Agencies can't give away their responsibility for proper disposal

As the only winner of the Gold Partnership award from the Environmental Protection Agency and the Federal Electronics Challenge for its e-cycling and peer-mentoring programs, the Bonneville Power Administration is considered a model and mentor for other agencies trying to improve their technology recycling programs.

The Portland, Ore., organization, an agency of the Energy Department, estimates that it safely disposes of its equipment for $4 per pound'90 percent of which covers labor and packaging costs.

The remaining 10 percent of the costs go for transportation and for recycling and disposal fees, according to Steve Sander, a Bonneville senior environmental scientist.

Cradle to grave

E-cycling is part of Bonneville's comprehensive asset-management strategy, which involves assigning a unique tracking number to every device so it can be followed from the day it arrives to its final resting place in the waste stream.

'They really need to know where this stuff is going,' Sander said. 'It's not good enough to just hire someone and say, 'Here, make this go away.' '

To dispose of its e-waste, Bonneville officials selected a high-tech shredding facility in Arizona, to reduce transportation costs.

'We were only interested in facilities that were going to do a certified destruction of equipment,' Sander said, adding that, for security reasons, Energy requires physical destruction of hard drives rather than the data-erasing process called degaussing.

Bonneville officials also were impressed with the facility because it did almost no landfilling, save for its own office waste, or overseas shipping, which some other West Coast brokers are known to do. This means they sometimes ship unprocessed machines to foreign countries, where the machines' data could be compromised or the equipment mishandled, causing environmental problems, Sander said.

Before choosing a recycling vendor, Sander said, an agency must ensure its e-waste is properly handled, by visiting or auditing the recycling or disposal site to verify compliance with regulations on how the hardware is broken down, resold or passed on to another facility.

Even if a facility meets federal regulations, agencies still may face additional state and local rules.

Bonneville, for example, could be fined by Oregon if it stores waste for more than six months, said Annette Guarriello, a Bonneville program analyst.

Sander said agencies should check whether a prospective disposal facility has the required state and EPA permits, and check references.

Despite this focus on proper recycling and waste-disposal practices, officials at EPA and model agencies, including Bonneville, emphasized the importance of having a broader lifecycle strategy to reduce the disposal rate of PCs and other equipment.

Having a program for donating equipment to schools and charities can help, as can an upgrade strategy that keeps PCs on desktops longer, experts say.

But Bonneville officials said they eliminated their donation program because the agency still would be responsible for taking back the equipment and disposing of it, or providing technical support to the recipient.

'We made the decision to keep the equipment longer,' adding two years to the previous three-year policy, then disposing of the equipment as they would have had to do anyway, Sander said.

Choose your poison

Bonneville officials also are getting a better handle on their e-waste by reorienting its purchasing toward equipment containing hazardous wastes it is already set up to dispose of most economically and safely.

Guarriello said, for example, that Bonneville expects to save $150 per monitor by buying flat-panel LCDs, which contain a small mercury fluorescent tube that can be easily removed and recycled, instead of CRTs with several pounds of leaded glass.

The strategy isn't easy to implement, though.

'The hardest part is the purchasing, because the buyers are not at all acquainted with the back-end, end-of-life issues,' Guarriello said.

Guarriello and Sander agreed that e-cycling needs support from state and federal laws.

'There has to be a level of expectation that everybody meets, such as no landfilling,' Guarriello said.

Other ideas include adding advance recovery fees that are charged at the point of sale to fund disposal, or placing hazardous-waste labels on equipment to better warn owners of their liability.

Agencies also must do more to address other electronic devices with security and waste issues of their own, such as cell phones, photocopiers and handheld computers, they said.

Bonneville officials said the law is clear: Individual agencies are responsible for identifying the hazardous waste in their electronic equipment and ensuring its proper recycling or disposal.

'You can't contract that responsibility away to someone else, or even assume that another government agency is going to do the right thing and thereby protect your liability,' Sander said. 'You, as the generator [of waste], must determine if a piece of equipment is hazardous and handle it appropriately.'

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