The Federal EPA is rapidly moving towards
the re-classification of computer equipment as "universal
waste". Computer waste has become a significant polluter
of our landfills. There is no single environmental issue
that has created more state legislative activity over the
past two years than electronic recycling.
Universal waste is a form of hazardous
waste. To be a universal waste, an item must be first classified
a hazardous waste and it must exist both in the private
and commercial sector in the same form.
Examples of universal wastes are: batteries, thermostats
containing mercury, florescent lights, and pesticides. The
purpose of the universal waste designation is to promote
the recycling of the particular item. The universal waste
designation significantly reduces the paper work documentation
versus a hazardous waste classification. (unlike hazardous
waste, shipping manifests are not required to accompany
the movements of universal waste) It reduces the cost of
transporting the product by allowing universal waste to
be transported by common carrier trucks rather than specially
licensed (and expensive) hazardous waste haulers. It also
exempts individuals and small business (identified as a
small quantity generator) from the liabilities (but not
the regulations themselves) associated to improper disposal.
Under universal waste regulations most
mid size and large organizations will be designated "small
quantity universal waste handlers" This designation
differs from the small quantity generator exemption definition
and is subject to the regulation's liabilities ($2000.00
fine per violation). The definition of this category covers
an organization that accumulates more than 100 kilograms
(220 pounds,about 8 monitors or CPUs) of universal waste
at one time, but does not accumulate more than 5000 kilograms
(11,000 pounds, about 350 monitor or CPUs) of universal
waste at one time at one location. Organizations that exceed
this limit are identified as "large quantity universal
waste handlers" and must register with both the State
DEP and Federal EPA.
State legislatures and DEPs have taken
the lead on this issue. There are currently 26 States that
have either adopted or are in the process of adopting regulations
governing the disposal of consumer electronics. Landfill
bans on CRTs are one of the most common regulations with
MA, ME, MI, WI, and CA all having adopted this regulation.
Federal EPA: The Federal
EPA is currently evaluating a change in CRT disposal regulations.
The EPA is evaluating the removal of CRTs from the solid
waste category, thus, in theory, easing the ability to recycle
the product. This relaxing of EPA control over the disposal
process is being criticized by environmental groups as a
step backwards. Several states have submitted comments recommending
that CRTs be classified as a universal waste. What ever
the case, any new regulations would not be adopted before
2005. The Federal EPA currently classifies cathode ray tubes
(CRTs) found in computer monitors and televisions as a hazardous
waste. This classification is based upon the high concentration
of lead found in all cathode ray tubes. The Federal EPA's
position on the disposal of CRTs found in both computer
monitors and televisions are as follows:
Households: Used computer
monitors or televisions generated by households are not
considered hazardous waste and are not regulated under federal
Donations or Resale: Monitors or televisions
sent for continued use (i.e., resold or donated) are not
considered hazardous waste.
Small Quantities Exempt: Businesses or
other organizations are not regulated under most federal
requirements if the facility discards less than 100 kilograms
(about 220 lbs or 8 monitors) of hazardous waste per month.
(this waste must still go to facilities authorized to receive
Ohio follows RCRA standards for electronics.
Under Ohio’s provisions, computer CRTs are not regulated
as hazardous wastes if the generator has them recycled.
The state considers discarded integrated circuits from computer
systems to be scrap metal. Scrap metal is not regulated
as hazardous waste if it is reclaimed or recycled.
Ohio EPA classifies used electronic equipment
exhibiting a characteristic of a hazardous waste as a characteristic
by-product when it is recycled. Unused, defective computers
and electronic equipment are defined as commercial products.
Computers and electronic equipment may exhibit the characteristic
of toxicity as defined in the Ohio Administrative Code (OAC)
rule. This rule indicates that characteristic by-products
and commercial products that are reclaimed are not wastes.
In Ohio, refurbished computer equipment
is not considered a waste because it is still in commerce.
However, any generator of discarded components must evaluate
these for the characteristics of a hazardous waste according
to the OAC rule.
U.S. Environmental Protection Agency
Ohio Environmental Protection Agency
Hazardous Waste Management Standards