
views on the end-of-life management of the electronics that we all use
and enjoy everyday.
This nation started on the path that brings us here today in the
1940s when we began producing and buying televisions. By 1960, about 60
million American homes had TV sets. By last year, we were over 250
million.
In the 1980's we began to acquire home computers and businesses,
universities and schools invested in personal computers.
Between 1986 and 1990, around 28 million personal computers were
sold in the U.S. By 2000, that number had more than doubled.
We all own and use these electronic products--TVs, computers, cell
phones, MP3 and DVD players--but we rarely stop to think about what
happens to all these products once we are finished with them.
Today the amount we have to dispose of is in the billions. We know
that many of these products end up in our landfills or are sitting in
our attics and storage closets because we aren't exactly sure what to
do with them.
Innovation in the electronics industry has produced staggering
advances and I don't think anybody would want to turn the clock back on
that progress.
But if we could turn the clock back on something, we would want to
ask the engineers who began using lead in televisions to shield viewers
from x-rays and ask, ``Can we come up with something better here?''
Because now in 2008, with the transition to digital TV signals fast
approaching and better technology on the market, we have millions of
TVs and monitors with untold tons of lead, headed to landfills. And
these old products also contain other toxins like mercury and cadmium.
Fortunately, there is a growing awareness of recycling and going
green. As we will hear today, e-waste is not just trash.
These products contain precious metals like gold and copper, and it
doesn't make sense to put gold in a dump.
Over a dozen states now have legislation mandating proper e-waste
disposal and many electronics producers now offer take-back services.
However, it's estimated that only about 10 to 15 percent of these
products reach recyclers. Clearly much needs to be done to educate
consumers about recycling and make sure everybody has access to
recycling.
But raising awareness is not the only thing that can be done to
tackle our growing pile of e-waste.
Today we will also hear about opportunities to design products to
avoid end-of-life problems and make product recycling more efficient
and economically attractive.
We must seriously look at the issue of reuse and help find ways to
safeguard against its downstream problems.
We must also develop methods to adequately assess the economic and
environmental impacts of e-waste and policies to manage it.
This is a problem of global proportions. Technology and innovation
have as much a role to play in solving it as they did in its creation.
We don't want to stifle the innovation that has put the computing
power of a room-sized mainframe into the palm of our hand, but we want
to go forward with enough information and foresight to ensure that
these modern marvels are not a modern environmental problem.
Chairman Gordon. And now I would like to recognize Mr. Hall
for an opening statement.
Mr. Hall. Mr. Chairman, thank you, and you adequately
stated it. I will be more brief than you were. You have covered
the subject. You wonder where a lot of the e-waste is going to
wind up. You know, mine winds up just as far as I can throw it
every now and then, and my grandchildren get tired of me
telling them I can take a Big Chief tablet and cedar pencil and
figure out anything you all can if you give me enough time.
It is an unusual panel, Mr. Chairman, and I really expect
to get some good information from them, and I am pleased that
we are having the hearing. E-waste is the unintended
consequence of a high-tech industry that has grown
substantially since its beginning in the second half of the
20th century, and although consumer electronics comprise less
than two percent of the municipal solid waste, it is really one
of the fastest growing waste, I guess streams, if you want to
call it that, in the United States. According to the EPA, less
than 20 percent of the e-waste is now recycled. Advancement in
the consumer electronics field helped create this growing
amount of e-waste as electronics rapidly become obsolete.
There are a lot of aspects to the e-waste dilemma: the
definition of e-waste, the reuse and recycling of electronics,
landfill disposal and hazardous waste, regulatory issues and
export economies. The complexity absolutely creates a vast
array of opinions on possible solutions to the problem. Today's
panel is well suited to help us explore the options before us
from recycling of e-waste to better design that will minimize
the problem in the future.
The House has passed H.R. 2850, which is the Green
Chemistry Research and Development Act of 2008, authored by my
friend, Dr. Gingrey. I think this legislation was a step in the
right direction, and like I said on the House Floor at the time
of its passage, advances in the research and development of
green chemicals and products will reduce the creation of
substances that are harmful to our environment. This certainly
applies to the problems with e-waste.
I look forward to hearing from the panel today. I yield
back my time, Mr. Chairman.
[The prepared statement of Mr. Hall follows:]
Prepared Statement of Representative Ralph M. Hall
Thank you, Mr. Chairman. I am pleased we are having this hearing
today. Electronic waste, or e-waste, is the unintended consequence of a
high-tech industry that has grown substantially since its beginning in
the second half of the 20th century. Although consumer electronics
comprise less than two percent of municipal solid waste, it is one the
fastest growing waste streams in the United States. According to the
EPA, less than 20 percent of e-waste is now recycled. Advancements in
the consumer electronics field help create this growing amount of e-
waste as electronics rapidly become obsolete.
There are many aspects of the e-waste dilemma: the definition of e-
waste; reuse and recycling of electronics; landfill disposal and
hazardous waste; regulatory issues and export economies. This
complexity creates a vast array of opinions on possible solutions to
these problems. Today's panel is well suited to help us explore the
options before us, from recycling of e-waste to better design that will
minimize the problem in the future.
The House has passed H.R. 2850, the Green Chemistry Research and
Development Act of 2008, authored by my friend, Dr. Gingrey. I believe
that this legislation was a step in the right direction, and like I
said on the House Floor at the time of its passage, advances in the
research and development of green chemicals and products will reduce
the creation of substances that are harmful to our environment. This
certainly applies to the problems with e-waste.
I look forward to hearing from the panel today about this important
issue. I yield back the balance of my time.
Chairman Gordon. Thank you, Mr. Hall.
If there are Members who wish to submit additional opening
statements, your statements will be added to the record at this
point, and with unanimous consent, Mr. Hall, I will ask for
that at the end of this hearing too in case there are other
folks that would like to ask questions.
[The prepared statement of Ms. Johnson follows:]
Prepared Statement of Representative Eddie Bernice Johnson
Thank you. I am glad to see that this committee is addressing the
issue of electronic waste.
Electronic products at the end of their usability must either be
thrown away or recycled. Some electronics contain mercury, lead,
cadmium or other toxic materials.
Today's hearing will be valuable because we have a variety of
witness perspectives on this issue.
The Committee will hear testimony from witnesses offering
perspectives from the electronics manufacturing sector, the recycling
industry, non-profit service provider, and academic research and
development.
This is actually an international issue. High disposal costs and
landfill fees in the developed world have conspired with low labor
costs and lenient health and environmental regulations in the
developing world to create an incentive to export used electronic
products to nations like China and Nigeria.
Our nation needs a uniform standard for recycling and appropriate
disposal of electronic waste.
It is wrong to leave an environment of mercury, lead and cadmium
for our grandchildren to clean up.
According to the Basel Action Network (BAN), approximately 80
percent of the e-waste directed to recycling in the U.S. is not
recycled, and instead finds its way overseas.
There is no universally accepted standard to qualify a product for
reuse.
I see a role for the Federal Government to play.
I will be particularly interested to know of the electronics
industry's recommendations of how to develop an economical, uniform
policy that is not harmful for our environment.
Again, welcome to our witnesses. Mr. Chairman, I yield back the
remainder of my time.
[The prepared statement of Mr. Carnahan follows:]
Prepared Statement of Representative Russ Carnahan
Mr. Chairman, thank you for hosting this important hearing on
managing electronic waste in the United States.
The digital era provides us with useful technological advances, but
with it comes the alarming result that our nation has already disposed
of millions of electronic products and will continue to in the coming
years. These electronics contain lead, mercury, and other harmful
substances that, unless properly disposed of, can contaminate our
environment and present health dangers to our citizens. I believe it is
our responsibility to examine how we can best encourage the manufacture
of electronic products while keeping the total cost of their life
cycle, including the ultimate disposal, in mind. I look forward to
hearing more from our witnesses on that subject.
In my own office, last year we transitioned staff to TV cards on
our computers, enabling us to watch the House Floor without losing desk
workspace. We've also been fortunate enough to install teleconferencing
between my district office and my DC office via a flat screen, enabling
me to hold meetings with constituents when I must be in Washington
voting and appearing in committee. Our office is a prime example of
many, many other businesses and households across the Nation. Our new
technologies help me to do my job better. Yet, multiple television sets
with Cathode ray tubes (CRTs) reside in a storage area. The disposal of
CRTs is a pressing issue, particularly with the upcoming digital
conversion.
I would like to thank today's witnesses, Mr. Castro, Ms. St. Denis,
Mr. Harris, Mr. Smith, Mr. Williams, and Dr. Williams, for coming
before the Committee. Mr. Harris, I'm pleased to tell you that one of
your active Members is a constituent of mine who has kept me informed
of these issues. I will be sure to tell him that you appeared before
us. I look forward to hearing all of our witnesses' testimonies.
[The prepared statement of Mr. Mitchell follows:]
Prepared Statement of Representative Harry E. Mitchell
Thank you, Mr. Chairman.
As American consumers attempt to keep up with the latest technology
trends by purchasing the newest cell phones and laptops, the number of
discarded electronic products is rapidly increasing.
When electronic products are properly handled, these products can
transform into a valuable source for reusable equipment.
However, if these products are not disposed of properly, they are
potentially harmful to both human health and the environment.
Currently, there are no federal regulations in place for the
appropriate disposal of electronic waste (e-waste).
I look forward to hearing from our witnesses about potential
practices for handing e-waste.
I want to extend a special welcome to Dr. Eric Williams, a
Professor from Arizona State University, for testifying here today. Dr.
Williams has focused his research on the environmental impacts of e-
waste, and I look forward to his testimony.
I yield back.
Chairman Gordon. As you can see, things are relatively
crowded up here so we have staff both in the anterooms that are
watching--this is being televised--as well as other Members who
are also watching. So we welcome your testimony, and at this
time I would like to introduce our witnesses.
Dr. Eric Williams is Professor at Arizona State University.
He holds a joint appointment in the Department of Civil
Engineering and the School of Sustainability. Mr. Gerardo
Castro is the Director of Environment Services for Goodwill
Industries of Southern California. Ms. Renee St. Denis is
Hewlett Packard's Director of Product Take-Back and Recycling
Services for America. Mr. Eric Harris is Associate Counsel and
Director of Government Affairs for the Institute of Scrap Metal
Recycling, and Mr. Ted Smith is the Chairman of the Electronics
Take-Back Coalition. And finally, Mr. Michael Williams is the
Executive Vice President and General Counsel for the Sony
Corporation.
Our witnesses should know spoken testimony is limited to
five minutes each, after which the Members of the Committee
will have five minutes each to ask questions. We will start
with Dr. Williams.
STATEMENT OF MR. ERIC D. WILLIAMS, ASSISTANT PROFESSOR,
DEPARTMENT OF CIVIL AND ENVIRONMENTAL ENGINEERING AND SCHOOL OF
SUSTAINABILITY, ARIZONA STATE UNIVERSITY
Mr. Eric Williams. Chairman Gordon and other Members of the
Committee, it is my pleasure to be here today to testify.
Management of end-of-life of electronics is a new challenge.
One reason is the rapid evolution of technology. While new
electronic products like computers and cell phones have as long
a potential lifespan as traditional white goods, in practice
they are considered obsolete very soon and replaced with new
models. These discards are our e-waste.
A second distinction is that the environmental intensity of
manufacturing electronics is comparatively high. For example,
it takes four times more energy to make a desktop computer than
it consumes while plugged in at home. In contrast, for a
refrigerator, most of the energy is used in operation.
Manufacturing is a small share. Surprisingly, a computer's
annual energy costs are higher than for a refrigerator if one
includes manufacturing. Extending electronics' lifespans thus
could be an important strategy to mitigate environmental
impacts. This does not mean that we should try to make do with
slide rules or pocket calculators. Rather, robust markets for
used electronics can help ensure that functions are well
matched with the needs and wants of users.
A third challenge is how to manage substances of concern in
electronics such as lead and brominated flame retardants. Much
of the environmental concern concerning e-waste is about the
potential for lead and other heavy metals to leach from e-waste
in landfills. Circuit boards and cathode ray tubes are
classified as hazardous waste because they fail EPA's TCLP
leaching risk test. My colleagues and I at Arizona State
University recently reviewed the literature, and our conclusion
was that the risk of leaching from sanitary landfills is very
small, if not negligible. The main reasons for this are, one,
the TCLP test is considerably more aggressive than the leaching
that actually occurs in landfills, and two, modern landfills
have control systems to contain toxics that may leach out. In
contrast, there is as yet no evidence that modern recycling of
circuit boards and CRTs is environmentally preferable to
landfilling.
A fourth challenge is that the reuse and recycling of
electronics is often a net cost in the United States but in the
developing world is a profitable business because the
developing world has lower labor costs, higher demand for
reused products and parts, and lower environmental protection.
This results in substantial export of end-of-life electronics
from the United States and other developed countries to
developing countries.
The electronics reuse and recycling industry is a double-
edged sword for the developing world. On one hand, reuse
markets provide access to technology which people could
otherwise not afford. Low-cost computers and cell phones in
particular enhance education and economic development. The
recycling and refuse industry employs thousands of people. On
the other hand, the recycling of electronics is often done in
developing countries via an informal industry. It is, in my
opinion, by far the most serious environmental problem
associated with end-of-life electronics. Yet there is as yet
little action taken to improve health and safety conditions in
this industry.
I believe that it is important we work toward electronic
product solutions and policies which aim at triple bottom-line
solutions: environmental, economic, and social benefits. While
it is tempting to focus only on environmental issues, some
environmental options have negative economic and social impacts
for disadvantaged groups leading to complex ethical choices. We
need to understand the tradeoffs between different options.
An important part of moving forward is understanding what
is really going on with reuse and recycling. One reason for the
current lack of information is that reuse and recycling
activities do not have their own industry or commodity codes
and thus are invisible to conventional statistics. Considering
product design, using and developing alternate materials is an
important strategy but it is important to note that even a
computer free of toxic substances would still be dangerous to
recycle informally. Many of the toxics are generated or used in
the recycling processes themselves.
The design of information systems for products is much less
discussed but I think one of the major untapped opportunities
to improve reuse and recycling. One idea is to place a radio
frequency identification device into a computer to act as a
black box, periodically recording the functionality of
different systems. At the end-of-life, a computer arriving at a
processing facility could be remotely scanned to test
functionality and classify it for reuse versus recycling. There
are many other possibilities.
To sum up, I am concerned that current policy direction
around the world may not take us in the direction we want to
go. I believe the United States should take a leadership role.
Here are some suggested directions: one, investigate the pros
and cons of different landfilling and recycling technologies to
establish best practices; two, promote reuse domestically and
abroad; three, cooperate with the developing world to mitigate
the impacts of informal recycling; and four, while the public
discourse on electronics in the environment focuses on end-of-
life issues, information technology has many important
environmental applications which we should not neglect or
ignore.
So I and my colleagues at Arizona State University would
like to thank you for your attention.
[The prepared statement of Mr. Williams follows:]
Prepared Statement of Eric D. Williams
Chairman Gordon and other Members of the Committee, it is my
pleasure to be here today to testify on the topic of end-of-life
electronics. My name is Eric Williams and I am an Assistant Professor
at Arizona State University with a joint appointment between the
Department of Civil and Environmental Engineering and the new School of
Sustainability.
The fate of end-of-life of electronics, also known as e-waste, has
gained a great deal of attention from policy-makers and public around
the world. The chain of activities from manufacturing to operation to
disposal is highly globalized and continues to globalize further.
Policy decisions taken here in the U.S., in Europe, in China have
global implications for the industries involved in electronics
manufacturing and end-of-life. Here in the U.S. some states such as
California and Maine have already developed and implemented State-level
legislation mandating recycling of end-of-life electronics. Given the
importance of the electronics industry both in the U.S. and globally, I
believe it important that the U.S. Government takes a leadership role
in developing responsible policies and practices for managing e-waste.
In my testimony I intend to lay out one view of how this nation might
work towards sustainable management of end-of-life electronics.
End-of-life electronics: a unique challenge
First I will discuss how management of end-of-life electronics is a
unique new challenge compared to previous products. One reason is the
rapid evolution of electronics technology. Rapid progress goes hand-in-
hand with rapid obsolescence, which has two main implications for
environmental management. One is that it stimulates purchases of new
devices as consumers aim to take advantage of improved technology. A
second is that the characteristics of the waste stream evolve along
with the product.
A second reason is that the environmental intensity of
manufacturing electronics, in particular information technology goods,
is higher than many other consumer products. For example, it takes four
times more energy to make a desktop computer than it consumes while
plugged in at home. For a refrigerator, in contrast, most energy is
used in operation, the energy used in manufacturing is a small share.
This high energy intensity in manufacturing combined with rapid product
turnover implies a surprisingly high net impact: when the energy used
in manufacturing is amortized over the life of the product, annual
energy costs for owning a personal computer are higher than for a
refrigerator.
How does this high environmental intensity of manufacturing tie in
with the e-waste issue? Reduce, reuse, recycle, or the 3Rs, is a mantra
of waste management. However, most of the environmental investment in
high-technology electronics is in not in the materials but is in its
complex manufactured form. Recycling is less effective at recovering
this investment than for many other goods (e.g., an aluminum can).
While appropriate end-of-life management is needed, the high
environmental investment in form versus materials in electronics tilts
the 3Rs such that Reduce and Reuse tend to be much more effective than
recycling at reducing life cycle environmental impacts. Extending
lifespan is thus an important strategy to mitigate environmental
impacts. Extending lifespan does not mean that we should make do with
slide rules or pocket calculators! Rather, we should work to match the
performance specs of hardware with actual needs of users, for example
with reuse markets.
A third reason e-waste management poses a unique challenge is the
mix of materials used in making electronics. Electronics contain
valuable materials for recycling such as copper, silver and gold as
well as known toxic substances such as lead, cadmium and mercury. There
are also new substances of concern: for instance, brominated flame
retardants are added to circuit boards and cases to reduce
flammability. Recent scientific studies show that some brominated flame
retardants are endocrine disruptors and that their concentrations in
human tissues are rapidly increasing. While the human health and
environment effects of brominated flame retardants are uncertain, I
believe there is enough evidence to justify concern and response.
Much of the environmental discourse surrounding e-waste centers
around the concern that lead and other heavy metals could leach from e-
waste put into landfills and contaminate ground water. Circuit boards
and Cathode Ray Tubes (CRTs) fail the EPA's Toxicity Characteristic
Leaching Procedure (TCLP) test, resulting in these items being
classified as hazardous waste. The TCLP test involves grinding up the
material in question, putting it into an acidic solution and measuring
the amount of material (such as lead) that seeps out. My colleagues and
I at Arizona State University recently reviewed the literature relevant
to the actual risk of heavy metals leaching from e-waste in sanitary
landfills in the U.S. Our conclusion was that the risk of environmental
harm from landfilled e-waste is negligible, despite the failure of the
TLCP test by some electronic components. The main reasons for this are:
1. that the TCLP tests are considerably more aggressive than the
leaching that actually occurs in municipal (non-hazardous) waste
landfills and 2. modern landfills have control systems to contain any
toxics which may leach out.
Is modern recycling of circuit boards and CRTs actually
environmentally preferable to putting these parts in sanitary
landfills? We argue that this is not known and that it is conceivable
that recycling could emit more toxic heavy metals over the life cycle.
Recycling by definition mobilizes materials (e.g., via smelting), and
depending on the level of process control can emit lead, mercury, and
other hazardous substances. In contrast with landfills however,
recycling has the virtue of replacing production of virgin materials
with recycled substitutes. If the avoided lead emissions associated
with mining and milling are larger than for recycling, recycling would
reduce total lead emissions. If not, recycling e-waste has the
potential to release more lead to the environment than e-waste in
landfills. Currently there are no analyses addressing under what
circumstances which option (recycle versus landfill) leads to lower
life cycle emissions of heavy metals. I suggest that this issue be
resolved before public policy mandates recycling as the default
environmentally preferable alternative.
A fourth reason e-waste management presents a challenge is that
while reuse and recycling of electronics in the developing world runs a
net profit in the U.S. recycling often results in a net cost. The main
factors contributing to this dichotomy are lower labor costs, higher
demand for reused products and parts, and less stringent environmental
protections in the developing world. Recycling in the developing world
at a net profit versus recycling in the U.S. at a net cost creates a
market dynamic for exporting electronics to the developing world. The
electronics reuse/recycling industry is a double-edged sword for the
developing world. On one hand reuse markets provides access to
technology to people who otherwise could not afford it and creates jobs
for thousands of people. Many of the electronics goods people own in
developing countries were first used in the U.S. The availability of
low cost recycled computers and cell phones, in particular, can play an
important role in increasing the use of Information Technology (IT) to
enhance economic and educational activities in developing countries.
On the other hand, recycling of electronics in developing countries
is often implemented by an informal industry. U.S. NGOs such as the
Basel Action Network (BAN) and the Silicon Valley Toxics Coalition have
reported that informal recycling activities in China, India and Nigeria
cause serious environmental harm. For example, in many cases wires are
pulled from computers, collected and burned in open piles to remove
casings and recover re-saleable copper. This results in creation and
emission of dioxins, furan and other environmental pollutants. Circuit
boards are treated to extract copper and precious metals using acid,
cyanide and/or and mercury often in a manners that leads to
uncontrolled discharge of contaminated process liquid, sometimes next
to rivers. Scientific evidence is mounting which confirms that the
environmental impacts of these activities are indeed severe. In Guiyu,
a town in China well known for informal electronics recycling,
emissions of dioxins were shown to be thousands of times the U.S.
standard and blood lead concentration in children were found to exceed
levels of concern. It is my opinion that informal recycling represents
by far the most serious environmental issue for end-of-electronics. Yet
there is as yet little action being taken to improve health and safety
conditions in the industry. I believe that the U.S. should work with
developing countries to address informal recycling.
Policy and e-waste
End-of-life electronics management interfaces with environmental,
social and economic issues. What are nations and regions around the
world doing legislatively to address this management challenge? There
are three primary approaches. The first legislative approach is
enacting take-back systems which collect end-of-life electronics for
recycling. Such systems have been mandated in the European Union, Japan
and other nations, and a few U.S. states such as California and Maine.
The ostensible goals of this legislation are to keep e-waste out of
landfills and increase recycling of materials. However, the net
environmental benefit of this legislation is, I believe, as yet
unclear. Recycling may not be environmentally preferable to landfilling
and in addition take-back systems could have an adverse affect on reuse
of equipment. I do not believe the landfill versus recycle question has
been sufficiently resolved to warrant a blanket priority for policy.
The second approach to legislation regulates the use of materials
in electronics. The primary example of this type of policy is the
Restriction on Hazardous Substances (RoHS) legislation promulgated in
the European Union. RoHS restricts six hazardous elements in different
applications; lead, mercury, cadmium, hexavalent chromium, and the
polybrominated biphenyls (PBB) and polybrominated diphenyl ethers
(PBDE) flame retardants. Any electronics manufacturer wishing to sell
their products in Europe must abide by the rules, thus this regional
legislation effects global change in the industry. Exposure to
brominated flame retardants presumably occurs while the goods are in
service, thus removing them has a high potential to reduce consumer
risk. However, banning the use of lead in solder has been a particular
source of controversy with respect to RoHS, with many in the U.S.
arguing that the environmental need for the ban is unclear. For heavy
metals like lead, exposure generally is not an issue during use of the
product but depends on handling at end-of-life. Furthermore, while lead
exposure in informal recycling is a clear risk to workers and local
communities, the overall risk to workers from lead exposure is reduced
but not clearly managed by banning lead solder, since lead is only
removed from solder but not from CRTs, which contain far more lead than
solder.
A third approach to legislation regulates trade in end-of-life
electronics. This is usually applied at the national level, for
instance China bans imports of used electronics and e-waste. However,
while officially a ban is in place in China, the imports of e-waste
coming in China have continued unofficially more or less as before. At
the international level, the central framework for controlling
international movements of hazardous substances is the Basel
Convention. The Basel Convention requires prior notification between
signatories when trading wastes classified as hazardous. Many
categories of e-waste are classified as hazardous waste and thus are
targeted for prior notification. Products intended for reuse, however,
are exempt from control. Furthermore, the Convention does not suggest
how to establish the reusability of a given trade flow in practice, a
nontrivial challenge.
Do these current policy directions achieve desirable environmental,
social and economic objectives for society? On the environmental side,
many in the scientific community are of the opinion that the risk
associated with landfilling e-waste has been vastly overstated. The
most pressing environmental issue is, in all likelihood, the adverse
impact of informal recycling in developing countries. Dealing with
these and other issues can lead to complex ethical choices. Policies
can result in tradeoffs between environmental, economic and social
issues. For example a ban on exports of end-of-life electronics might
seem an appropriate course of action to mitigate environmental impacts
of informal recycling. However, a blanket trade ban would make used IT
equipment less available abroad. Also, it would cut off the supply of
raw material to a reuse/recycling industry providing thousands of jobs
to poor people. Is this appropriate, especially given an absence of
prior attempts to redress occupational and safety issues of the
industry?
While it may seem off-topic, I think it important to raise the
issue of the environmental applications of IT. Informational Technology
can be used to reduce a variety of different environmental impacts. For
instance, it can reduce the impacts of transportation systems by
enabling telecommuting, virtual meetings, and creating virtual networks
of car-poolers. Furthermore, a great deal of energy consumption in
residential and commercial buildings goes towards energy services not
actually needed, such as heating or cooling unoccupied rooms.
Substantial energy can be saved via computerized monitoring and control
systems. The environmental management of electronics has come to be
conceptualized in terms of its potential end-of-life impacts. While
end-of-life impacts should certainly be better managed, we should
allocate our attention and resources in proportion to potential
benefits. The environmental potential of IT is significant yet
relatively ignored.
Towards the future: Product, reuse/recycling processes and policy
design
It is important to work creatively towards the design of products,
reuse and recycling processes, and policies to achieve multiple
societal objectives. An important starting point to achieve this goal
is characterizing domestic and international flows of end-of-life
electronics. Currently flows of e-waste products and materials are
poorly understood. One reason for this is that reuse and recycling
activities do not have their own industry or commodity codes and are
thus invisible to conventional trade statistics systems. Under a grant
from the National Science Foundation in the Environmental
Sustainability program, my colleagues and I at Arizona State University
are working to characterize international e-waste flows and come up
with new solutions to capture this information. This is at present the
only U.S. project of its ilk I know of. Japan in comparison is
investing far more in order to characterize and plan management of
international end-of-life flows for a variety of consumer products and
recycled materials.
Product design can be viewed through three different lenses:
materials, assemblies, and informatics. Material selection is one
important strategy for optimizing end-of-use value. The RoHS
legislation for example takes the step of banning two brominated flame
retardants. The potential snag is that it is not yet clear whether
environmentally acceptable alternatives are available. Research and
development in green chemistry is needed to develop and test
alternatives. We should however be cognizant that material selection
faces limits. Even a computer completely free of toxic substances would
still be dangerous to recycle informally because of the toxic
substances generated and used in recycling. I believe the target should
be managing the exposure to toxics by developing environmentally sound
recycling processes rather than the complete elimination of all
substances of concern.
Assemblies refer to how parts are put together, which also has
effects on end-of-life processing. Disassembly is currently carried out
by hand and labor costs are an important cost issue. Snap-fits for
easier disassembly and making parts of concern such as nickel cadmium
batteries easily accessible reduces labor costs of recycling and
potentially reduces adverse impacts of informal recycling.
The design of informatics as it relates to the end-of-life of
products is much less discussed than material and assembly choice.
Information Technology can be applied to construct information systems
to enhance the reusability and recyclability of products. For example,
Radio Frequency Identification Devices (RFIDs) could be placed in
computers to provide information wirelessly to reuse/recycling systems.
One concept is an RFID ``blackbox'' for each computer, which
periodically records the functionality of different subsystems. At the
end-of-life, a computer arriving at a processing center can be
wirelessly scanned for functionality and selected for reuse versus
recycling.
Another layer of informatics design relates to the ease and
security with which consumers can resell their computers. After
purchasing a replacement computer, consumers often store their old
computer, unused for years, until some decision is made regarding its
end-of-life disposition. One reason for this is concern whether data on
the old computer has been backed up and if it can be securely erased
before selling. There are software applications which could be packaged
with computers which create backups and then thoroughly erase all data.
Another obstacle to used markets relates to the transfer of the right
to use pre-installed software from first user to secondary user. In
general software license agreements grant the secondary user the same
rights to use software but in practice the current rights labeling
system does not enable the secondary user to clearly establish this
right from a legal perspective. To protect themselves from litigation
from software companies, reuse and refurbishing companies routinely
wipe hard drives of the used computers they purchase. This loss of
software reduces the value of the used computer. This could be avoided
if pre-installed software rights were packaged with the computer in a
verifiable way.
Considering end-of-life processes, one important task is to assess
the environmental characteristics of recycling, especially those
processes such as smelters and acid leaching which mobilize toxics.
There are a variety of recycling processes and practices currently in
use around the world. Assessment will reveal which are best practices
and in what specific areas it may be most appropriate to invest in
research and development of environmentally benign recycling processes.
Another layer of design is policy. It is fair to characterize the
current status of policy development as one in which nations and states
are experimenting with different policy designs to manage end-of-life
electronics. There is still much room to develop policy alternatives.
One alternative policy direction is to design systems intended to
ensure environmentally safe end-of-life management while at the same
time establishing a competitive market for reuse and recycling
services. One concrete idea to realize this goal is termed e-Market for
Returned Deposit. The e-Market system begins with a deposit paid by
consumers to sellers at the time of purchase, electronically registered
and tracked via a Radio-Frequency Identification Device (RFID) placed
on the product. At end-of-life, consumers consult an Internet-enabled
market in which firms compete to receive the deposit by offering
consumers variable degrees of return on the deposit. After collection
of the computer by the selected firm, the cyber-infrastructure utilizes
the RFID to transfer the deposit to the winning firm when recycled. If
the firm chooses to refurbish or resell the computer in lieu of
recycling, the transfer is deferred until true end-of-life processing.
A second policy proposal focuses on redressing the environmental
impacts of informal recycling abroad. The basic idea is to pay workers
involved in reuse and disassembly not to recycle those components
dangerous to handle with informal processing. This could be implemented
via a system which establishes collection points at which workers would
be paid fixed prices to deliver targeted parts. The price is set to
create a financial incentive for informal recyclers to deliver the
targeted parts rather than process them on their own. Under this system
the collected parts would be transported and processed in appropriate
recycling facilities. Since much of the cost associated with recycling
is with transport and disassembly, this system would presumably be an
inexpensive option to avoid informal recycling while maintaining an
active reuse industry.
Conclusion
Are there product, process and policy designs which allow us to
mitigate environmental impacts while at the same time realizing the
social and economic benefits of recycling and reuse of electronics?
Management efforts up to now have focused on heuristic goals such as
increasing recycling rates and banning e-waste from landfills. It is
not clear to me that this approach will take us where we want to go. We
need to think about desired endpoints such as safety from exposure to
toxics, net reduced energy use, availability of affordable IT to
everyone, and creating jobs and capital. We should work backwards from
these endpoints to find the policies, processes, and product designs
which deliver the desired outcomes. In addition, we also need to work
much harder on using IT as a tool to achieve environmental goals. Here
are some suggested starting points:
Investigate the life cycle environmental pros and
cons of landfilling and recycling end-of-life electronics in
order to benchmark best practices. This evaluation should allow
reconsideration of whether the current TCLP based standard
regulating the landfilling e-waste is appropriate.
Undertake research to develop new materials as
appropriate, such as bromine-free flame retardants. New
materials need to be thoroughly evaluated before they are
adopted.
Encourage reuse of electronics through improved
informatics design, such as bundling of backup/erase
applications with new computers. These improvements make it
easier for users to resell their computer securely and with
software intact.
Work to ensure that used electronics we export to
developing countries is in good working order. Strategies to
achieve this include use of RFID blackboxes to enable remote
checking of recent functionality and certification schemes for
used equipment.
Work with developing countries to improve
occupational, health and safety conditions in informal
recycling industries.
I believe the U.S. Federal Government should take a leadership role
in working towards a sustainable management of electronics. The
electronics industry is not a domestic affair, and policies outside the
U.S. federal context affect the global system. If the Federal
Government does not take action, other nations will, setting the
playing field without U.S. input. I hope we can proceed through a
combination of thinking creatively, assessing carefully, and acting
decisively to create sound policies and practices for end-of-life
management of electronics. I and my colleagues at Arizona State
University would like to thank you for your attention.
Biography for Eric D. Williams
Eric Williams is Assistant Professor at Arizona State University
with a joint appointment between the Department of Civil and
Environmental Engineering and the new School of Sustainability. Eric
has been active in researching the environmental assessment and
management of information technology and electronics for nearly 10
years. Eric has a global perspective on the industry, having spent a
good part of his career at United Nations University headquartered in
Tokyo. His research articles in Environmental Science & Technology,
``The 1.7 kg Microchip'' in 2002 and ``Energy Intensity of Computer
Manufacturing'' in 2004 have contributed to understanding of the supply
chain environmental impacts of electronics. He is co-editor and
contributor to the 2003 book Computers and the Environment:
Understanding and Managing Their Impacts, the first integrated
treatment of the issue. Eric's research results have been widely
covered by the scientific and popular media, with reports in Science,
Nature, New Scientist, PC Magazine, Foreign Policy, Scientific
American, Financial Times, BBC, and other media outlets. Eric is co-
chair of this year's IEEE International Symposium on Electronics and
the Environment in San Francisco, the Nation's premier annual event
addressing the environmental management of electronics. He is also
currently member of a National Academy of Science committee tasked with
the question of linking appliance energy efficiency standards with life
cycle considerations.
Education
1993--Ph.D. in Physics, C.N. Yang Institute for Theoretical Physics,
Dept. of Physics, State University of New York at Stony Brook,
Stony Brook, New York
1988--B.A. in Physics, Macalester College, St. Paul, Minnesota
Professional Experience
8.2006-present--Assistant Professor, Department of Civil and
Environmental Engineering & Global Institute of Sustainability,
Arizona State University, Tempe
9.2005-7.2006--Visiting Assistant Professor, Department of Civil and
Environmental Engineering, Carnegie Mellon University,
Pittsburgh
9.2001-7.2006--Project Coordinator, United Nations University/Centre,
Tokyo
9.2000-8.2001--Associate Fellow, United Nations University/Institute of
Advanced Studies (UNU/IAS), Tokyo
9.1997-8.2000--Research Associate, UNU/IAS, Tokyo
9.1995-8.1997--JSPS Postdoctoral Fellow, Institute for Solid State
Physics, University of Tokyo, Japan
9.1994-8.1995--Temporary Assistant Professor, Department of
Mathematics, University of Minnesota, Minneapolis
Selected Publications
1. E. Williams, R. Kahhat, B. Allenby, E. Kavazanjian, J. Kim and M.
Xu, ``Environmental, social and economic implications of global reuse
and recycling of personal computers,'' in press, Environmental Science
& Technology (2008).
2. R. Kahhat, J. Kim, M. Xu, B. Allenby, and E. Williams, ``E-Market
for E-waste: an alternative management system for the U.S.,'' in press,
Resources, Conservation and Recycling (2008).
3. A. Terazono, S. Murakami, N. Abe, B. Inanc, Y. Moriguchi, S. Sakai,
M. Kojima, A. Yoshida, J. Li, J. Yang, M.H. Wong, A. Jain, I. Kim, G.L.
Peralta, C.C. Lin, T. Mungcharoen, and E. Williams, ``Current status
and research on E-waste issues in Asia,'' J. Material Cycles and Waste
Management, 1-12 (2006).
4. H.S. Matthews and E. Williams, ``Telework adoption and energy use
in building and transport sectors in the U.S. and Japan,'' Journal of
Infrastructure Systems 11(1), 21-30 (2005).
5. E. Williams, ``Energy intensity of computer manufacturing: hybrid
analysis combining process and economic input-output methods,''
Environmental Science & Technology 38(22), 6166-6174 (2004).
6. E. Williams, ``The environmental impacts of semiconductor
fabrication,'' Thin Solid Films 461(1), 2-6 (2004).
7. R. Kuehr and E. Williams (eds.), Computers and the Environment:
Understanding and Managing their Impacts, Kluwer Academic Publications:
Dordrecht (2003).
8. E. Williams and T. Tagami, ``Energy use in sales and distribution
via B2C E-commerce and conventional retail: a case study of the
Japanese book sector,'' Journal of Industrial Ecology 6(2), 99-114
(2003).
9. E. Williams, R. Ayres, and M. Heller, ``The 1.7 kg microchip:
energy and chemical use in the production of semiconductors,''
Environmental Science & Technology 36 (24), 5504-5510, Dec. 15 (2002)
(cover story).
Selected Research Projects and Awards
Industrial Ecology Fellow, ``Substitution and Complementarity of ICT
products and services,'' AT&T Foundation, Jan. 2008-Dec. 2008.
``Assessing and managing the sustainability of global reverse supply
chains: the case of personal computers,'' National Science
Foundation, Environmental Sustainability program, Sep. 2007-
Aug. 2010.
Industrial Ecology Fellow, ``Information Technology-based monitoring
and control systems to mitigate energy use in households,''
AT&T Foundation, Jan. 2006-Dec. 2006.
``Energy consumption of IT infrastructure in Asia--Computer Use
Patterns,'' New Energy and Industrial Technology Development
Organization (NEDO)--Japan, April 2004-March 2005.
Industrial Ecology Fellow: ``Effects of computer usage patterns on the
life cycle energy consumption of IT infrastructure,'' AT&T
Foundation, Jan. 2004-Dec. 2004.
``The Digital Economy and Energy,'' Japan Foundation--Center for Global
Partnership, June 2001-May 2003.
Chairman Gordon. Thank you, Dr. Williams.
Mr. Castro, you are recognized.
STATEMENT OF MR. GERARDO N. CASTRO, DIRECTOR OF ENVIRONMENTAL
SERVICES AND CONTRACTS, GOODWILL INDUSTRIES OF SOUTHERN
CALIFORNIA
Mr. Castro. Mr. Chairman, Members of the Committee, my name
is Gerardo Castro and I am the Director of Environmental
Services and Contracts for Goodwill Industries of Southern
California. I am pleased to testify before the Committee today
on how we can best manage electronic waste.
Goodwill Industries International is a network of 184 local
autonomous Goodwill agencies in the United States and 16
countries. We fund our mission through revenues collected from
donated goods as well as through industrial and workforce
development contracts with government and the private sector.
In 2007, my agency served more than 31,000 people with
disabilities or vocational disadvantages through education, job
training and placement programs. We operate 54 retail stores,
40 attended donation centers, three campuses, and 21 workforce
training centers.
During the past decade, we have seen a growing number of
computers and other electronic devices dropped off at our
stores and donation centers. Nearly all of our agencies
received discarded electronics. In 2004, local Goodwill
agencies handled nearly 23 million pounds of electronics. With
the transition to digital televisions, California expects 15
million television sets to be discarded next year. The problem
of e-waste is a growing one but it also represents a great
opportunity.
My views today represent those of my agency, Goodwill
Industries of Southern California. In 2003, California became
the first state in the Nation to enact legislation which
implemented strict standards for the disposal of e-waste, the
California Electronic Waste Recycling Act, or S.B. 20 or S.B.
50. The program was later implemented in 2005. In 2007, my
agency was able to divert a total of 4.6 million pounds of
electronic waste out of county landfills. These products ranged
from computers and monitors to printers and other peripherals.
California is the only state which uses the advanced
recovery fee model to pay for the costs associated with
collecting, de-manufacturing and recycling covered electronic
products. Retailers are required to collect a fee of $6 to $10,
depending on the size of the screen, on any cathode ray tube,
liquid crystal display, or plasma device sold in California.
These fees go into a State recycling fund to reimburse
authorized collectors and authorized recyclers. Collectors
receive 20 cents per pound for picking up unusable CRTs and
delivering them to recyclers, who get 28 cents for canceling
them.
Along with nine other California Goodwills, we are a State-
authorized e-waste collector. As an authorized e-waste
collector, we process over 10,000 CRT units per month. We
follow specific procedures in recycling e-waste. First, we
recycle working computers by wiping the hard drives to
Department of Defense standards, install new hard drives and
sell the refurbished units in our stores. These sales generate
approximately 10 percent of our total e-recycling revenue.
Another 70 percent comes from the dismantling and sale of
plastic and metal circuit boards and other components to
commodity dealers. The final 20 percent is obtained by taking
unusable CRTs to State-authorized recyclers.
Through our national network of 2,100 stores and 4,100
attended donation centers in virtually every community in
America, Goodwill already has the capacity and infrastructure
to provide for nationwide collecting of e-waste products.
The Federal Government can encourage private-sector
investment and not-for-profit involvement in the used
electronic recycling reuse market through tax credits for
consumers and manufacturers who partner with social agencies,
recycling grants and other initiatives that help stakeholders
solve this growing challenge.
Goodwill Industries looks forward to working with the House
Science Committee to support a national solution to handle e-
waste.
Thank you.
[The prepared statement of Mr. Castro follows:]
Prepared Statement of Gerardo N. Castro
Mr. Chairman and Members of the Committee, my name is Gerardo
Castro and I am the Director of Environmental Services and Contracts
for Goodwill Industries of Southern California. I am pleased to testify
before the Committee today on how we can best manage electronic waste.
We have 184 local, autonomous Goodwill agencies in the U.S. and 16
countries, and we fund our mission through revenues collected from
donated goods, government contracts, and workforce development funding.
Goodwill Industries of Southern California serves more than 31,000
people per year with disabilities or vocational disadvantages through
education, job training, and placement programs. We also operate 54
retail stores, 40 attended donation centers, three campuses and 21
workforce/training centers in San Bernardino, Riverside, and Los
Angeles counties.
In a survey conducted in 2005, we found that nearly all of our
members receive electronics through their donation streams and our
members handled nearly 23 million pounds of electronics in 2004.
During the past decade, however, we have seen a growing number of
computers and other electronic devices donated to Goodwill agencies,
and many of these items are just dropped off at our stores or donation
centers. The problem is a growing one for us, but it also presents
opportunities. With the transition to digital television, we expect to
see an influx of television sets as well.
In a poll conducted by Goodwill Industries International, Inc., we
found that 91 percent of our local agencies accept donated televisions,
and local Goodwill agencies receive on average 118 televisions per
month or 1,400 per year. The total for all Goodwill agencies is more
than 163,000 per year. Fifty percent of our agencies re-sell the
televisions in stores and 30 percent recycle the sets.
My views today represent those of my agency--Goodwill Industries of
Southern California. Because of the environmental concerns specific to
computers and other electronic devices, many of our local agencies are
exploring various business-to-business solutions in the effective
disposal of electronic waste and ways to recycle the waste. Other
agencies are exploring methods of handling e-waste and still others are
working to understand and comply with new State laws on recycling e-
waste.
My particular agency received a total of 4.6 million pounds of e-
waste products ranging from computers, monitors, printers, and other
peripherals. A substantial number of these items are unusable and the
cost of safely and responsibly recycling or disposing of these products
can directly impact the job training and career services offered by our
agencies.
More and more states have passed landfill bans, and for those
Goodwill agencies that do dispose of electronic waste in landfills the
fees to do so can be exorbitant. In addition, some agencies are working
within various State laws on the effective disposal and recycling of e-
waste.
In 2003, California became the first state to enact a law that
implements stricter standards on e-waste disposal; SB20/SB50, the
California Electronic Waste Recycling Act, provides reimbursement to
authorized collectors and recyclers from a State e-waste fund. Today,
10 states have passed laws that create statewide e-waste recycling
programs. Others have passed laws that prohibit e-waste from being
disposed of in landfills or incinerated. In 2008, 18 states are
considering e-waste legislation.
California is the only state that uses the Advanced Recovery Fee
(ARF) model to pay for the costs associated with collecting, de-
manufacturing, and recycling of covered electronic products, which is
similar to the recycling payment system for beverage containers or used
tires. Retailers are required to collect a $6-$10 fee on cathode ray
tube (CRT), liquid crystal display (LCD), and plasma devices. The fees
collected go into a fund to manage the recycling program.
Goodwill Industries of Southern California, along with nine other
Goodwills located in the state, is a State-authorized e-waste
collector. There are 600 authorized collectors in the state. The fund
receives revenues from the point of sale fee on items with a screen
purchased in California. The State of California has just completed its
third year of the program. The program has been very successful when
measured by the pounds of CRTs diverted from landfills. The program has
built in review and adjustment points to maintain a self-funding level.
The program is revenue neutral to the State of California as it
involves zero tax dollars. It is authorized to adjust at least every
two years on both the ARF and the fees paid to authorized collectors
and authorized recyclers. We are expecting the state to increase the
ARFs and reduce the fees to collectors by about three cents a pound.
As an authorized e-waste recycler, we process over 10,000 CRT units
per month and pick up large corporate donations; in addition,
individual donations are accepted at our donation centers. We accept
computers, monitors, TV sets, digital cameras, printers, modems, and
other electronic equipment. We collect CRTs and ship non-working ones
directly to a cancellation facility that will break them down into
their basic commodity. All other obsolete or non-working electronics
are de-manufactured by our workforce who are people with disabilities.
We then sell the plastic, metal, circuit boards, and other components
for their salvage value.
We follow a system and certain procedures in recycling e-waste.
First, we recycle old computers by wiping the hard drives to the
Department of Defense standard. We then refurbish and resell about 10
percent, and then dismantle and sell the plastic and metal parts for
salvage; this amounts to about 70 percent. About 20 percent is sent to
other authorized recyclers.
Other local Goodwill agencies are developing innovative business
solutions to address the growing surplus of computer donations. I want
to note that our local Goodwill agencies have the capacity and the
infrastructure to provide nationwide collection, since we already have
locations throughout the country in both urban and rural areas. Some
agencies are refurbishing and de-manufacturing the equipment; reselling
systems and components; expanding client training and career services;
and avoiding high disposal costs.
