The Missing Pieces of a Comprehensive E-Waste Recycling System
With upcoming e-waste regulations and news coverage, many are likely asking: “Is my e-waste program in good standing?” And lately, to further confuse the regulatory environment, many inconsistent e-waste/hazardous waste legal matters have surfaced. The most recent involves a Mexican CRT processor. The closure of this facility had SB 20 recyclers, governed by the Electronic Waste Recycling Act, scrambling to find a local CRT recycler. Without SB 20 CRT glass processors, there’s a hold on the state’s fee payment.
This situation at a macro view realizes the state-run program has most of what is necessary to recycle covered e-waste display devices. However, what is lacking is the SB 20 monitor recycling program, which amounts to little more than a collection, dismantling and (sadly) an export program filled with pitfalls. The facility that once was supported my SB 20 work now retract their positions.
This is just crazy. Instead of working out something to put the facility in administrative and facility compliance, it was shut down. I heard through one SB 20 recycler that it may reopen soon. Realistically, some CRT e-waste recycling issues will subside, as the legacy diminishes. But some will remain, as new recycling issues surface with flat-screen technology.
In my view, before beginning state(citizen)-funded or OEM-funded recycling programs or running collections, state administrators should ensure these processes are in place for a comprehensive and successful e-waste recycling program:
1. Manual de-assembly
2. Remove none of the non shred items, such as devices containing mercury and or lead circuit cards
3. Allow circuit card processing if under controlled and regulated conditions
4. Material size reduction and magnetic separation system
5. Advanced material separation equipment
6. Fluff-removal system
7. Pure process/treatment output (product) material streams
8. Aluminum smelter
9. Lead smelter
10. Stainless mill
11. Steel mills
12. Brass/copper foundry
13. Wire choppers
14. Plastic mold injectors
15. Mercury retort treatment
16. Precious metal smelter
17. Process by-product solid waste hazardous waste landfills
18. Process emissions and/or effluents quantification and controls
From experience, I can say that not one company performs all of these processes, and fewer than three processes exist with quality output resources in the U.S. After all, converting e-waste into direct reuse metals and polymers resources that a U.S. processor can use to remanufacture into other products is not an easy task.
Many say the U.S doesn’t have the infrastructure to address our e-waste crisis. But we do, and there’s hope. Actually, we currently have all of the above items in place, with the exception of numbers 3-5. The U.S has the majority of the necessary processes.
Unfortunately, most e-waste non-ferrous material is smelted outside the U.S., for reasons of non-U.S. quality conforming, co-mingled shredded e-waste. These are the types of shredded e-waste that will increase air pollution, and thus are illegal to smelt in the U.S. Therefore, it passed on as co-mingled, shredded e-waste product to the next process point outside the U.S., where in most cases there is little pollution regulation.
There are many benefits to working with reputable e-waste recycling/treatment companies. But understanding the requirements in attaining true e-waste-to-resource conversion is tricky; this is especially true if you’re not familiar with the entire e-waste treatment sequence, procedure and scrap categories.
Will the U.S. ever get serious about putting into place those last few missing elements of a truly comprehensive e-waste recycling system? We can only hope it will.
For additional information on regulations governing the management and retirement of electronic equipment, including e-waste, data security and Sarbanes-Oxley laws, I welcome you to visit our website at www.redemtech.com/regulatory.

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