Local Goodwill agencies handle e-waste in different ways depending
on their size, community, and external partners. For example, some are
involved with producer take back programs, while our agency, because we
have SB 20/SB 50, is not. An internal Goodwill Industries
International, Inc. taskforce identified four innovative e-recycling
models that have so far been successful in meeting Goodwill Industries'
revenue goals, concern for the environment, and most importantly, our
charitable mission.
Specifically, the various models are as follows:
(1) Retail--a model focusing on the collecting, de-
manufacturing, refurbishing and reselling computer systems and
components in a dedicated retail store.
(2) Client--a model integrating client technology training and
workforce development programs into computer collection,
recycling, and reuse.
(3) Corporate--a model integrating corporate services into
computer collection, recycling, and reuse.
(4) Collaborative--a model utilizing partnerships and
collaboration to address computer collection and recycling.
Local Goodwill agencies are in a unique position to support
producer take back programs, because we already have a strong existing
infrastructure, and if any e-waste legislation is introduced in
Congress, we support pre-emption language that would allow states, such
as California, with the ARF model, and those with producer
responsibility take back programs to continue running them. We have
over 2,100 retail stores and 4,100 attended donation centers. Goodwill
Industries is a self-sustaining enterprise and recycling helps us to be
good stewards of the environment and also to help employ people with
disabilities and disadvantages.
In the future, we do believe advanced product designs such as those
already undertaken in Europe would help with the challenge of e-waste.
We support incentives to manufacturers for the design of such products.
Product design changes could facilitate the reuse, disassembly, and
recycling of products. Standardized chargers for cell phones are an
example of design changes that would add minimal costs to the product
while achieving substantial impact in the reuse area. The Federal
Government can play a vital role in assisting the development and
sustainability of a recycling/reuse infrastructure while creating green
collar jobs and stimulating research and development in a growth
industry.
The Federal Government, by utilizing incentives, could aid and
encourage necessary private sector investment in the used electronic
recycling/reuse markets. This can be done through tax credits for
manufacturers who partner with social agencies, recycling grants, and
other initiatives that could spur innovative solutions and help
stakeholders handle this problem. A partnership consisting of
government incentives, private industry and social agencies can protect
the environment, create jobs and spur innovation in the environmental
field.
Additionally, increased federal support for pilot projects and
other sustainable initiatives would be helpful in promoting the
development of a recycling/reuse infrastructure. The Federal Government
also can play a key role in educating consumers. We are currently
working with a broad-based coalition to help inform consumers about the
transition to digital television and the availability of coupons for a
digital converter.
Goodwill Industries looks forward to working with the Committee on
exploring the best ways to handle electronic waste. Thank you.
Biography for Gerardo N. Castro
Gerardo is Goodwill's Director of Facilities, Security,
Environmental Service and Mailroom. He is a bilingual professional with
more than 20 years of experience in construction and facilities
management.
Gerardo represents Goodwill Southern California on the Goodwill
Industries International E-waste Taskforce and has contributed in
formulating policies on a State and national level. He also sits on the
Board of Directors for the Secure Document Alliance, a trade
organization tasked with obtaining national shredding contracts for
nonprofit shredders such as Goodwill.
After a long career in poodle juggling and a stint with a
professional knife-throwing company of gypsies, Gerardo decided to
settle down and get a real job at Goodwill. Married with four children,
he finds that life at home tends to be less than tranquil.
Chairman Gordon. Thank you, Mr. Castro. You and Goodwill
should be congratulated on a very forward-thinking program.
Now Ms. Renee St. Denis from Hewlett Packard, you are
recognized.
STATEMENT OF MS. RENEE ST. DENIS, DIRECTOR OF AMERICA'S PRODUCT
TAKE-BACK AND RECYCLING, HEWLETT-PACKARD COMPANY
Ms. St. Denis. Good morning, Chairman Gordon, Ranking
Member Hall and Members of the Committee, my name is Renee St.
Denis and I am the Director of Product Take-Back for the
Hewlett-Packard Company in America.
HP has a longstanding history of being a leader in
electronics recycling. We first began recycling electronics in
1987 and in 1994 we opened a world-class electronics recycling
facility. In our 21 years of recycling electronics, we have
recycled more than one billion pounds of electronics from our
consumer, small and medium business, and enterprise customers--
quite an achievement.
We also operate a state-of-the-art printer supplies
recycling facility outside Nashville, Tennessee, in Chairman
Gordon's district. All of the material that is recycled in all
of our and our partners' U.S. operations are managed in an
environmentally sound manner. No waste is exported for disposal
overseas and no electronic materials are sent to landfills.
In addition to implementing programs on the ground and
testifying before Congress, we have played the leading role in
the policy development and debate about the end-of-life of
electronics in the United States and indeed around the world.
Based on our considerable experience, we believe that
appropriate legislation can create efficient, flexible
recycling systems that optimize the environmental impact,
research utilization and economic benefits of electronics
recycling. We look forward to continuing to work with the
Congress on such legislation.
We do see an increasing use of technology in the processing
of electronic materials for recycling. Materials designed for
recycling are first sent to a process where any materials
requiring special handling such as batteries or CRT glass are
removed and segregated for processing and treatment. At that
point large pieces of metals or plastics may also be isolated
and segregated for recycling. The residual materials are sent
through a series of size reduction and sorting steps. These
steps include mechanical shredding and the use of high-tech
material separation processes such as eddy currents, air tables
or magnetic separation.
I am pleased to report that HP's experience in designing
and operating recycling facilities around the world have led us
to incorporate much of our learning into new product design.
For example, we have reduced the number and type of screws or
fasteners used in new products, replaced paints and coatings on
plastic parts with molded-in colors, and have successfully
created a closed-loop recycling system for the plastics in our
ink jet products.
However, as an industry, we still face challenges in a
number of areas and we have provided suggestions for areas of
research in our written testimony to help create a more
efficient recycling infrastructure. I would like to highlight a
few of those today. In one example, there are materials which
have been used in products in the past which no longer have
economic value. These include CRT glass and plastics with
brominated flame retardants. Congress should consider support
for research into appropriate uses of these materials outside
the technology industry.
Another challenge is the inconsistent and somewhat
inappropriate regulatory framework in place to manage used
electronics. These products may be classified as hazardous
waste due to the testing protocols used to assess the risk of
managing them. The tests used to assess these risks were
developed for assessing industrial waste, not products that we
routinely use every day in our homes and offices. The tests can
give misleading and contradictory results. The resulting
regulatory classification that is put in place creates
burdensome and costly regulatory requirements and impedes the
development of a cost-effective recycling infrastructure while
not creating any additional environmental protection. Congress
could help to foster the development of an electronics
recycling infrastructure by conducting research into the actual
environmental and human health risks associated with the
storage, transportation, selection and recycling of used
electronics and into the development of new, appropriate
testing protocols.
Another slightly different area of research that the
Congress may want to consider is the overall climate impact of
recycling discarded electronics. There is currently little data
on the net carbon impacts of collecting, transporting and
processing used electronics. Recycling can play a positive role
in addressing climate change by conserving resources and
displacing the energy associated with acquiring raw materials
through mining or other processes. However, the process of
recycling used electronics will also generate emissions of
greenhouse gases and contribute to climate change. In a future
carbon-constrained world, all these impacts must be better
understood.
Thank you again for the opportunity to share our views. I
would be happy to answer any questions you might have.
[The prepared statement of Ms. St. Denis follows:]
Prepared Statement of Renee St. Denis
On behalf of Hewlett-Packard Company (HP), I am pleased to provide
this testimony on the recycling of used electronics. My name is Renee
St. Denis, and I am Director, Americas Product Take-Back, based in
Roseville, California. HP is a technology solutions provider to
consumers, businesses and institutions globally. The company's
offerings span IT infrastructure, global services, business and home
computing, and imaging and printing. More information about HP is
available at www.hp.com.
HP applauds Chairman Gordon and Ranking Member Hall for convening
this hearing to discuss electronic waste and appreciates this
opportunity for HP to testify on this important issue. Today's hearing
is a valuable first step in informing Members of the House and the
public on the emerging challenge of managing and recycling used
electronics in the United States. HP supports increased recycling to
conserve natural resources and protect our environment through a
harmonized national approach. HP calls on Congress to support a
national solution to the challenge of recycling used electronics, the
adoption of recycling incentives and the removal of regulatory barriers
to cost-effective recycling, and market-based solutions to finance
government recycling programs. We further call on Congress to support
research in this area to help address challenges that are hindering the
development of a cost-effective recycling infrastructure. We offer our
suggestions for research priorities later in this testimony.
As a major manufacturer of a broad range of technology products, as
well as a leading recycler of these products, HP has a strong interest
in the development of policies relating to electronics recycling. HP
has nearly twenty years of first-hand experience in product take-back
and recycling. Since 1987, HP has successfully collected and recycled
more than one billion pounds of used or unwanted computer-related
equipment globally. With our vast knowledge and experience, HP's goal
is to recycle an additional one billion pounds of equipment (for a
total of two billion pounds worldwide) by the end of 2010. HP has
established a recycling service throughout the U.S. (as well as other
countries around the world) that provides consumer and commercial
customers with a convenient opportunity to recycle their old products
in an environmentally sound manner. For more information on HP's
environment and broader global citizenship activities, see: http://
www.hp.com/hpinfo/globalcitizenship/.
HP currently partners with operators of seven large, state-of-the-
art recycling facilities in the U.S. and Canada, as well as operating
our own technologically-advanced facility used to recycled print
supplies. Our recycling facility for printer supplies is located
outside of Nashville, Tennessee, in the district of Chairman Gordon.
This facility consists of a 40,000 square foot building, including
separation and recycling technology. The facility employs approximately
50 full time employees and processes all of the material returned to HP
through our different print supplies programs in the U.S., Canada and
Latin America.
All materials collected in the U.S. and recycled by HP are managed
in the U.S. and Canada in an environmentally sound manner; under HP's
program, no waste materials are shipped overseas and no electronic
material is sent to a landfill. In the past year, HP recycled almost 40
million pounds of electronic waste in the U.S. in 2007 and reused or
donated an additional 30 million pounds. Including remarketed
equipment, we achieved a total reuse and recycling rate in 2007 of 15
percent of relevant hardware sales. While this metric attempts to
account for the time difference between when HP products are sold and
returned, we recognize the difficulty of matching returned product to
the appropriate sales period, which may affect the accuracy of the
calculation.
HP encourages Congress to continue to support technological
innovation such as HP has employed to reduce the impact of electronic
products on the environment and to encourage the reuse and recycling of
electronic products. Creating opportunities and incentives to support
the innovation of American companies which efficiently achieve superior
recycling results will help to best protect our nation's natural
resources for future generations.
We wish to emphasize the following points in our testimony today:
HP's history and leadership in electronics recycling,
including the effect of these recycling activities on design
and manufacture of HP products as a means of reducing the
overall environmental impact of our products.
The need for further research into creating
innovative recycling and disposal methods for the leaded glass
from CRT tubes and the older plastics from electronics in order
to find innovative, effective reuse options for these materials
of concern.
Increasing the understanding of regulators,
environmental groups, and the general public on the subject of
the environmental issues surrounding the management of
discarded electronics, and the appropriate level and type of
regulation surrounding recycling operations and the shipment
and handling of whole products. Additional research on these
issues is warranted ensure that the emerging electronics
recycling industry can find market- and economic-based
solutions for recycling and reuse, while also providing for
protection of the environment.
The necessity of research into the net carbon or
climate impact of electronics recycling is crucial to designing
appropriate collection, reuse, and recycling systems,
particularly given the likelihood of future legislation that
limits emissions of greenhouse gases or places greater costs on
such emissions.
I. HP'S RECORD OF ACHIEVEMENT IN RECYCLING ELECTRONICS
HP has been recycling used electronics for over 21 years. HP has
made great strides in increasing the volume of our products recovered
for reuse and recycling. However, the number of PCs, servers, print
cartridges and other electronics reaching the end of their usable life
is growing rapidly. In order to meet this need, HP offers a variety of
recycling services to customers in 52 countries and territories
worldwide.
Managing this increasing volume of discarded equipment conserves
natural resources by reducing the need for raw materials and energy to
manufacture new products. As such, our commitment to responsible
product reuse and recycling is integral to meeting our energy
efficiency objectives.
Product reuse and recycling offers other benefits as well.
Remarketing used equipment is profitable for HP, and businesses and
consumers are increasingly seeking out manufacturers that offer
responsible reuse and recycling options for used equipment. Plus, many
governments have passed legislation, such as the European Union's Waste
Electrical and Electronic Equipment (WEEE) Directive, requiring that
discarded electronic equipment be recycled. Our proactive approach to
product reuse and recycling helps us meet legal requirements, maintain
access to markets and win business.
HP began remarketing used equipment in 1981 and recycling in 1987.
This year, we exceeded our goal to recycle one billion pounds (450,000
metric tonnes) of electronic products and supplies by the end of 2007.
We have set an aggressive new goal to recover an additional one billion
pounds for reuse and recycling by the end of 2010.
Beyond that major milestone, our world wide efforts in 2007 yielded
significant progress. Specifically, we:
Increased our annual recycling volume by more than 50
percent over 2006 to 113,000 tonnes (250 million pounds). For
comparison purposes, the Environmental Protection Agency (EPA)
has reported that our nearest competitor recycled 78 million
pounds. See ``Plug Into e-Cycling with the EPA: 2007
Activities'' (EPA 530-F-08-002).
Collected approximately three million hardware units
weighing 28,500 tonnes (63 million pounds) for reuse and
remarketing, an increase of more than 31 percent compared to
2006.
Increased the volume recovered for reuse and
recycling as a proportion of relevant sales from 10 percent in
2006 to 15 percent.
Introduced recycling programs in several countries,
including Bulgaria, Indonesia, Malta, Philippines, Romania and
Turkey.
Introduced several products that use recycled
materials and include features to facilitate recyclability.
We offer a range of take-back services for both companies and
consumers. Responsible take-back is core to our leasing and reuse
services, and saves customers time and expense managing old equipment.
Free return and recycling is available for print cartridges in 47
countries or territories. We make arrangements with commercial
customers depending on the equipment involved and the specific
circumstances. Consumer recycling services vary from country to
country, depending partly on local regulations.
In all cases, it is important to manage the disposal of returned
equipment to protect data security. We have safeguards in place for all
products we take back, whether by trade-in, via donation or through our
recycling services.
The equipment returned to HP is managed through a network of
partners and service providers who perform the recycling of the
equipment. HP formerly partnered with a large electronics recycling
company to operate two recycling centers in the U.S.; our partner now
operates these facilities with the assistance of HP. HP invested in the
development of those recycling centers in order to directly participate
and lead the development of the types of technology and processes
necessary to recycle used electronics to the environmental and data
security standards we require. Over time, an infrastructure has started
to emerge which has created an ability for HP to reduce our focus on
the actual recycling operation and to renew our focus on the design of
products which are easier to recycle and can include recyclable
commodities in their manufacture as well as the development of
recycling services for our customers.
Any reusable equipment is segregated. From there, any customer data
is destroyed and the equipment is then reused either in whole or in
part. Equipment without a reuse channel is sent for removal of any
hazardous components (typically CRT glass, batteries or other
elements). After removal of any hazardous components the equipment is
either manually or mechanically separated into a variety of basic
commodities: various types of precious and base metals, plastics and
other constituent materials. These materials are processed in the
separation process to create valuable commodity streams which are then
sold for reuse into a variety of industrial processes. These include
the manufacture of new parts and products for a number of industries,
including, in some cases, the electronics industry.
II. RECYCLING AND ITS IMPACT ON HP's PRODUCT DESIGN
HP established our Design for Environment (DfE) program in 1992,
and it remains central to our business strategy today. Our approach to
DfE encompasses the entire product life cycle. In addition to
considering important product attributes such as energy efficiency and
materials innovation, design for recyclability (DFR) is one of our
primary design for the environment priorities. We believe that our
experience and expertise in recycling provides an important feedback
loop to designers to design future products so that they can be more
readily recycled.
HP's DFR efforts include using common fasteners and snap-in
features and avoiding the use of screws, glues, adhesives and welds
where feasible. This makes it easier to dismantle products and to
separate and identify different metals and plastics. The materials we
choose can also enhance recyclability. For example, in 2007 we
introduced several notebook PC models with LED technology, eliminating
mercury fluorescent tubes and making the display screens easier to
manage at end-of-life. These efforts have significantly improved the
recyclability of HP products, and we are pleased to report the
following:
HP notebook PC products are now more than 90 percent
recyclable or recoverable by weight (as per the definition used
in the European Union WEEE regulations).
HP printing and imaging products are typically 70
percent to 85 percent recyclable or recoverable by weight (as
per the definition used in the European Union WEEE
regulations).
We also made great progress in incorporating recycling materials
into our products. For example, HP has engineered print cartridges that
use recycled plastic without compromising quality or reliability. We
design HP print cartridges to meet the needs of our recycling system
and incorporate recycled material. Since we take back only our own
cartridges, we can be certain about the material content, making it
easier to process exhausted cartridges and reuse the material to
manufacture new ones. More than 200 million cartridges have been
manufactured using the process through 2007. HP used more than five
million pounds (2,300 tonnes) of recycled plastic in its original HP
inkjet cartridges in 2007, and the company has committed to using twice
as much in 2008. HP also uses post-consumer recycled plastic recovered
through our return and recycling program in the manufacture of original
HP LaserJet print cartridges. This recycled plastic can represent as
much as 25 percent, by weight, of the newly molded LaserJet cartridge
housing. HP has also incorporated recycled content into some hardware
products. For example, in 2007, we introduced a speaker module made
from 100 percent post-consumer recycled plastics in all HP Compaq 6500
and 6700 series Notebook PCs.
We strive to use recycled plastics in our products, but their
potential is limited for several reasons:
Most recycled plastics contain substances such as
BFRs, which we have eliminated from the external cases of our
current products. (See Part III below).
Mixed plastics do not have the mechanical properties
necessary for use in new IT products.
It is difficult to separate dissimilar plastics
during recycling to produce a homogeneous material.
As we discuss in further detail below, Congress should consider
supporting research on ways to promote the use of recycled materials in
future products and help overcome these challenges.
As one outside observer states in HP's Global Citizenship Report
(see http://www.hp.com/hpinfo/globalcitizenship/gcreport/productreuse/
perspectives.html) :
HP has made significant strides in design for recycling. Its
engineering and design teams have taken into account the
concerns of refurbishers and recyclers by creating products
that can easily be repaired, refurbished, disassembled or
recycled. Such enhancement in product design has been augmented
by the company's assistance to recyclers, making available to
them guidelines that greatly simplify the recycling process.
Among the latest of the company's techniques in the area of
design for recycling is the concept of modular design, which
combined with the use of the proper ``environmentally-
friendly'' materials help HP to increasingly establish itself
as a leading ``green'' IT supplier. HP further pushed to reduce
its products' environmental impact by incorporating more easily
recyclable plastics, reducing the number of different plastic
types in a single product and replacing coating and paint with
molded-in colors. Furthermore, reuse, as a way to extend the
life of a system, has been facilitated by HP's modular design
approach, enabling simple component swapping during the
refurbishing process.
These efforts have resulted in HP products qualifying for a large
number of global ecolabels, including the EPEAT (Electronic Product
Environmental Assessment Tool) designation in the U.S. HP is working
hard to improve our record of success in this area, including
establishing the following goals:
Double the use of recycled plastic in print
cartridges in 2008 compared to 2007, to 4,500 tonnes (10
million pounds)
Eliminate the remaining uses of BFRs and PVC from new
computing products launched in 2009 as technologically feasible
alternatives become readily available that will not compromise
product performance or quality and will not adversely impact
health or the environment
III. INNOVATION NEEDED TO INCREASE THE RECYCLABILITY OF ELECTRONIC
PRODUCTS
There are two materials which present particular challenges to the
current recycling processes used within the electronics industry and
which will present even greater challenges as time progresses. These
materials are (a) the leaded glass found in CRT tubes and (b) plastics
which may contain flame retardant additives which have been banned from
further use in many countries in the world.
A. CRT glass
Cathode Ray Tubes (CRTs) are the glass picture tubes found in
previous generations of computer monitors, televisions, and other
displays. CRTs contain leaded glass for two reasons:
It improves the optical quality of the glass. Adding
a small amount of lead to glass is very common when creating
glass for lenses, and you may have also heard of leaded
crystal. Optical quality is especially important at the front
of the CRT.
It acts as a shield against radiation generated by
the electron gun and electron beam.
Users of computer equipment are in the process of transitioning
from CRT displays to flat panel technologies, but large volumes of
traditional CRT displays remain in use or in storage. This presents a
recycling and logistical challenge. Among other things, one important
challenge is the limited current opportunities to reuse leaded CRT
glass. Congress should consider support for research in new
applications for leaded glass in building, the medical field, and other
applications.
B. Plastics containing banned/restricted flame retardants
Both the internal circuit boards and the external plastic housings
of electronic products contain chemical flame retardants for fire
safety purposes. Many of the chemical flame retardants used in the
past, such as brominated flame retardants (BFRs), have come under
increasing scrutiny by environmental and health officials in many
countries, and several U.S. states and many countries have banned or
restricted the use of some of these chemicals. These chemicals cannot
be removed from the plastics, so as a result the presence of these
chemicals in plastic parts presents a significant recycling and reuse
challenge. To address this concern, Congress should consider support
for research on reuse opportunities for plastics containing banned or
restricted chemicals.
IV. RESEARCH NEEDED ON THE PROPER REGULATORY APPROACH FOR THE
CLASSIFICATION OF USED ELECTRONICS
The Federal Government can play an important role in promoting
recycling by establishing an appropriate regulatory framework for
managing used electronics, including the removal of regulatory
impediments to cost-effective recycling. Under some interpretations of
current federal and State regulations, used electronics may be
classified as ``hazardous waste,'' even though they are routinely used
in our homes and offices and pose no risk to human health or the
environment when properly stored, transported, and recycled. When these
used products are classified as hazardous waste, they become subject to
burdensome and costly regulatory requirements associated with their
collection, storage, transportation, and processing. When classified as
``hazardous,'' these regulations can impede the development of a cost-
effective recycling infrastructure without adding to greater
environmental protection. Congress and the EPA should work to reform
these regulatory requirements to facilitate recycling of used
electronics, while continuing to protect human health and the
environment.
Additional research should be conducted regarding the actual
environmental and human health risks associated with the storage,
transport, and recycling of used electronics. This research should also
consider whether new test methods for assessing these risks should be
developed, instead of the current practice of using the test method
developed and employed for testing industrial process waste.
V. RESEARCH INTO THE NET CLIMATE IMPACT OF RECYCLING OF ELECTRONICS
Another area that warrants further research is the overall climate
impact of recycling discarded electronics. There is currently little
data on the net carbon impacts of collecting, transporting, and
processing large volumes of discarded electronics. In a future ``carbon
constrained'' world, these impacts need to be better understood.
Recycling can play a positive role in addressing climate change by
conserving resources such as precious metals contained in electronics,
and displacing the energy impacts associated with mining or otherwise
producing necessary raw materials. But the process of collecting and
transporting these products on a large scale will also generate
emissions of greenhouse gases, and therefore contribute to climate
change. We need a better understanding of whether the benefits of
recycling these products outweigh the potential adverse climate impacts
associated with this activity, as well as ways of mitigating any
adverse impacts. Unfortunately, little research has been done in this
area to enable policy-makers and industry to understand these impacts
and assess ways of mitigating them. These climate impacts can also have
an important effect on the economics of e-recycling in a future world
where emissions of greenhouse gases are capped or otherwise restricted.
V. CONCLUSION
HP is committed to strengthening our leadership in e-recycling and
innovative product design. We have suggested a number of areas for
further research that would enable HP and others in the tech industry
to do a better job at these tasks. HP looks forward to working with the
Subcommittee and other Members of Congress on the development of a
national recycling system that leverages the capabilities and expertise
of manufacturers, retailers, recyclers, and others to achieve efficient
and low cost opportunities for all consumers.
Biography for Renee St. Denis
Renee St. Denis is the Director of Product Take-Back and Recycling
in the Hewlett Packard Americas organization. In this role, Ms. St.
Denis represents HP on issues relating to the sound end-of-life
management of electronics. Ms. St. Denis and her team are responsible
for developing environmentally sound disposal solutions for all excess
and obsolete Hewlett-Packard products, as well as developing customer
solutions and legislatively required take back programs across the
Americas.
Ms. St. Denis and her team manage take back and recycling programs
at several locations in the U.S., Canada and Latin America with several
suppliers. These programs account for in excess of four millions of
pounds of hardware products and supplies being responsibly recycled
each month. Finally, Ms. St. Denis is responsible for designing and
implementing systems which ensure the compliance of HP with regard to
manufacturer-responsibility and fee-financed take back legislation
across the Americas.
Ms. St. Denis received her Bachelor's Degree in Finance at the
University of the Pacific in Stockton, California, and her Master's of
Business Administration at the University of Southern California in Los
Angeles, California. Renee has worked for Hewlett Packard for 17 years
in a series of operational and management roles. Prior to joining HP,
Renee was employed in a variety of roles regarding quantitative
analysis of financial instruments.
Chairman Gordon. Thank you, Ms. St. Denis, right on time.
Mr. Eric Harris is recognized.
STATEMENT OF MR. ERIC HARRIS, ASSOCIATE COUNSEL/DIRECTOR OF
GOVERNMENT AND INTERNATIONAL AFFAIRS, INSTITUTE OF SCRAP
RECYCLING INDUSTRIES
Mr. Harris. Mr. Chairman, Members of the Committee, good
morning. My name is Eric Harris. I am here today representing
ISRI, the Institute of Scrap Recycling Industries. ISRI is the
world's largest trade association of recyclers with 1,550
member companies and over 3,000 facilities throughout the
United States. Our members process, broker, and industrially
consume a number of recyclable commodities including metal,
ferrous and non-ferrous, paper, plastic, glass, textiles, tires
and rubber, and of course, electronics. Twenty percent of
ISRI's membership now focuses on electronic recycling. In fact,
it is our association's fastest growing segment.
Our electronics recyclers provide comprehensive recycling
operations, everything from logistics, including collection and
transportation, to asset management, that is, cleaning hard
drives and testing and reselling for reuse, and of course
processing electronics scrap to extract the various commodities
such as steel, gold, titanium, silver, copper, plastics, and
glass for use as valuable material feedstock in the
manufacturing of new products.
So what are some of the key challenges for electronics
recyclers? The first, something very sensitive to our industry,
is hosting this issue with the moniker of waste. In our
opinion, scrap is not waste and recycling is not disposal. It
is very important to distinguish between scrap and waste as
well as recycling and disposal. Simply stated, scrap is the
opposite of waste. Electronic scrap like scrap paper and glass
and plastic and metal and so forth is not waste when
responsibly recycled. Defining scrap electronics as waste
undermines and overlooks the values that those electronics
retain when properly recycled.
One of the other biggest concerns we have in the industry
is the cost to collect, transport, and responsibly recycle
household electronic equipment, which remains the greatest
challenge for our industry for two primary reasons. Household
electronics, as Mr. Williams has already pointed out, some of
the equipment has a negative cost to recycle. In other words,
it costs more to recycle the equipment than the value you can
extract from processing it. In addition, existing law, federal
law, allows household electronic equipment to be sent to
subtitle D landfills. This creates a tension in the market
because we lack the contractual connection with the consumer
and there is a behavioral pattern that suggests that this
equipment should continue going to the landfill.
Because of these reasons, until a sustainable market
presents itself, ISRI does support a short-term financial
mechanism from OEMs that would allow us to have help to
collect, transport, and responsibly recycle those household
electronic equipment goods that have a negative cost to
recycle, for example, the cathode ray tubes in the televisions
and monitors of today's market. There are three primary reasons
why, this will enhance competition and not inflate the value of
the recycling service that our members provide. The OEMs have
greater access to their own customers. They can convince and
educate their customers on the value of responsibly recycling
the materials they sell. And lastly, it provides an incentive
for the OEMs to design their products with an eye towards
recycling. A great example in today's market is manufacturers'
continued use of mercury in their products. If you see the
flat-screen monitors and televisions, if you take the time to
refurbish that system, pull the back panel off, what you will
see is a row of fluorescent bulbs that have mercury powder.
They are difficult to replace and they are difficult to remove
for recycling. As a result, they are not cost-effective in
today's market. We need to encourage more collaborative
programs to work with the OEMs to improve their design.
On the commodity side, we need better markets for scrap
plastics and scrap glass. CRT glass-to-glass manufacturing is
becoming more and more obsolete throughout the world, and the
few lead smelters that are remaining are actually refusing new
contracts from recyclers to process their CRT glass. This is
only complicated further by the four to eight pounds of leaded
glass that we see in the monitors and TVs entering in today's
market. As a result, recyclers have fewer and fewer markets for
the CRT glass. In our terms, this is a barn-burning issue: what
do we do with the glass?
For plastic, it remains difficult to separate and sort
commingled plastic resin streams to the quality that compete
with virgin plastics. You have to imagine a truckload of
commingled electronics from toaster ovens to monitors to radios
shows up at our facility and now we have to process that
material and process the plastic to a point where it can
compete with virgin plastic. This is a challenge.
All in all, what this does is creates hesitancy in the
marketplace. Recyclers are hesitant to further invest in the
technology needed for greater automation and optical sorting to
address the CRT glass and the plastic. So how do we inject
investor confidence? We would suggest targeted research and
development to new and used markets for mixed scrap plastic and
glass and potentially investment incentives for new recycling
equipment such as an accelerated depreciation model for new
recycling equipment that is energy efficient and climate
friendly and designed to increase recyclable yields.
And lastly, how do we find a responsible recycler? There
are a spectrum of players on the market from the leaders of our
association all the way down to what we call the sham recyclers
out there, and we would caution the Committee for the need for
new laws and regulations and would encourage enhancing policy
that rewards responsible recycling. On our side of the
equation, we have created a Recycling Industry Operating
Standard, or RIOS, that is an integrated, comprehensive
management system that incorporates environment, health and
safety and quality goals for the recycler in tomorrow's market.
[The prepared statement of Mr. Harris follows:]
Prepared Statement of Eric Harris
Mr. Chairman and Members of the Committee. Good Morning. My name is
Eric Harris and I am the Associate Counsel and Director of Government
and International Affairs for the Institute of Scrap Recycling
Industries, Inc.--the ``Voice of the Recycling Industry.''
Introduction
ISRI is the world's largest trade association of recyclers with
well over 1,550 member companies that operate over 3,000 locations in
the United States who process, broker and industrially consume scrap
commodities, including metals, paper, plastics, glass, rubber, textiles
and electronics. More than 20 percent of ISRI's membership is involved
in electronic scrap processing and industrial consumption of scrap
material generated by electronics recyclers. In fact, electronics
recycling is the fastest growing segment of ISRI's membership.
In 2007, the domestic scrap recycling industry manufactured
approximately $71 billion of specification grade commodities that were
used in lieu of virgin materials to manufacture basic products in the
United States and throughout the world. This figure includes more than
81 million tons of iron and steel, five million tons of aluminum, 1.8
million tons of copper, and two million tons of stainless steel, just
to name a few. Of the $71 billion of scrap recycled last year, nearly
$22 billion worth of these commodities were exported to 152 countries
worldwide, making a significant positive contribution to the United
States' balance of trade with other nations and serving as the first
link in the global manufacturing supply chain. Scrap accounts for
approximately 40 percent of the world's raw material needs.
Scrap recycling is one of the world's most climate friendly
activities. The use of recycled scrap materials to manufacture new
products sustains the Earth's natural resources, while at the same
time, conserves impressive amounts of energy in the manufacturing
process, and thereby significantly reduces greenhouse gas emissions
from those facilities.
For example, recycling 1,000 computers and monitors rather than
landfilling them would prevent a net total of 52.64 metric tons of
carbon equivalent (MTCE) and 193 metric tons of carbon dioxide
equivalent (MTCO2) from entering the atmosphere. This is the
equivalent of not driving 42 cars for an entire year. This would also
save over 3,370 million BTUs. And, the energy savings would equal
27,171 gallons of gasoline.\1\
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\1\ United States Environmental Protection Agency WAste Reduction
Model (WARM), http://www.epa.gov/climatechange/wycd/waste/calculators/
Warm -home.html
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U.S. Electronic Scrap Generation and Recycling
Approximately 2.8 billion pounds (1.4 million tons) of electronic
equipment were recycled in 2006, including 65 million units of computer
equipment (CPUs, monitors and printers). The electronics recycling
process yielded approximately 1.3 billion pounds of recyclable
materials, more than half of which were metals. Consumer electronics,
alone, are now considered to be approaching more than three million
tons generated annually.
According to a recent study by the Consumer Reports National
Research Center, E-Waste 2006, 90 percent of Americans own at least one
computer. That means there are over 270 million computers in America.
However, 45 percent of American consumers retain electronics because
they are unsure of the appropriate method to deal with such items at
the end of their useful lives. Moreover, 35 percent of American
consumers retain electronics because they consider it inappropriate to
dispose of them with the garbage. Consequently, upwards of 50 percent
of American consumers have yet to send their obsolete electronic
equipment into the recycling stream.
With the proliferation of new electronic products every day,
obsolete consumer electronic equipment levels are expected to increase
to 400 million units annually during the rest of the decade, including
100 million units of computer equipment. If we combine both consumer
and non-consumer computer equipment (commercial, industrial and
government sectors), we can estimate that more than two billion will
become obsolete over the next five years.
ISRI members provide comprehensive recycling operations, which
covers everything from logistics (e.g., collection and transportation)
and data security to de-manufacturing, to manufacturing specification
grade commodities from the electronic products. Our members make their
living scrubbing and reselling hard drives, by testing and then
reselling cell phones, monitors and CPUs that are in good working
order, and using machinery and equipment to shred or otherwise process
electronics to extract the various commodities that are contained in
electronic equipment including steel, aluminum, gold, silver, titanium,
copper, nickel, plastic and glass--for use as valuable raw material
feedstock in the manufacture of new products.
Once electronics products reach our members they are first triaged
to determine whether they are to be resold, refurbished, or processed
into specification commodity streams.
Whether the decision is made to refurbish or process into
specification grade commodities, the export market for the resulting
product is an essential part of the legitimate recycling chain. With
regard to reusable or refurbished electronics, there is an increasing
presence of large for-profit reuse markets in developing countries,
especially Asia, Africa, and South America, where the majority of the
population simply cannot afford to purchase the latest available
technology. It is both environmentally and socially responsible to
provide for the continued export of these viable products that make
basic technologies and communications available where they would
otherwise potentially not be. There is now even a growing market in the
third world for the purchase of monitors to be converted into TVs.
As a result of the above, recycling experts anticipate that as
collection of household electronic equipment in the United States
increases, exports of certain recyclable streams will also increase;
for example, used, intact equipment for reuse; used components for
reuse; used equipment for refurbishment; and, fully processed materials
for use as raw materials in manufacturing.
Key Challenges
The key challenges to increasing electronics recycling in the
United States include, among other things: (1) how to adequately cover
the costs associated with collection, transportation and recycling of
household electronic equipment; (2) distinguishing scrap from waste and
not over regulating; (3) free and fair trade; (4) developing adequate
end-use markets for recyclable plastics and glass and demand for that
material; (5) Design for Recycling; and, (6) promoting EPA's
Responsible Recycler practices and ISRI's Recycling Industry Operating
Standard (RIOS) as the proper means to address environmental concerns.
How to adequately cover the costs?
The cost to responsibly recycle electronic products remains the
greatest challenge for recyclers. As the competition to collect
household computer equipment increases across the country, recyclers
are being forced to take in a growing list of older, less valuable
electronic equipment, such as televisions, AM/FM radios, and old
hairdryers. Under current market conditions, much of the collected
electronic equipment, for example at weekend collection events, has
little to no resale value and has a net-negative cost to recycle (the
cost to recycle the equipment outweighs the value of the processed
material). This problem is only exacerbated when you factor in the
logistical challenges and associated costs to get the collected
electronic equipment transported to a facility that can responsibly
recycle it.
As a result, until such time as the market for recyclable
electronics becomes economically viable, ISRI's policy continues to
support holding producers responsible for the collection,
transportation and recycling of household electronic equipment that has
a net-negative cost to recycle, such as cathode ray tubes in monitors
and televisions. ISRI firmly believes that producer responsibility will
provide manufacturers with the needed incentive to design their
products with an eye to the future, incorporating design changes that
maximize recycling at the end-of-life. This concept, which ISRI calls
Design for Recycling, is critical to the success of increasing the
recycling of electronics long term. In the interim, as successful
business people, we believe that if given the flexibility and
opportunity to internalize the costs manufactures will create a model
that will be less bureaucratic and burdensome and cheaper for the tax
payer.
While ISRI will ultimately defer to the wisdom of the Congress and
the states to decide which financial mechanism is most apt to spur
markets for electronic recycling, we strongly encourage the Congress
and the states to end any financial mechanism as soon as markets for
recyclable electronics become economically viable. We are not an
industry that seeks government subsidies, and we believe markets must
ultimately stand on their own based on solid business principles.
However, whatever financial mechanism the Congress and the states
might decide to adopt in order to sustain this market, ISRI suggests
that a portion should be applied to the research and development of
end-use markets for the scrap materials recovered from electronics
products, particularly plastics and glass.
Scrap is not Waste, Recycling is not Disposal
For recycling in general, and particularly for electronics
recycling, we need to avoid creating unnecessary impediments. It is
very important to distinguish between scrap and waste as well as
recycling and disposal. Simply stated, scrap is the opposite of waste.
Processed scrap materials are commodities that have a significant value
on domestic and international markets as raw material feedstocks that
substitute for virgin materials in the manufacture of new basic
materials such as copper, steel, and plastics. Unlike scrap, `waste'
has no value and is typically buried in a landfill.
Electronics scrap, like scrap paper, glass, plastic, metal,
textiles, and rubber, is not waste when recycled. Defining scrap
electronics as waste undermines and overlooks the value that these
electronics retain, if properly recycled. Saddling them with the
moniker of ``waste'' imposes a whole host of unwarranted regulatory
burdens that will undermine the ability to allow the recycling system
to operate effectively and efficiently.
Private sector electronics recyclers are subject to all the federal
and State environmental, safety, and export/import regulations that are
applicable to any industrial operations. For example, recyclers
currently operate under a host of applicable environmental regulations,
such as permitting requirements in the Clean Air Act, the Clean Water
Act and its various storm water provisions, among others. In addition,
electronics recyclers adhere to State requirements which in some cases
are more stringent than the corresponding federal requirements, federal
and State transportation and occupational safety and health laws, U.S.
export laws and regulations and the import requirements of foreign
countries, such as those administered by China's General Administration
on Quality Supervision, Inspection and Quarantine (AQSIQ).
For these reasons, it is critically important that we avoid
confusing the valuable commodities manufactured by scrap recyclers with
wastes, whether in our vernacular or in written form.
Free and Fair Trade
Another key aspect underlying ISRI's policy is the concept of free
and fair trade. We have been in the recycling business a long time and
experience tells us that the specification grade commodities we
manufacture are some of the best examples of basic supply and demand
economics. These materials are traded in the global marketplace,
supplying America's basic manufacturing industries with valuable raw
material feed stocks that are used in place of virgin materials, and
also contributing significantly towards a positive balance of trade
with other nations. And these global markets are far from new--the
London Metal Exchange started trading copper in 1876, harnessing an
already existing global market in copper.
Despite the realities of the global marketplace, however, exporting
electronic scrap continues to be besmirched. We have all seen the
horrendous photographs and broadcasts regarding China's artisan
communities. But, there has been little to no coverage regarding
China's sophisticated recycling parks, which have been developed in
China over the past ten years in an effort by the Chinese government to
reign in the ``rogue recyclers'' who have been responsible for some
terrible situations. However, costs and demand for scrap material is
still driving the market. Experts tend to agree that this is largely
being driven by the fact that most of all new electronic equipment is
being manufactured in Asian markets. As a result, since demand is so
high, Asian brokers are able to pay more for the obsolete electronic
equipment than in Europe and the United States. Thus, countries like
China continue to purchase obsolete electronic equipment from countries
all over the world, including the United States.
ISRI contends that the stigma associated with ``exporting'' is
misguided and exports should be viewed from the prism of the realities
of the global economy. The focus must be to promote responsible
recycling globally and concentrate efforts towards enhancing and
promoting environmentally capable facilities that will receive and
properly handle recycled materials anywhere in the world. ISRI suggests
that the United States government should refocus its attention on
negotiating trade agreements with key trading partners around the
world, such as China and India. These agreements could detail the
environmental and safety requirements for these facilities and
establish a process that would allow the materials to flow more on the
basis of value of the commodity and less on the geographic location of
the collection.
Markets for Plastic and Glass
Two of the greatest challenges of electronics recycling are the
difficulties in recycling chemically coated glass from cathode ray
tubes (CRTs) and sorting the different resins of plastic.
ISRI has suggested that State bills and a federal bill should focus
on establishing a short-term financial subsidy for consumer generated
monitors and televisions with CRTs. Moreover, additional markets for
the recycled glass are a critical necessity. If CRT manufacturing is,
as most predict, soon to be obsolete and lead smelters continue to
charge a fee analogous to a hazardous waste landfill fee then recyclers
need alternative end-use markets for that CRT glass. ISRI strongly
recommends that research and development dollars need to be invested to
develop alternative markets.
With regard to plastics, despite the continual improvement in
automation and optical sorting technology (which helps distinguish
between different colors and streams, due to the heterogeneous nature
of input materials) sorting variations of mixed plastic resins remains
a challenge for recyclers. In addition, since the market for engineered
plastics is not fully developed in the United States, the vast majority
of baled plastic is being exported. And, although foreign markets are
driving the price of baled plastic in the right direction, the stigma
on exporting, in general, is creating a lack of confidence in the U.S.
market.
Although no single technology has solved the task of sorting
plastic to a level that can compete against virgin resin streams, the
technology has improved. What is lacking is investor confidence in the
overall market. ISRI contends that as the market matures and end-use
markets for plastic and glass develop investment dollars will follow.
Similar to CRT glass, research and development dollars are needed to
help develop new end-use markets for mixed plastics scrap. This will
create more opportunities in the market place and thus increase
investment confidence in existing optical and sorting technology.
Targeting funds to advance technology in these two fields would
have a positive impact on making end-use consumer markets more
economically viable, which would, over time, ensure these markets could
stand on their own without a subsidy. In fact, ISRI believes it would
be wholly appropriate for the Congress to support research efforts
aimed toward the development of technologies that could remove the
remaining impediments in plastics and glass in order to utilize these
materials in the manufacturing process.
Designing for Recycling
Removing hazardous components from scrap electronic equipment and
sorting through material that is difficult to recycle, such as mixed
plastics, costs recyclers time and money. ISRI has long advocated
working with manufactures to design their products to be easily
recycled at the end of their useful lives, without using hazardous,
toxic constituents, or impediments that can hinder the recycling of
those products.
To date, voluntary calls by the recycling industry to motivate
manufacturers to adopt a Design for Recycling philosophy have been met
with only a tepid response. We do recognize that electronics
manufacturers have taken some steps towards designing for recycling;
however, there is significant room for improvement. For example,
manufacturers use of mercury. The new technology in flat screen
monitors utilizes a system of lamps containing mercury powder. These
mercury lamps are very time consuming to remove or replace, which makes
this new technology difficult to recycle. Similarly, some of the cell
phone batteries with small traces of mercury take up to five minutes to
remove. And, laptops contain tiny mercury lamps that are very difficult
to locate and remove. In the end, it takes a lot of extra time to
recycle in the proper manner. This drives up the labor costs, which
makes recycling these products less profitable. Design for Recycling
will help to avoid these additional costs and improve recycling
efficiency.
More collaborative opportunities are needed to think through some
of these design issues before these products reach the market. For
example, EPEAT is an electronic product design standard adopted by the
Environmental Protection Agency that has been very successful in the
marketplace. Most major computer manufacturers are using EPEAT as their
measure of environmental product design, and are competing to gain
additional credits from EPEAT by going beyond what other OEMs have
done. Some manufacturers have incorporated significant amounts of
recycled plastic in their products. This creates demand for recycled
plastics from computers which increases the value that recyclers can
capture for the material. Similar types of programs could be encouraged
by the Congress.
EPA's Responsible Recycler Practices and ISRI's Recycling Industry
Operating Standard
For the past two years, ISRI has represented electronics recyclers
in a multi-stakeholder process to develop responsible recycling
practices (R2) for electronics recyclers. The Environmental Protection
Agency has convened and facilitated this effort. Once completed, ISRI
intends to incorporate this set of specific performance practices into
its Recycling Industry Operating Standard (RIOS) for electronics
recyclers.
ISRI developed RIOS as an integrated management system standard
designed specifically for the scrap recycling industry and the ANSI-ASQ
National Accreditation Board will oversee the third party registrars
who will audit recyclers. It provides electronic recyclers with an
affordable tool to monitor their quality, environmental, health and
safety goals. Few industries worldwide have endeavored to undertake
such a huge step, but the recycling industry in the United States has
always been, and intends to remain, the global leader in recycling
technology, environmental protection, worker safety and the production
of high quality materials. RIOS is a tool for us to accomplish those
goals and will help assure that ISRI members who recycle scrap
electronics will do so in a manner that is best for our country and the
world in which we live.
ISRI is hopeful that the combination of the EPA led effort, R2, and
RIOS will provide a ``one-stopshop'' for electronics recyclers. This
will help to build needed confidence in the market place and reward
responsible recyclers that are willing to be audited to a set of
requirements in an open and transparent process.
Conclusion
In closing, I want to remind the Committee that our members have
provided stable, good-paying jobs in this country during the boom
years, the lean years, in war time, and in peace time. In one capacity
or another, ISRI members have been recycling electronics for decades as
an integral part of their recycling operations. We feel these
experiences from our membership will assist the Committee in developing
effective solutions that will help address the onslaught of consumer
based electronic products that are now entering the market.
Thank you for this opportunity to address the Committee today. ISRI
looks forward to future opportunities to work with the Committee to
continue advancing these and other solutions on issues important to
recycling.
Biography for Eric Harris
Mr. Harris advocates policy and provides legal counsel for ISRI.
Areas include: climate change and sustainability, electronics, air, the
Basel Convention, and ISRI's arbitration program. Mr. Harris received
his masters of law degree from the George Washington University in
International Environmental law and his law degree from the University
of Montana. Before coming to ISRI, Mr. Harris provided legislative
counsel to U.S. Senator Max Baucus from Montana.
Chairman Gordon. Thank you, Mr. Harris.
Mr. Smith, you are recognized.
STATEMENT OF MR. TED SMITH, CHAIR, ELECTRONICS TAKEBACK
COALITION
Mr. Smith. Good morning, Mr. Chairman, Members of the
Committee. Thank you for inviting me to testify here today. My
name is Ted Smith. I am the Chair of the Electronics Take-Back
Coalition. I am also the founder of the Silicon Valley Toxics
Coalition, former Executive Director there, which was formed 25
years ago to address the issues of health, environment, and the
development of the electronics industry.
I want to run through several slides very quickly. The
problem I think is multifaceted, as you have heard. The
products don't last very long. The equipment is toxic. More e-
waste is thrown away than is recycled. More recyclers simply
export their products to developing countries and the toxic
components resulting from poor design make e-waste hard to
recycle. The shrinking lifespans is one of the serious issues
that we face. New technology drives consumers to buy new
products at astonishing rates. The prediction is 32 million new
television sets will be sold this year and 22 million new
computers will be sold, and the February 17, 2009, digital
conversion deadline is rapidly approaching. We predict that
this is going to mean millions more televisions will be coming
into our waste stream over the next few years.
You have heard that e-waste is toxic--lead, mercury,
cadmium, brominated flame retardants. Our landfills are
beginning to fill up. It is still a small percentage of our
landfill waste but it is the fastest growing, as you have
heard, and of all the equipment that is currently being
collected, we predict that something like 87.5 percent is
currently being trashed and only 12.5 percent is being
recycled. And this is the key: Of the products that are being
recycled or collected for recycling right now, we estimate that
50 to 80 percent are being exported for processing in
developing countries, and what this looks like is, some of the
most primitive processing you can imagine. There is video of
this that I highly recommend if people have time to look at it,
but what we know is that the products are being taken apart
with hammers and that they are being burned. They burn the
plastics in order to get the metals, which have value, and when
they burn the plastics, it is creating dioxin clouds which are
affecting the children in these communities throughout the
developing world. This is happening in China. It is happening
in Asia. It is happening in Africa. This is one of the biggest
problems that we are facing right now and I think the United
States is primarily responsible for this.
So what can Congress do? We do support strong producer
responsibility. We have been working with State legislatures
around the country. There are now almost a dozen states that
have passed laws. Most of them are producer responsibility. We
do think that we need to close the door on exporting the
hazardous e-waste to poor countries and we do need to promote a
comprehensive green design initiative. Producer responsibility
means electronic manufacturers should bear the responsibility
throughout the product life cycle. This is a design initiative
that started in Europe which has now spread around the world
and we are working actively to bring it into the United States.
We think that the legislation needs to include strong goals and
timetables that drive increases in recycling and we support
federal legislation but only if it is strong legislation and
not lower than what is already happening in the states and
certainly we don't want to see a situation where the Federal
Government would pass legislation, preempt the states and have
a lower standard than what is already happening out there.
But primarily we think that the role of the Federal
Government can focus on two things: it is preventing the export
of the hazardous waste because the states cannot address that.
We know that there are good processing options that do exist in
the United States and other developed countries and we think
that we do need to ban the export of the toxic e-waste so that
we can prevent the harm that we know is going on.
But the other major initiative that I would like to talk to
you today about is what we think that the Federal Government
can do to encourage green design and green engineering. E-waste
would not be an issue if the products themselves were not so
toxic, and industry's efforts to green their products are
increasing but we think still inadequate compared to rapid pace
of the design changes. The manufacturers can design electronic
products using green chemistry and green engineering principles
to make their products more durable, more upgradeable, to be
carbon neutral, fully recyclable and requiring fewer
unsustainable materials. We think that a national sustainable
electronics initiative is the way to go where we can combine
some of the best thinking in the country from within industry,
within academia, within government agencies, public health and
environmental organizations to develop the new strategies, not
only to address the problems of electronic waste but also to
really try to solve these problems at the front end, which we
do think is the place where we need to do it, and we think that
the new initiative could be composed of a national clean
electronics council, which would be a governing body, again a
multi-stakeholder body, as well as a national clean electronics
research and development fund funded by Congress. We think that
the appropriate role could be to assess the current and future
environmental and human health impacts, develop strategic plans
to identify priority research needs, funding public and private
research institutions, and to assure the diffusion and adoption
of safer and cleaner technologies.
Thank you very much.
[The prepared statement of Mr. Smith follows:]
Prepared Statement of Ted Smith
E-WASTE: The Exploding Global Electronic Waste Crisis and Why Green
Design Is the Solution
[GRAPHIC(S) NOT AVAILABLE IN TIFF FORMAT]
Introduction
I am Ted Smith, the Chair of the Electronics TakeBack Coalition, a
national coalition of organizations promoting green design and
responsible recycling in the electronics industry. I was also the
Executive Director of the Silicon Valley Toxics Coalition, an
organization I founded 25 years ago.
The Electronics TakeBack Coalition appreciates the opportunity to
speak to the Committee today on this important issue of electronic
waste.
What's the problem we need to solve?
The electronics we buy don't last very long, and we
are buying them at increasing rates. Shorter product lifespans,
coupled with explosive sales in consumer electronics, mean that
more products are being disposed of, and discarded computers,
TVs, and other consumer electronics (so-called e-waste) are now
the fastest growing waste stream in the U.S.
Electronic products contain many toxic materials
because they are not designed properly. E-waste contains toxic
materials harmful to humans and our environment. Over 1,000
materials, including chlorinated solvents, brominated flame
retardants, PVC, heavy metals, plastics and gases, are used to
make electronic products and their components.
Most e-waste is thrown in the trash--only a small
amount, around 15 percent, is collected for ``recycling.'' It's
legal in most states to put e-waste in the trash.
Most ``recyclers'' actually export the products they
collect to developing countries with no worker safety or
environmental protections. There the products are dismantled
and separated using such primitive and toxic technologies that
workers and communities are exposed to many highly toxic
chemicals. Consumers have no way to know if the recycler at
their city's Earth Day collection event is really going to
recycle their old product, or load it in the container and ship
it to China.
Toxic components and poor design make e-waste hard to
recycle.
The whole problem is made worse by the fast approaching 2009
digital conversion of television signal, which we see as the largest
government mandated planned obsolescence in history.
[For more details on these aspects of the problem, please see the
E-Waste Briefing book, in the Attachments.]
How do we solve the problem?
1. Establish Producer Responsibility for electronic products at the
``end-of-life.''
The first step in solving the problem is to mandate producer
responsibility--something that is already happening in State
legislation. We need the manufacturers to be responsible for taking
back and recycling their products when we are done with them. We
believe that if they have financial responsibility for their products
at disposal time, then they will have an incentive to design them to be
more recyclable. While the cost of recycling is passed on to the
consumers, the cost is internalized into the price (not added as a
visible fee), which rewards the companies who have designed their
products to be more recyclable. Since their better-designed products
will cost less to recycle, they can add a lower amount to their price
to cover the recycling.
We support strong producer responsibility legislation, that
includes goals and timetables that act to drive the companies to do
more recycling than they are doing with voluntary programs. Some
companies do have voluntary take-back programs, but except for Sony,
none of the television companies--the ones selling over 30 million TVs
each year in this country--have a national take-back program. In fact,
they have been lobbying against legislation to require them to take-
back their products. And for the companies that do have programs, the
volumes are not significant enough to solve this problem. Dell and HP's
take-back programs only take-back about 10-15 percent of what they sold
seven years ago. This is why we need legislation that actually drives
them to do take-back in a way that keeps up with the volume of products
they are selling.
``Individual producer responsibility encourages competition
between companies on how to manage the end-of-life phase of
their products. This in turn drives innovation, such as in
business models, take-back logistics and design changes, to
reduce the environmental impact of products at the end of their
life.'' [Joint Statement by a group of electronics companies
and NGOs on Producer Responsibility for Waste Electrical and
Electronic Equipment, March 2, 2007.]
2. Close the door on exporting toxic e-waste to poor countries.
While the states are passing take-back legislation, these laws
can't legally restrict exports. Sadly, it's perfectly legal to export
toxic waste from the U.S. to developing countries, even though it
violates the laws of most of the countries where e-waste ends up. We
are currently solving our e-waste problem by dumping it in poor
countries. And while you will hear from the recycling industry that we
shouldn't prevent export of toxic electronic products or components as
long as they have ``commodity value,'' we believe that if it's toxic,
it's toxic--whether it has value or not--and it should be controlled to
be sure that it isn't poisoning people elsewhere in the world. It's not
that we oppose exporting altogether--it's fine to export once you have
actually removed the toxics from the materials. But that's not what's
currently happening. (Instead, the EPA is just removing these toxic
materials from the definition of ``hazardous waste.'')
So we need the Federal Government to act to close the door on this
export of toxic e-waste to poor countries. Since there are many
processing options for these materials in the developed world, Congress
could solve the problem by banning the export of these toxic materials
to developing countries. This would have the added benefit of creating
more jobs in this country.
3. Promote Green Design and Green Engineering
Producer responsibility helps support redesign of electronics. But
we need some other significant efforts that will result in a wholesale
change in the way the electronics industry thinks about design.
Currently, many companies claim to have ``green products'' when they
have only done two things: reduced the products' energy consumption and
complied with the chemical reductions mandated by the EU. But what I am
talking about is a much broader scale of green design.
We want to see this industry think about the whole life cycle of
their products when they design them--a concept known as Green
Engineering. They shouldn't just consider the product's use as a
product--but also the impacts from production (including resource
acquisition) and disposal of the product. Working from two very good
lists developed by engineers of what comprises ``green engineering,''
we think it adds up to having the industry do the following:
Fully assess and minimize the potential
environmental, human health and social impact of the product's
production, use and end-of-life treatment, including commonly
used recycling and disposal technologies (like shredding).
Don't use customers as the testing ground for whether
materials in the product are safe or dangerous. Ensure that all
material used and or released are as benign and inherently safe
as possible BEFORE putting products on the market, by applying
a precautionary approach to chemical management and by finding
safer substitutes for chemicals that persist and accumulate in
the environment.
Design for carbon neutrality when possible to reduce
the energy impact of the product throughout its life cycle.
Maximize design for reparability, reuse and durable
use to increase the longevity of the product and thereby reduce
consumption of limited material resources.
Plan for recyclability and ease of disassembly of the
product, including using materials that can be recycled easily
into new products, and minimizing waste.
Minimize use of raw virgin materials, and maximize
use of recycled materials, to reduce consumption of limited
natural resources.
Invest in solutions that go beyond our current
dominant technologies to improve, innovate and invent
technologies that achieve sustainability.
Actively engage communities and stakeholders in the
development of new design solutions that improve the life cycle
impact of electronic products.
Focus on Safe Materials
U.S. based high-tech companies know pretty well what materials they
do not want to use in their products based on their toxicity and
overall impact on the environment. But they are not so sure about what
they do want to use. Companies have recently had to phase out the use
of those materials that are now being regulated in Europe and Asia
through laws such as the Restrictions on Hazardous Materials (RoHS).
Likewise, the EU's REACH legislation will have an enormous impact on
chemical use by the electronics industry, since it will cover as many
as 1,800 chemicals that are classified as Persistent Bioaccumulative
Toxics or as carcinogens, mutagens or reproductive toxins.
Since most global companies based in the U.S. no longer do their
own research and development--especially on environmental design--there
is a real need and demand for better environmental assessment tools
that are comprehensive, objective and credible for all stakeholders.
Currently, the U.S. EPA does not certify chemicals as ``safe'' or
``green''--they will sometimes provide data, but they have been unable
to evaluate and assess the data to reach conclusions about which
chemicals or materials are safer and preferable to others. Further, the
system they use to approach these concerns is based on risk rather than
hazard, which is less helpful in the real world. This is the approach
that EPA's Design for the Environment program has adopted.
Currently, federal policy is rudderless--not just for electronics
but for many industries that rely on the use of hazardous materials--
and too often companies simply don't know how to address the many
trade-offs inherent in materials selection. They don't know how to
evaluate the strengths and weaknesses of new materials based on the
trade-offs between reproductive toxicity and global warming potential,
as just one example. There is a new tool, called the ``Green
Screen''\1\ that can be used to help to fill this gap. It provides a
transparent way to ``grade'' chemicals based on actual hazard (not
risk) and tells you which ones are ``better'' to use and which ones are
``worse.'' We think it would be helpful to U.S. industry, particularly
in sectors that have a toxic and energy intensive footprint. But it's a
methodology, and there needs to be sufficient funding and institutional
resources to apply this approach to a lengthy list of chemicals. For
information, see http://www.cleanproduction.org/Green.Greenscreen.php.
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\1\ http://cleanproduction.org/library/Green%20Screen%20Report.pdf
U.S. Falling Behind. The basic university research at industry labs and
within universities is simply not keeping pace with global
developments. Some of the best ``green chemists'' in the country--such
as John Warner at University of Massachusetts, Lowell--are very
concerned that most of his graduate students come from other countries,
since U.S. high schools and colleges and not preparing enough chemists
domestically who want to help meet these challenges. At the same time,
the green chemistry revolution is expanding vigorously in other
countries, such as China and India. I was in China last year on a
university speaking tour, and met many enthusiastic and bright students
who are very excited about using the tools of green chemistry to help
solve the critical problems of environmental design. But in the U.S.,
---------------------------------------------------------------------------
we are falling further and further behind.
What Can Congress do to help promote Green Design and Green
Engineering?
Industry is simply not developing a sufficient green design agenda
on its own. The structure of this industry, where most of the
production is done by various subcontractors around the world--not by
the companies themselves--acts as a disincentive for R&D on green
design. Therefore, we believe that Congress can help by establishing
and funding a National Sustainable Electronics Initiative (NSEI), that
brings together members of industry, academia, government agencies, and
public health and environmental organizations, to insure the rapid
development of electronic products that embrace the Green Engineering
principles--that are cleaner, safer and more sustainable throughout
their life cycle. This initiative would be composed of a National Clean
Electronics Council (a governing body) and a National Clean Electronics
Research and Development Fund (funded by Congress.)
The National Sustainable Electronics Initiative should develop
strategies to:
1) Minimize their environmental and public health impacts on
workers, consumers and communities from manufacture through use
and final disposal or recycling. This includes but is not
limited to:
a) reducing the toxicity and volume of packaging
b) minimizing product shipping throughout its life
cycle, from raw material extraction through disposal
c) reducing or eliminating toxic materials in product
manufacture
d) effective and enforceable environmental standards
to assure that toxic electronic waste will be properly
managed in strict compliance with international and
domestic laws, including the laws of importing and
transit countries, that govern export of hazardous
electronic waste, worker safety, public health and
environmental protection, and the use of market labor
rather than incarcerated labor;
2) Be taken back at the end-of-life by manufacturers
3) Be designed for reuse and recyclability, including
maximizing componentization and part interchangeability
4) Be designed to minimize material use per functional unit
(de-materialization)
5) Minimize energy use/ maximize energy efficiency
6) Fully assess the environmental and public health impacts of
new materials and technologies prior to use and/or market
release (e.g., new chemical components, nanomaterials, bio-
plastics, etc.)
7) Minimize energy use/maximize energy efficiency
8) Fully assess the environmental and public health impacts of
new materials and technologies prior to use and/or market
release (e.g., new chemical components, nanomaterials, bio-
plastics, etc.)
The NSEI would promote a full-life cycle assessment approach for
the electronics industry, with continuous improvement goals to be set
by the National Sustainable Electronics Council in consultation with a
National Sustainable Electronics Research and Development Fund.
The Council, which would be comprised of representatives of the
electronics industry companies, environmental and public health
organizations, and national government agencies, would be responsible
for:
assessing the current and potential future
environmental and human health impacts of consumer electronics
developing a strategic plan for the reduction and
minimization of all detrimental impacts, including the
identification of current barriers and opportunities, the
identification of priority research needs, and the setting of
Strategic Program Goals for the industry,
awarding funding on a competitive basis to
universities, corporations, private research institutions and
national laboratories, for addressing priority research needs,
for eliminating current barriers, and for developing safer and
cleaner technologies,
assuring the diffusion and adoption of safer and
cleaner technologies,
assessing the effectiveness of the implementation of
the strategic plan,
reporting on a bi-annual basis on the performance of
the industry in meeting the Strategic Program Goals, and
managing the Research and Development Fund
4. Promote Tools For Consumers to Select Green Electronics
Consumers always ask us what electronic products are
environmentally preferable. Who makes a ``green TV?'' Which laptop is
greener? The primary tool available for this purpose is the fairly new
EPEAT tool--the Electronic Products Environmental Assessment Tool. It's
like an Energy star label, currently only for business computers. We'd
like to see this expanded to other electronics products, including
Televisions. The EPEAT board was slated to develop standards for
televisions next, but has recently decided to postpone this plan. We
think it's crucial for EPEAT to address televisions as its next target,
since we are buying so many televisions, and because there is so much
new technology coming out in televisions very quickly. We would like to
see Congress provide enough funding to EPEAT to make sure the standards
development process moves forward, plus we would like to see enough
money to allow them to market the EPEAT program in a way that makes it
a viable tool for consumers, not just institutional purchasers.
ATTACHMENTS:
SUSTAINABLE DEVELOPMENT THROUGH THE PRINCIPLES OF GREEN ENGINEERING
Julie Beth Zimmerman
Department of Civil Engineering, University of Virginia
Office of Research and Development, U.S. Environmental Protection
Agency
http://web.mit.edu/d-lab/assignment-files/green.pdf
INTRODUCTION
Concerns regarding population growth, global warming, resource
scarcity, globalization, and environmental degradation have led to an
increasing awareness that current engineering design can be engaged
more effectively to advance the goal of sustainability and that there
will need to be a new design framework that consciously incorporates
sustainability factors as performance criteria. Sustainability has been
defined as ``meeting the needs of the current generation without
impacting the needs of future generations to meet their own needs'' and
is often interpreted as mutually advancing the goals of prosperity,
environment, and society. The 12 Principles of Green Engineering
(Anastas, 2003) are collectively a design protocol for engineers to
utilize in moving towards sustainability.
The impact of population growth has long been understood as one of
the grand challenges to mutually advancing these goals and creating a
sustainable future. When the issue is examined more closely, the data
demonstrate that the vast majority of population growth is occurring in
the developing world while population is stagnant, and in some cases
declining, in the industrialized world (Figure 1). This may suggest
that within the complex equation of growing population including birth
and mortality rates, socio-political pressures, access to health care
and education, cultural norms, etc., there is an empirical correlation
between the rate of population growth and level of economic
development, often equated with quality of life.
This relationship suggests that one approach to be seriously
considered in meeting the challenges of stabilizing population growth
and advancing the goal of sustainability is through expanded economic
development and improved quality of life. Historically, however,
increases in development and quality of life have been inextricable
linked with environmental degradation and resource depletion. There is
a significant amount of evidence that suggests that conventionally an
increasing human population has put an increasing strain on natural
resources used for consumption and waste assimilation. While there is
no single satisfactory index of the state of the environment, the
relationship between population and environment can be analyzed in
terms of resource depletion or dimensions of environmental quality such
as land use, water quantity and quality, pollution generation
particularly from increased energy demand, bio-diversity, and climate
change. A brief review of each of these indicators supports the notion
that, traditionally, population growth has had a detrimental impact on
the environment.
Therefore, the question is how to bring about continued development
and enhanced quality of life in both the developing and developed world
without the historical environmental degradation and resource
consumption. Green Engineering, along with Green Chemistry (Anastas,
1998), are engaged through science and technology on ensuring that
quality of life, or state of economic development, is increasing
through benign chemicals and materials and life cycle-based design as
well as material and energy efficiency and effectiveness. This
decouples the historical relationship of population growth and
environmental degradation on the path towards an improved quality of
life. The 12 Principles of Green Engineering (Anastas, 2003) (see Table
1) provide a framework for scientists and engineers to engage in when
designing new materials, products, processes, and systems that are
benign to human health and the environment.
THE 12 PRINCIPLES OF GREEN ENGINEERING
A design based on the 12 Principles moves beyond baseline
engineering quality and safety specifications to consider
sustainability factors and allow designers to consider them as
fundamental factors at the earliest stages as they are designing a
material, product, process, building or a system. These Principles were
developed to engage in design architecture--whether it is the molecular
architecture required to construct chemical compounds, product
architecture to create an automobile, or urban architecture to build a
city, the Principles are applicable, effective, and appropriate. If
not, the value of these design principles diminishes as their
usefulness becomes dependent on local parameters and system conditions
and they cannot effectively function as global design principles.
The 12 Principles of Green Engineering (Anastas, 2003).
PRINCIPLE 1--Designers need to strive to ensure that all material and
energy inputs and outputs are as inherently non-hazardous as possible.
PRINCIPLE 2--It is better to prevent waste than to treat or clean up
waste after it is formed.
PRINCIPLE 3--Separation and purification operations should be a
component of the design framework.
PRINCIPLE 4--System components should be designed to maximize mass,
energy and temporal efficiency.
PRINCIPLE 5--System components should be output pulled rather than
input pushed through the use of energy and materials.
PRINCIPLE 6--Embedded entropy and complexity must be viewed as an
investment when making design choices on recycle, reuse or beneficial
disposition.
PRINCIPLE 7--Targeted durability, not immortality, should be a design
goal.
PRINCIPLE 8--Design for unnecessary capacity or capability should be
considered a design flaw. This includes engineering ``one size fits
all'' solutions.
PRINCIPLE 9--Multi-component products should strive for material
unification to promote disassembly and value retention. (minimize
material diversity).
PRINCIPLE 10--Design of processes and systems must include integration
of interconnectivity with available energy and materials flows.
PRINCIPLE 11--Performance metrics include designing for performance in
commercial ``after-life.''
PRINCIPLE 12--Design should be based on renewable and readily available
inputs throughout the life cycle.
ADVANCING GLOBAL SUSTAINABILITY
Science and technology will play a fundamental and vital role in
advancing global sustainability by engaging in next generation design
of fundamental products, processes, and systems necessary for
maintaining and enhancing quality of life while protecting the planet.
For global sustainability to be advanced the current operational model
of unilateral knowledge transfer from the industrialized world to the
developing world could be expanded to include knowledge exchange. The
exchange would allow for learning about indigenous knowledge and
traditional design, potentially simple and elegant, which has developed
and adapted for local people and place. This would provide an
opportunity to integrate the best and most appropriate knowledge,
methodologies, techniques, and practices from both the developed and
developing worlds in terms of designing for sustainability. The
examples of innovations in science and technology from the developing
world highlight alternative strategies to deliver services such as
clean drinking water, medical treatment, energy and power production,
material and product development, building technologies and techniques.
CONCLUSIONS
The achievements that have been obtained using green engineering
principles are exceptional examples of design with a new sustainability
perspective. If the challenges of sustainability are going to be
addressed both within the currently industrialized nations as well as
those developing nations whose path to development will be most
consequential for the environment and society, it will be essential
that these new design imperatives be incorporated systematically in the
next generation of products, processes, and systems. Within this
context, the technological dialogue that takes place between the
developed and developing world must be able to consider and utilize
both a high level understanding of complex systems as well as an
incorporation of simple elegance found in millennia of experience and
tradition. The sources of technological inspiration will likely need to
be broad and diverse if we are to design the products and systems of
tomorrow to be sufficiently improved and more sustainable than those of
today.
REFERENCES
Anastas, P.; Warner, J. Green Chemistry: Theory and Practice; Oxford
University Press: London, 1998.
Anastas, P.; Zimmerman, J. ``Design through the Twelve Principles of
Green Engineering,'' Environmental Science and Technology, 37,
94A-101A, 2003.
McDonough, W.; Braungart, M.; Anastas, P.T.; Zimmerman, J.B. ``Applying
the Principles of Green Engineering to Cradle-to-Cradle
Design.'' Environmental Science and Technology, 37 (23): 434A-
441A, 2003.
Mihelcic, J.; Ramaswami, A.; Zimmerman, J. ``Integrating Developed and
Developing World Knowledge into Global Discussions and
Strategies for Sustainability,'' submitted to Environmental
Science and Technology, 2005.
United Nations Department of Economic and Social Affairs (UNDESA),
Population Division, World Population Projections to 2050,
2004.
Zimmerman, J.B.; Clarens, A.F.; Skerlos, S.J.; Hayes, K.F. ``Design of
Emulsifier Systems for Petroleum- and Bio-based Semi-Synthetic
Metalworking Fluid Stability Under Hardwater Conditions,''
Environmental Science and Technology, 37 (23): 5278-5288, 2003.
Zimmerman, J.B.; Anastas, P.T. ``The 12 Principles of Green Engineering
as a Foundation for Sustainability'' in Sustainability Science
and Engineering: Principles. Ed. Martin Abraham, Elsevier
Science, available 2005.
See also http://www.epa.gov/oppt/greenengineering/pubs/
whats-ge.html for more about EPA's Green Engineering
initiative.
Information on EPEAT
http://www.epeat.net/
EPEAT is a system to help purchasers in the public and private
sectors evaluate, compare and select desktop computers, notebooks and
monitors based on their environmental attributes. EPEAT also provides a
clear and consistent set of performance criteria for the design of
products, and provides an opportunity for manufacturers to secure
market recognition for efforts to reduce the environmental impact of
its products.
The EPEAT Registry on this web site includes products that have
been declared by their manufacturers to be in conformance with the
environmental performance standard for electronic products--IEEE 1680-
2006. The standard is summarized here, and may be purchased from the
Institute of Electrical and Electronics Engineers. EPEAT operates a
verification program to assure the credibility of the Registry.
[GRAPHIC(S) NOT AVAILABLE IN TIFF FORMAT]
Biography for Ted Smith
Ted Smith is founder and former Executive Director of Silicon
Valley Toxics Coalition, a grass roots environmental coalition formed
in 1982 in response to environmental pollution caused by electronics
manufacturing in Silicon Valley, California. Ted is also co-founder and
Chair of the steering committee of the Electronics TakeBack Coalition,
which is working to promote life cycle producer responsibility within
the high-tech electronics industry. In addition, Ted is co-founder and
Coordinator of the International Campaign for Responsible Technology
(ICRT), an international network committed to working for the
development of sustainable, non-polluting technologies. He has served
on the boards of several environmental non-profit organizations and is
an environmental stakeholder in formal processes convened by Hewlett-
Packard and Dell. He is a widely published author and respected
speaker, and is co-editor of ``Challenging the Chip: Labor Rights and
Environmental Justice in the Global Electronics Industry'' published by
Temple University Press, 2006. In 2001, Ted was recognized by the Dalai
Lama for his environmental leadership. In 2006 he was named a Purpose
Prize Fellow. He is a graduate of Wesleyan University and Stanford Law
School and was a VISTA Volunteer in Washington, DC from 1967-1969.
Chairman Gordon. Thank you, Mr. Smith.
Mr. Williams, you are recognized.
STATEMENT OF MR. MICHAEL T. WILLIAMS, EXECUTIVE VICE PRESIDENT
AND GENERAL COUNSEL, SONY ELECTRONICS INC.
Mr. Michael Williams. Chairman Gordon, Ranking Member Hall
and distinguished Members of the Committee, on behalf of Sony
Electronics and its employees, I would like to thank you for
providing us this opportunity to testify about Sony's
environmental stewardship program.
Sony has long been an industry leader in the design and
manufacture of environmentally friendly information technology
and consumer electronic products. Sony has now made an even a
stronger commitment to the environment when last September Sony
launched the first national comprehensive electronics recycling
initiative in the United States. Our program provides customers
free recycling of any of their unwanted Sony products from a
Trinitron television to a PlayStation to even a Sony Ericsson
mobile cell phone. Under our program, Sony takes full
manufacturer responsibility for all products that bear the Sony
name and we will recycle Sony products at no cost to the
consumer, or, the way I explained it to my 83-year-old mother,
if we make it, we take it.
To carry out our nationwide take-back program, Sony
contracted with Waste Management to establish 138 drop-off
locations throughout the country. Our goal is to have 150 drop-
off locations with at least one recycling center in each state
by September. Our long-term goal is to have a collection
location within 20 miles of 95 percent of the United States
population. In addition to establishing these permanent
locations, we also work with our local retailers and local
municipalities to have recycling events. We have planned 50 of
those events this year. Since last September, our program has
collected almost seven million pounds of consumer electronic
products. Our five-year goal is to collect 600 million pounds.
In summary, Sony has set a goal for itself to collect one pound
of recycled product for every pound that we sell. Sony wants to
make the recycling of our products as easy for consumers as it
is purchasing them.
Mr. Chairman, we believe this is a path to sustainability.
But our environmental work at Sony doesn't stop at collection.
All Sony products collected must be recycled using the
strictest environmental standards. We seek at least 95 percent
recycling rates. In addition, we provide full public
accountability of where and how our waste material is disposed.
We seek to reuse as much material as possible and we prohibit
the exportation of hazardous waste to developing countries.
But Sony's environmental efforts are also forward looking
as well. We continue to introduce a variety of environmentally
friendly electronic products, and today I brought along two
examples--the Sony e-Reader and our OLED television. Now, the
Sony e-Reader, Mr. Chairman, Ranking Member Hall and Members,
is a unique on-the-go reading experience. This little book,
this little tablet can hold up to 160 novels, and with its
rechargeable battery, you can have 7,500 page turns, and if you
are like me, sometimes I forget to bring my reading glasses,
you can even press a button and it changes the size of the
font. But just think of how much paper, how much energy is
saved with an e-Reader product.
I have also brought along our OLED television. This stands
for organic light-emitting diode. It is only three millimeters
thick, or I should say three millimeters thin. It represents
the latest in Sony display technology, and it is also
exceptionally energy efficient. The OLED technology can result
in reduced power consumption of up to 40 percent per square
panel inch, and because we use organic polymers in this
display, it does not have any mercury or lead.
Mr. Chairman, these are just two products that Sony is
doing today. Coupled with our stewardship program, our full
producer responsibility take-back program, we believe this is
the path that companies should take.
Thank you again for the opportunity to testify before this
committee, and Sony looks forward to working with you in
developing a successful national e-waste program.
[The prepared statement of Mr. Williams follows:]
Prepared Statement of Michael T. Williams
On behalf of Sony Electronics Inc. and our employees throughout the
country, I would like to thank the Committee for the opportunity to
testify about Sony's environmental stewardship program.
Sony's National E-Cycling Program
Sony has long been an industry leader in the environmentally-
friendly design of our consumer electronics and information technology
products. Sony has now made an even stronger commitment to
environmental stewardship. Last year, we announced a ground-breaking
program to encourage consumers to recycle and dispose of electronic
devices in an environmentally sound manner.
Sony teamed up with Waste Management, Inc. to implement the first
national recycling initiative in the U.S. to involve both a major
electronics manufacturer and a national waste management company.
Our program provides customers free recycling of any of their
unwanted Sony products, including Playstation consoles and Sony
Ericsson phones. Under this program, Sony takes full manufacturer
responsibility for all products that bear the Sony brand. We will
recycle those products at no cost to the consumer. This not only
includes consumer products, but business and professional products as
well.
While Sony will recycle its own products for free, our recycling
locations will also accept non-Sony consumer electronics and
information technology products.
To fully carry out this nationwide e-waste take-back program, Sony
and Waste Management Recycle America utilize 138 drop-off centers
throughout the country. This is an increase from the initial 75. In
addition to setting up permanent collection centers, we are also
holding recycling events, coordinating with retailers and local
municipalities. By the end of this year, we plan to have held at least
50 special recycling events.
Our goal is to have 150 drop-off locations throughout the United
States, with at least one recycling location in every state by
September 2008. Our longer term goal is to have a collection location
within 20 miles of 95 percent of the United States population at which
consumers, retailers, and municipalities can have any product from any
consumer electronic manufacturer recycled.
Sony has set a goal to recycle one pound of consumer electronics
goods for every pound sold. This is sustainability.
Since its inception last September, our program has collected
almost seven million pounds of consumer electronics products. Our five-
year goal is to raise that number to 600 million pounds per year.
In summary, Sony wants to make the recycling of our products as
easy for consumers as the purchasing of products.
Other Sony Recycling Programs
Beyond the program described above, in an effort to encourage
customers to recycle, Sony offers customers Sony credit toward the
future purchase of a similar product if they send in their old product
for recycling. This ``trade-up'' program is applied to laptops, digital
cameras and camcorders. By going on to our website, www.sonystyle.com,
customers can enter specific values describing their old product. Once
the appropriate value is determined, customers will receive an e-coupon
valid at our Sony Style website toward the purchase of a new product.
Depending on the product, values can range up to $1,000.00.
Product Recycling
After products are collected through the Sony Take Back and Recycle
program, Waste Management will store, track inventory and dismantle the
products into the form of common raw materials where they can be bought
and sold on the global market. In some cases, it is likely that
recycled plastics will be purchased for reforming into a new current
model electronic product.
All products which are collected through the Sony Take Back and
Recycle program must be recycled using the strictest and highest
environmental standards. We seek at least 95 percent recycling rates,
with less than five percent of materials going to landfills. In
addition, we provide full public accountability of how and where the
material goes. We seek to reuse as much as possible in new Sony
products. Most importantly, we prohibit the exportation of hazardous
waste to developing countries.
Product Innovation
Sony has long been an industry leader in product innovation. And we
are continuing to add an array of environmentally-friendly electronic
products, such as our e-Reader.
The Reader Digital Book offers a unique, on-the-go reading
experience. With a compact and lightweight design, it holds up to 160
e-Books. You can easily hold it in one hand, and with its rechargeable
battery, you can turn up to 7,500 continuous pages on a single charge.
Today, I have brought with me an example of Sony's latest product
innovation, our new OLED television. OLED (or Organic Light Emitting
Diode) is a revolutionary Sony display technology that offers
exceptional picture quality and color reproduction from a screen that
is a mere 3mm thick. Unlike liquid crystal display (LCD) televisions,
the Sony OLED TV does not utilize a backlight. In LCD TVs, a backlight
must remain ``always on'' for video display. Rather, each OLED pixel
produces its own light and is off, using no power, when displaying
blacks.
While this OLED technology offers exceptional contrast ratios and
outstanding dark scene detail, it also leads to improved power
performance. Under normal viewing conditions, the OLED technology can
result in reduced power consumption of up to 40 percent per panel
square inch. As with all Sony BRAVIA LCD HDTVs, the OLED displays do
not incorporate any lead content, and, with no backlight needed, offer
no mercury content as well.
Sony hopes to utilize this technology for other future products,
such as laptops, cell phones and larger size televisions.
Sony's Comments on Federal Legislation
Sony urges you to adopt legislation that supports our efforts and
extends the environmental stewardship we have demonstrated to all
electronics manufacturers and retailers. While we are confident that
Sony's voluntary e-waste recycling program will make great strides
forward, only a truly comprehensive and consistent program will allow
all interested parties to achieve our shared recycling goals. Sony,
therefore, respectfully requests that any legislation reflect the
following:
Preemption
Although it is of course a significant event when Congress
preempts State regulation on a particular point, Sony believes
that electronics recycling is an issue on which State
preemption is essential. We and other stakeholders already have
to comply with numerous, and sometimes contradictory, State and
local e-waste laws. The inconsistency between these programs
inevitably creates inefficiencies in the system and minimizes
any economies of scale that could be achieved. And since Sony
(and likely no other manufacturer) does not build products to
be sold in a particular state, adding a federal bill without
State preemption merely adds more complexity rather than
simplifying and streamlining the process. In the end, a
patchwork quilt of different and ultimately contradictory State
and municipal laws will only serve to undermine everyone's
shared goal of recycling as much electronic waste as
efficiently and cheaply as possible.
Producer Responsibility
Sony believes that it is the individual manufacturer's
responsibility to assure that any product that bears its name
is properly recycled using the highest standards possible at
the end of the product's life. That said, other stakeholders
who directly benefit from the sale or enjoyment of electronic
products must also bear some responsibility. More specifically,
retailers--at the very least--must take an active role in the
collection of e-waste and consumers must be encouraged to take
the extra step necessary to properly dispose of their products.
Market Share
In order to create a level playing field, any manufacturer
obligation should be based upon present market share and not on
historical activities or waste collected. Systems based upon
the amount of waste collected will give a cost advantage to
those companies that are new to the market. Such companies can
avoid any recycling cost by simply staying in business and
changing their brand or company name every year. Many of these
``no name'' brands are made of lower quality materials, which
can contain higher levels of toxic chemicals and may be more
difficult to recycle. Any mandate not based upon today's market
share will give those companies a ``free ride'' on recycling.
This will lower their costs when compared to responsible
companies by rewarding manufacturers who avoid their
environmental obligations and penalizing responsible companies
by putting environmentally-advanced products at a competitive
cost disadvantage.
Products Covered
Our recycling program covers all of our branded products
from movies (i.e., DVDs), to professional equipment used to
project movies in theaters, to laptops or televisions used to
watch movies at home.
Sony, therefore, respectfully urges you to adopt one program
with one set of requirements which will require full producer
responsibility for all products manufactured. The advancement
of technology has enabled manufacturers to create an array of
products using the same chemicals and metals that are used in
the products commonly covered in e-waste recycling mandates.
Given this, Sony suggests adopting legislation to target all
products that contain these same internal and external
components and chemicals.
Cost
Sony internalizes the cost of recycling and requests that
any mandate require the same. Currently, Sony pays to recycle
our old products. While there are several financing mechanisms
that allow for recovery of this cost, Sony believes that
internalizing the cost is the most effective and fair method
for funding a comprehensive electronics recycling program. Such
funding mechanisms create market incentives for manufacturers
to ex ante design and produce the most environmentally-friendly
products possible. In addition, it encourages manufacturers to
develop and implement the most efficient and cost-effective
recycling procedures. Indeed, it is Sony's ultimate goal
through design improvements, the growth of the recycling
industry, and economies of scale to drive these recycling costs
down, thus making recycling cost effective. Until that time,
Sony considers the cost of recycling as part of the cost of
doing business.
Thank you again for the opportunity to testify before the
committee. Sony looks forward to working with you in developing a
successful, national e-waste recycling program.
Biography for Michael T. Williams
Michael T. Williams is Executive Vice President, General Counsel &
Secretary of Sony Electronics Inc.
As General Counsel, he leads and manages a law department of over
fifty members which is responsible for providing accurate and timely
legal advice and guidance and rendering proactive, cost-effective
counsel to achieve the Company's business goals at prudent risk levels.
Mr. Williams is responsible for overseeing the environmental compliance
support program of Sony Electronics and supports the environmental
compliance activities of several Sony affiliated companies and joint
ventures located throughout the world.
As Executive Vice President, Mr. Williams is also responsible for
managing six other company departments: Corporate Security (including
supply chain security & brand integrity); Trade Strategy & Compliance;
Government Affairs; Technologies Standards Office; Community Affairs;
and Ethics, Compliance and Personal Information Management.
As Sony Corporation's outside counsel for more than two decades,
Mr. Williams represented the Company in a variety of litigation and
business transactions, most notably working on the successful defense
of the Company in the Go Video dual deck VCR litigation, as well as
many class action suits.
Mr. Williams is a member of the American Bar Association;
Association of Corporate Counsel; State Bar of California; United
States District Courts in the State of California; and the United
States Court of Appeals for the Fifth, Eighth, Ninth and Eleventh
Circuits.
His professional appointments include Director and member of the
Executive Committee of the National Association of Manufacturers,
Director and member of the Executive Committee of the San Diego
Regional Economic Development Corporation; Past Chairman, City of Palos
Verdes Estates Planning Commission and Director of the Palos Verdes
Home Association.
Additionally, Mr. Williams is active in various charitable
organizations and events, including benefits for the Special Olympics
of Southern California, San Diego Homeless Youth Project and ProKids.
Along with Sony Electronics, he is being honored by the Minority
Corporate Counsel Association this year for his success in establishing
a diverse workforce.
Mr. Williams proudly served his country as an infantry officer in
the United States Marine Corps. from 1975 to 1979. He received his
Juris Doctorate, cum laude, from the University of San Diego School of
Law and a Bachelor of Arts degree, magna cum laude, from Ithaca
College. He resides in Rancho Santa Fe, CA with his wife and two
daughters.
Discussion
Chairman Gordon. Thank you, Mr. Williams. I hope it will be
a few years, but I have a TV I am going to bring back to you
one of these days.
Mr. Michael Williams. Not a problem, Mr. Chairman.
Chairman Gordon. At this point we will open the first round
of questions, and the Chair recognizes himself for five
minutes. I am not going to take that. What I am going to do is
ask--and many of you have been responsive already. I am going
to submit questions to you and ask your suggestions on any type
of federal research that might be beneficial both in the back
end of recycling or the front end in developing technologies to
make it easier to recycle on the back end, and I also will ask
you about any other type of federal programs you think could
expedite this. Your testimony has been very good.
And now I am going to yield the balance of my time to Ms.
Richardson.
Ms. Richardson. Well, thank you, Mr. Chairman. I have
several questions and I would also like to--I think I will only
get through a couple, if I could submit the rest into the
record.
My first question is, I was very appreciative of Mr.
Castro. First of all, I represent southern California and
several of your sites are in my district, so welcome to
Washington. One of our major issues regarding these recycling
programs is the cost. California is the only state, as you
mentioned, sir, with a consumer fee to pay for recycling.
Almost other states have the manufacturer take the
responsibility for the recycling cost. Which one of these
models would you recommend would be best, and this question is
for both Ms. St. Denis and I think Mr. Williams. My question is
on the advanced recovery fee in California.
Ms. St. Denis. Thank you for your question. In our
experience with the model in California and the models that
have been developed in other states, we find that where the
manufacturers are more directly involved in the recycling
processes, as they are in other parts of the world, the systems
become more efficient. We are much more tied to actually doing
the recycling ourselves or having it done on our behalf. I am
sure Mr. Smith would agree that the more we are involved in the
recycling, the more we are motivated to find alternatives to
some of the materials of concern that are in the products. The
system in California has proved to be somewhat inefficient.
There is a need for an increase in the fees. That was discussed
at a meeting earlier this week. And increasing those fees from
a range of $6 to $10 to a range of $10 to $30, and we see that
as, you know, a burden on current consumers that is really
going to pay for the waste of former consumers and so we are
much more in favor of the producer responsibility systems that
we are seeing developed in other states.
Ms. Richardson. Well, Ms. St. Denis, according to your
testimony, HP, your recycling rate for 2007 was 15 percent so
it sounds like to me you could use a little help. So wouldn't
you think maybe a combination of the two, maybe a fee that the
consumer pays directly and then also a portion that you are
involved with?
Ms. St. Denis. So----
Ms. Richardson. Because 15 percent isn't satisfactory.
Ms. St. Denis. Well, so the 15 percent is predicated on one
very important factor, and that is the behavior of the
consumer. The California system also does not provide any--
neither system provides direct incentives to the customers to
recycle the electronics. So we do recycle everything customers
want to give us. Another important fact to note is that none of
the recycling that takes place in California is counted in that
15 percent number because we don't do the recycling ourselves;
it is handled by State agencies. So we can't count that. The 15
percent reflects only what we do ourselves, which, again, is
what we are seeing in the states that have legislation
emerging. The first of those actually took effect in large
scale in Minnesota this year, so you will see that number go
up.
Ms. Richardson. Ms. St. Denis, maybe I am not clear. What I
thought you said in your answer to the advance recovery fee was
that it would be better served if you were more engaged and
involved, and then when I referenced the area that you are
engaged and involved in, it is only 15 percent of what you are
saying your role of what you are doing. So what would you--let
me ask it in a different way. What would you suggest as to how
we could increase that number or increase consumer education to
assist you?
Ms. St. Denis. So I think one thing that is important is to
educate the consumer about the need to recycle these products
when they are done with them. We find that they are often
stored for long periods of time before they enter into the
recycling system, and when we have events, much like the one
that you had here last weekend, there is overwhelming demand
for this service. So people show up with a lot of things to
recycle but they often don't know that systems exist. We
manufacturers often advertise this fact as part of our new
sales but there is a lack of understanding in the sort of the
general population that they have a responsibility to start
these products on the way to the appropriate recycling
solution. There also are states where these products can still
be landfilled and so in many cases those products escape what
we think of as the kinds of systems that we put in place.
Ms. Richardson. And Mr. Williams, what is your thought on
the advance recovery fee? And I am down to my last minute.
Mr. Michael Williams. Yes, ma'am. In terms of the advance
recovery fee, in the past we have supported that but since
then, as you can tell from my testimony, we believe in producer
responsibility. We make it, we will take it back. We will take
responsibility for the product. That being said, the issue with
advance recovery fees, is the money being collected to address
legacy issues, manufacturers have gone out of business, or the
current players in the marketplace. Moreover, with advance
recovery fees, not all State governments are fiscally
responsible. The money may be collected on the sale of a
television, but if it goes into the general fund, we don't know
where that money is going to be 10 or 15 years from now when we
may need it. That is where we think federal legislation in this
area is essential. Moreover, not only should the producer take
some--take responsibility, but other stakeholders have to be
involved to make this successful. We need the retailers to be
involved. They have a stake in this outcome as well as consumer
education.
Ms. Richardson. Thank you, Mr. Chairman.
Chairman Gordon. Thank you, Ms. Richardson. As usual, you
had very good questions, and Mr. Hall is recognized for five
minutes.
Mr. Hall. Because we are only about 10 minutes away from
the joint session, I won't ask questions but I will yield to
Mr. Bartlett, who I think has some interesting questions
involving Dr. Gingrey's bill. I yield my time to you, Roscoe.
Mr. Bartlett. Thank you very much, and thank you all for
your testimony. As I sat here thinking about what I might say
or ask you, I really was in quite a quandary, because what we
are dealing with is really a self-inflicted wound, a self-
inflicted problem. We have recycling problems. We have huge
energy costs in making this equipment that we then throw away.
We have big environmental problems. Much of this equipment is
made with planned obsolescence. You just expect the people very
shortly to throw it away. You design it to dispose of it. You
don't design it so that it can be repaired or upgraded, and we
behave as if resources are unlimited like there is unlimited
amount of energy.
This morning I noted that in every one of the papers I
looked at in our Hill newspapers, the major headline on the
front page of every one of them had to deal with energy and the
high cost of gasoline, that everybody is being blamed and the
person that really is to blame for this is the millions of us
who are out there riding around in our SUVs. The demand is just
greater than the supply. It is simply a supply-and-demand
problem which is why the price of gasoline is up. I said this
was a self-inflicted problem and it really is. Much of the
equipment, this electronic equipment that is sold is bought
with discretionary money. You just don't need it. And we have
to trade off in our society today, what is more important, to
spend more time with these silly games or to use less energy so
there will be more of it available for our kids and our
grandkids. Yet we have a huge beast to feed out there. We have
this huge industry that is making this stuff, and if you aren't
buying it and throwing it away, they aren't making it.
How do we resolve this problem? What do we do? I have 10
kids, 16 grandkids and two great-grandkids. We are handing them
a huge debt, not with my votes, if you will look at my voting
record. Wouldn't it be nice if we left them a little energy? I
am having a big problem with a society that just wants to
consume, profligate spending, just play, play, play with no
thought for tomorrow, no thought for your kids, no thought for
your grandkids, and here we are today talking about a problem
that is almost totally self-inflicted. You know, if you want
to--if people need to work, why can't they work rebuilding this
equipment and repairing it rather than just throwing it away?
There is no reason, for instance, that--we don't have frames on
cars anymore. When we used to have a frame, no reason that that
wouldn't last 100 years. Why does it have to go to the junkyard
in 16 or 18 years? You know, these things are not limitless.
There is a limit to the amount of energy that is out there.
There is a limit to the amount of these metals and so forth
that are out there. There is a limit to the capacity of the
environment to absorb all of these things. How do we reach a
balance in this so that we aren't looking just to the next
election pandering to people so we will get elected, so that we
aren't looking just to the next quarterly report so that it
will look good so that your stockholders feel good about you
and invest even more money in you? How do we strike a balance
that looks long term to the future?
Mr. Smith. If I could start a response, I think--I agree
with everything you said and I think that the strategy of
trying to bring in a producer-responsibility approach into the
United States and really importing that policy initiative from
Europe and elsewhere is at least a part of the solution,
because what that does is to internalize the costs of
production into the full life cycle of the product, and if the
producers have to be responsible for those costs throughout the
entire life cycle, they are going to tell their designers, you
know, let us figure out a way to make these products last
longer, be more efficient and be less expensive throughout the
life cycle. So the point is that if they have to pay for the
costs of recycling and disposal, we think that that is going to
send some important design signals up to the front end where it
really belongs. It will help shift that focus. It is probably
not going to solve all the questions that you are raising
because I do think that the rapid obsolescence is the major
thing.
You probably know of Moore's law, which was based on Gordon
Moore, one of the founders of the semiconductor industry. If
you look at the slope of change in the industry, it looks like
this. It is a logarithmic scale going straight up to the sky.
When you look at the slope of the environmental and social
improvements that we have, it is a much shallower slope like
this. I think our job is to try to figure out how to make those
slopes be coincidental, and right now we are way out of whack
on that, in my opinion.
Chairman Gordon. Thank you, Mr. Williams, and Mr. Hall is
recognized for a unanimous-consent request.
Mr. Hall. Mr. Chairman, EPA has provided a written
statement to us and I ask unanimous consent that the statement
be included in the written record and that any questions
Members might have for EPA and their answers also be included,
and I thank you.
Chairman Gordon. Thank you, Mr. Hall, and I will raise you
one. Mike Thompson, the Chairman of the E-Waste Caucus also has
a statement that he would like to submit and I ask unanimous
consent that that be made part of the record.
Mr. Hall. I object.
Chairman Gordon. I think he is kidding.
Mr. Hall. I withdraw my objection.
Chairman Gordon. If there is then--since there is no
objection, those two records will be made a part of the record.
[The information follows:]
Prepared Statement of Representative Mike Thompson (D-CA)
Thank you for the opportunity to comment briefly on electronic
waste, or ``e-waste.'' I appreciate Chairman Bart Gordon and Ranking
Member Ralph Hall allowing me to submit these remarks to the record as
part of your hearing on e-waste, a subject I've been involved with
since I was first elected to Congress.
As you will hear today from the other witnesses, electronic
products are becoming smaller and lighter, but they also are creating
an ever-growing environmental and waste disposal problem. That's
because it's often cheaper and more convenient to buy a new PC or cell
phone than to upgrade an old one. Today, the average lifespan of a
computer is only two years and Americans are disposing of 3,000 tons of
computers each day.
The buildup of e-waste on the local and State level has led sixteen
states, including California, Tennessee and Texas, to implement their
own e-waste laws--each very different from one another. Thirteen
additional states are also considering e-waste legislation. As states
continue to develop their own approaches, the need for a federal
solution grows. Without federal action, both consumers and businesses
will have to contend with an unmanageable patchwork of State laws. This
might also put many U.S. manufacturers at a competitive disadvantage if
they have to juggle multiple State regulations.
As the founder of the Congressional E-Waste Working Group, I along
with co-chairs Congresswomen Louise Slaughter and Mary Bono Mack, and
Congressman Zach Wamp, with the assistance of Congressman Wynn and
Senators Ron Wyden, Maria Cantwell, and Sherrod Brown recently
submitted a comprehensive concept paper to nearly 60 stakeholders in
the electronics industry. Five of the six witnesses on your panel this
morning received the paper and have since commented on it. I want to
thank them for their valuable feedback and I look forward to working
with them in near future as we craft this important legislation.
The concept paper represents an important step towards enacting a
federal e-recycling solution. It relies on an extended producer
responsibility model, with manufacturers, retailers and recyclers
sharing the responsibility for establishing and maintaining a national
program to collect, transport, reuse and recycle e-waste with little or
no cost to consumers or government. The document incorporates many of
the principles articulated in e-recycling proposals and comments put
forth in past years by electronics manufacturers, the environmental
community, retailers, recyclers, waste handlers, the states, and other
interested groups. It also addresses the exporting of e-waste to third
world countries, the role of the states and the Environmental
Protection Agency, and creates incentives for greener production and
reuse.
Thank you for bringing much needed attention to this issue and to
allow us to gather expert testimony on the problem of e-waste. The
other members of the E-Waste Working Group and I look forward to
working with you as we work towards enacting a comprehensive plan to
reduce e-waste in a way that considers the interests of all
stakeholders.
Chairman Gordon. Mr. Lipinski, you can close us out.
Mr. Lipinski. Do we really have any time, Mr. Chairman?
Chairman Gordon. Well, we don't have much. If you want to
have one question or statement.
Mr. Lipinski. I just want to say that there has to be some
way of working this in. Very quickly, one thing that I find
difficult is not knowing as a consumer what needs to be
recycled. I had a VCR, and I wasn't sure, can I throw this in
the trash, what do I do with this, so the information to begin
with, and what is it--very quickly, Mr. Williams, why is Sony--
why did Sony take this step? Why is Sony doing as much as you
are doing?
Mr. Michael Williams. It is the right thing to do, number
one. Number two, because it makes sense. You are being the
responsible producer. You hope that people have brand loyalty
and that you take responsibility for your product. I want to
design and build in, as Ted was talking about earlier, in terms
of market efficiency. If I know it is going to be recycled, I
am going to design it with parts and machinery with that in
mind. So it makes sense for us from an economic point of view
to recycle the products, to create recycled waste for, let us
say, as an example, plastic, so I have enough of a supply of
post-consumer recycled plastic that I can use in my new models,
and so we have to create the supply of the recycled material in
order to put it into our new products. The way we do that is to
get our consumers who have the Sony products to bring them to
us and to recycle them. So it is in our interests, it is in the
environment's interest to do what we are doing today and also
to educate the American public that going green is good for
business, it is good for the environment. It is a win-win
situation. But it is going to take some work and effort on the
part of Congress through initiatives, legislation, and on the
part of industry to educate the American consumer why it is in
everyone's interest to recycle responsibly and properly.
Mr. Lipinski. I commend Sony on that, but I agree that
there is more that we are going to have to do to make sure this
is done across the board. Thank you.
Chairman Gordon. Thank you, Mr. Lipinski.
Before we bring the hearing to a close, I want to thank our
witnesses for testifying today. Mr. Hall also would like to
know where to take his Victrola.
Mr. Michael Williams. I don't think that has the Sony brand
on it.
Chairman Gordon. The record will remain open for additional
statements from Members and for answers to any follow-up
questions the Committee may ask of the witnesses, and let me
ask, is there anyone that wants to ask the witnesses to come
back after the joint hearing? If not, then again, I want to
thank our witnesses. We are going to submit additional
questions to you. This is an issue that this committee is very
interested in, and we consider this one of our major areas of
concern this year, and as I say, we are interested in knowing
on the federal level--if there is--we are not looking to do
something if there is not something there to do, what we can do
in terms of research to help on the recycling end, and if there
is something on the front end to make it easier to recycle as
well as other areas.
So with that, the witnesses are excused and the hearing is
adjourned.
[Whereupon, at 10:58 a.m., the Committee was adjourned.]
Appendix 1:
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Answers to Post-Hearing Questions
Answers to Post-Hearing Questions
Responses by Eric D. Williams, Assistant Professor, Department of Civil
and Environmental Engineering and School of Sustainability,
Arizona State University
Questions submitted by Chairman Bart Gordon
Q1. You state in your testimony that you and your colleagues' review
of the scientific literature concluded that the risks associated with
disposing electronics in sanitary landfills are negligible. You also
mention that the EPA's Toxicity Characteristic Leaching Procedure
(TCPL) test is ``more aggressive'' than the actual conditions in
landfills. What type of further study is needed to accurately assess
the environmental and human health impacts of electronics disposed in
landfills?
A1. It is possible that the core research establishing the risk of
toxics leaching from sanitary landfills is mainly done. I suggest that
if the National Research Council were asked to do a study on the
interfaces between the risk of toxics leaching from landfills, the TCLP
test and e-waste that it would be a valuable step to gauge the degree
of scientific knowledge and consensus on this issue. This report would
clarify if and what further work is needed.
I think an important related issue is the potential to mine
landfills at a later date to recover valuable materials. Existing
research suggests that despite favorable concentrations of valuable
materials in landfills compared to ore deposits, the relatively small
size of the landfill ``deposit'' pose a challenge to recycle from
landfills at low cost. There are strategies however which ought to be
researched. One strategy is to consider how defining a new waste
category as material destined for future recovery would affect the
economics and environmental issues associated with mining landfills. A
second strategy to work on developing materials recovery processes
which economically scale favorably down to smaller deposit sizes.
Q2. You say in your testimony that end-of-life management for
electronics is a qualitatively new challenge and that we do not have
the proper tools to measure the impacts of recycling and other end-of-
life policy options. What types of tools do we need to make these
assessments and what type of research is necessary to develop these
tools? Which agencies would be best to fund this type of research and
how should it be prioritized?
What funding opportunities exist in addition to the
National Science Foundation's Environmental Sustainability
Program to study and assess the end-of-life management of
electronics and other products?
You mention in your testimony that Japan is investing
more than the U.S. to characterize and plan for the management
of international end-of-life flows for a variety of consumer
products. By not investing in the analysis of this issue, is
the U.S. at a competitive disadvantage?
A2. What opportunities exist other than NSF Environmental
Sustainability to support research related to end-of-life electronics?
To summarize, few and far between. Regions 4 and 5 offices of the USEPA
have supported the work at the University of Florida on leaching
potentials from landfills. While in principle research on electronics
reuse/recycling could be supported as part of federal and State
programs addressing waste related issues, I know of no dedicated
programs devoted to e-waste. In practice, it is definitely an
underfunded area.
The NSF and EPA are natural agencies from which to base future
research on management of end-of-life electronics. NSF could focus on
the more fundamental knowledge needs while EPA could focus on
applications. I hesitate to prioritize research topics in an ordered
listed as society needs to decide what aspects of the end-of-life
electronics it deems most important and weigh issues accordingly. I
scope out below how I view the main challenges and some of the research
related to addressing these challenges:
Global environmental impacts--from a global
perspective the main environmental impacts associated with end-
of-life electronics are probably due to informal recycling in
developing countries. Research addressing this would include 1.
exploring policy/business models to develop new systems for
managing global end-of-life flows 2. research into alternative
recycling technologies.
Domestic environmental impacts--for people in the
U.S. I believe the main potential exposure issue is brominated
flame retardants. Research is needed to determine the risk of
these substances and to develop and assess alternatives in view
of the improved fire safety gained from flame retardants. The
energy use associated with production and manufacture of
equipment is an important issue to consider from global warming
and resource scarcity perspectives. Potential health impacts
due to exposure to electromagnetic fields should also receive
more attention.
Social and economic benefits--Reuse and recycling of
electronics is an important economic activity and access to
low-cost used machines delivers social benefits. On the
technology side, developing informatics systems such as RFID
tags can help improve the functioning of reuse/reusing. Also,
work is needed to develop and assess electronics policy
alternatives which encourage reuse.
Applications of Information Technology--while I
understand the focus here is on end-of-life management issues,
it is also important to bear in mind that there are many
important environmental applications of information technology.
The potential benefits outweigh much of the environmental risk
of equipment in my opinion. More research is needed to develop
and promote adoption of applications such as home energy
management systems, Internet-enabled ride sharing programs, and
telecommuting.
News tools and methods to be developed in this research include
multi-issue models of alternate reuse/recycling systems, computer-aided
toxicity screening methods, materials/emissions models of different
recycling processes, simulation models of environmental/economic/social
implications of different global paths for electronics, and designs for
informatics systems supporting reuse and recycling (e.g., RFID
systems).
Is the U.S. at a competitive disadvantage compared to Japan due to
its relatively small investment in research and development related to
green electronics? Potentially yes, although the economic impacts are
difficult to gauge. There are two aspects, manufacturing and reuse/
recycling. For manufacturing, Japan has been proactive in responding to
the European Directive on Restriction on Hazardous Substances which
regulates materials used in electronics. U.S. manufacturers on the
other hand objected to the European legislation on scientific grounds
and have been less willing to respond. I believe U.S. manufacturers had
valid concerns about policy developments in Europe, but at the time
there was insufficient research activity by neutral parties (e.g.
academia) in the U.S. engineering/scientific community to weigh in
substantively on the debate. Ultimately the European legislation went
through in spite of the questions raised by U.S. industry. The outcome
is that the Japanese electronics is relatively well situated to deliver
products meetings the new regulations in Europe and elsewhere.
Considering the end-of-life, Japan is also being proactive in
working to assess and address concerns being raised regarding the
environmental impacts of international flows of end-of-life
electronics. The relative lack of response in the U.S. may have been
based on the perception that environmental problems of end-of-life
electronics abroad are the jurisdiction of recipient countries.
However, public pressure on this issue is resulting in response even if
the Federal Government takes no action. Many nations are implementing
bans on importing e-waste. NGOs are developing guidelines for
environmentally friendly recycling practices which many firms follow in
order to maintain a positive perception by customers. The result is
that U.S. manufacturers are increasingly acting in an policy
environment in which the U.S. had has little voice. Investments in
research and development are part of a process through which the U.S.
can engage in and influence the international discourse.
In addition, the internationalization of reuse and recycling may
present a business opportunity for those firms situated to take
advantage of trends. For example, there is an increasing international
need for technologies and facilities which can safely recover valuable
metals from circuit boards. Japanese smelters such as those operated by
Dowa Holdings have advanced technologies and could serve future
international markets for recycling services.
Q3. In your testimony you propose interesting ideas to facilitate
reuse and prevent harmful recycling practices in developing countries.
What would be needed to develop and evaluate ideas like the use of
Radio Frequency Identification (RFID) technology to indicate
functionality or link a recycling deposit to a piece of equipment? How
can innovative management options be encouraged?
A3. The first step is a set of high-level feasibility studies exploring
technological, economic and other aspects of different proposals. Based
on the result of these feasibility studies, specific research is needed
to develop the most promising options. Some of this research will be
product engineering/technology related, such as the design and
integration of RFID tags in computers. Another aspect of the research
relates to design and operation of the overall system, which should
integrate engineering, business and social aspects.
How can innovative management options be encouraged? It may be that
the new technology and management system go hand-in-hand with new
policy. For example, one proposal my colleagues and I at Arizona State
have made is for an electronics take-back system which establishes an
Internet market in which reuse and recycling companies compete to offer
consumers rebates on a prepaid recycling deposit. This system would
utilize RFID and other information infrastructures. Thus in this case
the innovative management system is integrated with policy. A general
strategy to encourage innovative management options is to encourage
joint industry/academic research to couple academic understanding of
the issues with real world commercial systems to enable workable
solutions to real problems.
Q4. What policy tools would you suggest to compel electronics
producers to consider end-of-life management in their product designs?
If CRTs are permitted into landfills, how do we encourage green
engineering and the thorough evaluation of materials before they are
used products?
A4. To summarize my response, I recommend first exploration of
voluntary product certification and take-back systems which explicitly
create a market for improved designs. There are three types of policy
tools currently on the table. The first is command-and-control
mandating of design aspects, the European Directive Restriction on
Hazardous Substances is the prime example of this approach. Though not
addressing recycling, there is precedent for this type of approach in
the U.S.: the appliance efficiency standards managed by the Department
of Energy.
The second type of policy is voluntary certification programs such
as Energy Star. A new computer certification scheme, EPEAT, includes
recycling and reuse related aspects. Voluntary certification programs
seem to have an effect well beyond the demand of individual consumers
for green products. This is partly because green purchasing programs
for organizations create a market for certified products which one
designed spills over into other markets. Another factor is that firms
compete to gain certification as a means to establish an image of a
socially responsible corporation.
The third approach is economic instruments. Making manufacturers
responsible for recycling under the mantle of Extended Producer
Responsibility (EPR) is a popular approach. The challenge is to develop
a system which is both workable in practice and provide a clear
economic incentive to improve design. Take-back systems have yet to be
successful in inducing substantial design shifts. One strategy is to
develop take-back system which explicitly create a market over which
manufacturers and reuse and recycling firms compete to deliver more
efficient services. We are developing such a concept at Arizona State
which we term the e-market for e-waste. The idea is that at the end-of-
life firms compete to offer consumers higher levels of return on a
prepaid recycling fee.
How do we encourage green engineering and thorough evaluations of
material used in products? In short, I believe work is needed to build
a method and modeling infrastructure which allows for a realistic
assessment of the macroscopic risk associated with using different
materials in products. Based on results from these macro risk
assessments, stakeholder groups recommend on a product by product basis
appropriate green engineering incentives such as voluntary
certification, economic tools and/or regulation.
There are two aspects of managing toxics. The first is assessing
the toxicity of a substance. Given the variety of new chemicals and
materials being developed and in use combined with vastly more
sensitive detection equipment, this assessment is a significant
challenge. Computer-based modeling of substances and their biological
activity will presumably better help us screen toxicity. I suggest that
more resources be devoted to developing such models. This being said,
for the foreseeable future we will still need empirical work on fate,
exposure and epidemiological effects, which also requires research
resources.
The second aspect of managing toxicity is assessing how toxics in
products might actually end up with exposures and damage health.
Surprisingly this is not often studied. For example, given all the
attention given to the potential risks of lead leaching from CRTs, one
would assume that there are many existing studies which total up the
total potential lead emissions from CRTs going to landfills and show
that the potential leaching is significant compared to other problems
we have with lead, such as paint or pipes in legacy buildings.
Apparently no one has done this yet. Much more work needs to be done to
scale up the product level content of toxics to potential macroscopic
levels of risk. The result of not doing this research is that
regulations are liable to equate toxicity with hazard, resulting in
inefficient and ineffective regulation.
Q5. In traditional undergraduate engineering curriculum, how much
attention do life cycle assessments and end-of-life management receive?
What types of changes can be made to encourage our future engineers to
prioritize these issues?
A5. In general, very little attention is given to LCA or other
sustainable engineering issues. There are exceptions where an
instructor will find a way to work such material in, but currently such
material is hardly ever part of an official curriculum.
I believe that in the future we need to incorporate sustainability
aspects into core engineering curricula to introduce all students to
basic issues and methods. In addition, we need to provide avenues for
students interested in sustainability to learn in depth.
The Center for Sustainable Engineering, a joint initiative by
Carnegie Mellon, the University of Texas--Austin, and Arizona State
University is funded by both NSF and EPA and aims to integrate
sustainability aspects including LCA into engineering curricula. It is,
however, a beginning effort, and there should be much more attention
paid to this requirement.
Q6. In your testimony, you propose a method to make the informal
recycling of electronics safer in developing countries, where workers
would be paid for targeted parts like wires, but not the actual
commodities. This would discourage them from unsafely processing
materials. Who should invest in evaluating and developing innovative
markets to end or mitigate harmful recycling practices abroad?
A6. Who should invest in subsidy system to prevent informal recycling
in developing countries? It is my view that if an organization or
individual in the U.S. or another country receives economic benefit due
to exporting end-of-life electronics, this should also entail an
investment to ensure safe recycling abroad. Practically speaking this
could mean that recycling fees collected domestically for take-back
systems would involve international monetary flow if the equipment is
exported. Domestic generation of e-waste in developing countries is
increasing and monetary flows should be mobilized internally to ensure
safe recycling.
There is in addition an economic investment associated with initial
research development of knowledge and technology bases to enable the
new reuse/recycling systems. There is a strong argument that much of
this R&D should be undertaken by developed areas such as the U.S.,
Europe and Japan.
Questions submitted by Representative Ralph M. Hall
Q1. How have electronics in the waste stream changed over the past
decade and what predictions can we make about changes in the coming
years? How do these changes affect our ability to safely and
efficiently recycle or reuse these devices?
A1. This is a very pertinent question given the rapid evolution of
products in the sector. There are three main issues. One is changes in
the use of precious metals in electronics over time. In the late 1980's
and early 1990's products used to contain substantially more gold,
silver and other precious metals, which made recycling more
economically attractive. These amounts have gone down over time. There
are contravening trends however. High capacity hard disks tend to
contain more platinum than previous generations. At any rate, it is
difficult to design recycling systems where the economic are a moving
target.
The second issue is the increasing diversity of devices. E-waste is
no longer only televisions, stereos and desktop computers, it is also
laptops, VCR and DVD players, game consoles, cell phones and personal
data assistants. Uniform waste streams are generally easier to recycle,
but e-waste has become more and more diverse.
The third issue is that many of these new product types such as
laptop computers and cell phones are switching to smaller more packed
designs which are harder to disassemble.
One result of this trend has been the increased use of shredders.
Products with valuable components such as components may be dissembled
by hand but most others tend to be put into a shredder after removing
certain parts of concern. Material recycling rates for shredder-based
systems are reasonable but clearly the level of reuse is reduced.
Q2. Most major manufacturers claim that they do not ship e-waste
oversees for recycling. Where does the e-waste found in environmentally
unsound recycling operations originate?
A2. With the exception of equipment leased by the manufacturer, the
end-of-life fate of electronics is in the hands of the purchaser, not
the manufacturer. Reuse and recycling companies who ship abroad can
often offer to pay for the equipment rather than be paid by the
disposer to recycle domestically, so there is a natural economic
incentive to choose those firms which ship abroad. Looking at recycling
operations abroad, reports by NGOs suggest that a substantial part of
the e-waste being recycled was originally from the U.S. and other
developed countries.
Q3. What are some of the toxic hazards that arise in the recycling
process itself?
A3. For informal recycling the big problems are obvious. Open burning
of wires to recover copper generates dioxins, furans and other toxics.
Acid and cyanide leaching of circuit boards create serious pollution
problems unless properly managed.
For formal recycling the situation is much less clear. Recycling
circuit boards usually involves melting the boards in a copper smelter.
The resulting slag is then processed to separate the different metals.
The heat of the smelter releases toxic substances such as lead and
mercury as well as various brominated organics. With appropriate
technologies one would presume that these toxic emissions are
controlled. There is a dramatic lack of information on the emissions
and energy use in different stages of recycling. It is worth noting
that copper smelters in the U.S. are reluctant to recycle scrap circuit
boards because of the entailing difficulty to meet EPA air regulations.
More research is needed to clarify the materials use and emissions
associated with different recycling methods.
Q4. You lay out an ambitious agenda for what needs to be done from an
R&D standpoint. However, accomplishing this work requires a skilled
science and engineering workforce in green engineering. Do U.S.
universities train a workforce sufficient for this task and if not how
many more programs would be required in order to fulfill this need?
A4. For e-waste and other environmental issues such as climate change
the U.S. needs a human workforce expert in sustainable engineering.
While training of such engineers and scientists is increasing, I
estimate that we are still not yet near to meeting the potential demand
for sustainability engineers and scientists. This is a three pronged
challenge. The first is to encourage more transdisciplinary engineering
education in areas such as sustainable engineering and earth systems
engineering and management. The second is to improve disciplinary
education by introducing students to real world social and
environmental complexity entailed in their engineering area. The third
is to introduce concepts of sustainable engineering in K-12 as well as
in undergraduate/graduate education, ensuring that we have a more
technologically competent workforce generally.
While it is difficult to give a precise number for a desired number
of programs, in green electronics the U.S. would benefit from several
centers capable of research and training in different aspects of the
challenge. Some centers could focus on more technical issues such as
development and assessment of new materials while other could be more
interdisciplinary and integrative in nature. Considering sustainable
engineering more broadly, the Federal Government could play a key role
in promoting sustainable engineering by increasing funding to NSF, EPA
and DOE towards university research programs.
Q5. What organizations in the U.S. and abroad are capable of
performing assessments on recycling, reuse, and landfilling processes
and practices?
A5. I cannot here review the full set of organizations around the globe
with capacity to address this issue, I mention a few of the main ones
currently active on green electronics. Focusing first on the domestic
situation within our universities, between myself, Braden Allenby and
our collaborators and students, Arizona State University has a group
which is strong at LCA and an integrative systems perspective. Timothy
Townsend and collaborators at University of Florida have particular
experience and capacity to study landfills issues. Hong Zhang and
collaborators at Texas Tech University have been working on developing
new recycling technologies. A group at University of California-Irvine
has been working on engineering and assessment issues related to lead-
free electronics.
Manufacturers, including U.S. based Dell and HP have personnel
dedicated to green electronics issues. The groups are small and mainly
focused on compliance issues. Japanese manufacturers in comparison
support research and development groups devoted to life cycle
assessment and development of green electronics.
The U.S. EPA Office of Solid Waste has experience and expertise
related to e-waste. Claire Lindsay, Robert Tonnetti and Angie Leith
have been involved in important e-waste related work such as the recent
benchmark assessment of generation and disposition of end-of-life
electronics in the U.S. Lawrence Berkeley National Laboratory is very
active with regards to operational electricity use for electronics,
though not end-of-life issues.
Looking abroad to Europe and Japan one sees a comparatively large
degree of research and industry activity related to green electronics.
The University of Delft has been active in assessing take-back and
recycling policies. One of the Frauenhofer Institutes in Germany is has
a substantive group active in electronics manufacturing and e-waste.
The Swiss federal research institute EMPA is the home to what is the
largest research project addressing international issues related to
reuse and recycling of electronics. Japan is very active both in terms
of technology issues and larger systems assessment. The National
Institute of Environment is a laboratory sponsored by the Ministry of
Environment and is prominently active is characterizing international
material and product flows. The Institute for Advanced Science and
Technology, sponsored by the Ministry of Economy, Trade and Industry is
active in both life cycle assessment of electronics and green design
issues.
Questions submitted by Representative Daniel Lipinski
Q1. In 2006, the Government Accountability Office estimated that more
than 100 million computers, TVs, and monitors are thrown away each
year. In addition, the EPA estimates that electronic waste is growing
two to three times faster than any other waste stream. Yet presently,
there is no specific federal law or regulation governing the disposal
of consumer electronic products in the U.S. Should there be?
A1. The short answer is yes. Various states are developing and enacting
their own electronics take-back and recycling systems. A patchwork of
State-level systems is inefficient and manufacturers have to devote
significant resources just to keep up with the different regulations.
Plus, states have fewer resources to invest in research and development
to develop and assess alternatives and thus have largely borrowed much
from systems abroad. As I discussed in my testimony, were based more on
simple heuristic goals which may not be efficient.
Q2. The EPA estimates that at most, only 15% of products at the end of
their useful lives reach a recycling or reuse program. This does not
come as a shock to me. In fact, it might seem a little high given the
impediments that consumers currently face.
First, how are average consumers to know what to do
with their e-waste when it comes to the end of its useful life?
This past weekend, Washington, D.C. held an e-waste
recycling day. Over ten times as many residents as last year
showed to recycle their gadgets, leading to over two hours wait
time. The incentives to recycle just don't seem to be there
right now. What do you recommend be done to fix this problem?
A2. Municipalities are traditionally charged with informing average
consumers about how to recycle. Depending on the community the level
and effectiveness of this communication varies considerably.
Communication may be enhanced by linking in with people's personal
computers. I.e., there could be pre-installed applications on computers
which hook up with databases with information on the recycling and
reuse practices of different locales.
Also, if the take-back and reuse/recycling system includes a
financial incentive to return machines (i.e., a returned deposit), I
suspect that word of mouth becomes a more effective means of
communication. One way to introduce such an incentive is a new type of
take-back system we are developing at Arizona State. The basic concept
of the e-market for e-waste model is that at the end-of-life firms
compete to offer consumers higher levels of return on a prepaid
recycling fee.
Regarding the unfortunately long wait times at the DC event, I
suspect that periodic recycling events are a temporary way-station on
the path to a national reuse/recycling system. In an organized system
these events would not be needed. Until we get a national system
however recycling events will remain one way to collect equipment. Some
problems might be avoided is a manual of best practice was developed
and made widely available to those planning such events.
Q3. The European Union is often ahead of the United States when it
comes to the issue of recycling. Where do U.S. capabilities stand as
compared to Europe on the topic of e-waste?
A3. Currently behind. Europe and Japan have advanced smelters with
experience in recovering precious metals in circuit boards. The
university and government research base is larger and governments have
mandated take-back and recycling systems. On the other hand, the U.S.
does have a fifteen year history of addressing green electronics issues
through the IEEE International Symposium on Electronics and the
Environment which has been held annually since 1993. This is an
important base of results and expertise to draw on.
Still, I believe that the U.S. has strong potential to become a
world leader in efficient reuse and recycling systems. We have
excellent research universities and a tradition of partnership between
universities and industry. The U.S. is more oriented towards combining
environmental solutions with free market efficiencies. Given the
importance of reuse in environmental performance this emphasis should
serve us well. The U.S. economy has shown a particular adaptability and
openness to adopting new technologies such as the Internet and its
applications.
Questions submitted by Representative Bob Inglis
Q1. In your testimony you suggest that take-back systems could have an
adverse effect on reuse. Can you expand upon this? If most reuse occurs
in developing nations, wouldn't take-back campaigns give companies the
opportunity to efficiently redistribute their wares?
A1. Yes, take-back campaigns do present an opportunity for reuse,
whether reuse is helped or hindered depends on the implementation. Many
existing take-back systems measure success in terms of achievement of
domestic materials recycling and do not include incentives for reuse.
In Japan, for example, some equipment manufacturers have a policy of
disassembling any product which they receive through the take-back
system regardless of its newness and condition. This practice is
supported by high recycling fees paid by consumers and without the
system it is more likely that some of the equipment would have been
reused abroad. On the other hand, a take-back system designed with
reuse in mind could enhance the collection of reusable machines in good
condition for export.
Answers to Post-Hearing Questions
Responses by Gerardo N. Castro, Director of Environmental Services and
Contracts, Goodwill Industries of Southern California
Questions submitted by Chairman Bart Gordon
Q1. You mentioned that Goodwill does expect an influx of televisions
due to the digital transition. Has your organization made plans for how
it will handle this increased volume?
A1. Goodwill Industries of Southern California is making plans to
increase our staffing and infrastructure to ensure that we are ready to
accept, store, and ship an increased number of analog televisions. In
addition, we are exploring opportunities that would allow us to provide
people who buy working analog televisions with coupons that would
enable them to purchase digital converter boxes at a reduced cost. In
addition, we are exploring partnerships to expand our ability to
process electronic waste. For example, after the April 30 hearing, we
met with representatives from Sony to explore a partnership between
Goodwill and Sony. We are still working out the details of the
partnership.
Goodwill Industries International, Inc. is working to build
collaborations modeled after the Dell Reconnect program and ideally
would like electronic manufacturers to work collaboratively together.
Local Goodwill agencies may have different plans for the transition.
Some have simply chosen not to accept analog televisions; however, they
still expect that they will receive analog televisions left at donation
sites during hours when the sites are not staffed.
Q2. In your testimony, you mention that Goodwill is unable to resell a
substantial number of the electronic products they receive. Is this
mainly an issue of durability or obsolescence? What types of design
changes would help in the repair and upgrade of this equipment?
A2. When Goodwill receives electronic products, we inspect them to
determine whether they are working. Those that are working, we resell
them in our stores. However, we often discover that the electronic
product is not working. While many of the non-working computers we
receive could be candidates for being refurbished, due to planned
obsolescence in the design of hardware and software, we have found that
replacements for non-working parts are often no longer being produced
by their manufacturers.
Incentives to design standardized products and components that are
universal and interchangeable would help to lengthen the life of
electronic products. For example, universal chargers for cell phones or
universal printer cartridges for printers would help to reduce the
amount of electronic waste that we receive while extending the life of
discarded working electronic products.
Q3. In your testimony, you state that about 20 percent of the products
you receive are neither resold nor dismantled into salvageable and
recyclable parts and are sent directly to recyclers. What prevents the
dismantling of these products by Goodwill employees? Also, what type of
oversight do Goodwill agencies use to ensure that they are contracting
with responsible recyclers?
A3. The bulk of the products that we send directly to recyclers are CRT
monitors that are not working and we are not able to resell. The proper
process for dismantling and breaking down electronic products that use
CRTs and other hazardous materials requires costly and expensive
equipment and facilities. Acquiring the in-house capacity to process
CRTs would represent a sizable investment from Goodwill Industries of
California. It makes better financial sense for Goodwill Industries of
Southern California to send CRT monitors directly to recyclers. Because
these recyclers are authorized by the State of California, we are
assured by the State of California, which audits recyclers to ensure
that products are being recycled properly, that the recyclers we use
are responsibly processing the CRT monitors we send.
Q4. In your testimony, you state that the Federal Government can play
an important role in assisting the development and sustainability of
electronics recycling and reuse infrastructure. What specifically could
the Federal Government do to bolster this industry?
A4. First, the Federal Government could create a nation-wide financial
mechanism to help stakeholders--including producers, recyclers,
collectors, states and municipalities--to support efforts to collect,
reuse, and recycle electronic products. For example, the Federal
Government, by utilizing incentives, could aid and encourage necessary
private sector investment in the used electronic recycling/reuse
markets. This can be done through tax credits for manufacturers who
partner with social agencies, recycling grants, and other initiatives
that could spur innovative solutions and help stakeholders handle this
problem. A partnership consisting of government incentives, private
industry and social agencies can protect the environment, create jobs
and spur innovation in the environmental field. Additionally, increased
federal support for pilot projects and other sustainable initiatives
would be helpful in promoting the development of a recycling/reuse
infrastructure.
Second, create disincentives, such as phasing in a nationwide
landfill ban, for disposing electronic products, including televisions,
in landfills.
Lastly, the Federal Government also can play a key role in
educating consumers about how to properly dispose of their unwanted
electronic products.
Questions submitted by Representative Ralph M. Hall
Q1. How have electronics in the waste stream changed over the past
decade and what predictions can we make about changes in the coming
years? How do these changes affect our ability to safely and efficiency
recycle or reuse these devices?
A1. Goodwill Industries of Southern California is seeing a huge
increase in the volume and variety in electronic products that are
donated. Spurred by the production of cheaper electronics, rapidly
advancing technology, and the emergence of popular electronic gadgets,
the consumption of electronics is dramatically increasing while the
lifespan of electronics is relatively short.
In the past, many electronic products were designed such that it
made financial sense to repair them when they broke. Today, it is often
cheaper to discard malfunctioning consumer electronics and to replace
them with newer and more technically advanced products. Recycling
begins with design. Manufactures should be encouraged to design
products that are more easily refurbished and recycled.
Q2. How does Goodwill train its employees to properly disassemble
electronic equipment? What are the greatest challenges to quickly and
efficiently breaking electronics down into basic commodities?
A2. Goodwill Industries of Southern California's training program
consists of an eight-step de-manufacturing process. People with
disabilities are taught each task in the process one step at a time.
When they show that they have learned that specific task and can
perform it safely, we teach them the next task in the process. For a
variety of reasons, such as a physical impediment, some people may not
be suited to perform certain tasks in the de-manufacturing process.
However, we still teach our employees about all the tasks to build
teamwork and a better understanding of the complete process.
Design variety represents a significant challenge for the Goodwill
employees that de-manufacture electronic products. The de-manufacturing
process could be streamlined if manufacturers produced products that
met certain universal design criteria.
Q3. Dr. Williams suggests that some take-back programs have an adverse
effect on reuse. Do you agree with this assessment: What effect does
your organization see on reuse of commodities like cell phones due to
the increase in take-back campaigns?
A3. Goodwill Industries of Southern California has not experienced an
adverse affect on the reuse of electronic products due to the
implementation of California's law, which involves an advanced recovery
fee. Goodwill Industries of Southern California is an authorized
collector under California's program. Whether the donated product is a
shirt or a computer, Goodwill Industries of Southern California first
attempts to resell the donation in one of its retail stores. The funds
we raise from the sale of the donation are used to support employment
services for people with barriers to employment in the area. In the
case of CRT monitors, we first test the monitor to determine whether it
is working. If it is, we attempt to resell it for reuse before we send
the CRT monitor to an authorized recycler. Our attempts to resell
working CRT monitors are usually successful.
Questions submitted by Representative Daniel Lipinski
Q1. In 2006, the Government Accountability Office estimated that more
than 100 million computers, TVs, and monitors are thrown away each
year. In addition, EPA estimates that electronic waste is growing two
to three times faster than any other waste stream. Yet presently, there
is no specific federal law or regulation governing the disposal of
consumer electronic products in the U.S. Should there be?
A1. Yes. Research shows that the improper disposal of electronic waste
in the United States creates serious environmental and public health
concerns. It also is an opportunity to create jobs and develop designs
that would help reduce the amount of electronic waste that is disposed
of each year. The Federal Government should enact electronic waste laws
and regulations that create jobs in the computer reuse and recycling
fields; and encourage manufactures to develop products that are more
amenable to being reused, refurbished, or recycled.
Q2. The EPA estimates that at most, only 15 percent of products at the
end of their useful lives reach a recycling or reuse program. This does
not come as a shock to me. In fact, it might seem a little high given
the impediments that consumers currently face.
First how are average consumers to know what to do
with their e-waste when it comes to the end of its life?
This past weekend, Washington, DC held an e-waste
recycling day. Over ten times as many residents as last year
showed to recycle their gadgets, leading to over two hours wait
time. The incentives to recycle just don't seem to be there
right now. What do you recommend be done to fix this program?
A2. Because Goodwill already has a strong existing infrastructure,
local Goodwill agencies are in a unique position to collaborate with
producers who are operating take-back programs by offering convenient
locations for consumers to dispose of their unwanted electronic
products. Consumers have been bringing their gently used items to local
Goodwill agencies for 105 years, so people know that they can bring
their gently used commodities, whether it is a shirt or a computer, to
a local Goodwill and we will reuse it or recycle it. In 2007, our 168
agencies in the United States and Canada were visited 65 million times
by an estimated 21.7 million household members, who donated items.
Incentives to increase the amount of electronics recycled and thus
decrease the amount of electronics that are sent to landfills include:
1) Ensure that municipalities have convenient collection sites
that are open year round. Nationwide, Goodwill has over 2,100
retail stores and 4,100 attended donation centers that could
potentially serve as the backbone for a national collection
infrastructure for the convenient collection and reuse of
unwanted electronic products.
2) Increase public outreach and education about how to recycle
electronic products.
3) Create disincentives, such as a zxccb nationwide landfill
ban, for disposing electronic products in landfills.
4) Offer incentives that lead electronic manufacturers to
develop partnerships with community-based organizations to
collect and reuse their unwanted products from consumers.
Answers to Post-Hearing Questions
Responses by Renee St. Denis, Director of Americas Product Take-Back
and Recycling, Hewlett-Packard Company
Questions submitted by Chairman Bart Gordon
Q1. In your testimony you stated the need for R&D into several areas
related to electronic waste, including research into applications for
recycled materials, proper regulatory approaches, and the net climate
impact of recycling electronics. What would be the best framework to
implement these research initiatives and who should be involved?
A1. The Federal Government needs to play an active role in supporting
research on key questions regarding the proper management of used
electronics, including the climate impacts. This will help inform
policies that will ensure that the best environmental outcome is
achieved in the most efficient manner. To achieve this goal, the
Federal Government should support research at major universities with
expertise on these issues. A broad set of stakeholders--including the
electronics industry, State and local governments, environmental
groups, and others--should be engaged in working with the academic
community on these issues. These groups can provide useful data,
expertise, and insights in addressing these issues in an efficient
manner.
Q2. How does Hewlett-Packard link recyclability and other
environmental considerations to the product design process? Are
engineers with these expertises integrated into all development teams
or is there a separate team devoted to these issues?
A2. As stated in our written testimony, HP works to create a close link
between our product design and recyclability. HP established our Design
for Environment (DfE) program in 1992, and it remains central to our
business strategy today. Our approach to DfE encompasses the entire
product life cycle. In addition to considering important product
attributes such as energy efficiency and materials innovation, design
for recyclability (DFR) is one of our primary priorities for design for
the environment. We believe that our experience and expertise in
recycling provides an important feedback loop to designers to design
future products so that they can be more readily recycled. It is this
link between the product design and how it is handled at the end of its
life that makes it important for manufacturers to remain engaged
throughout the products' life cycle.
HP's DFR efforts include using common fasteners and snap-in
features and avoiding the use of screws, glues, adhesives and welds
where feasible. This makes it easier to dismantle products and to
separate and identify different metals and plastics. The materials we
choose can also enhance recyclability. For example, in 2007 we
introduced several notebook PC models with LED technology, eliminating
mercury fluorescent tubes and making the display screens easier to
manage at end-of-life. These efforts have significantly improved the
recyclability of HP products, and we are pleased to report the
following:
HP notebook PC products are now more than 90 percent
recyclable or recoverable by weight (as per the definition used
in the European Union WEEE regulations).
HP printing and imaging products are typically 70
percent to 85 percent recyclable or recoverable by weight (as
per the definition used in the European Union WEEE
regulations).
We also made great progress in incorporating recycling materials
into our products. For example, HP has engineered print cartridges that
use recycled plastic without compromising quality or reliability. We
design HP print cartridges to meet the needs of our recycling system
and incorporate recycled material. Since we take back only our own
cartridges, we can be certain about the material content, making it
easier to process exhausted cartridges and reuse the material to
manufacture new ones. More than 200 million cartridges have been
manufactured using the process through 2007. HP used more than five
million pounds (2,300 tons) of recycled plastic in its original HP
inkjet cartridges in 2007, and the company has committed to using twice
as much in 2008. HP also uses post-consumer recycled plastic recovered
through our return and recycling program in the manufacture of original
HP LaserJet print cartridges. This recycled plastic can represent as
much as 25 percent, by weight, of the newly molded LaserJet cartridge
housing. HP has also incorporated recycled content into some hardware
products. For example, in 2007, we introduced a speaker module made
from 100 percent post-consumer recycled plastics in all HP Compaq 6500
and 6700 series Notebook PCs.
Each product team in HP includes a ``product steward'' that is
responsible for all aspects of environmental compliance. This approach
enables HP to ensure that environmental considerations are taken into
account during the design of HP products.
Q3. In your testimony you state that Hewlett-Packard's efforts toward
more environmentally conscious design have resulted in ``HP products
qualifying for a large number of global eco-labels, including EPEAT.''
As you know, EPEAT does not cover consumer electronics, and eco-
labeling for these types of products in the U.S. is limited to the
Energy Star program. Do HP consumer products favorably qualify for some
of these global eco-labels? Does HP believe that these labels
effectively educate consumers about products' environmental attributes
and that educating consumers in this manner will result in increased
U.S. sales for more environmentally sound products?
A3. HP has a long history of promoting environmentally sound design. As
a result of these design initiatives, HP offers a range of products -
both for consumers and businesses--that comply with global eco-labels.
See http://www.hp.com/hpinfo/globalcitizenship/environment/
productdesign/ecolabels.html.
HP believes that educating customers on the environmental
attributes of the products they buy can play a significant role in
shaping purchasing behavior. However, eco-labels are only one means of
achieving this goal. Information on a product web-site, for example,
can be a more efficient way of informing customers than a physical
label, and the glue used on some labels can add to the complexity and
cost of recycling electronic products. Companies should have
flexibility in choosing the manner they communicate to customers. In
this regard, we note that EPEAT does not require a physical label to be
affixed to the product, and that Energy Star only recently mandated the
labeling of products as a requirement of this program.
HP recently announced a new initiative to provide additional
information on the environmental attributes of HP products. HP will
begin using a ``HP Eco-Highlights'' label on new product packaging, web
sites, and data sheets to help customers better understand the
environmental attributes of the product, such as energy consumption and
recycled content.
Q4. You state in your testimony that HP has established the goals of
doubling the use of recycled plastics in printer cartridges in 2008 and
eliminating the use of materials that contain brominated flame
retardants and polyvinyl chloride. What are the challenges your company
faces to reaching these goals?
A4. Incorporating greater amounts of recycled content and phasing out
specific materials each pose distinct challenges. The challenge of
using more recycled content presents a classic ``chicken or the egg''
dilemma. Our desire to use more recycled content is hindered by the
limited availability of suitable materials, and the supply of suitable
materials is limited by insufficient demand. Despite this problem, we
have succeeded in using more than five million pounds (2,300 tons) of
recycled plastic in its original HP inkjet cartridges in 2007, and the
company has committed to using twice as much in 2008. HP also uses
post-consumer recycled plastic recovered through our return and
recycling program in the manufacture of original HP LaserJet print
cartridges. This recycled plastic can represent as much as 25 percent,
by weight, of the newly molded LaserJet cartridge housing.
The challenge of phasing out polyvinyl chloride (PVC) is
complicated by the lack of suitable alternatives for some uses of this
material. Our goal is to eliminate all remaining uses PVC from new
computing products as technologically feasible alternatives become
readily available. To be accepted, alternatives also must not
compromise product performance or quality or adversely impact health or
the environment. We expect to achieve this goal for new computing
products launched in 2009.
An important component of HP's materials substitution efforts is
determining that replacement substances have a lower environmental and
health impact than the substances identified for possible phase-out.
Many potential replacement materials are still being evaluated for
environmental and health impacts. Unfortunately, standard methods to
perform these evaluations do not exist, and as a result differing
conclusions are sometimes drawn from the same study. To address this
concern, HP engages with government agencies, such as the United States
Environmental Protection Agency, and nongovernmental organizations,
such as Clean Production Action, to develop standard methods for
evaluating the environmental and health impacts of new substances.
Q5. In his testimony, Dr. Eric Williams mentioned several applications
for using radio frequency identification (RFID) tags in the management
of end-of-life electronics. From the producer's perspective, what might
the advantages and disadvantages be in using RFID technology to manage
used electronics?
A5. HP has played a leadership role in the development and deployment
of RFID technology. We are currently using this technology to track
product inventory, monitor customer returns and improve product
quality, and other uses.
We agree with Dr. Williams that RFID technology could potentially
play a useful role in helping to manage end-of-life electronics. It is
possible that the tags could help recyclers identify the material
composition of products, identify components requiring special handling
(e.g., batteries), and other issues.
Certain issues need to be addressed before RFID technology could be
employed on a large scale for managing used electronics. First, the
cost of RFID tags are an obstacle, and it remains unclear whether the
benefits of using this technology outweigh these added costs. Second,
the current recycling infrastructure lacks the capability to read RFID
tags and make use of the potentially valuable information on the tags.
Finally, some consumer groups have raised concerns regarding potential
privacy issues associated with the use of these tags on consumer
products.
Questions submitted by Representative Ralph M. Hall
Q1. Does Hewlett-Packard currently publish the life cycle energy costs
for all HP products? If not, would you consider providing such
information to consumers in the future?
A1. HP currently publishes a considerable amount of information on the
environmental and energy attributes of HP products. See http://
www.hp.com/hpinfo/globalcitizenship/environment/productdesign/
products.html. HP recently announced a new initiative to provide
additional information on the environmental attributes of HP products.
HP will begin using a ``HP Eco-Highlights'' label on new product
packaging, web sites, and data sheets to help customers better
understand the environmental attributes of the product, such as energy
consumption and recycled content.
We do not publish ``life cycle energy costs'' for HP products at
this time. HP products are comprised of thousands of parts, components,
and materials, provided by a complex array of suppliers located around
the world. This supply chain consists of many levels or steps that
contribute to the final product. It would be a hugely complex
undertaking to calculate the ``life cycle energy costs'' of the final
product, and there is currently no generally accepted way of collecting
this data and calculating the net energy impacts. HP is working within
the international standards bodies to devise ways of improving the way
such information is provided to consumers. We would consider publishing
the ``life cycle energy costs'' for HP products once there were a clear
methodology for doing so and if there were better ways of compiling the
data in a standardized way.
Even in the absence of publishing this information, HP has made
great strides in reducing the overall energy impacts of our products at
every stage in the life cycle. In our own operations, HP is on track to
achieve a 16 percent reduction in our energy consumption of our
operations by 2010 from 2005 levels. We are also working with our
suppliers around the world to reduce the energy consumed by the
manufacturing, distribution, and packaging of our products. Finally, we
are continuously achieving significant improvements in the efficiency
of our products during the ``use'' stage by the consumer. For example,
we have set a goal of reducing by the energy consumption of volume
desktop and notebook computer families by 25 percent by 2010 compared
with 2005 levels.
Q2. What are the liability concerns for companies that take-back
electronics and reuse or recycle them? Does liability for damages to
workers from exposure during recycling or liability for harm caused by
refurbished equipment limit the growth of take back programs?
A2. HP takes seriously its responsibility to recycle our products in an
environmentally sound manner, including the protection of workers
involved in the recycling process. In addition to our obligations as a
leading corporate citizen, HP seeks to limit any liability that we may
incur as a result of our recycling operations. To achieve this result,
HP requires our recycling vendors to comply with HP's Supplier Code of
Conduct, and we monitor compliance through site audits. See http://
www.hp.com/hpinfo/globalcitizenship/gcreport/productreuse/
recyclingapproach.html. While there is an added cost to recycling in an
environmentally sound manner, we believe that there are cost avoidance
benefits associated with doing so.
Q3. Most major manufacturers claim that they do not ship e-waste
oversees for recycling. Where does the e-waste found in environmentally
unsound recycling operations originate?
A3. HP has a longstanding practice of ensuring that products and
materials from our U.S. recycling programs are not shipped overseas
(i.e., outside the U.S. and Canada) for processing. Unfortunately,
there are numerous other entities involved in the collection and
recycling of used electronics that simply serve as ``waste brokers''
and sell discarded products to others, or ``sham'' recyclers who simply
utilize some profitable parts or materials and sell the rest. Thus, it
appears the most materials found in the developing world that is
subject to environmentally unsound practices originates from waste
collectors, brokers, or ``recyclers''--including municipal and other
governments--that do not manage their materials properly.
According to a recent article in National Geographic Magazine, much
of the improperly managed e-waste in the developing world originates
with local collection events in the U.S. by municipalities or so-called
``recyclers'':
Currently, less than 20 percent of e-waste entering the solid
waste stream is channeled through companies that advertise
themselves as recyclers, though the number is likely to rise as
states like California crack down on landfill dumping. Yet
recycling, under the current system, is less benign than it
sounds. Dropping your old electronic gear off with a recycling
company or at a municipal collection point does not guarantee
that it will be safely disposed of. While some recyclers
process the material with an eye toward minimizing pollution
and health risks, many more sell it to brokers who ship it to
the developing world, where environmental enforcement is weak.
For people in countries on the front end of this arrangement,
it's a handy out-of-sight, out-of-mind solution.
See ``High Tech Trash: Will Your Discarded TV End Up in a Ditch in
Ghana?'' National Geographic Magazine (January 2008) (available at
http://ngm.nationalgeographic.com/2008/01/high-tech-trash/carroll-text/
3).
Q4. Your testimony highlights how HP is investing significantly in
your ``Design for Environment'' and take-back campaigns. However, due
to the storied history of your company you have a long tail of legacy
waste as well. Does HP have a strategy for dealing with legacy waste or
suggestions for the Committee on how best to tackle this problem?
A4. HP has been implementing and expanding its recycling strategy for
nearly 20 years. Since 1987, HP has successfully collected and recycled
more than one billion pounds of used or unwanted computer-related
equipment globally. With our vast knowledge and experience, HP's goal
is to recycle an additional one billion pounds of equipment (for a
total of two billion pounds worldwide) by the end of 2010. HP has
established a recycling service throughout the U.S. (as well as other
countries around the world) that provides consumer and commercial
customers with a convenient opportunity to recycle their old products
in an environmentally sound manner. For more information on HP's
environment and broader global citizenship activities, see: http://
www.hp.com/hpinfo/globalcitizenship/.
HP currently partners with operators of seven large, state-of-the-
art recycling facilities in the U.S. and Canada, as well as operating
our own technologically-advanced facility used to recycled print
supplies. Our recycling facility for printer supplies is located
outside of Nashville, Tennessee. This facility consists of a 40,000
square foot building, including separation and recycling technology.
The facility employs approximately 50 full time employees and processes
all of the material returned to HP through our different print supplies
programs in the U.S., Canada and Latin America.
Q5. Can you describe for us how the current system of print supply
recycling came to be? What obstacles or successes have characterized
this system and can be translated to the broader e-waste problem?
A5. HP recognized early on that print supplies posed unique recycling
opportunities and challenges, and we promptly took steps to provide
customers with a solution for their recycling needs. Unlike computer
hardware products that can be used for many years, print supplies are
``consumables'' that are used for a more limited period. In the absence
of a convenient recycling system, many of these print supplies would be
disposed. To avoid this result, and given the relatively small size and
weight of these products, HP determined that these products could be
readily shipped through the mail or other shipping services to a
recycling facility. HP recognized that customers wished to avoid
disposing of these products, so HP developed a simple product return
system that has been in place for almost two decades. Many of our new
print supplies come with a return envelope or label that allows
customers to return their products quickly and easily. HP is also
expanding its recycling offering by partnering with retailers to allow
customers to drop-off their used cartridges. Once HP receives the used
cartridge, HP recovers plastics that are then used in the production of
new products. Other materials, such as metals, are recycled and made
available on the commodity markets for use in other products.
The success of our recycling system for pint supplies demonstrates
the viability of cost-effective, market-based systems for recycling
used products. However, each product category necessitates a tailored
approach. Just as the collection and recycling system for other common
recyclables--such as appliances, tires, car batteries, and others--are
each different, the system established for computers, TVs, or other
electronic products may likely be different than the system of
returning used print supplies through the mail. In addition, print
supplies use a limited number of different types of plastics that makes
recycling more feasible, many hardware products use a complex
assortment of types of plastics that adds to the cost and complexity of
recycling.
Questions submitted by Representative Daniel Lipinski
Q1. In 2006, the Government Accountability Office estimated that more
than 100 million computers, TVs, and monitors are thrown away each
year. In addition, the EPA estimates that electronic waste is growing
two to three times faster than any other waste stream. Yet presently,
there is no specific federal law or regulation governing the disposal
of consumer electronic products in the U.S. Should there be?
A1. HP has long supported the adoption of federal e-recycling
legislation as a means of encouraging harmonized national approaches to
the challenge of e-recycling. Other major markets, including the EU and
Japan, have adopted legislation on this topic, and we believe it is
appropriate for the U.S. to act as well. In the absence of federal
legislation a growing number of states have enacted their own laws. But
the emerging patchwork of divergent State laws does not serve the
interests of environmental protection and needlessly increases costs.
HP believes that federal legislation is needed to establish a more
efficient, effective harmonized national system.
Q2. The EPA estimates that at most, only 15 percent of products at the
end of their useful lives reach a recycling or reuse program. This does
not come as a shock to me. In fact, it might seem a little high given
the impediments that consumers currently face.
A2. The 15 percent figure is consistent with the results of HP's
recycling program and reflects the challenges of influencing consumer
behavior. Including remarketed equipment, we achieved a total reuse and
recycling rate in 2007 of 15 percent of relevant hardware sales. We
cannot assess the accuracy of this number for other manufacturers.
Q2a. First, how are average consumers to know what to do with their e-
waste when it comes to the end of its useful life?
A2a. Recycling opportunities for average consumers typically vary by
product category and locality. This is likely to be the situation for
e-recycling as well. Under the State programs currently in place, the
options on the ground for consumers vary in terms of drop-off at retail
establishments, municipal collection sites, one-day collection events,
or other collection mechanisms. Consumers typically become aware of
these opportunities by company or government websites or local
advertising. Given that consumers will only look for these recycling
opportunities on an infrequent basis, this approach is probably
appropriate.
Q2b. This past weekend, Washington, D.C. held an e-waste recycling
day. Over ten times as many residents as last year showed to recycle
their gadgets, leading to over two hours wait time. The incentives to
recycle just don't seem to be there right now. What do you recommend be
done to fix this problem?
A2b. The significant wait time for consumers at local collection events
is relatively common, particularly when it is a one-time event.
Consumers may have a number of used devices in storage and they are
looking for an opportunity to recycle a number of these devices at
once. We believe that this ``backlog'' will dissipate once collection
opportunities increase in frequency and convenience, as consumers find
outlets for the devices they currently have in storage. Legislation can
play a significant role in achieving this outcome. Legislation should
establish a framework to create a more frequent and available system of
collection points or events.
Q3. The European Union is often ahead of the United States when it
comes to the issue of recycling. Where do U.S. capabilities stand as
compared to Europe on the topic of e-waste?
A3. The electronics recycling infrastructure is better developed in
Europe than it is in the U.S. In most countries, collection of products
is facilitated by municipal governments and retailers, thereby creating
an efficient and convenient way for consumers to drop off unwanted
products. Also, there are a larger number of recycling vendors to
conduct recycling operations in an environmentally sound manner. HP
played a leading role in the development of a consortium of companies
to conduct recycling operations. For more information, see www.erp-
recycling.org. HP is working to develop the recycling infrastructure in
the U.S. as well by partnering with leading metals recyclers,
developing technologies, and auditing outside vendors to ensure
compliance with environmental and other requirements.
Questions submitted by Representative Bob Inglis
Q1. Many manufacturers support a national solution to deal with e-
waste; a federal law that would preempt the patchwork of State and
local laws that are beginning to crop up. Are there any aspects of
those State laws that would/should be expanded to the national level?
What provisions of State laws in place now would be detrimental to
efforts dealing with e-waste if ramped up to a national scale? Can you
give an example or two of each?
A1. The costs of the emerging patchwork of State recycling laws will
impose significant overall costs on companies. A study by the National
Electronics Recycling Infrastructure Clearinghouse (NERIC) has
estimated the manufacturer compliance costs in 2010 for all 14
jurisdictions having enacted mandatory e-waste financing requirements.
According to the study, even if no other State or local legislation is
passed, the NCER estimates that manufacturers will spend approximately
$71 million in 2010 to comply with the U.S. patchwork of State e-waste
mandates. See www.ecyclingresource.org. This emerging patchwork of
differing State laws is adding significant new costs and impeding the
development of an efficient nationwide infrastructure, while creating
the potential for consumer confusion. A consistent national approach is
necessary and appropriate.
A major goal of federal e-recycling legislation should be the
achievement of a high degree of harmonization among the states and the
elimination of unnecessary duplicate activities. Manufacturers of
covered products are currently facing a variety of State laws that have
differing approaches, product scope, and administrative requirements.
These inconsistent State programs do not improve environmental
outcomes, but instead simply add complexity and cost. Driving greater
consistency among the State programs should be a key priority of
federal legislation.
An important area that demands greater consistency is laws and
regulations governing collection and transport of discarded
electronics. As long as even a few states interpret their authority as
allowing them to impose their own requirements on interstate transport
of these discarded products, be they requirements to transport the
products as hazardous wastes or some other special classification, and
these products must be transported to recycling centers through these
states, efforts to develop a national recycling system will be stymied.
The State of Maine is one example of a state acting to impose unique
requirements for certain discarded electronic products. In various
cases, Maine regulation requires shippers to use a hazardous waste
manifest or shipping papers similar to a hazardous waste manifest, and
to use transporters with special plans and programs in place. In our
experience, we have found it to be extremely difficult to find
interstate transporters prepared to meet Maine's unique requirements.
For these and other reasons, we currently do not offer one of our
hardware take back programs in the State of Maine. [Optional: We do
retain a recycling company nearby to Maine that operates their own
transport vehicles to meet legislated take back obligations in Maine,
but we do not have the same flexibility as in various other states to
hire any common carrier to transport products to our various chosen
recycling contractors. If we wished to, we would have to attempt to
have the local recycler collect the material and take it to a
neighboring state, then transfer the load to a common carrier there to
enable it to be transported to one of our more distant U.S. recyclers
managing large volumes for us.]
Another approach adopted in one state--California--that would be
detrimental if expanded would be the imposition of point-of-sale fees
on the sale of new products to finance the recycling of old products.
Fortunately, California is the only state that has adopted that
approach. Our experience and data from other recycling programs
indicate that these fees (which are, in fact, taxes) result in higher
overall costs than producer responsibility models that enable
innovation and incentives for efficiency. See, e.g., Gregory and
Kirchain, ``A Comparison of North American Electronics Recycling
Systems.''
Answers to Post-Hearing Questions
Responses by Eric Harris, Associate Counsel/Director of Government and
International Affairs, Institute of Scrap Recycling Industries
Questions submitted by Chairman Bart Gordon
Q1. In your testimony you mentioned the need for research and
development into new markets for plastic and glass, and recycling
technologies for plastics. What would be the best mechanism to fund and
prioritize this research? What would be the best mechanism to
facilitate technology transfer to the recycling industry?
A1. It would seem that the best means to fund and prioritize plastic
and glass research would be to include in the Appropriations Interior,
Environment, and Related Agencies bill an appropriation directed to the
U.S. EPA Office of Research and Development.
The research and development for new markets and technology related
to glass and plastic would assist manufacturers in developing new
technologies and uses for recyclable materials. And it would make more
efficient existing uses of recyclable materials in the manufacturing
process. Subsequently, manufacturers would develop additional
requirements to utilize the recyclable material in their manufacturing
processes.
Q2. You mention the difficulties associated with recycling the leaded
glass from cathode ray tube televisions and monitors. Are there end-of-
life challenges associated with flat panel displays? Is there a market
for this glass?
A2. Yes. The new technology in flat screen displays utilizes a system
of cylindrical lamps that contain mercury powder. These mercury lamps
are very time consuming and costly to remove or replace, which also
makes these products difficult to recycle.
The Institute of Scrap Recycling Industries Inc., (ISRI) has long
advocated working with manufactures to design their products to be
easily recycled at the end of their useful lives, including eliminating
hazardous, toxic constituents, or creating other impediments that can
hinder the recycling of those products. Design for Recycling (an ISRI
program established to encourage manufacturers in all industries to
design their products, from the outset, with recycling in mind) will
help to avoid these additional costs and improve recycling efficiency.
The best market for flat panel screens and cathode ray tubes is
resell. In today's market, the resell value for flat panel displays is
strong. Similar to the lead in cathode ray tubes, the mercury in the
flat panel screens reduces the cost effectiveness of processing flat
panel displays.
Q3. Now that producers are designing products to eliminate hazardous
substances under Europe's Restriction on Hazardous Substances (RoHS)
Directive, what more needs to be done to increase product
recyclability?
A3. Rather than prescriptive changes, ISRI suggests that more
collaborative opportunities are needed to think through some of these
design issues before these products reach the market. For example,
EPEAT is an electronic product design standard adopted by the
Environmental Protection Agency that has been very successful in the
marketplace. Most major computer manufacturers are using EPEAT as their
measure of environmental product design, and are competing to gain
additional credits from EPEAT by going beyond what other OEMs have
done. For example, some manufacturers have incorporated significant
amounts of recycled plastic in their products. This creates an
increased demand for recycled plastics from computers. Additional
programs could be encouraged by the Congress such as the EPEAT program.
Q4. You mention in your testimony that the recycling industry has
called upon producers to adopt a Design for Recycling philosophy but
thus far they have met with only limited success. How do recyclers
presently engage with electronic producers? Are there other industries
with stronger partnerships that the electronics industry could learn
from? Is there evidence from the electronics industry, or other
industries, which shows producers will design products for easier
recycling if they are financially or physically responsible for the
product at the end of its life?
A4. Recyclers have had some success working with electronics
manufacturers regarding design issues but such interactions have been
limited.
ISRI has presented its Design for Recycling award to HP for its
leadership in designing its products for recycling. Certainly, HP is a
good example of a manufacturer that promotes producer responsibility
and is committed to Design for Recycling because it makes good
environmental and economic sense.
Another example focuses on the use of mercury switches in the
automobile industry. That industry began to use convenience light
switches and ABS brake sensors that contained mercury. Because of
concerns about the hazards of mercury, especially to children and
pregnant women, most non-American auto makers ended the use of mercury-
containing switches in vehicles in 1993. The American manufacturers,
however, continued to use mercury switches in vehicles built for the
American market--until 2003. It was then that various states began
requiring the removal of mercury switches from end-of-life vehicles at
the expense of the manufacturers. That economic disincentive caused the
auto makers to end the use of mercury switches and to seek a national
program to support such switch removal.
Some years ago, ISRI worked with the Association of Home Appliance
Industries (AHAM) to eliminate the use of cadmium paints in the
manufacture of new appliances. Cadmium is a hazardous substance. And,
ISRI works with the Vehicle Recycling Partnership (VRP), an entity
created by the American auto manufacturers to develop ways and means to
increase a vehicle's overall recyclability. In addition to ISRI and the
auto manufacturers, other VRP participants are the auto dismantlers and
the steel industry.
Q5. You state in your testimony that export of electronics can be safe
and is an important part of the recycling industry. You also mention
that in places like China there are legitimate and responsible
recyclers. How should we close the loop on used electronics shipped
overseas so that once they reach true end-of-life they are handled by
legitimate recyclers?
A5. In today's market, buyers and brokers around the world are paying
for scrap electronics as compared to recyclers in the U.S. having to
charge to recycle the same material. This is due to the fact that some
electronic equipment, such as monitors and televisions, has a net-
negative cost to recycle; that is, the costs outweigh the value of
recoverable material. However, at the same time, there is a thriving
reuse market outside of the United States that allows foreign buyers to
pay a premium for monitors and TVs.
ISRI advocates recognizing and giving contractual preferences to
responsible recyclers anywhere in the world that can demonstrate that
they are `legitimate' recyclers. In fact, for the past two years ISRI
has represented electronics recyclers in a multi-stakeholder process to
develop responsible recycling practices (R2) for electronics recyclers.
The Environmental Protection Agency has convened and facilitated this
effort. Once completed, ISRI intends to incorporate this set of
specific performance practices into its Recycling Industry Operating
Standard (RIOS) for electronics recyclers.
ISRI developed RIOS as an integrated management system standard
designed specifically for the scrap recycling industry and the ANSI-ASQ
National Accreditation Board will oversee the third party registrars
who will audit recyclers. It provides electronic recyclers with an
affordable tool to monitor their quality, environmental, health and
safety goals. Few industries worldwide have endeavored to undertake
such a huge step, but the recycling industry in the United States has
always been, and intends to remain, the global leader in recycling
technology, environmental protection, worker safety and the production
of high quality materials. RIOS plus R2 are tools for recyclers to
accomplish those goals. This will help to build needed confidence in
the market place and reward responsible recyclers that are willing to
be audited to a set of requirements in an open and transparent process.
Questions submitted by Representative Ralph M. Hall
Q1. What are the liability concerns for companies that take-back
electronics and reuse or recycle them? Does liability for damages to
workers from exposure during recycling or liability for harm caused by
refurbished equipment limit the growth of take-back programs?
A1. As with any business decision, there is always some risk associated
with choosing strategic business partners. However, companies can
dramatically reduce their potential risks associated with recycling
electronic equipment (like re-selling hard drives with sensitive data
or mismanaging material like mercury, batteries or leaded glass) by
selecting a recycler that correlates to their risk tolerance. Companies
need to educate themselves as to the differences of recyclers on the
market. There is a wide disparity of services being offered from a wide
variety of recyclers. As with other prudent business decisions,
conducting appropriate due diligence and then contracting with a
responsible recycler based on individual needs can significantly reduce
if not eliminate a companies potential liabilities.
Q2. How has electronics in the waste stream changed over the past
decade and what predictions can we make about changes in the coming
years? How do these changes affect our ability to safely and
efficiently recycle or reuse these devices?
A2. The precious metal quantities have decreased on a per unit basis,
which has decreased the per unit recoverable value of electronic
equipment. However, the overall volumes have increased. Recyclers are
simply seeing more electronic equipment coming into their facilities.
The biggest challenges are finding end-markets for leaded glass and
mixed-plastic resin.
Another emerging challenge is smelting capacity. Globally, the lead
and precious metal smelters are quickly running out of capacity to
recover the world's growing supply of electronic scrap. For example,
there are only two major lead smelters left in North America. Lack of
smelting capacity could significantly impact the sustainability of this
market.
Q3. Most major manufacturers claim they do not ship e-waste overseas
for recycling. Where does the e-waste found in environmentally unsound
recycling operations originate?
A3. As scrap commodities and new and used electronic equipment is
traded globally, the material is being generated from all over the
world, which includes from the importing countries themselves. For
example, China and Southeast Asian countries are the largest growth
markets to sell new and used electronic equipment. Once that equipment
reaches its end-of-life, artisan communities are purchasing and
processing that material as well as material imported from developed
countries. Since demand is so high, Asian brokers are able to pay more
for the obsolete electronic equipment than in Europe and the United
States. Thus, countries like China continue to purchase obsolete
electronic equipment from countries all over the world, including the
United States.
Q4. In your testimony you state that, ``electronics recycling yielded
approximately 1.3 billion pounds of recyclable materials'' in 2006. How
much of this material was subsequently used as raw manufacturing
inputs?
A4. ISRI asserts that most, if not all, of the 1.3 billion pounds is
absorbed back into the manufacturing process.
Q5. You state that much collected equipment has a net-negative cost to
recycle. What are some examples of goods that generally cannot be
recycled efficiently? How much of the current electronic waste stream
is comprised of these goods?
A5. Unlike central processing units that yield a positive value of
around 10 cents a pound and can be resold as a usable device for $50-
$70 dollars, and 99 percent of laptops that are resold in their
entirety and yield between $300 and $550 a unit, most electronics
recyclers must charge their customers to recycle televisions and
monitors containing cathode ray tubes (CRTs) to off-set the negative
costs. Recyclers generally charge between 20-30 cents a pound, relative
to truckload bulk equations for televisions and monitors with CRTs.
Televisions and monitors with cathode ray tubes pose the biggest
challenge to municipal landfills and for-profit recyclers. The hard
reality is that many consumers are not prepared or willing to pay an
additional fee to responsibly recycle their old TVs and monitors.
It is worth mentioning that experts estimate that 30 percent of
Americans currently throw televisions in the garbage (permitted under
existing federal law) rather than recycle or donating them. That is the
equivalent of 67,698,877 televisions. By recycling those televisions,
according to the EPA's WARM model\1\ environmental benefits calculator,
753,072.68 metric tons of carbon equivalents would be prevented from
entering the atmosphere.
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\1\ United States Environmental Protection Agency WAste Reduction
Model (WARM), http://www.epa.gov/climatechange/wycd/waste/calculators/
Warm-home.html
Q6. What are the most difficult components to safely and cost-
effectively recycle? Other witnesses have raised plastics, mercury
lamps, and lead content as having the potential to negatively affect
environmental and public health. What is the state-of-the-art for
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recycling or reuse of these items?
A6. We would generally agree with your aforementioned list. Mixed
plastic resin, mercury lamps, batteries, and leaded glass are the most
difficult items to cost-effectively recycle. However, if responsibly
recycled these materials pose little to no risk to the environment or
to public health. Each of these materials are sorted and then sent to
appropriate material recovery facilities. For example, leaded glass is
sent to either a glass-to-glass manufacturer or to a lead smelter.
Depending on the quality of the sort, mixed plastic is either sold to a
plastic manufacturer or for energy recovery. Mercury lamps are sent to
facilities that specialize in mercury recovery and then to retort
facilities.
Questions submitted by Representative Daniel Lipinski
Q1. In 2006, the Government Accountability Office estimated that more
than 100 million computers, TVs, and monitors are thrown away each
year. In addition, the EPA estimated that electronic waste is growing
two to three times faster than any other waste stream. Yet presently,
there is no specific federal law or regulation governing the disposal
of consumer electronic products in the U.S. Should there be?
A1. ISRI supports a national solution that promotes a sustainable,
market-based recycling infrastructure. We also support a system that
improves Design for Recycling, promotes responsible recycling and
allows the free and fair trade of scrap commodities globally. ISRI is
concerned that a multiplicity of 50 different laws and regulations will
inhibit economies of scale and market efficiencies, thereby hindering
the development of a sustainable recycling infrastructure, and slowing
the development of end-use consumer markets for these valuable raw
materials.
However, private sector electronics recyclers are already recycling
under a host of applicable environmental, health and safety, commercial
and import/export regulations; such as permitting requirements in the
CAA, CWA and storm water provisions, RCRA (solid and hazardous wastes
provisions), OSHA, more stringent State requirements, federal and State
transportation laws, U.S. export laws and import requirements of
foreign countries, such as those administered by China's General
Administration on Quality Supervision, Inspection and Quarantine
(AQSIQ). We are doubtful that a set of new regulations are needed to
address electronics recycling. At the same time, we recognize that a
few ``sham'' recyclers may be spoiling the concerted efforts of most
responsible recyclers to adhere to high standards and applicable law.
ISRI asserts that more precise enforcement efforts targeted at ``sham''
recycling, and making certain that governmental entities involved in
electronics recycling are fully complying with the current statutory
and regulatory regime, is more appropriate than creating new laws and
regulations.
Q2. The EPA estimates that at most, only 15 percent of products at the
end of their useful lives reach a recycling or reuse program. This does
not come as a shock to me. In fact, it might seem a little high given
the impediments that consumers currently face.
A2. First, how are average consumers to know what to do with e-waste
when it comes to the end of its useful life? This past weekend,
Washington, D.C. held an e-waste recycling day. Over ten times as many
residents as last year showed up to recycle their gadgets, leading to
over two hours wait time. The incentives to recycle just don't seem to
be there right now. What do you recommend be done to fix this problem?
One of the primary benefits of having OEMs and retailers
participating in producer responsibility and take-back programs is
their access to consumers. Educating consumers about were they can
recycle their household electronics is essential to furthering a
sustainable infrastructure. Recyclers do not have the same access to
consumers as do the OEMs and retailers. ISRI strongly believes, for
this type of reason, that OEMs, retailers, collectors, transporters and
recyclers must work together to educate consumers in order to utilize
the existing reuse/recycling infrastructure.
As far as incentives, one of the primary challenges is to reeducate
the consumers to think of household electronic equipment as a
recyclable and not a waste. It is very important to distinguish between
scrap and waste as well as recycling and disposal. Simply stated, scrap
is the opposite of waste. Processed scrap materials are commodities
that have a significant value on domestic and international markets as
raw material feed stocks that substitute for virgin materials in the
manufacture of new basic materials such as copper, steel, and plastics.
Unlike scrap, waste has no value and is typically buried in a landfill.
Electronics scrap, like scrap paper, glass, plastic, metal,
textiles, and rubber, is not waste when recycled. Defining scrap
electronics as waste undermines and overlooks the value that these
electronics retain, if properly recycled. Saddling them with the
moniker of ``waste'' imposes a whole host of unwarranted regulatory
burdens that will undermine the ability to allow the recycling system
to operate effectively and efficiently.
ISRI is confident that making the connection between recycling and
climate change will provide an extra incentive to recycle household
goods. Scrap recycling is one of the world's most climate friendly
activities. The use of recycled scrap materials to manufacture new
products sustains the earth's natural resources, while at the same
time, conserves impressive amounts of energy in the manufacturing
process, and thereby significantly reduces greenhouse gas emissions
from those facilities.
In addition, the market is also responding with new incentive
approaches. For example, Sam's Club stores has a program that will
allow consumers to redeem unwanted electronics for a Sam's Club gift
card, the value of which is determined by the quantity and quality of
electronics traded in. These types of programs coupled with the
public's desire to recycle more due to climate change will likely
provide extra incentives into the marketplace.
Q3. The European Union is often ahead of the United States when it
comes to the issue of recycling. Where do U.S. capabilities stand as
compared to Europe on the topic of e-waste?
A3. ISRI is perplexed by the notion that the European Union is
presumably ``ahead of the United States'' when it comes to recycling.
In the minds of many, recycling in the United States is a phenomenon
that began in the 1970's following the original Earth Day celebration.
For others, awareness dates to the late 1980's following the infamous
voyage of the ``garbage barge'' and the ensuing fears that landfill
capacity had reached a crisis stage. It may interest the Committee to
know that the scrap recycling industry actually dates back to the
beginnings of our nation, when a statue of King George III was toppled
in NYC and its metal was used to make bullets for the Continental Army.
Our members are in the business of recycling, and have formed the basis
of the established recycling infrastructure that exists in this country
today.
ISRI is now the largest trade association of recyclers throughout
the world. With approximately 1,500 member companies that process,
broker and industrially consume scrap commodities, including metals,
paper, plastics, glass, rubber, electronics and textiles. Our members
operate at over 3,000 locations in the United States alone. More than
20 percent of ISRI's membership is involved in electronic scrap
processing and industrial consumption of scrap material generated by
electronics recyclers. In 2007, the domestic industry manufactured
approximately $71 billion of specification grade commodities that were
used in lieu of virgin materials to manufacture basic products,
including over 81 million tons of iron and steel, five million tons of
aluminum, 1.8 million tons of copper, and two million tons of stainless
steel, just to name a few. Of the $71 billion, nearly $22 billion worth
of material was exported to 152 countries worldwide, making a
significant positive contribution to the United States balance of trade
with other nations.
Recyclers' capacity in the United States to responsibly recycle
electronic equipment is comparable if not superior to European
operations. Approximately 2.8 billion pounds (1.4 million tons) of
electronic equipment were recycled in 2006, including 65 million units
of computer equipment (CPUs, monitors and printers). The electronics
recycling process yielded approximately 1.3 billion pounds of
recyclable materials, more than half of which were metals.
Questions submitted by Representative Bob Inglis
Q1. Many manufacturers support a national solution to deal with e-
waste; a federal law that would preempt the patchwork of State and
local laws that are beginning to crop up. Are there any aspects of
those State laws that would/should be expanded to the national level?
What provisions of State laws in place now would be detrimental to
efforts dealing with e-waste if ramped up to a national scale?
A1. Short-term Financial Mechanism
ISRI supports a federal approach over a patchwork of State laws. As
with most of the existing State laws, until such time as the market for
recyclable electronics becomes economically viable, ISRI's policy
supports holding producers responsible for the collection,
transportation and recycling of household electronic equipment that has
a net-negative cost to recycle, such as cathode ray tubes in monitors
and televisions. ISRI firmly believes that producer responsibility will
provide manufacturers with the needed incentive to design their
products with an eye to the future, incorporating design changes that
maximize recycling at the end-of-life.
We strongly encourage the Congress and the states to end any
financial mechanism as soon as markets for recyclable electronics
become economically viable. We are not an industry that seeks
government subsidies, and we believe markets must ultimately stand on
their own based on solid business principles. However, whatever
financial mechanism the Congress and the states might decide to adopt
in order to sustain this market, ISRI suggests that a portion should be
applied to the research and development of end-use markets for the
scrap materials recovered from electronics products, particularly mixed
plastic resins and leaded lass.
Concentrate on Household Monitors & Televisions
Many states are asking OEMs to pay for the costs to recycle
electronic equipment that has a positive value to recycle. This makes
no sense. Recyclers do not need help covering the costs of recovering
positive valued electronics, like central processing units, laptops and
cell phones. ISRI suggests that the federal bill only begin with
consumer generated monitors and televisions with cathode ray tubes. You
may recall that EPA in recent years finalized a federal rule for CRTs,
and their action was very timely in light of the digital transition.
That action may help to alleviate consumers' reluctance to pay to
responsibly recycle these devices.
Electronic Scrap Must Be Allowed To Move
States lack the jurisdiction to regulate exports. Nevertheless,
ISRI contends that the stigma associated with ``exporting'' is
misguided and exports should be viewed from the prism of the realities
of the global economy. The focus should be to promote responsible
recycling globally and concentrate efforts towards enhancing and
promoting environmentally capable facilities that will receive and
properly handle recycled materials anywhere in the world.
Reasonable Performance Requirements
OEMs, in association with interested stakeholders should determine
the best process performance requirements placed on their businesses;
however, there is a growing concern in Europe that performance
requirements that are too aggressive can distort the collection market
and ultimately the long-term sustainability of electronics recycling.
Many in Europe (and a growing number in the U.S. concerned about
domestic programs with high quotas such as Minnesota's) now argue that
performance quotas which are too high can distort the price of
collection by forcing OEMs to compete for a limited supply of
electronic devices. Nevertheless, any quota system should track the
available supply as it relates to the phased-in landfill ban.
Include Transportation Costs
ISRI suggests that transportation costs need to be included with
the OEM obligations because the transportation expense associated with
moving old computer monitors and TVs into the recycling stream is one
of the largest costs of electronics recycling. Without addressing this
important consideration, it is likely many of these older and heavier
products will not be returned to the recycling stream by their owners.
Therefore, any collection system must cover all the costs of
transportation in order for the program to be effective.
Landfill Ban for Recyclable Material
As with most states, keeping these materials out of the landfill is
an important component to ensuring enough supply is available to enable
an economies of scale business model. Under existing federal law,
consumers can dispose of their household electronic equipment legally.
In order to ensure adequate supply for positive-valued electronics
equipment, ISRI supports a national land-fill ban for recyclable
material that cannot be safely and economically recycled using existing
technologies and methods.
Reasonable Recycling Standards
ISRI promotes the benefits of comprehensive, integrated
environmental, health and safety and quality management systems, such
as ISRI's Recycling Industry Operating Standard (RIOS), implemented by
electronics recyclers as a means to promote and to ensure the proper
handling of electronic products destined for recycling.
Answers to Post-Hearing Questions
Responses by Ted Smith, Chair, Electronics TakeBack Coalition
Questions submitted by Chairman Bart Gordon
Q1. In your testimony, you suggest a National Sustainable Electronics
Initiative. Which federal agency or agencies should oversee this
initiative? How should industry be involved?
A1. We propose that Congress establish a new National Sustainable
Electronics Initiative which would be composed of a National Clean
Electronics Council (a governing body) and a National Clean Electronics
Research and Development Fund (funded by Congress.) Rather than house
this new Initiative in any one federal agency, we propose that it be a
collaborative effort that would include several federal agencies as
well as participation from industry, academia and non-governmental
organizations. We have looked at the National Nanotech Initiative and
the National Renewable Energy Laboratory's (NREL's) Science and
Technology Organization as potential models. Both include broad
representation of federal agencies with outside stakeholders and serve
as good models to address other major federal needs. Our proposal is
for an ``initiative'' rather than a new single agency ``center'' and
the inclusion of the National Clean Electronics Council is similar to
the governing structure established for the National Nanotech
Initiative.
We believe that it would be most effective if it includes a broad
range of expertise from federal agencies which could include the
Department of Commerce, Department of Energy, Department of Health and
Human Services, National Institute for Occupational Safety and Health,
Environmental Protection Agency, Department of Labor, Occupational
Safety and Health Administration, National Science Foundation, the
National Labs, Consumer Products Safety Commission, and other agencies
and departments with appropriate expertise. Representatives from
industry will need to be significantly involved--especially those who
are already involved in research and development, as well as in
environmental and occupational health and safety.
Another arena that we believe should be assessed is the model of
the Centers for Excellence in the semiconductor industry (through
SEMATECH) as well as for nanotechnology, which provide for
collaboration between academia and industry. Another example is the
Center of Excellence for Photovoltaic Research and Education.
One of the key issues that will need to be addressed, however, is
the need for real transparency and effective public participation,
which often present challenges when dealing with the electronics and
scrap industries. It is also essential that `customers' who generate e-
waste (such as corporations, universities, municipalities, etc.) are
valued stakeholders in the process of defining a solution to this
problem, as they have needs around data security, CRCLA liability,
brand name protection, etc.
We believe that a real public/private partnership between the
Federal Government and industry experts--with full collaboration from
universities and NGOs--is necessary to address these concerns in a
comprehensive manner. We look forward to working with the Committee to
further define and give shape to this initiative as it moves forward.
Q2. In your testimony you stated that 50 to 80 percent of the
electronics products taken in for recycling are instead shipped to
developing countries where they are de-manufactured in unsafe and
environmentally harmful conditions. What accounts for the range in your
estimate?
A2. The 50 percent to 80 percent figure is an estimate that we have
developed through extensive discussions with experts in the industry.
We initially developed this estimate when we were researching and
writing the first report on the hazards of exporting electronic waste--
``Exporting Harm: The Toxic Trashing of Asia'' by Basel Action Network
and Silicon Valley Toxics Coalition, February 25, 2002. See http://
www.computertakeback.com/docUploads/Exporting-Harm.pdf for
the full report. In doing this research, we discovered that the Federal
Government does not collect data on hazardous waste exports so it is
unable to measure or monitor this growing problem. Since there is no
effective federal oversight of e-waste exports, the only way that we
are able to make this estimate is by surveying the experts in the
industry. It is a significant fact that the U.S. does NOT have any
definitive quantities and destinations for exports of electronic waste.
All other developed countries, and a total of 170 nations are legally
bound to control and monitor their exports of toxic waste, as a result
of ratifying the Basel Convention. The U.S. (the largest generator of
e-waste globally) has no system in place to quantify--much less
restrict--where our toxic waste ends up.
The reason most electronic waste collected for recycling is
exported is that waste generators here is the U.S. (such as
corporations, universities, municipalities, individuals, etc.) are
faced with a choice between paying for their e-waste to be responsibly
managed in the U.S./developed world versus generating revenue by
selling their e-waste to a broker or `recycler' who exports it to the
highest bidder globally, usually China.
For example, many municipalities across the country want to keep
these toxins out of their landfills and would like to offer free
recycling to the public so that there is no disincentive for the public
to bring equipment in, but this can be very expensive for local
governments. Because of these pressures, less savvy solid waste
officials frequently contract with exporters to either take all the
equipment for free or even buy it for a few cents on the pound. These
exporters usually do nothing other than repackage the e-waste into
international shipping containers, exporting everything from sensitive
data on hard drives to toxic waste (which is illegal for many nations
to import from the U.S.). On the other hand, responsible U.S. recyclers
with permitted warehouse facilities, providing data security, worker
protections, U.S. wages, etc., must charge customers for managing this
toxic waste. Even though the metals market currently has a high market
value, responsible recyclers in the U.S. repeatedly tell us that proper
management of the leaded glass, mercury lamps, etc., results in a net
cost for the overall labor and administration of this complex waste
stream.
In our unregulated U.S. arena, not only are there no hard numbers
quantifying exports, but there is a very wide range of recycling
practices in an often unscrupulous industry. This eaves it up to the
waste generators to navigate a complex, multi-tiered world of brokers
and middle men, all looking to make a profit on this problematic waste
stream.
An additional factor that encourages export of e-waste is that some
U.S. based companies that call themselves recyclers are unscrupulous.
They engage in outright bribery in sending shipments of hazardous waste
to foreign countries, since it is illegal for about 140 countries--the
non-OECD Basel Parties--to trade in toxic waste with the U.S. In one of
the most notorious cases documented, Mark Dallura of Chase Electronics
explained how the system works:
``Mark Dallura, head of Chase Electronics Inc. of Philadelphia,
which buys discarded computers in the United States and then ships them
to China via Taiwanese middlemen based in Los Angeles, said he has been
in the trade for 15 years and has not been slowed by the [Chinese] ban.
``I sell it to [the Taiwanese] in Los Angeles and how they get it
there is not my concern,'' Dallura said. ``They pay the customs
officials off. Everybody knows it. They show up with Mercedeses, rolls
of hundred-dollar bills. This is not small time. This is big-time
stuff. There's a lot of money going on in this.''
Dallura said his company gets many of its old computers from
recyclers scattered across the United States. They pick them up from
well-intentioned citizens and businesses that hand them off at events
organized by cities and counties aimed at keeping e-waste out of
landfills. He acts as a broker, consolidating container shipments that
he then hands off to the middlemen. Most weeks, he ships at least one
container bearing 45,000 pounds of such waste.
A container full of computer monitors brings him a fee of $2,600,
he said. During a recent week, he planned to ship four containers. Two
were bound for Hong Kong, the other two for Nanhai, bearing mainframe
computers not covered by China's ban.
``I could care less where they go,'' Dallura said. ``My job is to
make money.''
``China Serves As Dump Site For Computers'' Washington Post,
Monday, February 24, 2003.
http://www.etoxics.org/site/
PageServer?pagename=svtc-washpost-2-24-
2003
Since these early stories of exporting toxic e-waste were
published, there has been tremendous consolidation and growth in the
U.S. e-waste recycling industry. Yet, most of these U.S. companies face
frustration as they are well under capacity. In contrast, exporters
offer cheaper or free service, subsidized by human health and the
environment in developing countries.
In recognition of the seriousness of the impact of exporting
hazardous e-waste, the GAO is currently investigating the extent of the
problem, at the request of late Chairman Tom. Lantos. The GAO is
expected to report back to Congress this fall.
Q3. You stated that electronic waste ``would not be an issue if the
products themselves were not so toxic.'' Does Europe's Restriction on
Hazardous Substances (RoHS) Directive sufficiently address the toxicity
issue for electronics? You also state that electronics products are
``poor[ly] designed'' in terms of recyclability. With the increased
adoption of extended producer responsibility legislation, have
producers made any changes to their products to make them easier to
recycle?
A3. While the RoHS Directive will help address the toxicity issue to
some degree, it is really only a drop in the bucket when assessing the
overall problem. The current version of RoHS addresses only 6 of the
more than 1000 substances that are involved in the manufacture of
electronic products, many of which are toxic--carcinogens, reproductive
toxins, neurotoxins, tetratogens, etc. With that said, the European
Union is set to revise RoHS over the next twelve months and include
additional substances since there was recognition that RoHS version 1
was a small first step towards greening the supply chain of the
electronic sector. This is another area where the U.S. needs to become
more active.
An important recently published epidemiological study published by
Richard Clapp of Boston University found high rates of cancer among
manufacturing workers at IBM plants in the U.S. See Mortality among
U.S. employees of a large computer manufacturing company: 1969-2001,
http://www.ehjournal.net/content/5/1/30. The study, which evaluated the
cause of death for over 30,000 IBM workers, concludes:
``Mortality was elevated due to specific cancers and among workers
more likely to be exposed to solvents and other chemical exposures in
manufacturing operations. Due to lack of individual exposure
information, no conclusions are made about associations with any
particular agent.''
Some product designers tell us that manufacturing of new products
happens in China and other developing countries because Original
Equipment Manufacturers (OEMs) demand the use of chemicals (e.g., to
achieve specific surface treatments) that are no longer allowed in U.S.
manufacturing facilities.
It is clear that the issue of toxicity is pervasive in electronics
products--from manufacturing through disposal. This is why we need a
major R&D initiative that helps major OEMs--many of which have
headquarters and research and development operations based in the
United States--to replace chemicals and materials that are problematic
throughout the life cycle of their products with safer more innovative
alternatives. Enhanced research and development of environmentally
improved chemicals and materials can also be an important step toward
improved global competitiveness.
It is also true that electronic products are poorly designed in
terms of recyclability. Since manufacturers have not been financially
or physically responsible for end-of-life treatment historically, they
have not felt the need to design for recyclability. For example,
recyclers tell us that one electronic device may have 6-8 different
types of screws or fasteners needed to de-manufacture a single piece of
equipment, requiring workers to change tools multiple times, increasing
ergonomic stresses and slowing efficiency. This is beginning to change
with the recent implementation of the Waste from Electronics and
Electrical Equipment (WEEE) directive in Europe (2006) and similar new
initiatives in many other countries, and this is the principle reason
that we are supporting similar legislation here in the U.S. However, it
is still too early to see much direct impact from product re-design in
response to these new initiatives, as most of the current waste stream
doesn't include these new products. In fact, one of the most
significant technological innovations--the development of flat panel
monitors and TVs to replace Cathode Ray Tube (CRT)--has resulted in the
creation of new problems for recyclers. While the large amount of lead
in CRTs has presented one of the most significant challenges for
recycling, the transition to flat panel Liquid Crystal Displays (LCD)
monitors which contain mercury lamps has created new challenges, since
most of these monitors were not designed for ease of removing the
mercury before shredding or recycling. To make matters worse, many
manufacturers are not inclined to re-design these monitors to increase
the ease of disassembly. To do so would include costly design changes
at a time when most manufacturers are developing the next generation of
products based on light emitting diode (LED) technology. This is a good
example of how rapid technological change invariably outpaces the
ability of government, workers, communities, and recycling communities
to keep up and why we need a major new initiative to require some
baseline minimums for toxic inputs and design for recycling, and to
better integrate the advances in technological change with society's
need for improved health and environmental protections.
I am providing links to the following articles from Clean
Production Action that further elaborate on these issues:
1. How Producer Responsibility for Product Take-back Can
Promote Eco-Design, http://www.cleanproduction.org/pdf/
cpa-ecodesign-Apr08.pdf
2. Why promote Green Chemistry, http://
www.cleanproduction.org/Green.php
Q4. What responsibility should the consumer bear for the end-of-life
management of electronics? How can consumers be better educated about
recycling and who should do this? Do you believe that an eco-label or
eco-rating system for consumer electronics would motivate consumers to
buy products that were more environmentally friendly?
A4. There is a very significant need for better consumer education
about the myriad challenges of dealing with end-of-life electronics.
Most consumers still are not aware of the hazards resulting from
disposal of their old electronic products. Even for those who are,
there are no free and convenient options readily available in most
cases. Some consumers who are more aware of the irresponsible disposal
of e-waste are hesitant to recycle their e-waste for fear it will not
be responsibly recycled. The Federal Government needs to act to stop
low-end practices of dumping e-waste on developing countries and
federal prisons so that all those with e-waste--consumers and
institutions--can do so without fear of contributing to the poisoning
of other people.
However, there needs to be a combination of massive public
education and increase in consumer options in order to address the role
and responsibility for consumers. One without the other simply does not
work. Yet, with appropriate attention to education and convenience, it
will be possible to make major changes in the way that consumers deal
with their obsolete products, much in the same way that many consumers
have significantly changed their behavior with respect to recycling
paper, aluminum and plastic over the past few years. To create an
effective infrastructure for collecting e-waste from consumers for
recycling or reuse, we need to undertake a major expansion of options
for consumers, including return to retail stores, return to nearby
collection centers, free mail back, etc. There is a need to encourage
people to get their equipment into reuse streams when the equipment has
the most value for another user.
Eco-labels can be a part of this needed cultural change, as has
been shown in several European countries. The TCO eco-label in Sweden,
for instance, has a consumer awareness and acceptance of over 80
percent. Thus, many manufacturers design their products to meet the
requirements of the European labels in satisfaction of consumer
demands. While the U.S. lags far behind Europe in this regard, there is
reason for optimism with the experience of the Energy Star label, as
well as with the early interest with the EPEAT labels. Again, the
increased availability (and affordability) of eco-label branded
products combined with greater public education will help to motivate
more consumers to purchase more environmentally friendly products, and
more manufacturers to make them.
Questions submitted by Representative Ralph M. Hall
Q1. How have electronics in the waste stream changed over the past
decade and what predictions can we make about changes in the coming
years? How do these changes affect our ability to safely and
efficiently recycle or reuse these devices?
A1. One of the most important changes in the electronics waste stream
over the past decade is the enormous growth rate, both in the number of
new products and in the decreasing life span of new products.
Electronics innovation is largely driven by Moore's law (named for
Gordon Moore, inventor of the semiconductor and one of the founders of
Intel, who predicted in the 1970s that each new generation of
electronic products would be twice as fast and twice as small as the
previous generation ( a generation of electronic products is about 18
months to two years). This prediction has held true for more than three
decades and has been the source of the enormous innovation driver for
the industry. It has also been the underpinning of the rapid
obsolescence that underlies the rapid growth of e-waste. This
phenomenon, when combined with the development of entirely new
electronic products--such as mobile phones, portable music players,
flat panel displays, electronic games, etc.--has led to the explosive
growth in e-waste which is creating the crisis that we are now
attempting to address. Just as the growth rate for technological
developments predicted by Gordon Moore is exponential, so too is the
growth rate of e-waste.
The rapid increase in e-waste makes it extremely challenging to
develop comprehensive reuse and recycling systems that are capable of
keeping pace. We need to address the huge stockpile of ``historic
waste'' that has accumulated over the past few decades while at the
same time expanding our infrastructure to address the new growth in
future e-waste. That is why setting effective goals and timetables for
manufacturers to meet is so important, since they need to develop the
capacity to properly collect and recycle not only their fair share of
their historic waste but also to collect and recycle all of their newly
created e-waste. When the leading companies acknowledge that they are
only collecting about 15 percent of their waste products when compared
to new sales, it is a compelling argument that we need enforceable
goals and timetables in order to catch up to the rapidly escalating
problems. We need to get to the point where companies have successfully
reduced their historic or legacy waste to zero as well as implemented
an effective program to collect and process all of their future e-
waste.
Q2. Most major manufacturers claim that they do not ship e-waste
oversees for recycling. Where does the e-waste found in environmentally
unsound recycling operations originate?
A2. Most e-waste that gets into the ``recycling stream'' (as opposed to
the waste stream) is currently collected and recycled by municipalities
(in collection events and permanent facilities), recyclers, asset
recovery operations, and independent waste haulers--not by the
manufacturers. The sources of the e-waste that is being disposed of in
unsound operations are many and varied--from discards by public
agencies to corporate disposal to household hazardous waste. The old TV
that a well-meaning consumer hauls down to his city sponsored e-waste
collection event on Earth Day very likely ends up being exported to
Asia, Africa, or Latin America where it is causing great harm. In fact,
the report by the Basel Action Network--``The Digital Dump: The Export
of Reuse and Abuse to Africa'' which documents such abuses includes an
appendix that lists the origin of e-waste found in Nigeria, based on
the asset tags. See http://www.ban.org/BANreports/10-24-05/documents/
ListofAssetTags.xls. The report includes photos of 90 asset tags which
identify the many diverse original owners of the equipment such as the
Department of General Services, St. Mary's Hospital, City of Houston,
Headquarter of U.S. Army Corps of Engineers, Trinity College, IBM, U.S.
Government Property, Wauwatosa School District, San Mateo Union High
School District, Illinois State Police, Kansas Department of
Transportation, Michigan Dept. of Natural Resources, and Federated
Systems Group, INC. The link to the full report is at http://
www.ban.org/BANreports/10-24-05/index.htm and the link to the Asset Tag
appendix is at http://www.ban.org/BANreports/10-24-05/documents/
ListofAssetTags.xls. Tax payer supported public institutions (such as
universities, school districts, etc.) are under enormous pressure to
select ``low bid'' recycling contractors to dispose of their e-waste,
so it no surprise that much of the e-waste that ends up being exported
to developing countries originates from these institutions. This is
another reason why we need to prohibit the export of hazardous e-waste
to developing countries in order to protect public institutions from
having to do business with low-bid exporters.
While manufacturers (and others) frequently claim that they do not
ship e-waste overseas for recycling, there are four important facts to
understand:
a. The U.S. has shut down all of its secondary smelters except
one (which does not process circuit boards) and therefore the
U.S. companies currently export their circuit boards to other
countries. Some companies, however, ship these obsolete circuit
boards to state-of-the-art smelters in Canada and Europe where
they are processed in a responsible manner. Circuit boards
clearly do not need to be exported to developing countries
where they continue to cause great harm to health and
environment. The question is not whether hazardous e-waste is
exported, since much of it is, but rather exported to where.
b. Leaded glass has two primary types of destinations (other
than landfills), which are to lead smelters (like the one
remaining in the U.S., which has limited capacity and charges
for accepting the glass), and to manufacturers of new CRTs,
which are no longer located in the U.S., and are almost
exclusively located in developing countries now. So any U.S.
company sending old CRT glass into the ``glass-to-glass''
market, for `recycling' into new CRTs, must export the leaded
glass out of the U.S. Unfortunately, there are not currently
other, better options available for CRT glass.
c. Many companies exporting e-waste simply label the volumes
as going for `reuse' (not recycling), regardless of the end
destinations or usage. This is the central theme of BAN's
second documentary film, ``The Digital Dump.''
d. Many unscrupulous companies will frequently say that they
do not export any electronic materials, when they turn it over
to brokers or others who do the exporting. This is a very
common `white lie' in the industry.
Q3. Your testimony focuses on the potential harms of exposure to toxic
chemicals in electronics. However, doesn't exposure primarily occur
during the recycling and waste disposal stages? Since average consumers
have little risk of exposure from their electronic products, shouldn't
we focus our efforts on the end-of-life environmental concerns?
A3. While there is exposure to toxic substances throughout the life
cycle of electronic products, the two most toxic phases in the life
cycle of electronics are in the manufacturing and in recycling of the
products. The most significant exposures to toxic chemicals occur in
the manufacturing stage of the electronics life cycle, even more than
in the waste disposal stages. Hundreds of thousands of people are
involved in electronics manufacturing, far more than are involved in
recycling, and the variety of toxic chemical exposures are also more
extensive, since many of the chemicals used in manufacturing do not end
up in the products but rather end up as hazardous waste or released
into the environment. I have attached two articles that further
elaborate on these health hazards: the ``Cancer and Reproductive Risks
in Semiconductor Industry'' by Dr. Joseph LaDou and John Baillar and
published in the International Journal of Occupational and
Environmental Health (2007) and a paper that assesses the health
hazards in the circuit board industry entitled ``Printed circuit board
industry'' by Dr. Joseph LaDou from International Journal of
Occupational and Environmental Health (2006). A long awaited study of
chronic health issues among semiconductor industry workers (funded by
the Semiconductor Industry Association) is due to be published in 2009
by researchers at Vanderbilt University.
In addition, recent studies have emerged indicating that people are
being exposed to toxic chemicals during the use of these products in
our homes and workplaces. Fire retardant chemicals that are used in
electronics, including the outer enclosures of TVs, can migrate out of
consumer products and find their way into our bodies. A study by Dr.
Arlene Blum (http://greensciencepolicy.org/files/standards/
MASTERWhitepaper.pdf) revealed that fire retardants are being ``found
in rapidly increasing levels in dust, the food chain, pets, wild
animals, and human fat, body fluids and breast milk worldwide. The
United States has much higher levels of fire retardant chemicals in
dust, food, and breast milk than Europe where fire retardants are less
used. The average U.S. woman's body and breast milk contains fire
retardant levels approaching those that cause adverse reproductive and
neurological health problems in animals.''
The Boston University School of Public Health just published an
article on April 30, 2008 showing that bromine levels in TVs can be
related to decaBDE levels in dust in homes. Those homes with more
occupants, and therefore presumably more TV usage, demonstrated higher
levels of decaBDE in the dust. It is believed that as the temperature
of the plastic TV enclosure increases due to usage, the rate at which
the decaBDE migrates from the TV into the dust is also increased
(http://pubs.acs.org/cgi-bin/abstract.cgi/esthag/2008/42/i11/abs/
es702964a.html). The presence of fire retardants in household dust is
especially worrisome because children take in approximately seven times
more pentaBDEs each day than adults (Lorber, M. 2007, Exposure of
Americans to polybrominated diphenyl ethers. Journal of Exposure
Science and Environmental Epidemiology, published online April 11,
2007). Flame retardants are one example of a chemical contained within
electronics that poses hazards throughout its entire life cycle,
including the household and workplace use phase.
Q4. Are worker and environmental safety protections in the U.S.
adequate for e-waste recyclers? Would you support a system whereby U.S.
recyclers handled only certain commodities, like CRT monitors?
A4. Worker and environmental safety regulations pertaining to this
waste stream are patently inadequate in the U.S. In fact, many of the
toxic materials are exempt from RCRA definitions of hazardous waste,
such as the mercury lamps in LCD screens, circuit boards, and all e-
waste generated by households. While some recyclers have established
state-of-the-art health and safety protections for their workers, going
far beyond compliance, most do not. The lack of meaningful OSHA
regulations and enforcement, or other worker health and safety
standards for recycling workers adds to the hazards. The recycling
industry is still relatively new and has not had (to the best of our
knowledge) any comprehensive health assessments or industrial hygiene
assessments done. At the same time, there have been isolated studies
done suggesting that recycling workers are being exposed to hazardous
materials in the processing of e-waste. One of the leading such studies
conducted in the U.S. is entitled ``Occupational risks associated with
electronics de-manufacturing and CRT glass processing operations and
the impact of mitigation activities on employee safety and health'' by
Peters-Michaud, N.; Katers, J.; Barry, J. from Cascade Asset
Management, LLC, published in Electronics and the Environment, 2003.
IEEE International Symposium, Volume, Issue, 19-22 May 2003 Page(s):
323-328. For the full report which evaluates specific emphasis on the
impact of operational and training improvements to mitigate exposure to
potential harm from airborne contaminants and other environmental
hazards, see http://ieeexplore.ieee.org/Xplore/login.jsp?url=/iel5/
8575/27162/01208098.pdf?arnumber=1208098. Another widely cited health
study of e-waste recycling workers is Flame Retardant Exposure:
Polybrominated Diphenyl Ethers in Blood from Swedish Workers by Andreas
Sjodin, et al., Environmental Health Perspectives Volume 107, Number 8,
August 1999, http://www.ehponline.org/docs/1999/107p643-648sjodin/
abstract.html.
Similar health concerns have been documented at e-waste recycling
facilities managed by UNICOR in federal prisons. See ``Corporate
Strategies for electronics recycling: A tale of two systems'' published
by Silicon Valley Toxics Coalition and Computer TakeBack Campaign,
2003, http://www.etoxics.org/site/DocServer/
prison-final.pdf?docID=201. This is particularly important
since the U.S. Government is the single largest customer for UNICOR,
which has been investigated by the U.S. Department of Justice due to
complaints of toxic exposure to prison guards, prison staff and
inmates. In fact, when Leroy Smith, a safety manager for United States
Penitentiary Atwater in California tried to address the health and
safety hazards inside the prison where he worked, his warnings were
ignored, he was subjected to retaliation by his superiors, and he was
subsequently recognized by the U.S. Office of Special Counsel as a
Public Servant for his actions as a whistleblower. For further
information, see http://www.peer.org/news/
news-id.php?row-id=687; http://www.peer.org/news/
news-id.php?row-id=746; http://www.osc.gov/
documents/press/2006/pr06-16.htm
We do not believe that only CRT monitors should be handled within
the U.S. since that serves to push our problems off onto others around
the world.
Q5. What is an appropriate metric for recycling? Should we calculate
by the weight of material that is recycled or should we measure by the
number of units that are disassembled but not entirely recycled?
A5. This is an important question and one that is at the center of a
major debate now taking place amongst the e-waste recycling
stakeholders. Many favor using weight as the metric because of its
relative ease in measuring and widespread usage in industry practices
already; others favor the use of units since it is the best way of
measuring the number of units recycled compared to the number of units
sold as a way of measuring a company's progress toward its overall fair
share goal. Weight is a less burdensome requirement, and the definition
of a `unit' can get complicated with components and subassemblies
arriving from consumers. Likewise, it is not useful to compare a large
TV console with a small cell phone for recycling purposes, even though
each is ``one unit.'' The other major debate at this time is whether
``fair share'' metrics should be evaluated compared to ``market share''
or to ``return share.'' Companies that currently hold a small or no
market share (such as IBM) favor a market share approach, while
companies that hold a growing market share but a relatively small
return share favor the alternative approach (newer market entries).
Since a main purpose of effective metrics is to drive the development
of a comprehensive recycling system which apportions financial
responsibility fairly, it is important to develop metrics that can be
used to help measure both weight and units. There is a significant need
to improve the data collection across the board--from collection, to
processing, to export--in order to help develop a more robust and
effective e-waste recycling infrastructure.
Q6. Does the Electronics Take-Back Coalition collect statistics on
recycling by individual manufacturers? Do you know what the average
recycle rate of manufacturers is in the U.S. for the following
products: CRT monitors, televisions, computers, car batteries, and cell
phones?
A6. While ETBC has attempted to collect such statistics, it is very
difficult since only the manufacturers themselves have this data and
until recently they have not made it public. Based on recent
environmental reports by Hewlett-Packard and Dell, we have the
following information available:
There are low overall recycling rates when compared
to sales:
-- 2007--HP had reuse/recycling rate of 15 percent
compared to sales seven years ago (including remarketed
equipment). That's up from 10 percent in 2006.
-- Dell had a reuse/recycling rate of just over 12
percent in 2006.
Companies don't state annual goals compared to
sales--just overall volumes.
There is no common way companies track information
comparing to sales.
There is little transparency in reporting--it is
difficult to really understand how we are doing in addressing
this problem.
There is no reliable data available by manufacturer
that describes the recycling rate by product such as CRT
monitors, TVs, computers, cell phones, etc.
Dell breaks down recycling volumes by avenue of
return (HP does not):
-- Asset Recovery Services End-of-lease Returns
-- Consumer Recycling Programs and Goodwill End-of-
life Parts
-- Asset Recovery Business and Dell Factory
-- Outlet--Consumer returns and exchanges less than
thirty days
-- Recycling Events and Tours
This is another area where there is a significant need for better
data.
Q7. Is there a full array of non-toxic substitutes currently available
for use by electronic manufacturers?
A7. There is not a ``full array of non-toxic substitutes currently
available'' which is one of the main reasons why we are promoting the
National Sustainable Electronics Initiative and why we need to
significantly increase the research and development funding for green
engineering and green chemistry. Many currently essential compounds
used in electronics production are toxic; they currently do not have
readily and easily available and effective alternatives that have been
demonstrated to be safer. There are some recent examples of success
stories for the substitution of certain materials--such as the
replacement of lead solder and brominated flame retardants in response
to the RoHS directive in Europe. A small set of market leaders within
the industry are working to establish chemical/material standards, but
this is very difficult to do without government regulations that level
the playing field for the entire sector. Also, there are still
significant questions about which substitutes are the ``most''
sustainable, when evaluating not only toxicity but also persistence,
bio-accumulation, greenhouse gas potential, etc. That is why we
presented information about the ``Green Screen'' which can help
companies make informed choices. See http://www.cleanproduction.org/
Green.Greenscreen.php for more information. It is also true that for
many other toxic chemicals used in electronics, there has not been
significant research done to evaluate safer alternatives--at least not
that has been made public.
Questions submitted by Representative Daniel Lipinski
Q1. In 2006, the Government Accountability Office estimated that more
than 100 million computers, TVs, and monitors are thrown away each
year. In addition, the EPA estimates that electronic waste is growing
two to three times faster than any other waste stream. Yet presently,
there is no specific federal law or regulation governing the disposal
of consumer electronic products in the U.S. Should there be?
A1. Yes. We do not believe that solid waste (non-hazardous) landfills
and incinerators are an acceptable final disposition for known toxins,
such as lead, mercury, cadmium, arsenic, hexavalent chromium,
polybrominated diphenylethers, etc. In addition to questions about long
term leaching from plastic lined landfills, solid waste officials are
increasingly worried about future liability for allowing these immortal
heavy metals and chemicals into non-hazardous landfills and
incinerators. Already, studies show that 70 percent of heavy metals in
landfills come from electronic waste.
Several states have already banned at least some electronic
components from disposal in solid waste facilities, frustrated that the
Federal Government has not addressed this complex and partially toxic
waste stream. In addition, countless cities and counties across the
country have also banned such disposal, even ahead of their State
legislatures. The amount of scientific literature on the toxic impacts
of lead alone ought to be enough to convince anyone that putting them
in landfills make no sense whatsoever.
We believe that there is a real need to establish ground rules for
addressing hazardous e-waste, similar to what the Europeans did with
the WEEE directive. But we also believe that the states have an
important role to play in serving as the incubators of effective
policy. Thus, any federal initiative must build on the experience of
the states rather than undermine them. In particular, we believe that
the Federal Government should first ban the export of toxic e-waste to
developing countries Perhaps, in the future there should be a strong
federal solution that is modeled on the best State laws, but a weak
federal effort that undermines the states and preempts them with weaker
language that sets a low bar as a ceiling would be a major setback. A
federal law that sets minimum standards and allows and encourages
states to go beyond those standards would be a good model and one which
works well in many other arenas. It is also important to remember that
traditionally waste policy and practice has been the province of local
(and State) governments that are closest to the problems, and that it
is imperative that national legislation support this model and not
undermine it.
Q2. The EPA estimates that at most, only 15 percent of products at the
end of their useful lives reach a recycling or reuse program. This does
not come as a shock to me. In fact, it might seem a little high given
the impediments that consumers currently face.
Q2a. First, how are average consumers to know what to do with their e-
waste when it comes to the end of its useful life?
A2a. We need a comprehensive, well financed public education campaign
to better inform consumers about what to do with their obsolete
electronics--starting with the importance of reuse as a first priority.
At the same time we need a comprehensive, convenient and accessible and
affordable e-waste recycling and reuse infrastructure so that consumers
who are informed will be able to access it. We need to make recycling
of electronic products just as easy as it is to buy new products. We
have been engaged with many companies at the highest level urging them
to engage their customers to inform them about the importance of
recycling--at the point of purchase, on the new products or packaging
themselves, through utility billing, solid waste official websites, as
well as at convenient end-of-life recycling sites. The sales and
marketing ingenuity of companies like HP, Dell, Sony, Apple, etc. to
educate consumers about how and why to purchase new products has been
demonstrated conclusively. They can also use those skills to educate
their consumers on how to properly recycle their equipment. The tobacco
industry and the alcohol industry have invested significant amounts of
funds in robust advertising campaigns to promote responsible consumer
behavior; there is no reason why the electronics industry can't do the
same. These efforts, of course, should be done in close collaboration
with other stakeholders to help make sure that the both the messages
and the delivery of the messages, are effective.
Q2b. This past weekend, Washington, D.C. held an e-waste recycling
day. Over ten times as many residents as last year showed to recycle
their gadgets, leading to over two hours wait time. The incentives to
recycle just don't seem to be there right now. What do you recommend be
done to fix this problem?
A2b. This exact same phenomena has occurred in many places around the
country for the past several years, due to the pent up demand by
consumers to find accessible recycling options. In fact, in some cases
the lines of cars waiting to recycle e-waste were so long that they
created major traffic jams and had to be shut down. The solution is not
to keep holding individual events, although they can be useful to
initiate public discussion. What is really needed, however, is a
permanent, ongoing, convenient system that makes it easy for consumers
to recycle their old products so that it becomes a normal habit, much
the same way that people now are in the habit of recycling cans,
bottles and newspapers. Yet, because recycling electronic products is
more complicated and potentially hazardous than these other products, a
curb-side collection model is not favored. Likewise, there is a much
more important reuse market and potential for electronic products, and
putting them into curbside collection containers could undermine their
reuse potential. Developing policies that promote a major expansion of
e-waste recycling collection sites and methods is the real key to
developing an effective infrastructure--a wide variety of sites and
methods that include retail stores, charities like Goodwill, shopping
malls, schools, offices, community centers and senior centers,
apartment complexes, transfer stations, mail back programs, etc. Sony
has developed a good model, for a start, by announcing that their goal
is to establish a recycling drop off site within 20 miles of most of
the U.S. population; ultimately we will need a model that provides for
even closer proximity. While we are a long way from meeting that goal,
it is important that we get there as quickly as possible and then
improve it so that it is even more convenient. It ought to be recalled
that when consumers had to travel five to 10 miles to drop off their
household recycling, the participation rate was very low, but when
collection became convenient, the rates of participation went way up.
It ought also to be noticed that many electronic products are much
heavier and more difficult to transport than are other household goods
that are recycled.
One additional development of note is that some of the producers--
such as Sony, Dell, Hewlett Packard, Apple, etc.--as well as some
retailers--such as Best Buy--have been experimenting with incentives to
encourage consumers to bring back their old electronics when purchasing
new products and their experiences have been generally favorable.
Consumers have responded well to coupons that provide discounts on
purchases of new products when they return older ones.
Q3. The European Union is often ahead of the United States when it
comes to the issue of recycling. Where do U.S. capabilities stand as
compared to Europe on the topic of e-waste?
A3. The U.S. is behind Europe in e-waste recycling in several
significant ways:
European laws have been on the books for several
years--at the national level going back more than 10 years, and
at the EU level since 2005. Electronics manufacturers,
governments, recyclers, and consumers have all been involved in
developing effective recycling systems and infrastructure for
many years and therefore have a big head start over the United
States. Many other countries in Asia and elsewhere are also
ahead of the U.S. in this area, having passed their own
versions of producer take-back laws. With the passage by some
states of e-waste legislation, there is a growing awareness and
acceptance as well as a developing infrastructure in some parts
of the U.S., but it is still in its infancy.
In Europe, leading brand name electronics companies
established the European Recycling Platform several years ago
to get ahead of the recycling initiatives that they saw coming,
but many of these same companies have been slower to take such
a proactive stance in the U.S. in the absence of national
legislative leadership.
The U.S. is finally beginning to develop a growing
recycling infrastructure, with capital venture coming into the
industry and therefore consolidation occurring. Some well
funded, large recyclers in the U.S. are currently operating
under capacity, and would love nothing more than to shut down
the mass export of this waste stream from the U.S. (The one
exception is that shredded e-waste goes to smelters for further
reclamation of materials, and the U.S. has shut down all
secondary smelters but one.)
It is also important to note that the EU has not only
passed laws requiring manufacturers to collect and pay for
recycling of their electronic products, but the EU has also
ratified and enforced a UN treaty (the Basel Convention and the
Amendment to the Convention) making it illegal for EU countries
to ship toxic waste to any developing country for recycling or
disposal. Keeping their e-waste within the EU not only builds
their businesses, but provides an incentive for the EU to find
safer alternatives to toxins they must manage themselves,
unlike the U.S.
The political climate in Europe is also quite
different from that in the U.S. Whereas the U.S. was the global
environmental leader several decades ago, that mantle of
leadership has been assumed by the EU which has now become the
global environmental leader, as evidenced by the passage of the
WEEE directive, RoHS directive, the REACH directive, etc.
Consumers as well as companies have come to accept that
leadership in Europe while we are still trying to develop that
culture within the U.S.
Q4. As the country transitions to digital television next year, I am
concerned that this will divert potentially millions of old analog TVs
into the waste stream. Are we prepared for this wave of old technology?
Should a system be put in place to educate consumers on how to dispose
of their TVs, especially our seniors who will be most impacted by this
change and probably least likely to know how to recycle?
A4. We agree that this is one of the most pressing issues that we face
as the digital transition will greatly exacerbate what is already a
major environmental crisis. The U.S. does not have in place anything
remotely needed to meet this impending deadline--either in terms of the
capacity to properly collect and responsibly recycle the millions of
old TVs that will be discarded or in terms of the public education
necessary to inform people about what to do. Again, it is a two fold
issue--the need for appropriate and convenient infrastructure combined
with massive public education to help people better understand what
their options are. Education with out accessible infrastructure is just
as frustrating and ineffective as infrastructure without public
education.
We believe that there needs to be a substantial effort to reach out
to seniors who are disproportionally linked to the older, analog TVs
and who seem to be less likely to be connected to cable or satellite
TV. They are also less likely to be comfortable with purchasing and
installing a new digital converter box and more likely to be
intimidated by the prospect of having to do so. This seems to be an
area that is ripe for a major new initiative by the industry in
conjunction with the FCC. We urge Congress to prod the Consumer
Electronics Association to work with the FCC to help avert a major
injustice to seniors to make sure that they do not end up as collateral
damage of the digital conversion.
In addition, we are also very concerned that with the anticipated
increase of older televisions being discarded due to the digital
television conversion, there will be a significant increase in the
amount of lead coming into the waste stream, which will have several
significant impacts. First and foremost, the increased environmental
loading of lead to the environment for older CRT televisions that end
up in waste sites will result in millions of pounds of lead being added
to the environment. Since older CRT televisions contain several pounds
of lead--estimates range from four to eight pounds an up, depending on
the size of the unit--and since current projections estimate that tens
of millions of televisions will be discarded, the environmental loading
will be enormous. All of this will be happening without proper
governmental oversight, since in most states it is still legal to
simply discard old electronic products into landfills.
In addition, for those CRT televisions that do get recycled, the
amount of lead recovered will also be so substantial that it will
likely cause a significant decrease in the price of lead when it is
recycled. This will likely increase the amount of lead that is used in
making new, cheap consumer products. Thus, another unintended
consequence of the digital conversion will likely be the increase in
dangerous materials in cheap consumer goods that will be imported into
the U.S. and potentially harm the children who will be exposed to them.
This problem will continue to grow until the Federal Government gets
firm control over the lead and other toxic materials contained in
obsolete electronic products.
For all of these reasons, we urge Congress to adopt a comprehensive
ban on the export of hazardous e-waste, including lead, and applaud the
House for passing H.R. 1534, the Mercury Export Ban Act (Rep. Allen (D)
ME and 14 co-sponsors) which is an important step in the right
direction.
Q5. In your testimony, you address the EPEAT program, which I think
sounds like a great idea in the wake of the Energy Star Program's
success. Can you tell us a little bit more about this program? Why has
the EPEAT board postponed plans to develop standards for televisions?
Energy Star has been immensely successful and I would predict EPEAT
could be equally successful by providing a viable rating tool for
consumers.
A5. We agree that EPEAT has the potential to match the success of the
Energy Star program. For computers alone, EPEAT has already influenced
over a billion dollars worth of purchasing decisions. Expanding EPEAT
to include other product categories has been met with staunch
resistance from television manufacturers, however. We believe that this
is because EPEAT has a provision that encourages company-side product
take-back programs, and with the important exception of Sony, the rest
of the TV industry has not developed comprehensive national take back
programs, unlike many of the computer companies. ETBC has urged EPA and
others to move forward with EPEAT for TVs and attended the recent
scoping meeting in Washington, DC to urge them to do so. We made the
point that this is of paramount importance given the impending digital
deadline for conversion, but the decision to develop standards for TVs
was postponed due to lack of support from the TV companies as well as
due to the lack of full financial support from EPA, which would have
only required $115,000. There have also been efforts to restrict the
scope of EPEAT to apply only to institutional purchasers. By not
targeting the consumer market, we are fail to address a large part of
the e-waste problem. This important purchasing tool should be expanded
to cover consumer products, particularly in the case of TVs.
We would like to see the EPA fully fund to the development of this
standard. Right now they partially fund it and have to raise remaining
resources from whatever product sector is affected by the developing
standard.
Questions submitted by Representative Phil Gingrey
Q1. In September of 2007 the House passed H.R. 2850, the Green
Chemistry Research and Development Act of 2007, which undertakes many
of the recommendations in your testimony. Does the Electronics Take-
Back Coalition agree with the goals and policies in H.R. 2850 and have
you supported passage of the companion bill, S. 2669, in the Senate?
A1. The Electronics Take Back Coalition supports green chemistry
application in the electronic sector and believes it is one of the most
promising ways to green the supply chain of the electronics industry.
One of ETBC's coalition partners, Clean Production Action has actively
worked to build support for the legislation. With that said, this
legislation has an indirect influence on the electronic sector.
Authorizing $84 million is a small investment compared to other major
government research and development programs such as the National
Nanotechnology Initiative worth more than a billion dollars. ETBC will
continue to leverage support for Green Chemistry application in the
electronic sector, but the scale of investment for new research and
development will need to meet the scale of production of electronic
products.
Answers to Post-Hearing Questions
Responses by Michael T. Williams, Executive Vice President and General
Counsel, Sony Electronics Inc.
Questions submitted by Chairman Bart Gordon
Q1. You state in your testimony that Sony has long been an industry
leader in environmentally friendly design. What are some of the design
changes Sony has made that have resulted in greener products? Have any
of these increased either the recyclability of the product or the use
of recycled materials in the product?
A1. (a). ENVIRONMENTAL DESIGN: Sony has pioneered the elimination of
hazardous materials in its products and the creation of more energy
efficient devices. We have, among other things: (1) eliminated the use
of lead in solder; (2) eliminated the use of brominated flame
retardants; (3) developed numerous products that use less energy and/or
can be powered by rechargeable batteries; (4) created new lithium-ion,
rechargeable battery technology that eliminated the need for nickel or
cadmium in most batteries; (5) led the change in display technology
from cathode ray picture tube (CRT) televisions that used lead to
liquid crystal display (LCD) displays that use no lead; (6) developed
the organic light-emitting diode (OLED) television which can result in
reduced power consumption of up to 40 percent per panel square inch as
compared to other television technologies. In addition, Sony has
reduced the types of plastic we use and reduced the amount of packaging
materials, thus, substantially eliminated the need or use of ozone
depleting chemicals. And finally, by reducing the number of screws that
hold the products together and the other non-recyclable or incompatible
materials in our products, Sony has developed products specifically
designed to make it easier to recycle.
(b). USE OF POST-CONSUMER MATERIALS: In the long-term, the
elimination of hazardous materials in covered products will make
recycling easier and more cost-effective, consequently, making more
post-consumer material available for new products. In the short-term,
it is difficult to reuse old post-consumer recycled material in new
products, because of concerns about incidental contamination of toxic
metals and flame retardants in the recycled material.
Q2. How does Sony advertise its take-back program? You state in your
testimony that Sony's goal is to increase the amount of products
collected through your take-back program to 600 million pounds per year
within five years. Since the program started in September of 2007, you
report that Sony has collected seven million pounds. How does Sony plan
to increase the amount collected so substantially? How much does Sony's
recycling program currently cost?
A2. (a). CONSUMER EDUCATION: Sony is using a wide range of methods to
promote its Take Back program, including the use of print, television,
and radio media. We also use our 50 regional ``recycling events'' to
educate consumers and retailers about our program as well as our many
fixed recycling locations. Sony is also committed to cross-marketing
and promotion with our national Take Back partner, Waste Management,
Inc. (``WMI''), and various government and nongovernmental
organizations.
(b). SONY'S PROGRAM GOALS: Presently, Sony has, in conjunction with
WMI, almost 150 locations in which a consumer can drop off a product.
To achieve our goal of recycling 600 million pounds per year, we will
need to establish roughly 10,000 drop off locations that would feed
into the WMI recycling network. Candidly, we cannot reach this
benchmark without the active participation of other e-waste
stakeholders. We are, therefore, actively seeking the participation of
retailers, other manufacturers, and non-profits. Indeed, as a direct
result of the Committee's e-waste hearing, Sony has entered into
discussions with Goodwill Industries. And by way of example, we have
worked to help create a similar successful program for rechargeable
battery collections. Through the non-profit ``Rechargeable Battery
Recycling Corporation'' (of which Sony is a part owner and present
Chairman of the Board) we have established 50,000 locations in the
United States that will accept batteries for recycling.
(c). PROGRAM COSTS: Sony treats the cost of its Take Back program
as a confidential trade secret.
Q3. You state in your testimony that some recycled plastics will be
purchased and used to make new electronics products. Approximately how
much post-consumer recycled plastic does Sony use in its products now?
How much of that is plastic recovered from electronic waste?
A3. USE OF POST-CONSUMER MATERIALS: Sony products manufactured in the
United States use approximately five percent post-consumer recycled
plastics. At this point, little of those plastics come from recovered
electronic waste because of some of the concerns identified above in
1(b). We do expect, however, that both the amount of post-consumer
material Sony uses and the amount of such material related to waste
electronics will increase dramatically as our program achieves even
greater success.
Q4. In your testimony you mention `` `no name' brands (that) are made
of lower quality materials, which can contain higher levels of toxic
chemicals and may be more difficult to recycle.'' You also mention the
need for consumer education about recycling. Would an eco-ranking
system for consumer electronic products help educate consumers about
the environmental impacts of these products?
A4. ECO-RANKING SYSTEM: An ``eco-ranking system'' for consumer
electronic products would be a good idea. To be helpful to consumers,
however, it would have to employ clearly understandable criteria and be
consistently administered by the Federal Government. Presently, there
are many ranking systems from various organizations and countries which
employ different criteria. The end result of this patchwork of ranking
systems is largely only consumer confusion.
Questions submitted by Representative Ralph M. Hall
Q1. What is the total life cycle energy cost of Sony's e-Reader? What
is the equivalent to this energy usage in pages printed from a typical
printer? Does Sony currently publish the life cycle energy costs for
all your products? If not, would you consider providing such
information to consumers in the future?
A1. LIFE CYCLE COSTS: Sony does not currently publish the life cycle
energy costs for its products but would be willing to do so provided
that the proper metrics for such a measurement can be developed and
standardized.
Q2. What are the liability concerns for companies that take-back
electronics and reuse or recycle them? Does liability for damages to
workers from exposure during recycling or liability for harm caused by
refurbished equipment limit the growth of take-back programs?
A2. LIABILITY ISSUES: Sony cannot comment on liability issues related
to recycling of waste electronics since we do not handle the actual
recycling, but rather, use the country's leading recycler, WMI, to
manage that part of our Take Back program. Please note, however, that
Sony firmly believes and supports stringent worker and environmental
protection requirements for the recycling industry. Indeed, to the best
of our knowledge, Sony is the only electronics manufacturer to sign the
Electronics Take Back Coalition's ``Pledge of True Stewardship'' (the
``Pledge'') which prescribes strict, environmentally- and socially-
conscious limitations on how and where electronics waste can be
recycled.
Q3. Most major manufacturers claim that they do not ship e-waste
overseas for recycling. Where does the e-waste found in environmentally
unsound recycling operations originate?
A3. OVERSEAS RECYCLING: Sony has no direct knowledge about the products
that are recycled overseas. But as noted above, as a signatory to the
Pledge, we have committed that all products that are collected through
the Sony Take Back program will be recycled using the strictest and
highest environmental standards. Moreover, we provide full, public
accountability of how and where our products are recycled.
Q4. How does Sony treat products from other manufacturers at your
recycling centers in terms of cost to the consumer and disposal?
A4. SONY PRODUCTS VS. OTHER PRODUCTS: Sony pays for the recycling of
all Sony-branded products, but the consumer must pay the cost to
recycle any other brands.
Q5. Can you give us some examples of how Sony has had to tailor its
recycling programs to meet different State requirements? Considering
that e-waste recycling already occurs under a variety of legal
frameworks in the U.S., why should federal legislation preempt States
from experimenting with different collection systems or fees?
A5. (a). STATE PREEMPTION: State preemption is necessary to create a
single, consistent e-waste recycling program that will develop the
economies of scale required to make recycling cost-effective and to
create enough recycled material to make re-using large quantities of
such material in new products realistic. The recycling of e-waste is
not a traditional local or State issue that can or should be treated
differently based on the particularities of each jurisdiction. Rather,
e-waste is exactly the opposite. That is, the same products that are
sold in Tennessee are sold in Texas and the means to recycle those
products are the same across jurisdictions. Society will not benefit
from the traditional notion of allowing the states to serve as
incubators of new and novel approaches. And even if this were the case,
there have certainly already been enough states that have enacted
different e-waste laws that Congress can benefit from any and all
available ``lessons'' learned from these various State ``experiments.''
(b). THE CONTRADICTORY STATE LAWS: The disparity between the
starkly differing State e-waste laws inherently creates inefficiencies
and complications in how Sony runs its Take Back program. For example,
we cannot operate our program in the State of Maine; that state chooses
the recyclers to be used and charges manufacturers a tax based upon the
amount of products collected. In contrast, Minnesota and Washington
have identified the number of manufacturers that must have programs
and/or pay fees, even though manufacturers sell consumer electronics in
every state. Indeed, to operate a recycling program in the State of
Washington, we must have fixed collection locations in each of the 80
counties.
Q6. How would you describe the influence of other countries' recycling
and waste laws--such as Japan--on your Take Back and Recycle programs?
Do these laws affect your global operations?
A6. (a). OTHER COUNTRIES: The recycling laws of other countries have a
limited impact on what Sony is doing in the United States. Our Take
Back program is the result of over 15 years of experimenting and
testing by Sony's U.S. operations.
(b). SONY'S GLOBAL RECYCLING GOAL: Sony is a global company, and as
such, all laws affect our global operations. Sony has as a goal to
globally conform to the most stringent environmental regulations world-
wide. In the case of our U.S. Take Back recycling program, Sony
believes that we are well ahead of that goal.
Q7. You argue that e-waste legislation should cover all products with
certain components or chemicals. How do the recycling processes differ
between a Sony laptop and a Sony LCD or plasma television?
A7. RECYCLING OF VARIOUS PRODUCTS: The actual recycling of various
electronic products does not differ much. When recycling our products
we look at three components: glass, metal, and plastics. It matters
little what type of products these components come from. Indeed, it is
not the actual recycling of different types of products that creates
issues, but rather the logistics and costs associated in the collection
and management of products as these can vary substantially as to weight
and size.
Q8. How much does it cost Sony to collect and recycle all their legacy
waste? What are the benefits--other than the obvious environmental
ones--to your company? How has the program impacted your ability to
compete within the global marketplace?
A8. COSTS AND GLOBAL COMPETITION: Sony treats the cost of its Take Back
program as a confidential trade secret. The goal of the program,
however, is to make electronics recycling a cost-effective, profitable
business. If Sony succeeds in our efforts, we will have created a low-
cost, efficient source of post-consumer plastic and metals for our new
products, thus making Sony more competitive in the global marketplace.
Questions submitted by Representative Daniel Lipinski
Q1. In 2006, the Government Accountability Office estimated that more
than 900 million computers, TVs, and monitors are thrown away each
year. In addition, the EPA estimates that electronic waste is growing
two to three times faster than any other waste stream. Yet presently,
there is no specific federal law or regulation governing the disposal
of consumer electronic products in the U.S. Should there be?
A1. A FEDERAL LAW. Sony urges you to adopt legislation that supports
our existing efforts and extends the environmental stewardship we have
demonstrated to all electronics manufacturers and retailers. While we
are confident that Sony's voluntary e-waste recycling program will make
great strides forward, only a truly comprehensive and consistent
program will allow all interested parties to achieve our shared
recycling goals. Sony, therefore, respectfully requests that any
legislation reflect the following:
Preemption
Although it is of course a significant event when Congress
preempts State regulation on a particular point, Sony believes
that electronics recycling is an issue on which State
preemption is essential. We and other stakeholders already have
to comply with numerous, and sometimes contradictory, State and
local e-waste laws. The inconsistency between these programs
inevitably creates inefficiencies in the system and minimizes
any economies of scale that could be achieved. And since Sony
(and likely no other manufacturer) does not build products to
be sold in a particular state, adding a federal bill without
State preemption merely adds more complexity rather than
simplifying and streamlining the process. In the end, a
patchwork quilt of different and ultimately contradictory State
and municipal laws will only serve to undermine everyone's
shared goal of recycling as much electronic waste as
efficiently and cheaply as possible.
Producer Responsibility
Sony believes that it is the individual manufacturer's
responsibility to assure that any product that bears its name
is properly recycled using the highest standards possible at
the end of the product's life. That said, other stakeholders
who directly benefit from the sale or enjoyment of electronic
products must also bear some responsibility. More specifically,
retailers--at the very least--must take an active role in the
collection of e-waste and consumers must be encouraged to take
the extra step necessary to properly dispose of their products.
Market Share
In order to create a level playing field, any manufacturer
obligation should be based upon present market share and not on
historical activities or waste collected. Systems based upon
the amount of waste collected will give a cost advantage to
those companies that are new to the market. Such companies can
avoid any recycling cost by simply staying in business and
changing their brand or company name every year. Many of these
``no name'' brands are made of lower quality materials, which
can contain higher levels of toxic chemicals and may be more
difficult to recycle. Any mandate not based upon today's market
share will give those companies a ``free ride'' on recycling.
This will lower their costs when compared to responsible
companies by rewarding manufacturers who avoid their
environmental obligations and penalizing responsible companies
by putting environmentally-advanced products at a competitive
cost disadvantage.
Products Covered
Our recycling program covers all of our branded products
from movies (i.e., DVDs), to professional equipment used to
project movies in theaters, to laptops or televisions used to
watch movies at home.
Sony, therefore, respectfully urges you to adopt one program
with one set of requirements which will require full producer
responsibility for all products manufactured. The advancement
of technology has enabled manufacturers to create an array of
products using the same chemicals and metals that are used in
the products commonly covered in e-waste recycling mandates.
Given this, Sony suggests adopting legislation to target all
products that contain these same internal and external
components and chemicals.
Cost
Sony internalizes the cost of recycling and requests that
any mandate require the same. Currently, Sony pays to recycle
our old products. While there are several financing mechanisms
that allow for recovery of this cost, Sony believes that
internalizing the cost is the most effective and fair method
for funding a comprehensive electronics recycling program. Such
funding mechanisms create market incentives for manufacturers
to ex ante design and produce the most environmentally-friendly
products possible. In addition, it encourages manufacturers to
develop and implement the most efficient and cost-effective
recycling procedures. Indeed, it is Sony's ultimate goal
through design improvements, the growth of the recycling
industry, and economies of scale to drive these recycling costs
down, thus making recycling cost effective. Until that time,
Sony considers the cost of recycling as part of the cost of
doing business.
Q2. The EPA estimates that at most, only 15 percent of products at the
end of their useful lives each a recycling or reuse program. This does
not come as a shock to me. In fact, it might seem a little high given
the impediments that consumers currently face.
Q2a. First, how are average consumers to know what to do with their e-
waste when it comes to the end of its useful life?
A2a. CONSUMER EDUCATION: Consumer education is a necessary component of
any successful e-waste program, and that is why Sony uses, as noted
above, a wide range of methods to promote its take back program,
including the use of print, television, and radio media. We also use
our 50 regional ``recycling events'' to educate consumers and retailers
about our program and our various fixed recycling locations. Sony is
also committed to cross-marketing and promotion with our national take
back partner, WMI and various government and non-governmental
organizations.
Q2b. This past weekend, Washington, D.C. held an e-waste recycling
day. Over ten times as many residents as last year showed to recycle
their gadgets, leading to over two hours wait time. The incentives to
recycle just don't seem to be there right now. What do you recommend be
done to fix this problem?
A2b. OPTIMIZING RECYCLING: Sony's goal is to make it as easy to recycle
our products as it is for our consumers to purchase them. Indeed, we
want to make recycling as effortless as throwing a product away. Simply
stated, every additional step that we require the consumer to take will
result in a decrease in the recycling rate. To optimize consumer
recycling, we need curb-side collection of electronic waste just as we
do with other types of waste. This collection should be incorporated
seamlessly into the existing municipal waste collection system. Once
collected and consolidated, recyclers can efficiently process this
electronics waste, thus creating a stream of post-consumer material for
reuse by manufacturers.
Q3. The European Union is often ahead of the United States when it
comes to the issue of recycling. Where do U.S. capabilities stand as
compared to Europe on the topic of e-waste?
A3. THE UNITED STATES VS. EUROPE: The United States has a greater
capability to handle e-waste than does Europe. The issue is in the
collection of electronics waste, not in the processing.
Q4. You mentioned in your testimony that Sony teamed up with Waste
Management to implement a national recycling initiative in the U.S. for
e-waste. Many waste companies out there have been caught throwing away
recyclables in the past. What guarantees do you have from the company
that the waste is actually being recycled?
A4. PERCENT OF MATERIAL RECYCLED: As part of its contract with Sony,
WMI guarantees that at least 95 percent of the material collected will
be recycled. Sony also has the right to audit WMI's physical locations
and WMI's books to ensure that this goal is achieved. Lastly, as noted
above, Sony will make the results of its recycling effort fully
transparent to the public.
Questions submitted by Representative Bob Inglis
Q1. Many manufacturers support a national solution to deal with e-
waste; a federal law that would preempt the patchwork of State and
local laws that are beginning to crop up. Are there any aspects of
those State laws that would/should be expanded to the national level?
What provisions of State laws in place now would be detrimental to
efforts dealing with e-waste if ramped up to a national scale? Can you
give an example or two of each?
A1. (a). SONY'S FUNDAMENTAL RECYCLING PRINCIPLE: Sony believes in
``full producer responsibility'' in which a producer takes the
responsibility for the recycling of all the products that bear its
brand name. Full producer responsibility, however, must be augmented by
participation in the process by other stakeholders and by reasoned
application of the law. More specifically:
Since manufacturers do not in most cases directly
sell their products to consumers, the collection of waste
products is often best served by those who initially distribute
the products (i.e., retailers).
The recycling responsibility must be forward-looking
rather than backward-looking, and as such, any obligation must
be based upon a manufacturer's present market share. As
explained above, collection requirements based upon return
share would give a significant advantage to those companies
that are new to the business.
(b). POSITIVE LESSONS LEARNED FROM THE STATES: Sony generally
supports the recycling performance standards provisions that are
incorporated in the Minnesota and Washington State laws. More
specifically, Sony believes that performance standards should be based
upon actual past performance instead of an arbitrarily selected
percentage. We feel that, similar to the Energy Star program,
performance standards should reflect the best of what the industry is
actually doing. Although we do not support advanced recovery fees, we
do believe that much can be learned from the California State law. It
has resulted in the development of one of the most mature recycling and
collection infrastructures in the United States and has identified a
role and responsibility for retailers which many of the other State
laws tend to omit.
(c). NEGATIVE LESSONS LEARNED FROM THE STATES: At least two aspects
of the Maine law should not be replicated in a federal bill. Maine
bases the collection responsibility on return share, thereby giving the
new ``no name'' brands that flood the market an advantage over
companies like Sony who were in business 40 years ago and who plan to
stay in business for at (Past another 40 years. Maine also runs the
program as a tax on manufacturers who have no say in how or who
recycles our products; we simply get invoices from recyclers selected
by the State which we must pay in order to sell products in that state.
Q2. You state in your written testimony that Sony believes that
internalizing the cost of recycling in the price of your products is
the most effective mechanism for recycling electronics. Am I correct to
say that this means that a small amount of the cost to consumers would
be directly related to your recycling efforts? If this is the case, how
much does this internalization cost your customers?
A2. THE COST OF RECYCLING: The cost of electronics recycling and
collection today generally ranges from 25 to 50 cents per pound. Sony
believes, however, that if a single, consistent national e-waste
program is created electronics recycling can become profitable. That
is, a uniform program will establish economies of scale that will
dramatically improve the efficiency of e-waste recycling. This,
combined with the rise in the price of commodities, likely means cost
internalization--and thus the need to pass any such costs along to
consumers--will be a short-term issue.
Appendix 2:
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Additional Material for the Record
Statement of Parker E. Brugge
Vice President, Environmental Affairs and
Corporate Sustainability
The Consumer Electronics Association
Introduction
Mr. Gordon, Mr. Hall and Members of the Committee:
My name is Parker Brugge and I am the Vice President, Environmental
Affairs and Corporate Sustainability for the Consumer Electronics
Association (CEA). CEA is the preeminent trade association promoting
growth in the $161 billion U.S. consumer electronics industry. CEA
sponsors and manages the International CES--the Nation's largest annual
trade event. More than 2,200 companies enjoy the benefits of CEA
membership, including legislative advocacy, market research, technical
training and education, industry promotion and the fostering of
business and strategic relationships. Moreover, CEA's members include
manufacturers of consumer electronics products, as well as many of the
largest retailers. CEA commends the Committee for holding this hearing
on the important issue of electronics recycling and we appreciate the
opportunity to provide the views of our membership.
By extending information and entertainment to everyone--regardless
of income or geographic location--our members' products have improved
lives and changed the world. Meanwhile, America stands as the global
leader in innovation, ingenuity and creativity. In addition, the
competition and falling prices characteristic of our industry continue
to confer benefits to consumers. As our products become increasingly
affordable, it is often more economical for consumers to replace a
product with a new one rather than repair older equipment.
Electronics Recycling is Primarily a Resource Recovery and Management
Issue
CEA concurs with the longstanding view of U.S. EPA officials that
electronics recycling is primarily a resource issue, not a toxicity
issue. At a 2005 conference EPA's Director of the Office of Solid Waste
said it succinctly:
EPA is confident that properly managed, modern landfills are
safe for disposal of electronics, but there are a couple of
problems: electronics waste doesn't always make it to safely
run disposal sites, and more important, we don't simply believe
it makes good sense to landfill or throw away these materials.
Certainly, there are different views on the risks of
electronics (or in the municipal solid waste stream)--but why
would we want to bury heavy metals like lead or cadmium in
landfills, where they will remain forever, at the same time as
we unearth these materials elsewhere in the world? We don't
have to agree how imminent the hazards are from our landfills
here in the U.S. to agree that this practice just doesn't make
sense in the long-term.
Instead this is an issue of resource conservation. We need to
capture valuable materials to use them again, and to reduce the
upstream environmental impacts of extracting and refining
virgin materials. . .\1\
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\1\ Address by Matt Hale to RECCON 05: Global Electronic Recycling
Solutions, November 29, 2005, Radisson Hotel and Conference Center,
Morgantown, West Virginia.
CEA's view of electronics recycling as a resource concern in no way
diminishes our call for good public policies to facilitate recycling of
used electronics. But recognizing this point does shed light on what
policy approaches are most suitable to address this problem. Existing
regulatory command and control programs such as RCRA Subtitle C are not
appropriate for facilitating the collection and recovery of used
electronics, and the components therein, for which we are advocating
today.
CEA Supports Shared Responsibility for Recycling
CEA advocates strongly for a shared financial responsibility among
all stakeholders--manufacturers, retailers, consumers and local, State
and Federal governments--for electronics recycling at all levels of
government. Placing the financial burden entirely on any one
stakeholder is contrary to the concept of shared responsibility which
CEA believes is the best option for recycling financing.
A primary responsibility of manufacturers lies in product design.
Most consumer electronics manufacturers have reduced and, in most
cases, greatly minimized the use of potentially hazardous substances in
their products. Additionally, manufacturers have developed new ways to
incorporate recycled components and design for responsible end-of-life.
CEA supports market-driven environmental design initiatives, including
Federal and State government programs that give preference towards
purchasing of environmentally preferable technology products.
CEA's Members Are Committed to Electronics Recycling
CEA and its member companies have been and will continue to be
fully supportive of the safe and appropriate recycling and reuse of
consumer electronics products. A number of our member companies, both
manufacturers and retailers, have initiated voluntary take-back
activities to collect and recycle televisions, computers, monitors and
other consumer electronics.
CEA Supports Responsible Free Trade of Used Electronics
CEA also concurs with conclusions of U.S. EPA officials regarding
the export of used electronics, electronic parts and materials. First,
CEA concurs that most reuse markets are export markets--that is where
most of the demand for used electronic products resides, not in the
United States. Similarly, CEA concurs that many recycling markets are
also located primarily abroad for a variety of economic and logistical
reasons, including strong foreign demand for raw materials and the lack
of U.S. smelting and glass furnace capacity.
Rather than cutting off the export of used electronics, CEA
supports the development of responsible reuse and recycling systems
both domestically and abroad. Used consumer electronics, even scrap
electronics, are not the industrial wastes for which the Basel
Convention was created. Used consumer electronics are old household
appliances that consumers no longer use in their homes. These are not
wastewater treatment sludges or distillation bottoms that are
appropriately regulated by RCRA, Basel Convention and similar command
and control systems. Rather they are remnants of past consumer
technology breakthroughs made up primarily of aluminum, steel, silicon,
copper, plastic and glass. Whether that used product is a waste or a
bargain-priced product depends on the individual consumer. Common sense
suggests that addressing the e-waste problem calls for a different
approach that acknowledges these facts and facilitates responsible
commerce.
CEA also concurs with U.S. EPA's conclusion that as collection of
used electronics in the U.S. increases, exports will increase on
several levels: export of intact units for reuse, used parts for reuse,
used equipment for refurbishment, intact equipment for dismantling,
partially processed materials for further processing, and fully
processed materials for use as raw materials in manufacturing. To
ensure proper reuse and recycling of used electronics here and abroad,
CEA supports efforts to increase the monitoring of environmental
performance at reuse/recycling facilities to increase the transparency
of used electronics management. CEA looks forward to working with other
interested stakeholders in developing environmentally responsible
systems for the export of used electronics for reuse and recycling. CEA
does not support, whether in the U.S. or abroad, any electronics
recycling that presents unacceptable risks to human health or the
environment.
Impact of DTV Transition
With the DTV cut-off date fast approaching (February 17, 2009), the
topic of its impact on televisions entering or leaving the home has
been on the mind of many. First, it's worth a broad look at consumer
expectations for removing TVs from their home over the next few years.
Results from CEA's recent consumer survey ``Trends in CE Reuse, Recycle
and Removal'' published earlier this month are illuminating.
In 2008, consumers expect to remove 43.5 million televisions from
their home. Based on consumer reported plans, the removal will take
place in the following way: 56 percent of the TVs will be given away/
donated, 25 percent will be recycled, 13 percent will be sold and six
percent will be thrown in the trash. The expected behavior follows the
very encouraging trend of fewer units trashed and more units recycled.
Beyond 2008, consumers expect to remove 41.9 million TVs in 2009
and 34.3 million 2010. These figures are significantly lower than the
2005 and 2007 aggregates (64.6 million and 72.2 million respectively).
Two factors may help explain this downward trend. With a large
percentage of consumers already making the transition from analog to
digital, it may suggest a large volume of unwanted TVs have already
been removed from homes and we are now settling into an equilibrium
period where the number of TVs entering and leaving the home is roughly
balanced. The other possible explanation centers around the difficulty
consumers have in predicting their behavior over an extended time
frame. It's not so much that consumers know whether or not they will
remove a TV from their home, but rather the timing of the removal.
Finally, CEA research underscores that the DTV cut-off will impact
a relatively small portion of the U.S. population--the 11 percent of
households that rely exclusively on over-the-air television reception.
Most households subscribe to cable or satellite, so the DTV cut-off is
not really an issue for this segment (although some may have secondary
sets in their home that rely on over-the-air that will require some
action to be taken).
With consumers projecting fewer televisions to remove during the
next two years compared with previous calendar years, and with earlier
CEA research showing that the DTV cut-off will directly affect only a
small fraction of U.S. households, the logical conclusion is that the
DTV cut-off will have little impact on the waste stream.
CEA Supports Consumer Education Initiatives
Consumers need reliable, up-to-date information to make the right
environmental choices about electronics. And, industry has a role to
play in providing such information.
CEA recognizes that the recycling of electronics products is
essential as we work to do our part to contribute to a more sustainable
world. Recycling must be made convenient, cost-effective and easy for
individuals, businesses, community centers, schools and government
agencies to participate. In order to educate consumers about options
for electronics products at the end-of-life, CEA launched
myGreenElectronics.org at the 2007 International CES.
MyGreenElectronics.org empowers consumers by providing online resources
regarding responsible use, reuse, and recycling of electronics with the
use of an online searchable database of electronics recyclers, a
database of green products and tips for saving energy with electronics.
CEA works with our members to make these resources available and
transparent to all interested stakeholders. We will continue to buoy
our education effort and have plans to expand upon this website
throughout 2008.
CEA Supports a National Approach to Electronics Recycling
CEA strongly believes that a national solution is the most
appropriate means to addressing this significant public policy
challenge, primarily as a means to provide consistency in recycling
opportunities to consumers and for uniform requirements for
manufacturers along with other key stakeholders. Without a uniform
national requirement, an ad-hoc array of State regulation imposes
unnecessary financial and administrative burdens on global technology
companies, which will ultimately increase costs to consumers. Each
state and municipality that creates a new authority with a new
governing body, or creates a new administrative or enforcement
structure, is duplicating many of the implementation struggles already
underway in other states around the country. Electronics recycling is a
national issue that warrants a national solution.
A national end-of-use framework should apportion responsibility
among all of the stakeholders and ensure a level playing field, while
promoting a widespread and adequately financed electronics recycling
solution.
Conclusion
Finding a solution to this public policy challenge is a priority
for CEA. As we continue to make strides in eco-friendly design
initiatives, lead the consumer electronics industry on environmental
issues and be a part of the effort to educate consumers about
electronics recycling, CEA stands ready to work with Congress and all
interested parties to reach a common-sense, national solution that
makes recycling as convenient as possible for all Americans.
Thank you again for the opportunity to share CEA's position on this
important public policy issue.
Statement of Meggan L. Ehret
Senior Counsel and Secretary
Thomson Inc.
Thank you Mr. Chairman and distinguished Members of the Committee
for inviting me to testify today. I am Meggan Ehret and I am Senior
Counsel and Secretary of Thomson Inc. Thomson Inc. is committed to
developing a workable and environmentally sustainable solution for
electronic recycling, which, according to the EPA, is the fastest
growing portion of the municipal solid waste stream. We applaud this
committee for holding this hearing to explore the appropriate treatment
for electronic recycling and to ensure that the solution is a workable
one that accomplishes the goal. We appreciate the opportunity to
participate in this discussion.
Thomson is committed to complying with all environmental, health,
and safety laws and regulations applicable to our business activities.
We are equally committed to preventing deterioration of the environment
and minimizing the impact of our operations on the land, air, and
water. These commitments can only be met through the awareness and
cooperation of all stakeholders. Today, Thomson is a world leader in
digital video technologies. Thomson provides technology, services, and
systems and equipment to help its Media & Entertainment clients--
content creators, content distributors, and users of its technology--
realize their business goals and optimize their performance in a
rapidly-changing technology environment. The Group is the preferred
partner to the media and entertainment Industries through its
Technicolor, Grass Valley, RCA, and Thomson brands. As background,
RCA's stock was acquired by General Electric in 1986, and shortly
thereafter Thomson bought certain consumer electronics assets from GE
and eventually acquired the RCA trademark (in most classifications) and
today licenses the trademark to a number of different companies that
make RCA televisions and other RCA-branded products. In 2004, Thomson
sold its television manufacturing assets and now licenses the RCA
trademark to a television manufacturer.
When considering the appropriate approach to electronic recycling,
we ask the Committee to recognize and implement two key and important
principles: first, computers and televisions warrant different
treatment and, second, financing the costs associated with recycling
televisions based on market share is the only approach that levels the
playing field for television manufacturers.
First, based on our experience, we have learned that each product
is different and, of direct relevance here, there are the differences
between televisions and computers. The different product life
expectancies, market economics, residual values, and product
portability necessitate different approaches to recycling to each
product.
Different Product Life Expectancy--Televisions have
an average useful life of 15 to 17 years and have been
available on the market since the late 1920's. Computers, on
the other hand, have only been widely available to consumers
since the 1980's and have an average life expectancy of at
least 10 years less than the average television. Because
televisions have been in existence much longer and have a much
longer life, many of the manufacturers of the televisions
entering the waste stream are either no longer in business or
are no longer manufacturing televisions.
Different Market Economics--It is estimated that over
30 million TVs will be sold in 2008 (U.S. News & World Report,
12/31/07). Of these, many will be sold by value brands that
have only been established in the past few years. (``Flat
Panels Have Poor Fundamentals,'' 03/26/2007 stating ``The
rampant competition from value brands like Vizio and
Westinghouse has undercut prices of brand names like Sony,
Philips and Panasonic by as much as 40 percent. . .Sustaining
healthy returns on capital in such an environment is almost
impossible.'') Far East manufacturers are flooding the market.
``China. . .has emerged to build consumer electronics. . .as a
new manufacturer. Any company with the resources and a market
entry point can deliver product relatively quickly by
contracting with the original design manufacturers.'' (The
Consumer Electronics Industry in Flux, Gartner Inc. Research
Report, November 16, 2005.). According to an article in Smart
Money Magazine (``Behind the Glass,'' March 2005), 70 percent
of the television manufacturers were not in business ten years
ago. By the time a new market entrant must pay to recycle its
products (approximately 15 years from today), it is likely no
longer in business. Thus, requiring present-day TV
manufacturers to fund a TV recycling program based on their
current market share ensures they are not given a free pass
until their branded products begin to appear in volume in the
State's recycling stream more than 15 years later and, in some
instances, at a time they are no longer in business.
Different Residual Value--A computer's residual value
is much greater than the typical cathode ray tube television.
Computers contain precious metals and other valuable and easily
recycled or reused materials. This significantly impacts the
economics of recycling a television versus recycling a
computer. A recent study demonstrates that computer recycling
creates profit or costs a few cents per pound while televisions
require thirteen to sixteen cents a pound to process (not
including costs of collection or transportation). (NERIC 2008
Recycler Pricing Study, www.ecyclingresource.org).
Different Product Portability--Computers are lighter
and easier to handle, thus different opportunities exist for
collection and recycling. Those opportunities do not exist for
television manufacturers. Thus, ``take-back'' programs that
require consumers to send equipment to a manufacturer is more
workable for computers than televisions.
These important differences support separate approaches to
recycling programs for each product. Many computer manufacturers have
already implemented ``take-back'' programs and thus requiring take-back
programs is the most logical and workable approach for computer
products. For televisions, which is my focus today, the only approach
that levels the playing field and maintains the competitive marketplace
is allocating the costs of a recycling program to the present day
manufacturers based on each manufacturer's respective current share of
the market. It is a fairer approach for the following reasons:
The television market is an easy-entry and easy-exit
industry, making short-term competitive advantages the rule.
According to an article in Smart Money Magazine (``Behind the
Glass,'' March 2005), 70 percent of the television
manufacturers were not in business ten years ago. By the time a
new market entrant must pay to recycle its products
(approximately 15 years from today), it is likely no longer in
business.
Far East manufacturers are flooding the market.
``China. . .has emerged to build consumer electronics. . .as a
new manufacturer. Any company with the resources and a market
entry point can deliver product relatively quickly by
contracting with the original design manufacturers.'' (The
Consumer Electronics Industry in Flux, Gartner Inc. Research
Report, November 16, 2005.). History has proven that they will
not be in business by the time televisions they sold/
manufactured enter the waste stream and, given their location,
enforcement or collection (particularly after they are out of
business) will be difficult if not impossible, unless a barrier
to entry to the market is contributing to the costs of
recycling televisions now.
It is difficult--if not impossible--to estimate today
the costs associated with recycling televisions 15 years from
now (e.g., collection, transportation and recycling) and market
share allocation ameliorates this concern. Thus, allocating the
actual costs to recycle products today among today's market
participants is fair and permits today's market participants to
plan accordingly.
A market share approach requires each current manufacturer to pay
for a share of the recycling of discarded televisions based on its
respective share of the market and account for these costs in the price
of their product. Any other alternative will give a free ride to new
market entrants as they will not be required to pay any costs for
recycling today and history has demonstrated that they will be out of
business in 15 years (which is when their products enter the waste
stream). Thus, new market entrants will likely never pay for recycling
electronics. Importantly, as a result of not having to factor in the
cost of electronic recycling, they are able to price their products
lower than the long standing market participants and increase their
share of the market. This is the same conclusion reached by the Council
of State Governments NE region, Minnesota, New Jersey, and Oregon. (See
http://www.csgeast.org/pdfs/RegionalDraft7-06---
revised.pdf). In fact, to date, there are only two states that have
adopted electronic recycling laws that allocate the costs of recycling
televisions based entirely on return share. Those are Connecticut and
Maine. Connecticut's Senate and House recently passed an amendment to
change the financing for the costs associated with recycling television
to market share and the bill awaits the Governor's signature.
In summary, Thomson respectfully asks that this committee consider
allocating the costs of recycling televisions to the current market
participants based on their respective share of the market, thereby
leveling the playing field for all television manufacturers and
maintaining the competitive marketplace for television manufacturers.
Thank you for allowing me the opportunity to provide my comments to
you.
Statement of the Office of Solid Waste
and Emergency Response
U.S. Environmental Protection Agency
Mr. Chairman and Members of the Committee, thank you for the
opportunity to provide testimony on electronics and the U.S.
Environmental Protection Agency's (EPA's) efforts to encourage more
environmentally preferable electronics product design and recycling.
EPA's Resource Conservation Challenge (RCC) seeks to renew the
emphasis on resource conservation under the Resource Conservation and
Recovery Act (RCRA) and the emphasis on preventing pollution and
conserving natural resources under the Pollution Prevention Act. The
RCC brings greater urgency to EPA's message of reducing, reusing, and
recycling valuable materials habitually discarded by American industry
and the general public by linking the importance of these activities to
energy conservation and greenhouse gas (GHG) reductions. One key area
of focus under the RCC is electronics.
WHY WE CARE ABOUT ELECTRONICS AT EPA
EPA has been actively helping to improve the design and recovery of
electronics for more than ten years. Our interest in electronics stems
from four primary concerns:
1) rapid growth and change in this product sector, leading to
a constant stream of new product offerings and a wide array of
obsolete products needing appropriate management;
2) energy consumption by these products (the Energy
Information Agency's Annual Energy Outlook 2006 projects that
electronics will a count for 19 percent of residential energy
use by 2020, compared with 14 percent of home energy
consumption in 2006);
3) the presence of toxic substances in many products which can
cause problematic exposures during manufacturing, recycling or
disposal, if not properly managed--the presence of these
constituents has sparked the search for workable substitutes
and development of better management practices; and
4) the need to ensure widespread, convenient and affordable
reuse/recycling infrastructure for electronics (with initial
emphasis on TVs, PCs and cell phones) and, in doing so, to
conserve and recover the large amount of embodied energy and
valuable materials inherent in used electronics.
THE CHANGE IN TV TECHNOLOGY AND TRANSMISSION
Change is about to happen in the TV world. First, as prices come
down for newer models, consumers are upgrading from the old cathode ray
tube style of TV to newer, flat screen, high definition models (such as
LCD and plasma). In addition, the ``Digital Transition'' is around the
corner. On February 17, 2009, all full-power television stations will
broadcast only in digital.\1\ Nielsen estimates that more than 13
million households have TV sets that only receive over the air (OTA)
analog broadcasts and an additional six million households have at
least one OTA analog television set.\2\ Households that receive free
over the air television broadcasts on analog TVs must take action by
connecting their TV to a digital-to-analog converter box, purchasing a
digital television, or subscribing to a paid TV service.
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\1\ See 47 U.S.C. 309(j)(14)(A), 337(e).
\2\ The Nielsen Company. Press Release ``13 Million U.S. Households
Not Yet Ready for Digital Television Conversion, Nielsen Says.''
February 15, 2008.
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Both of these changes are raising questions about how many old TVs
will find their way to the recycling/disposal path in the near future.
Some are predicting a ``tidal wave'' from the digital transition. More
likely, however, the increase will be gradual over a several year time
frame as consumers take advantage of falling prices for new TV
technologies. The digital transition, by itself, is unlikely to cause a
large spike in TV disposal. This is because fifty percent of homes
already have digital TV so will receive programming after the
changeover, without doing anything additional.\3\ In addition, those
that have analog TV only, or other analog TVs in the home, can either
obtain digital-to-analog converters or cable service to extend the life
of their analog TVs. Furthermore, some homes will keep analog TVs to
use for gaming or movies, or hand them off to someone else who may want
to use them this way. There are many options, and it is unlikely that a
sudden wave of TVs will find their way to the recycling/disposal path
due primarily to the digital transition in February 2009. Still the
digital transition, plus the move to adopt new TV products, will mean
that greater collection and recycling infrastructure will be needed to
properly handle these TVs as they emerge from homes over the next few
years.
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\3\ Consumer Electronics Association. Market Research Report:
Trends in CE Reuse, Recycle and Removal. April 2008.
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WHAT ARE WE DOING ABOUT ELECTRONICS?
EPA is engaged in several broad scale partnerships with
manufacturers, retailers, other federal agencies, State and local
governments, recyclers, non-government organizations (NGOs) and others
to encourage and reward greener design of electronic products, to help
develop the infrastructure for collection and reuse/recycling of
discarded electronics, and to promote environmentally safe recycling of
used electronics. More detail about each of these efforts is provided
below.
1) GREENING DESIGN OF ELECTRONICS
EPEAT: EPA funded and participated in a multi-stakeholder and
consensus-based process, involving electronics manufacturers, large
government IT purchasers, NGOs and others, to develop the Electronics
Product Environmental Assessment Tool (EPEAT). Now codified as IEEE
Standard 1680, EPEAT was launched in 2006 to meet growing demand by
large institutional purchasers for a means to readily distinguish
environmentally-preferable desktop and laptop computers and monitors in
the marketplace. Modeled on other environmental rating tools like the
Leadership in Energy and Environmental Design's (LEED's) Green Building
Rating system, EPEAT includes environmental criteria encompassing the
product life cycle. EPEAT also provides a system for registering and
verifying equipment that meets its criteria. EPEAT-registered computers
and monitors have reduced levels of toxics, are more energy efficient,
easier to upgrade and recycle, and use more sustainable packaging than
conventional equipment. EPA supported the development of EPEAT, and it
is now a self-sustaining system operated by the Green Electronics
Council.
EPEAT has been a tremendous success. Even with recent upgrades to
the EPEAT criteria, there are more than 550 products from 26
manufacturers registered to the EPEAT standard. In the first six months
the system was in place, manufacturers reported selling more than 36
million EPEAT-registered products. EPEAT is now the official
environmental standard for electronics in all federal purchasing. More
than six states and many other public and private purchasers are
specifying EPEAT equipment.
There is increasing demand for EPEAT to expand to additional
products. This year, EPA is funding a neutral organization to convene
stakeholders to develop standards for additional electronic products,
including possibly TVs. EPA has committed resources to help develop
four new standards. Interest is growing in using EPEAT to promote
greener electronics purchases by consumers.
ENERGY STAR: Starting as early as summer 2008, consumers will be able
to purchase ENERGY STAR qualified TVs covering all of today's screen
technologies, in all sizes. The ENERGY STAR label will mean these
products are up to 30 percent more energy efficient in both standby and
active (when they are on) modes than conventional models. The
approximately 275 million TVs currently in use in the U.S. consume over
50 billion kWh/year--or four percent of all households' electricity
use. When coupled with digital video recorders, they account for about
13 percent of an individual household's electricity bill.
Energy consumption can vary greatly among different models. In
general, the larger the TV, the more energy it will consume. However,
when similarly sized products are compared, projection units use the
least energy, followed by LCD products, with plasma products using the
most energy. EPA will make available on the ENERGY STAR Web site an
estimate of the annual kilowatt-hours (kWh) for all qualified TVs, so
consumers are aware of the amount of energy the TV they are considering
for purchase will use each year. On average, under the new
requirements, an ENERGY STAR qualified TV will save $35 off a
consumer's utility bills over the life of the TV. If each TV purchased
in the U.S. in one year were ENERGY STAR qualified, we would prevent
more than three billion pounds of greenhouse gas emissions per year.
This equals a savings of over two billion kWh and $250 million in
energy costs and reduces greenhouse gas emissions equal to taking about
300,000 vehicles off the road annually.\4\
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\4\ Energy Star uses standard assumptions for converting energy
savings to greenhouse gas (GHG) reductions and dollars saved. For GHG
conversions used by the Energy Star program, please see http://
www.epa.gov/cleanenergy/energy-resources/refs.html
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On April 24, 2008, EPA announced a new specification for ``boxes''
that deliver television and video content, also called set-top boxes.
Effective January 1, 2009, new cable, satellite, and telecom set-top
boxes that carry the ENERGY STAR will be at least 30 percent more
energy efficient than conventional models. If, after this new
specification goes into effect, all set-top boxes sold in the United
States meet the Energy Star requirements, the savings in energy costs
will grow to about $2 billion each year and greenhouse gas emissions
will be reduced by the equivalent of taking about 2.5 million vehicles
off the road annually.
Furthermore, EPA recently made the ENERGY STAR available for
digital-to-analog converter boxes (DTA's). ENERGY STAR qualified DTAs
are eligible for purchase under the National Telecommunications and
Information Agency's TV Converter Box Coupon Program. This program
provides consumers coupons to save on the purchase of DTA's so older
TVs can continue to receive over-the-air broadcasting after February
17, 2009. Consumers are encouraged to check that a product is both a
coupon-eligible converter box and ENERGY STAR qualified model prior to
purchasing. Savings from an ENERGY STAR qualified DTA over a
conventional model are estimated to be up to 37 kWh annually or $4.
DESIGN FOR THE ENVIRONMENT (DfE): Over the years, EPA's DfE Program has
worked with the electronics industry to help green the manufacturing of
electronics, as well as electronics products themselves. DfE has worked
with the industry on ways to green the manufacture of printed wiring
boards, assess the life cycle impacts of CRTs and flat panel displays,
and assess substitutes for tin-lead solder that have acceptable
engineering performance yet are less toxic, and pose the fewest risks
over their life cycle. The solder life cycle assessment generated data
to help manufacturers, users, and suppliers incorporate environmental
considerations when choosing replacements for the 176 million pounds of
leaded solder used annually in the United States.
DfE also recently completed a life cycle assessment for various
kinds of wire and cable products (including network and low voltage
cables). The study results will help companies make environmentally-
informed product and material choices and will identify the relative
contributions of various processes and materials to the overall impacts
of the wire and cable products.
2) ENCOURAGING MORE REUSE AND RECYCLING
PLUG-IN TO eCYCLING: Plug-In to eCycling is working, through
partnerships, to expand infrastructure for collection and safe
recycling of e-waste nationwide. In 2007, EPA's Plug-In partners
collected more than 47 million pounds of electronics. The energy
conserved through these recycling efforts is equivalent to the annual
GHG emissions of taking nearly 24,000 cars off the road annually.\5\
Since the partnership began in 2003, Plug-In partners have recycled
more than 142 million pounds of unwanted consumer electronics. All
Plug-In partners, whether they recycle electronics directly or contract
with others for recycling services, are required to abide by the Plug-
In Guidelines for Materials Management. These Guidelines spell out
preferred recycling practices for used electronic products.
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\5\ EPA calculates these greenhouse gas (GHG) equivalent emissions
reductions based on the WARM model (Waste Reduction Model), following a
life cycle assessment methodology using estimation techniques developed
for national inventories of GHG emissions. See Solid Waste Management
and Greenhouse Gases: A Life-Cycle Assessment of Emissions and Sinks
(EPA530-R-06-004). To convert GHG equivalent emissions to more easily
understood metrics, such as cars off the road, gallons of gasoline,
etc., EPA uses the Greenhouse Gas Equivalencies Calculator developed by
the U.S. Climate Technology Cooperative.
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Plug-In partners continue to demonstrate innovation and creativity
in sponsoring collection events and take-back programs and reaching out
to consumers. As an example, Dell has expanded its Reconnect
partnership with Goodwill Industries to include select cities in six
states. Reconnect, a comprehensive electronics recovery, reuse, and
environmentally responsible recycling opportunity for consumers, is now
providing electronics donation opportunities to several million
households. Dell also has a free, online computer recycling program for
consumers who own Dell computers.
In 2007, Staples, Office Depot, Hewlett Packard, and Sony also
launched nationwide eCycling efforts. The Staples program, launched in
May, lets consumers drop off their computers and other electronic
office equipment at any of the company's 1,400 U.S. retail locations.
Sony's Take Back Recycling program, launched in September 2007, allows
consumers to take, free of charge, their unwanted Sony-branded
electronic products at 138 drop-off centers across the country run by
Waste Management eCycle America.
As part of its Plug-In to eCycling program, EPA teamed up with cell
phone manufacturers, service providers, and retailers in 2007 to
increase America's cell phone recycling and donation rate. EPA
distributed public service announcements and podcasts and increased
publicity about available partner recycling programs.
These and other initiatives sponsored by industry, states, and
recyclers are generating critical data which will inform policy-making
on electronics recycling. These innovations are crucial to learning
what works, what does not, where collaboration is possible and where it
is not, what kinds of opportunities really get the attention of the
consumer and what kind of material the consumer wants to recycle. And
very importantly, these projects clarify what it costs to get
electronics from the consumer into responsible recycling under varying
circumstances.
FEDERAL ELECTRONICS CHALLENGE: The Federal Government is a very large
purchaser of IT products. To help the Federal Government lead by
example in buying green electronics and managing them appropriately at
the end of their useful life, the Federal Environmental Executive and
the EPA launched the Federal Electronics Challenge (FEC) in 2004. The
FEC is a voluntary partnership program designed to help federal
agencies become leaders in promoting sustainable environmental
stewardship of their electronic assets. As FEC Partners, federal
agencies work towards goals in all three of the electronics life cycle
phases--acquisition & procurement; operations & maintenance; and end-
of-life management.
In 2007, the President signed Executive Order (E.O.) 13423,
``Strengthening Federal Environmental, Energy, and Transportation
Management.'' E.O. 13423 consolidates and strengthens five executive
orders and two memorandums of understanding related to Federal
Government environmental, energy, and transportation performance and
accountability, including electronics stewardship by federal agencies.
CEQ and OMB implementing instructions for the E.O. were issued later in
2007 requiring that all federal agencies and their facilities
participate in the FEC, or an equivalent program.
Today, the FEC has 16 federal agency partners and 184 facility
partners. Facility partners reported many successes in 2007. These
included 1) 80 percent of computer desktops, laptops and monitors
purchased or leased were EPEAT registered,\6\ 2) 86 percent of monitors
and 69 percent of computers had ENERGY STAR features enabled, and 3) 99
percent of non-reusable computers were recycled in an environmentally-
sound manner.
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\6\ The Federal Acquisition Regulations requirement that 95 percent
of applicable federal information technology purchases meet the EPEAT
took effect in December of 2007. As a result, it is anticipated that
more federal purchases will be EPEAT-compliant in FY 2008.
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The Recycling Electronics and Asset Disposition (READ) services
program assists Federal agencies in assuring environmentally sound
management of their electronic discards. Managed by EPA, the READ
program offers federal agencies access to recycling and asset
disposition services providers that have been evaluated to ensure that
they recycle and properly dispose of excess or obsolete electronics in
an environmentally responsible manner.
3) WORKING TO IMPROVE ELECTRONICS RECYCLING
RESPONSIBLE ELECTRONICS RECYCLING PRACTICES: A broad group of
stakeholders, including states, electronics manufacturers, electronics
recyclers, trade associations and public interest groups, have been
convened to develop voluntary ``responsible recycling'' (R2) practices
for electronics recyclers, and a process for assessing conformity of
recyclers with these practices. We expect that these practices will be
implemented by private organizations, and not EPA. The dialogue began
in 2006 and has resulted in a set of draft practices that has been
reviewed by experienced facility auditors and will be undergoing field
testing in the next few months. However, it should be noted that these
draft practices have not been agreed to by the stakeholders and are
likely to be further modified after field testing and further
discussions.
The current draft includes provisions for recyclers to 1) comply
with all applicable environmental, health, and safety legal
requirements, 2) manage used and end-of-life electronic equipment based
on a ``reuse, recover, dispose'' hierarchy of responsible management
strategies, 3) utilize practices at their facilities that protect
worker health and safety and the environment, 4) manage the R2 ``focus
materials'' that pass through their facilities or under their control
in a manner protective of worker health and safety, public health, and
the environment, and 5) perform due diligence on downstream vendors to
which it ships these materials, including those that are exported from
the United States. ``R2 focus materials'' are materials in end-of-life
electronics equipment that warrant greater care because of potential
hazards during recycling, refurbishing, materials recovery, energy
recovery, incineration, and/or disposal.
After the practices have been field tested, the stakeholder group
expects to revisit and revise the practices based on information and
recommendations gathered during the field testing process, and to make
other changes as appropriate. EPA is also conducting research on
electronics recycling that includes environmental sampling and
characterization of an electronics recycling facility. Data from this
testing will assist the stakeholders in adopting practices to comply
with applicable environmental requirements.
EXPORTS MANAGEMENT: It is well known that electronics material
collected in the United States and other developed countries is
exported to foreign countries. Some are concerned that this amounts to
``exporting harm,'' because electronics materials have been mishandled
in some of the receiving locations. Those that object to exports of
used electronics point to the coming digital transition and consumer
upgrading to new TV technologies (e.g., LCD, plasma, flat screens) and
the insufficient infrastructure in the U.S. to process these materials
as evidence that abuses abroad will only worsen. However, it must be
recognized that while there have been demonstrated problems, export of
electronics collected is a necessary and useful function, and important
work is underway to ensure that these exports are managed appropriately
at their destination. Also, it should be understood that without export
of electronics as an option, most of the electronics in the United
States would be disposed.
Used electronics can be exported to other countries for the purpose
of continued use or recycling. It is difficult to generate good
estimates of how much used and scrap electronics are exported for reuse
and recycling, because data on export volumes is not always required to
be reported. However, EPA has attempted to quantify the amount of CRT
TVs and monitors that are exported for reuse or recycling. We estimate
that more than 80 percent of CRT devices (including materials such as
processed glass resulting from processing CRTs in the U.S.) that are
collected for reuse or recycling are sent to foreign markets.
Given the concerns expressed by some about improper handling of
electronics abroad, should there be any export at all? There are
examples of unsafe recycling practices in some areas of the world where
dismantling occurs in unregulated and uncontrolled cottage industry
conditions. However, there are also benefits associated with export of
this material. Much of what goes abroad is whole equipment or
components for reuse. This reuse avails many people in developing
countries with information technology that would otherwise be
unaffordable for them. Materials such as plastics or metals derived
from electronics and processed in the United States make up another
large portion of the amount exported. These ``scrap'' commodities are
in high demand overseas as raw materials for manufacturing. Because
most electronics are manufactured abroad, using materials from
discarded electronics in the manufacture of new electronics cannot
occur unless the raw materials are sent back to where the products are
manufactured.
Without international markets, many of the efforts currently
underway in the United States to divert obsolete electronics away from
disposal and toward reuse and recycling could not be sustained. For
example: 1) there are no smelters/refiners in the United States to
convert copper and precious metal (gold, silver, palladium) bearing
electronics into metals that are pure enough for use; 2) there are no
longer any cathode ray tube (CRT) glass furnaces in the Western
Hemisphere for use of recycled CRT glass; 3) nearly all markets for
plastics from electronics are overseas, primarily in Asia; and 4) the
major markets for reuse (of both whole equipment and components) are
outside the United States, mostly in developing countries.
At the same time, EPA is taking steps to improve the management of
electronics sent abroad for management. This is particularly relevant
to concerns that evolution to new TV technologies which will increase
the number of old TVs available for end-of-life management. EPA's new
CRT rule requires exporters of CRTs for reuse to file a one-time
notification with EPA stating that they plan to export CRTs for reuse.
The rule also requires persons who export CRTs for reuse to keep, for
not less than three years, copies of business records demonstrating
that each shipment of exported CRTs will be reused. This requirement
provides United States regulatory authorities the opportunity to
inspect these records in order to verify that the CRTs were actually
sent to legitimate reuse or refurbishment entities. For export of CRTs
and unprocessed CRT glass for recycling (as opposed to reuse), the rule
requires both notification to EPA of the intended export and consent by
the receiving country. These regulations are relatively new, and we are
still in the process of implementing the requirements. These new
requirements promise to ensure significantly better control over CRTs
exported for recycling.
We also have several initiatives that promote safe management of
used electronics exported for recycling, including the Plug-In
guidelines for sound reuse and recycling of electronic products and the
multi-stakeholder dialogue to issue ``responsible recycling'' practices
for incorporation into a certification program for e-waste recyclers,
both of which have previously been discussed in the testimony. EPA also
led the development of international guidelines on the sound use and
recycling of personal computers by the Organization for Economic
Cooperation and Development (OECD). We participated in a Basel
Convention partnership effort with industry that is developing
guidelines for the safe reuse, recycling and transboundary movement of
used and scrap mobile phones. Finally, we are a participant in a
working group of international stakeholders of academia, trade
associations, industry and governments--called the StEP initiative--to
identify voluntary activities that promote sound reuse and safe
recycling, especially concerning the transboundary flows of
electronics.
With global markets being essential to sustainable and sound
management of electronics, the key is to continue to work towards
assuring that management of electronics at their end-of-life is
protective of human health and the environment whenever and wherever it
takes place. EPA is committed to continuing its ongoing efforts in this
regard.
Conclusion
EPA appreciates the Committee's interest in this issue and the
opportunity to discuss the Agency's electronics goals, what efforts are
currently underway, and how EPA works with partners throughout the
product chain to achieve shared responsibility for a greener, recovery-
oriented product cycle.
Follow-up Questions for Written Submission
by the Environmental Protection Agency (EPA)
Questions submitted by Chairman Bart Gordon
Q1. How much funding has EPA allocated for the development of the
Electronics Product Environmental Assessment Tool (EPEAT) standards for
televisions and when will this funding be given to the Green
Electronics Council to develop these standards?
A1. The Green Electronics Council is not the developer of EPEAT
standards. The Council maintains the EPEAT Product Registry and
conducts verification to help ensure products meet the EPEAT Standard
criteria and markets EPEAT to purchasers. Rather, EPA will be awarding
a $300,000 four year cooperative agreement, which will pay for 50
percent of the costs of managing the process of developing four new
product standards--imaging equipment, televisions, servers, and cell
phones/PDAs: The recipient of this cooperative agreement will
facilitate the development of these new standards through a multi-
stakeholder voluntary consensus process. EPA provided partial funding
under the Pollution Prevention Program/Project (502C95) in EPA's
Environmental Programs Management appropriation for this work due to
limited resources and a belief that other stakeholders needed to
jointly-fund the development of standards which meet their needs. The
EPA cooperative agreement is in the final stages of obtaining Agency
approval, and is scheduled to be awarded in the summer of 2008.
Q2. EPA states in its testimony that ``starting as early as 2008,
consumers will be able to purchase ENERGY STAR qualified TVs.'' Is
ENERGY STAR available now for televisions?
EPA states in its testimony that ``. . . they [TVs
and digital recording devices] account for about 13 percent of
an individual household's electricity bill.'' Given this high
energy usage, why has the ENERGY STAR program been so slow to
expand the program to televisions?
The Committee heard testimony at the hearing, that
the production of an electronics product uses considerably more
energy than the energy use over the product's lifetime. Why
hasn't EPA added a provision to ENERGY STAR that would help
consumers assess and compare the embodied energy of electronics
products?
Q2a. Is ENERGY STAR available now for televisions?
A2a. EPA has had ENERGY STAR requirements for TVs since 1998. Version
2.2 of these requirements is in place now and more than 2,200 TV models
have earned the ENERGY STAR label. In November 2008, EPA's new Version
3.0 requirements for TVs will go into effect. These new requirements
ensure that TVs are more energy efficient in all modes of operation. In
order to qualify for ENERGY STAR, TVs must be tested using the
internationally vetted and supported On Mode test procedure for TVs
(IEC 62087).
Q2b. EPA states in its testimony that ``. . . they [TVs and digital
recording devices] account for about 13 percent of an individual
household's electricity bill.'' Given this high energy usage, why has
the ENERGY STAR program been so slow to expand the program to
televisions?
A2b. ENERGY STAR has addressed what was the significant contribution
TVs historically made to a household's electricity bill (i.e., standby
power consumption). As TV technology and usage patterns have changed,
EPA contributed to the development of an internationally accepted ``On
Mode'' test procedure and incorporated requirements into ENERGY STAR to
address power consumption across all modes of TV operation. With these
new requirements, if all TVs sold in the United States met ENERGY STAR
requirements,\1\ the savings in energy costs would grow to about $1
billion annually.
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\1\ As of 2015 and thereafter.
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Standby power consumption remains a focus of the ENERGY STAR
program as U.S. households spend $100 per year to power devices while
they are in a standby power mode--roughly eight percent of household
electricity costs. Consumer electronics, including audio, video and
telephone products account for 40 percent of low power mode consumption
(roughly $40 per household per year).
Q2c. The Committee heard testimony at the hearing that the production
of an electronics product uses considerably more energy than the energy
use over the product's lifetime. Why hasn't EPA added a provision to
ENERGY STAR that would help consumers assess and compare the embodied
energy of electronics products?
A2c. EPA has, to date, focused on the savings available to consumers by
reducing the power draw of products they use in their homes and
workplaces. Through this focus, Americans, with the help of ENERGY
STAR, prevented 40 million metric tons of greenhouse gas emissions in
2007 alone and saved more than $16 billion on their utility bills.
The program is committed, however, to achieving additional savings.
For example, ENERGY STAR initially focused on achieving greater
efficiency while products were in low power mode as there was an
opportunity to deliver significant savings in a cost effective manner.
In recent years, EPA has turned its attention to On Mode power
consumption for many product categories as their power consumption in
this mode has become a more significant portion of the products'
overall consumption and meaningful savings were measurable and
achievable. A sister program to ENERGY STAR, EPA's Climate Leaders
program, has challenged partners to reduce their carbon footprint,
including that which is associated with the manufacture of products
like TVs.
EPA is considering how the Agency can weigh products' embodied
energy, as well as the product's in-use performance against a range of
other environmental criteria when recognizing products as
environmentally preferable. This effort, underway now, will align with
ENERGY STAR's guiding principles--engaging key stakeholders, and
building on existing data.
Q3. When did EPA begin its Design for the Environment (DfE) program?
How much funding has gone to the initiative since its inception (by
year) and how much has been specifically devoted to electronics
products (by year)? How much funding did EPA request for these
activities in FY 2008 and FY 2009?
Please list the electronics producers EPA has worked
with through the DfE program. How has EPA worked with
electronics recyclers or facilitated dialogue between
electronics producers and electronics recyclers through the DfE
program?
How are tools like the solder life cycle assessment
and the wire and cable life cycle assessment used by
manufacturers? Can you please provide us with some specific
success stories from the WE program?
Q3a. When did EPA begin its Design for the Environment (DfE) Program?
A3a. The Office of Pollution Prevention and Toxics' Design for the
Environment (DfE) Program was established in 1992. More information on
the DfE Program is available at www.epa.gov/dfe.
Q3b. How much funding has gone to the initiative since its inception
(by year) and how much has been specifically devoted to electronics
projects (by year)? How much funding did EPA request for these
activities in FY 2008 and FY 2009?
A3b. Year-by-year funding for DfE and for DfE electronics projects is
provided in Attachment A. The attachment also provides the President's
budget request for DfE for fiscal years 2008 and 2009. All DfE
resources are housed in the Pollution Prevention Program/Project
(502C95) in EPA's Environmental Programs Management appropriation.
Q3c. Please list the electronics producers EPA has worked with through
the DfE Program.
A3c. Attachment B includes the electronics manufacturers who have
played a significant role in DfE partnerships. Also in this list are
suppliers to electronic manufacturers who have provided input in the
dialogue. These include manufacturers of printed circuit boards, flame
retardants, and resins. After the industry partners, we list other
significant participants.
Q3d. How has EPA worked with electronics recyclers or facilitated
dialogue between electronics producers and electronics recyclers
through the DfE Program?
A3d. Multi-stakeholder engagement is central to DfE's approach; DfE
engages industry, environmentalists, and others. These stakeholders
help EPA to define project goals and scope, and enable EPA to
understand and account for the broad range of concerns and issues
associated with exploring alternative, safer chemicals, more efficient
processes, and preferable product end-of-life scenarios.
Recyclers have shown great interest in DfE projects. For example,
in the case of the ongoing EPA Flame Retardants in Printed Circuit
Boards Partnership, copper smelters participated in scoping and design
of the partnership and are now working with us to conduct the work.
Copper smelters have helped DfE and the full stakeholder group to
understand how the smelting process works, and the printed circuit
board constituents that may cause concern for the industry. The
smelters have been very helpful in designing a study to understand the
unintended byproducts that may result from combustion.
Based on our partnership work involving their industry, the
Institute of Scrap Recycling Industries, Inc., gave DfE their Design
for Recycling Award in 2007.
Q3e. How are tools like the solder life cycle assessment and the wire
and cable life cycle assessment used by manufacturers?
A3e. DfE Lead-Free Solder Partnership
The study results have provided the industry with an objective
analysis of the life cycle environmental impacts of leading candidate
alternative lead-free solders, and have allowed the industry to
redirect efforts towards products and processes that reduce solders'
environmental footprint. The electronics industry has substantially
reduced the use of lead in electronics since this study began. More
information can be found at www.epa.gov/dfe/pubs/projects/solder/
index.htm.
DfE Wire & Cable Partnership
Opportunities for improvement of environmental performance in wire
and cable products were identified in the Life Cycle Assessment,
focusing primarily on energy efficiency, and recycling of chopped cable
resin. For example, electricity generation for raw material production
and cable extrusion were a large part of the environmental burden of
wire and cable products. Finding opportunities to reduce energy inputs
would likely have a large effect on the overall environmental burden of
wire and cable products. Also, increased recycling of chopped cable
resin, although an energy-intensive process, would decrease the
potential impacts associated with land-filling and incineration. The
draft final LCA is now posted on the DfE web site for public comment.
Please see: www.epa.gov/dfe.
Q3f. Can you please provide us with some specific success stories from
the WE Program?
A3f. Below are success stories from the DfE Program.
Informed Substitution: Safer Flame Retardants for Furniture and Printed
Circuit Boards
DfE's Furniture Flame Retardancy Partnership was initiated in
response to stakeholder concerns with the occurrence of
pentabromodiphenyl ether (pentaBDE) in the environment and human
tissues. PentaBDE was the primary flame retardant in the manufacture of
low-density, flexible polyurethane foam for furniture, with production
levels of approximately 19 million pounds per year.
To ensure that decisions were made based on the best information
available, and to minimize the chance of unintended consequences, DfE
brought together a multi-stakeholder group to consider the move to
alternative chemicals. In consultation with this group, DfE developed
an alternatives assessment methodology for evaluating alternative flame
retardants based on the tools and expertise of the Office of Pollution
Prevention and Toxics.
DfE evaluated 14 commercially-available alternative flame retardant
formulations. The outcome of the partnership was a move to alternative
flame retardant formulations. The results from this partnership were
used by foam manufacturers, in the period leading up to the voluntary
December?2004 phase-out of production of pentaBDE, in choosing
alternative flame retardants. These efforts complemented an EPA
Significant New Use Rule (SNUB) under the Toxic Substances Control
Act--a regulatory backstop to require notification to EPA before
restart of U.S. manufacture or import of pentaBDE for any use.
Please see: http://www.epa.gov/dfe/pubs/projects/flameret/index.htm
for more information.
DfE's Printed Circuit Board Partnership
DfE is now working with the electronics industry, the chemical
industry, and environmental groups to adapt the technical methodology
described above to electronics applications. The Printed Circuit Board
Flame Retardancy Partnership was convened to better understand the
environmental health and safety aspects of commercially available flame
retardants that can be used to meet fire safety requirements for the
type of printed circuit board that dominates the industry.
A draft report for public comment will be available later in 2008.
Please see: http://www.epa.gov/oppt/dfe/pubs/projects/pcb/index.htm for
more information.
DfE Formulator Safer Product Recognition Program
EPA allows safer products to carry the Design for the Environment
(DfE) label. This mark allows consumers to quickly identify and choose
products that can help protect the environment and are safer for
families. When you see the DfE logo on a product it means that the DfE
scientific review team has screened each ingredient for potential human
health and environmental effects and that--based on currently available
information, EPA predictive models, and expert judgment--the product
contains only those ingredients that pose the least concern among
chemicals in their class.
Product manufacturers who become DfE partners, and earn the right
to display the DfE logo on recognized products, have invested heavily
in research, development and reformulation, to ensure that their
ingredients and finished product line up on the green end of the health
and environmental spectrum, while maintaining or improving product
performance.
More than 100 manufacturers have met DfE's criteria for displaying
the logo on more than 500 products, including: Clorox, Method, SC
Johnson and Son, Colgate Palmolive, Dial Corporation, SYSCO, and
Corporate Express. Additionally, retailers such as WalMart and Home
Depot ask their suppliers to work with DfE. Visit http://www.epa.gov/
oppt/dfe/pubs/projects/formulat/label.htm for more information and a
listing of safer products.
Please also see Design for the Environment Partnership Highlights
at http://www.epa.gov/dfe/pubs/about/index.htm.
Q4. When did EPA begin its Plug-In To eCycling program? Since its
inception, how much funding has EPA requested for this program (by
year) and how much has been allocated (by year)? What specific
activities are funded under this program, and what activities does EPA
carry out?
In its testimony, EPA states that these ``initiatives
sponsored by industry, states, and recyclers are generating
critical data which will inform policy-making on electronics
recycling.'' Please provide some examples of the critical data
generated and how it will inform policy-makers. What is EPA's
role in collecting and processing this information?
A4. In 2003, EPA launched the Plug-In To eCycling partnership program
to work with electronics manufacturers and retailers to offer consumers
increased opportunities to donate or recycle--``eCycle''--their used
electronics. The program's initiatives are intended to reflect shared
responsibility among manufacturers, retailers, governments and
consumers. These initiatives seek to demonstrate how voluntary,
industry-led models or public-private partnerships can complement
existing state or municipality-led collection and recycling efforts.
Plug-in initiatives also inform policy-making on electronics recycling
by demonstrating what works and what does not (e.g., how best to
encourage consumer participation, what various approaches cost). Over
the past five years, the Plug-In program has grown to include 25
industry partners. Through their collective, voluntary efforts,
partners have recycled more than 142 million pounds of unwanted
consumer electronics.
Since its inception, Plug-In To eCycling has been allocated
approximately $742,000\2\ in funding ($207,000, $125,000, $100,000*,
$100,000*, $100,000, and $110,000 for fiscal years 2003-2008,
respectively).\3\ The Plug-In program is not included as a separate
item in our program budget requests, but it is one of the many
activities over the years that we implement during the budget year to
foster improved end-of-life management of electronics, as described in
our Congressional Justifications.
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\2\ In FY07 and FY08 we funded this out of 301DA2--Waste
Minimization and Recyling funds.
\3\ For FY 2005 and 2006, Plug-In was not itemized in the operating
plan budget. It was included within the $275,000 allocated to the
Office of Solid Waste's activities on management of end-of-life
electronics and received an estimated $100,000 in both FY05 and FY06.
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With these funds, Plug-In To eCycling carries out the following
functions: 1) providing information to educate and encourage the public
to increase participation in electronics recycling, 2) facilitating
partnerships to increase opportunities for consumers to recycle their
used electronics; 3) researching ways that manufacturers can
collaborate to help manage collection and recycling of e-waste; and 4)
supporting efforts to quantify the environmental benefits of
electronics recycling. Specific activities that have been undertaken
include:
To increase public awareness of the opportunities to
donate and recycle used electronics and the environmental
benefits of doing so, Plug-In has created a variety of outreach
tools, including: an eCycling event toolkit, brochures, flyers,
web pages, public service announcements, podcasts, and a short
video promoting computer reuse. Earlier this year, Plug-In
launched the Recycle Your Cell Phone. It's an Easy Call.
campaign to highlight the many opportunities for consumers to
recycle their cell phones. In just two weeks, the campaign
received over 10,000,000 media impressions from national
outlets, such as AP, the New York Times, NPR and Reuters and
this earned media valued at over half a million dollars.
Outreach activities help to raise public awareness of the
importance of electronics recycling and stimulate participation
in existing recycling programs.
Plug-In has supported the development,
implementation, and evaluation of four pilot projects to assess
different approaches to effective collection techniques for
end-of-life electronics. These pilots included retail take-back
pilots involving Staples, Good Guys, Office Depot, and Best Buy
and researched the creation of manufacturer-led third party
organizations to coordinate collection and recycling. The
lessons learned and data collected from participating in the
pilot projects enabled the retail partners to test the
feasibility of collecting used electronics in a retail setting
and understand the degree to which the reverse distribution
collection approach could be part of the company's sustainable
business model. For example, based on the experience gained and
the success of its pilot project, Staples has since expanded
their program nationwide. The retail pilots have demonstrated
that retailers are potent partners in educating and
incentivizing consumers to recycle by providing them with
convenient drop-off outlets and offering them attractive
rebates and discounts on the purchase of new products when they
bring in an old product for recycling. The research on
manufacturer-led third party organizations illustrates how
consortia of manufacturers can pool their resources and
business expertise to provide efficient and effective take-back
services. These lessons are being applied in such states as
Washington and Minnesota, two states that are encouraging
manufacturer collaborations on take-back. All of these pilots
have helped to expand collection and recycling not only in
states that have electronics recycling requirements, but states
that do not.
EPA created the Plug-In To eCycling Guidelines for
Materials Management, which serves as national guidance for the
safe management of used electronics. These Guidelines have
allowed EPA and Plug-In partners to gain experience and
information about what practices, will most effectively protect
human health and the environment, while at the same time
enabling practicable programs for the management of used
electronics. The Guidelines have also served as a basis for the
development of the ongoing effort to formulate consensus
``Responsible Recyclers Practices.'' \4\
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\4\ EPA is working with stakeholders (i.e., states, electronic
manufacturers, recyclers, trade associations and public interest
groups) to develop one agreed upon set of practices that can be used in
a voluntary certification program which assures the environmental
performance of electronic recyclers. This certification program is
expected to be run by private organizations, not EPA.
EPA has collaborated with the National Center for
Electronics Recycling (NCER) to help populate NCER's database
on electronics collection. Plug-In To eCycling partners are
being asked to share their data with NCER. The centralized
database, designed by a range of key stakeholders in
conjunction with the NCER and EPA, is intended to provide
recycling program designers and managers, as well as policy-
makers, with information on electronics recycling program
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structure, costs, and results.
Plug-In has contributed to the broader EPA effort to
develop the Electronics Environmental Benefits Calculator
(EEBC). The Calculator estimates the benefits of
environmentally sound management of electronic equipment from
purchase to use to end-of-life management. With this tool, a
user can quantify and articulate the environmental benefits of
their electronics recycling activities in terms of greenhouse
gas reductions and energy savings.
Q5. Regarding the export of used electronics, EPA's testimony states,
``. . . it should be understood that without export of electronics as
an option, most of the electronics in the United States would be
disposed.'' Does this mean disposed of in a landfill, incinerated; or
by some other means? Is the recycling infrastructure in the U.S.
sufficiently robust to handle the volume of used electronics generated
in this country?
EPA also states in its testimony that ``important
work is underway to ensure that these exports are managed
appropriately at their destination.'' What are the specifics of
this work and who is responsible?
Lastly, EPA's testimony describes the Cathode Ray
Tube (CRT) Export for Re-Use Notification Rule that went into
affect in January of 2007 and states that the ``new
requirements promise to ensure significantly better control
over CRTs exported for recycling.'' How much funding has EPA
requested for the oversight and enforcement of this rule, and
how much has been allocated, for FY 2007, FY 2008, and FY 2009
(requested)? How will this new rule ensure better control of
the export of CRT televisions and monitors? Will this rule be
expanded to cover other electronic devices, like computers,
cell phones, and flat panel displays?
A5. When we say that without export most electronics discarded in the
U.S. would be disposed, it refers to the limited U.S. markets for reuse
of this equipment, as well as for use of recycled raw materials in
manufacturing. Thus, without international markets, many of the efforts
currently underway in the U.S. to divert used electronics away from
disposal (land-filling and/or incineration) and toward reuse and
recycling could not be sustained.
Our study on electronics management in the U.S. estimates that
between 15-20 percent of used electronics collected in the U.S. are
reused or recycled--with much of this material exported as described
below. The remaining 80-85, percent are disposed of domestically. We
estimate that most of the disposal is in landfills, based on the fact
that the vast majority of waste disposed of in the U.S. is managed in
landfills, as opposed to incinerators or waste-to-energy facilities (80
percent land-filled, versus less than 20 percent in incinerators or WM
facilities).\5\ We hope that the amount of electronics destined for
reuse and recycling will grow as a percentage, but this will
necessarily mean that more electronics will be destined for reuse or
recycling abroad for the reasons discussed below.
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\5\ U.S. EPA, Office of Solid Waste. Electronics Waste Management
in the United States: Fact Sheet, Management of Electronic Waste in the
United States. April 2007. EPA530-R-07-004a. www.epa.gov/ecycling/
manage.htm
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The worldwide demand for used electronic equipment and components
is both very high and extensive. Many used electronic components are
marketed globally, with the highest demand in Asia, where these
components are often used in the production of refurbished or
remanufactured electronics. Although there are some U.S. markets for
used electronic components and whole equipment, these are limited
compared to export markets, where these materials generally have a much
higher value. U.S. consumers also are much less likely to purchase used
electronic goods than consumers in poorer countries.
Although hundreds of recyclers dismantle and process used
electronics in the U.S., the primary markets for many of the derived
materials are foreign ones. For example, because there no U.S. smelters
equipped to recover copper and precious metals from circuit boards, all
circuit boards must be exported. Likewise, all CRT glass furnaces are
outside the U.S., primarily in Asia. Thus, most CRT glass is exported
to glass manufacturing furnaces in Asia, where new CRTs are made using
recycled glass. Virtually all plastics derived from processing used
electronics in the U.S. are exported to Asia.
In general, the recycling infrastructure in the U.S. is adequate
for the preliminary processing of electronics (e.g., separating out
parts and some of the material streams, such as metals, plastics and
glass). Numerous recyclers have positioned themselves to provide even
greater U.S. processing capacity as an increasing number of state
recycling mandates take effect. However, many factors affect where
processing, and recycling will ultimately occur--that is, whether
certain stages of processing are performed in the U.S. or outside the
U.S. These factors include, among others, proximity to markets and
manufacturing, labor rates and regulation.
With regard to our statement that ``important work is underway to
ensure that these exports are managed appropriately at their
destination,'' we were referring to: 1) developing responsible recycler
practices; and 2) actively participating in international dialogues
focused on developing international guidelines for the sound management
of e-waste. We are also implementing the new CRT rule which is intended
to provide better control over CRTs exported for reuse and
recycling.\6\
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\6\ The new CRT rule requires exporters of CRTs for reuse to file a
one-time notification with EPA stating that they plan to export CRTs
for reuse. The rule also requires persons who export CRTs for reuse to
keep, for not less than three years, copies of business records
demonstrating that each shipment of exported CRTs will be reused. This
requirement provides U.S. regulatory authorities the opportunity to
inspect these records in order to verify that the CRTs were actually
sent to legitimate reuse or refurbishment entities. For export of CRTs
and unprocessed CRT glass for recycling (as opposed to reuse), the rule
requires both notification to EPA of the intended export and consent by
the receiving country.
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For implementation of the CRT rule, EPA's Office of Solid Waste
expended 0.4 FTE in FY 2007 and 0.3 FTE in FY 2008. We project a need
of 0.3 FTE in FY 2009. No extramural funds were used by OSW during this
time period. We do not have plans to expand the coverage of the CRT
rule to the export of other forms of used and scrap electronics. EPA's
Office of Enforcement and Compliance Assistance has not specifically
requested any funding for enforcement of the CRT rule and has no plans
to do so for 2009. As with other rules, this office will devote
resources as necessary to address identified cases of noncompliance,
but will not request resources specifically for that purpose.
To enable businesses and organizations to verify that electronic
recyclers are employing environmentally responsible practices, we are
working with stakeholders (i.e., states, manufacturers, recyclers,
trade associations and public interest groups) to develop an agreed
upon set of practices that can be used in a voluntary certification
program to assure responsible environmental performance by electronic
recyclers. Draft recycling guidelines have been reviewed by experienced
facility auditors, and field testing of these guidelines is now
underway. The draft certification guidelines place a great deal of
emphasis on ``downstream due diligence'' to assure that e-waste is
handled properly in the U.S., as well as outside the U.S., and
specifically address the need to ensure that exported equipment and
materials comply with the requirements of importing and transit
countries.
Also, as we mentioned in our testimony, we have led the development
of international guidelines on the sound use and recycling of personal
computers by the Organization for Economic Cooperation and Development
(OECD). We participated in a Basel Convention partnership effort with
industry that is developing guidelines for the safe reuse, recycling
and trans-boundary movement of used and scrap mobile phones. We are
also involved in the early stages of a similar Basel partnership
regarding personal computers. Finally, we are a participant in a
working group of international stakeholders of academia, trade
associations, industry and governments--called the StEP initiative--to
identify voluntary activities that promote sound reuse and safe
recycling, especially concerning the trans-boundary flows of
electronics.
Questions submitted by Representative Ralph M. Hall
Q1. How have electronics in the waste stream changed over the past
decade and what predictions can we make about changes in the coming
years? How do these changes affect our ability to safely and
efficiently recycle or reuse these devices?
A1. Over the past 10 years, both the quantity and composition of
electronics in the waste stream have changed dramatically. From 1997 to
2007, the number of TVs, computers, keyboards, hard copy devices, and
cell phones that Americans generate increased by 220 percent,\7\
although the percentage of end-of-life electronics compared to
municipal solid waste is still relatively low--less than two
percent.\8\ There have been many changes in the types of products
entering the market and subsequently the waste stream. Portable
computers now comprise over a quarter of the, computers generated for
end-of-life management, whereas a decade ago they were only beginning
to take a stronghold in the market.\9\ The number of cell phones that
were generated in 2007 increased by nearly 20 fold compared to
1997.7 Additionally, cell phones have continued to become
smaller and lighter. Flat screen monitors and TVs (featuring liquid
crystal displays or plasma screens) are displacing cathode ray tubes
(CRTs).7 Sales of flat panel TVs outstripped CRTs in
2007.7
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\7\ Preliminary results from our analysis Electronics Waste
Management in the United States: Approach 1. Updated May 2008.
\8\ U.S. EPA. Municipal Solid Waste Generation, Recycling and
Disposal in the United States: Facts and Figures for 2006. EPA-530-F-
07-030.
\9\ The new CRT rule requires exporters of CRTs for reuse to file a
one-time notification with EPA stating that they plan to export CRTs
for reuse. The rule also requires persons who export CRTs for reuse to
keep, for not less than three years, copies of business records
demonstrating that each shipment of exported CRTs will be reused. This
requirement provides U.S. regulatory authorities the opportunity to
inspect these records in order to verify that the CRTs were actually
sent to legitimate reuse or refurbishment entities. For export of CRTs
and unprocessed CRT glass for recycling (as opposed to reuse), the rule
requires both notification to EPA of the intended export and consent by
the receiving country.
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These changes in the composition of the electronics waste stream
have implications for recycling markets. For example, as more and more
CRTs are returned for recycling, but, fewer CRTs are produced, new
markets for leaded CRT glass will be needed. While there continue to be
markets for reusable/refurbishable CRTs and CRT glass in developing
countries (where CRT glass recycling capability is available), this
will only last until the markets in those locales change too. Then,
alternative uses for CRT glass will be necessary, as old CRTs will
still be disposed of even after new CRTs are no longer made.
Some of the newer products entering the market are smaller and
serve multi-functions. For example, the new cell phones are lighter and
more compact than earlier models, reducing the amount of packaging and
the number of trucks needed to transport the finished product. On the
other hand, some new products are significantly larger, such as new TVs
which are significantly larger than the TVs they are replacing,
suggesting that there will be more material to manage when these
products reach the end of their useful life. There has been relatively
little focus on how to recycle these new products (e.g., LCDs and
plasma screens), suggesting a need for more information on how to
manage these products properly.
It also is likely that rapid innovation and product convergence
will continue. Many ``stand-alone'' products, such as PDAs, cell
phones, MP3 players, and digital cameras, are merging into single
multi-function products, in some cases rendering the single function
products less desirable, although there still seem to be markets for
stand-alone products. Many products will be capable of doing more in
smaller sizes. As a result, they will be made of less material that
needs recycling. Recyclers will be faced with continually changing
streams of materials and configurations to deal with.
Worldwide, there has been increasing pressure for the electronics
industry to adhere to stricter materials restrictions, such as the
Reduction of Hazardous Substances (RoHS) Directive in the European
Union, California's version of RoHS and EPEAT (which incorporates the
RoHS requirements into its standards). New generations of electronics
(including TVs, computers and mobile phones/PDAs) are being designed to
meet these requirements through use of fewer toxic inputs and greater
use of recyclable materials. These requirements will reduce certain
substances of concern and substitute new constituents and materials not
used before in electronics. More research will be needed on new
constituents and additives to replace banned substances to make sure
that the substitutes will both ensure product performance integrity
without introducing new environmental problems.
Demand is increasing on the part of the electronics industry for
more secondary materials (e.g., plastics, metals) to use in new
products. However, bans on certain chemicals and constituents in
electronics are making it harder to do this. This is because many
materials recovered from older electronics contain banned constituents
(e.g., plastics impregnated with certain brominated flame retardants,
lead). As a result, new sources of secondary materials will be needed
for the electronics industry as well as ways to remove banned
substances from the materials currently being recovered from
electronics so that they can be used in the manufacture of new
electronics.
Finally, as electronic products continue to change and evolve, it
will be necessary to support continuing research on how to make
recycling of these products more cost-effective and safe. Research will
be necessary on how best to design products to facilitate dismantling,
how to identify toxic components for separation and safe processing, as
well as methods to minimize worker exposures during recycling.
Q2. Dr. Williams suggests that some take-back programs have an adverse
effect on reuse. Do you agree with this assessment? What effect does
EPA see on reuse of commodities like cell phones due to the increase in
take-back campaigns?
A2. Generally speaking, reuse occurs for products that have a reuse
market. The strength of the reuse market depends on a number of
factors, such as the quality and age of the product in question and
demand for the product. For example, there is a strong reuse market for
working CRT tubes to be used intact in new TVs or computer monitors in
developing country markets, where consumers cannot afford the newer
flat panel screens. EPA's Office of Solid Waste estimates CRTs that can
be reused or refurbished are worth $4-$10 apiece. In addition, there is
a strong demand for working CPUs in these same regions. However, as
prices for shipping a container to China rise dramatically (up from
$400 in 2004 to $1,850 as estimated by American Retroworks, Inc.),
exports of electronics need to be valuable enough to cover this cost,
meaning that products sent abroad are more likely now to be reusable or
refurbishable or mined for working parts. This means that most
recyclers (with the exception of recyclers that shred exclusively) have
incorporated reuse into their business model. There is a whole
community of ``refurbishers'' whose business model is based on reuse of
the electronic equipment.
Another example is cell phones, which currently has a strong reuse
market. While some manufacturers of cell phones do not include reuse in
their take-back programs (due to competition from used equipment and
concerns about the standards used for ``refurbishing'' phones affecting
their reputation), most cell phone retailers, carriers, and private
recyclers, as well as charities, schools and other public interest
organizations have a strong reuse component in their take-back
programs. This is because there is still a greater economic return for
resale of used phones than can be earned from recycling them. Even
companies that do not resell or refurbish recovered phones, are likely
to break-down the phone into its parts and recover items, such as LCD
screens, speakers, and other parts that are in good working order.
It is true that some take-back programs have had the effect of
discouraging or preventing reuse of some kinds of products. One example
has been seen in California, not because the State's law explicitly
requires recycling over reuse, but because California offers
electronics recyclers a per-pound reimbursement for recycling covered
electronics. This gives recyclers a choice: if they can earn more by
selling discarded products for reuse, they will. Conversely, if they
can earn more by recycling and claiming reimbursement from the State,
they will. For a time, the recycling value paid by the state exceeded
the reuse value of certain products. California recently reduced its
reimbursement rate to processors who recycle, so sale for reuse may
become more attractive for some products. Some voluntary manufacturer
take-back programs for IT equipment do not focus on reuse, emphasizing
instead parts recovery or recycling over reuse or refurbishment of the
product. At least one manufacturer, Dell, however, has incorporated a
strong reuse component into all of its voluntary take-back programs--
both in their consumer take-back program and their partnership with
GoodWill. In Dell's recycling programs, they have determined that the
amount of material that goes to reuse (both whole equipment and parts)
versus the amount of material that goes to recycling stays constant,
indicating that reuse is still a viable part of their program.
Q3. What are the most difficult components to safely and cost-
effectively recycle? Other witnesses have raised plastics, mercury
lamps, and lead content as having the potential to negatively affect
environmental and public health. What is the state-of-the-art for
recycling or reuse of these items?
A3. There are two different questions here: whether it is possible to
cost-effectively recycle electronics and whether it is possible to
safely recycle electronics.
As to cost-effectiveness, it is possible to recycle many computers
cost-effectively. Many used IT products (especially those of more
recent vintage) can be resold as is or refurbished, at a profit (e.g.,
CRTs, CPUs). For those that cannot, there is often positive value in
these products in the way of parts (e.g., circuit boards and disk
drives) and recyclable materials. But there is a cost to collecting and
transporting these products to recycling facilities. Sometimes the
resale value of the products or the value of the materials in the
product covers the collection and transportation costs (especially in
the case of smaller, newer products such as laptops); sometimes it does
not (e.g., with larger or older products, such as desktop computers).
This is why some manufacturers and retailers that offer take-back
programs sometimes charge a fee for some IT products.
TVs are just the opposite. It takes more labor to dismantle TVs
than is earned from the materials recovered. Because TVs are a net
negative cost to recycle, many collection programs (outside of those in
states that mandate a point of purchase fee or manufacturer
responsibility for used electronics) charge consumers a price to manage
discarded TVs. Also, TVs depreciate as they age. The average PC monitor
brought in for recycling is about 10-15 years newer than the average TV
brought in for recycling. However, the average age of TVs brought in
for recycling is starting to decline as hotels and many Americans start
trading-up to flat screen models. At the same time, the average weight
of these TVs is going up (reflecting the larger TVs purchased over the
years) and this adds to the cost of managing them. The weight of TVs
may drop again over time as thinner ``flat'' screens displace CRTs and
large projection TVs.
Regarding safety issues in recycling electronics, many smaller
products, such as cell phones, PDAs, bluetooths and cameras, contain
batteries that may cause problems in recycling unless they can be
readily located and removed. Some digital cameras contain mercury lamps
that are time consuming to locate and remove. Failure to remove these
items can contaminate the material stream if these products are crushed
or shredded, creating the risk of employee or environmental exposure,
as well as significantly reducing the re-sale value of the resulting
materials.
Looking forward, several factors will affect how safely and cost-
effectively electronics will be recycled. These factors include: 1)
amount of electronics available for recycling; 2) innovations in
recycling technology; 3) the degree to which products are designed to
be more readily recyclable; and 4) the development of markets for
materials that cannot be readily used in the making of new electronics.
Due to State take-back requirements and the expanding use of voluntary
industry take-back options, the volume of electronic material for
recycling has increased. As the volume increases, economies of scale in
collection, transportation and processing will reduce costs. New
technologies are being developed that will make it easier and more
lucrative to process older electronics moving through the system. New
methods to quickly and safely dismantle CRTs are now being
demonstrated; technologies for improving the recognition and
segregation of the multiple plastics used in electronics are starting
to improve. While more research is needed to perfect these new
technologies, these improvements will increase the speed with which
products can be processed and improve the end-markets for the materials
recovered.
Also, newer electronics are increasingly designed for recycling as
a result of EPEAT, green design innovations by manufacturers, and EU
mandates. For example, manufacturers are looking at ways to identify
where toxic components are located inside products and make it easier
to remove them. They are also looking for ways to mark various
materials (e.g., plastics) so that they can be quickly identified and
separated in the recycling process, leading to more consistent and
valuable material streams. EPA recently approved a grant for the Green
Electronics Council to work with recyclers to recommend design changes
to an array of electronics that will facilitate faster and safer
recycling.
New markets for certain materials recovered in the recycling
process may be necessary to help electronics recycling succeed
economically. One example is CRT glass. While CRT glass can be used in
lead smelting as a fluxing agent (and there is worldwide capacity for
this use), there are also markets for CRT glass in Asia to make new
CRTs. As CRTs are gradually replaced by other screen technologies,
these glass-to-glass markets will decline and so other leaded glass
markets would be good to identify. The same will be true for LCDs and
plasma screens that may be supplanted by other technologies.
It also is likely that many newer electronic products will contain
less of the high value metals (precious and otherwise) that typified
the earlier generations of these products. This will mean that the
value to be recovered from these products will decline, unless the
value of materials in electronics increases. This is particularly true
of computers and TVs. Older computers, like those in the early '90s,
were larger and with more copper wiring and steel casing (steel casing
in the support banding of the CRT in TVs and CPUs). Now CPU casing is
made primarily from plastics. Computers and TV housings are now
smaller, with less metal content and snore plastics. Additionally, in
some cases, copper wiring is being replaced by fiber optic.
How these two conflicting trends (lower cost of recycling vs. lower
inherent value in electronics for recovery), will affect the overall
cost-effectiveness of electronics recycling is hard to predict.
However, as long as the costs of recycling continue to decline and the
value of materials and the ability to find markets for materials that
are recovered improves (as a result of better technologies for
separation (e.g., plastics) and new market applications for materials
that need them (e.g., CRT glass), the economic outlook for recycling of
electronics should improve.
With respect to the state-of-the-art recycling methods for
plastics, mercury lamps, and lead, the following describes those
methodologies that are currently used:
Recycling of mercury-containing devices, such as
mercury lamps, occurs in a number of U.S. facilities. The
process they follow includes recycling the glass and aluminum
end caps, and recovering the mercury through retorting. The
mercury is then used in the manufacture of new products.
Lead has two primary uses in consumer electronics:
(1) it is used in CRTs to prevent consumer exposure to harmful
x-rays, and (2) its use in solder used in electronic circuitry.
State-of-the-art reuse and recycling of CRTs is (1)
reuse of the CRT for its original function--that is as
a video display device, (2) recycling of scrap CRT
glass for the purpose of producing new CRTs in a CRT
manufacturing furnace (glass to glass furnace), and (3)
placement of CRTs and CRT glass in a lead smelter. In a
lead smelter, not only is the lead recovered for reuse,
but the glass serves as a flux that is useful to the
smelting process.
State-of-the-art for the recycling of circuit boards
is placement in a smelter to recover copper and
precious metals. Depending upon the particular smelter,
the lead may also be recovered or it will remain in the
smelter slag, which is land-filled.
Plastics from electronics are also recovered and
recycled, often involving hand separation of plastic types,
removal of contaminants, pelletization and then use in
manufacturing new plastic products. Although a great deal of
research has been conducted on methods for mechanical sorting
of mixed plastics, it is not clear that such methods have been
perfected to the point of being viable on a commercial scale.
Q4. There have been claims in the testimony that most electronics
recycling in the U.S. is collected for export to countries with less
stringent environmental safety laws. Is there truth to this claim and
if not where does the e-waste in other countries come from?
A4. As discussed above, most used and scrap electronics are exported
for reuse or recycling abroad, either intact, or as parts or as pre-
processed materials that can be used directly in the manufacture of new
products. The U.S., like other developed countries, operates in a
global market where much of our electronic material is recycled in
other countries based on economic drivers. Thus, Western Europe, Japan,
South Korea, Australia and Canada all have exports of used and scrap
electronics for reuse and recycling. These exports often go to the same
locations as exports from the U.S.
Used electronics are exported to many countries for the purpose of
recycling, not just developing countries with less stringent
environmental laws. Currently, the primary destinations for these
materials are Canada, Belgium, Sweden, Japan, Mexico and various Asian
countries, including China, India and Malaysia. Electronic circuitry is
exported to smelters in Canada, Belgium, Sweden and Japan for copper
and precious metals recovery. Materials for copper recovery are also
exported to China. Plastics are largely sent to Asian recycling
facilities, particularly China. Glass from cathode ray tubes is
exported to Canada for lead smelting, Mexico for processing prior to
shipment to Asian glass furnaces, and CRT glass furnaces in India and
Malaysia. Whole used electronics are also exported for dismantling or
refurbishment or remanufacturing in Canada, Mexico, and a number of
Asian countries. EPA is aware that not all of these exports result in
environmentally sound management. Since global markets are essential to
sustainable and sound management of e-waste, the key is to continue to
work towards assuring that management of e-waste is protective of human
health and the environment wherever it takes place. We are committed to
continuing our ongoing efforts in this regard.
Q5. Does the EPA collect statistics on recycling by individual
manufacturers? Do you know what the average recycle rate of
manufacturers is in the U.S. for the following products: CRT monitors,
televisions, computers, car batteries, and cell phones?
A5. No, we do not have information to determine an average manufacturer
recycling rate, but we do have information on the national recycling
rate of select electronic products. In the U.S., computer products and
TVs are recycled at a rate of approximately 18 percent. For cell
phones, we have published a recycling rate of less than 20 percent, but
based on recent analyses believe it closer to 10 percent.\10\
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\10\ Preliminary results from our analysis Electronics Waste
Management in the United States: Approach 1. Updated May 2008.
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Through the Plug-In To eCycling Program, which includes electronic
manufacturers and retailers, partners inform EPA of their recycling
activities. Often times the recycling data that partners provide is a
total summation of their voluntary recycling efforts and it is not
broken down by product.
With respect to car batteries, they typically are managed in
programs separate from those designed for collection of consumer
electronics. In 2006, lead-acid car batteries were recycled at a rate
of 99 percent.\11\
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\11\ U.S. EPA. Municipal Solid Waste Generation, Recycling and
Disposal in the United States: Facts and Figures for 2006. EPA-530-F-
07-030.
Q6. How many products require refurbishment before they can be reused?
Where does refurbishment typically take place and are refurbished goods
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subject to, different trade standards?
A6. We are not able to say how many products require refurbishment
before they can be reused. However, products which typically undergo
some degree of refurbishment are those for which there is a reuse or
resale market. This includes late model computers, laptops, and CRTs
(either computer or TV CRTs) which can be used in new computers and TVs
(typically for sale in developing countries where the market for newer
monitor technologies is limited), and cell phones.
Refurbishment typically takes place at the recycler, with
refurbishment of all electronic equipment being done both domestically
and abroad. Refurbished or remanufactured electronic goods are not
subject to trade standards (i.e., refurbishing process standards).
They are, however, subject to general FTC standards which require
them to be labeled and marketed as refurbished/remanufactured to
prevent deceptive practices. Consequently, electronic recyclers have
developed their own individual policies for (1) what used equipment can
be refurbished or remanufactured; and (2) to what level they will be
refurbished (sometimes in conjunction with manufacturers and carriers).
There is a broad spectrum of recycling programs established across
the United States. Recycling programs may incorporate reuse and or
refurbishment to different levels. Specifically, recyclers may:
Set no criteria, other than reuse or refurbish all
collected material that has a viable resale market.
Set minimum criteria. Criteria may be set with regard
to functionality, cosmetics or age of the equipment. Companies
have also set criteria based on the ability, or ease of
clearing personal data. Any or all of these criteria could be
part of a recyclers refurbishing policy.
Set very strict criteria. Some manufacturers and
network carriers in both the PC and cellular industry have set
strict standards (called factory refurbishment standards) for
what is required for use in warranty exchange. These standards
address both the cosmetic and the functional condition.
Industry sources state that a large percentage of cell phones
that are retired when consumers upgrade to new devices are
fully functional and require no repair. However, these phones
would require cosmetic renewal to meet the strict warranty
exchange requirements.
Engage in no refurbishment or reuse at all. Under
this model, all material goes directly to material recovery,
often shredding. Some of the original electronic manufacturers
have programs in this category as they express concerns with
competition from used equipment and the ``standards'' used for
refurbishing phones affecting their reputation.
[GRAPHIC(S) NOT AVAILABLE IN TIFF FORMAT]
Attachment B
List of stakeholders from the U.S. Environmental Protection Agency
Design for the Environment (DfE) Partnerships
Industry
Acer in cooperation with ITRI (Industrial Technology
Research Institute)
Agilent
Albemarle
Alcatel Telecom
AlphaGary
Alpha Metals
Apple Computer, Inc.
Chemtura
Cable Components Group
Celestica, Inc.
Chemson
Ciba Specialty Chemicals
Clariant
CommScope
Cookson Electronics
Corning Asahi
Daikin America
Dell Computer
Delphi Delco
Display Device Consultants
Display Search
The Dow Chemical Company
DuPont
Dynamic Details, Inc.
Eastman Kodak Company
Electronic Industries Alliance
Ecolibrium
Electrochemicals, Inc.
Enthone-Polyclad Technologies
Ferro Corporation
Florida CirTech
Fujitsu Siemens Computers
GE Power Systems
Georgia Gulf
HDP User Group International, Inc. (High Density
Packaging)
HFFREC (The Halogen-Free Flame Retardants Electronics
Consortium)
Hitachi Chemical Company America, Ltd.
HP (Hewlett-Packard Company)
IBM
ICL Industrial Products
Intel
Isola
ITEQ Corporation
ITI (Information Technology Industry Council)
Judd Wire
Lenovo
Manitoba Corporation
MacDermid, Inc.
Matsushita Electronic Corporation of America
McGean-Rohco, Inc.
METSS Corp.
Motorola, Inc.
Nabaltec AG
Nan Ya Plastics
Nokia
Ormet Corporation
Panasonic
PE International
Phibro-Tech Inc.
Philips Consumer Electronics
Pitney Bowes
Polaroid Corporation
Princeton University Center for Energy &
Environmental Studies
PWB Interconnect Solutions, Inc.
Raytheon Systems Co.
Rockwell Collins
Rockwell International Corp.
Sematech
Sharp Electronics Corporation
Sony Electronics Inc.
Southwest Technology Consultants
Southwire Company
Substrate Technologies Inc.
Sud-Chemie
Superior Essex
Supresta
Technic, Inc.
Teknor Apex
Teradyne Inc.
Thomson Multimedia
Tyco Printed Circuit Group, LP
United Copper Industries
Universal Circuits Inc.
Associations and Consortiums
BSEF (The Bromine Science and Environmental Forum)
Electronic Industries Alliance, IPC--Association
Connecting Electronics Industries (printed circuit board trade
association)
iNEMI (International Electronics Manufacturing
Initiative)
National Electrical Manufacturers Associations (NEMA)
Society of the Plastics Industry
U.S. Display Consortium
Vinyl Institute of the American Plastics Council
Environmental Groups
Clean Production Action
Communities for a Better Environment
GreenBlue
Greenpeace
Silicon Valley Toxics Coalition
Universities and Other Organizations
City of San Jose Environmental Services
Contamination Studies Laboratory
Georgia Institute of Technology Materials Science &
Engineering
Minnesota Office of Environmental Assistance
NJ Institute of Technology
Purdue University
The Swedish Institute for Fibre and Polymer Research
(IFP Research) in cooperation with KemI
The SemiCycle Foundation
Underwriter's Laboratories
University of Massachusetts Toxics Use Reduction
Institute
University of Tennessee--Center for Clean Products
and Clean Technologies
University of Michigan School of Natural Resources &
the Environment
U.S. Navy