21 Data is provided by Cheryl Lofrano Zaske, Principal Planning Analyst, Problem Materials Program, Department of Public Works, Hennepin County Minnesota. 22 Mining discarded electronics. H. Veldhuizen and B. Sippel. Industry and Environment. Volume 17, No. 3. JulySeptember 1994, pp 9. page 53 Arsenic Not analyzed 0.02 to 0.03% Cadmium Not analyzed Less than 0.01%

Other materials not found on circuit boards, such as copper wire or aluminum parts, also yield high revenues per pound. Under current market conditions, metals and electrical parts yield the best revenue from scrap. Based on this information, a demanufacturer needs to collect computers (containing metal parts, circuit boards, chips, and electrical parts) to gain the maximum revenue from demanufactured equipment.

All of the collection programs that were profiled focused on collecting this type of equipment.

Commodity Yield The amount of the commodity that is extracted is also affected by the type and volume of the inflow of equipment, so the greater the participation, the greater the inflow, and the greater the volume of extracted material (assuming that demanufacturing efficiency stays constant). Therefore, one way for a demanufacturer to increase its profit is to work with the collection agency to promote the collection of equipment that is economically valuable from a commodity standpoint– computers and other commercial grade electronics.

The quality of the items that are collected greatly affects what commodities are extracted. A computer in bad condition will yield less revenue for its components than a similar computer in very good condition. A hypothesis that came from the Binghamton/ Somerville report was that, as most of the older equipment is collected and leaves the residents' households, the collection events would start to take in newer equipment. This assumption has merit considering the inexpensive and disposable nature of most of today's technology. Continuing the assumption, this would mean that as time goes by, more high grade material would be available for potential reuse, leading to higher revenues. While the validity of this scenario is unknown, there are some points that contradict this:

· There seems to be a lag time associated with the disposal of equipment. It is IMPROVING DEMANUFACTURING Recent studies in Japan have examined the amount of work required to disassemble electronic products. The results show that most of the improvement burden is on the OEM. For example, for PCs, the time required can be lowered by reducing the number of inter connections, and by making fastenings, particularly screws, more easily accessible. Of course, the impact of these modifications will only have a long term impact since these case studies have indicated that most electronic or electrical equipment is discarded when it is very old.

Also in Japan, steps have been taken to automate demanufacturing. In March of 1996 Sony constructed a pilot plant for the automated dismantling of TV sets. The $4 million plant was designed to handle around 100,000 TVs (from between 12 and 29 inches in size) a year. The size of the TV is determined using a video camera, and a circular saw makes cuts in the front and sides of the cabinet. The CRT is then dismantled using automated procedures. While no exact data is available on the cost of this system, the evidence suggests that the expense of the process outweighs its value.

SOURCE: Recovery of Waste from Electrical and Electronic Equipment: Economic and Environmental Impacts, A report produced for the European Commission DGXI, AEA Technology, AEAT/ 2004 Issue 1, July 1997. page 54 logical to assume that if residents are now turning in 286 series computers or analog stereo equipment (items that are at least 10 years old) the lag in the disposal of today's Pentiums or digital VCRs would at least parallel this.

· In response to the concerns of consumers, OEMs are evaluating making computers that are easier to upgrade, which could minimize the need to buy a new computer (and dispose of the older one).

· Much of today's equipment is made with fewer precious metal components as companies try to reduce their production costs. This will lead to a smaller amount of valuable scrap material once the item is recycled.

The amount of revenue generated from the sale of commodities is dependent on the yield of revenue per commodity. To maximize this yield, the quality of the collected material must be high, the demanufacturing process must be at its optimum level, and the materials collected must contain commodities that have high market values. A collection agency can only directly affect the latter, and ELECTRONICS RECYCLING IN EUROPE AND JAPAN Before the 1990s in Europe, the main items that were dismantled were mainframe computers for which the primary environmental concerns were relays and switches containing mercury. Items currently being disposed of contain lower concentrations of precious metals, but higher concentrations of other elements of concern, notably leaded glass from CRTs. This has lead to a change in the demanufacturing scheme: whereas originally demanufacturers paid companies for old mainframes, now companies must pay the demanufacturers to take the equipment.

The general practice in Europe is to first remove any hazardous components from the discarded equipment, such as batteries, mercury switches, and capacitors containing PCBs. Most items are then dismantled into components, one exception being products such as hi fi equipment, which demanufacturers consider not economical for dismantling. These products are usually shredded, with metal and plastics then recovered from the shredded product.

The equipment is dismantled into four main components: metal, plastics, CRTs, and printed circuit boards. Some components are recovered for reuse. Hazardous components are sent to treatment facilities. Metal is sent to metal processors for recovery.

Circuit boards are generally sent to a copper refiner, who is able to deal with brominated flameretardants in the circuit boards. The price paid to the smelter per board depends on their copper and precious metal contents. Shredding before smelting enables recovery of the steel and aluminum in the boards, but also distributes the precious metals between the two streams.

A technique being developed in Japan by NEC would first heat the circuit board to a temperature at which the solder melts, after which the components would be mechanically removed. The circuit board is then shredded and separated into glass fiber and copper. Whether this method is economically viable is not yet known.

SOURCE: Recovery of Waste from Electrical and Electronic Equipment: Economic and Environmental Impacts, A report produced for the European Commission DGXI, AEA Technology, AEAT/ 2004 Issue 1, July 1997. page 55 should focus its efforts on promoting the collection of economically valuable items while also evaluating relevant environmental impacts.

<IP_ADDRESS> Demanufacturing Fee A demanufacturing fee is charged of the collection agency running the program in order to cover the demanufacturer's disassembly costs. None of the collection pilots indicated that the participating demanufacturer charged a fee to cover the costs of its services. This is due to the fact that most of the programs were pilots, in which the demanufacturer provided in kind services. In Hennepin County, no demanufacturing fee was charged because the county is the demanufacturer. However, it seems logical that a demanufacturer would assess a fee over the long term since in kind services are not economically feasible for a demanufacturer. This fee would be a function of the amount of equipment taken in and the estimated revenue share and associated costs that could be obtained from that equipment. It is possible that, as the yield from the collected equipment increases and the demanufacturer begins to offset its costs, this fee could decrease over time.

5.3 THE COLLECTION AGENCY Costs related to the setup, operation, and maintenance of an EEE waste collection program can vary, depending on the type of collection model that is in place. Most of these varying costs are directly incurred by the collection agency. For the collection agency, the program cost and demanufacturing fee appear to be the elements most affecting the net economics of their program. A user fee for service can also be evaluated on a site specific basis.

In the following figure, the arrows leading out of the box labeled "Collection Agency" indicate the types of costs that a collection agency can incur from the organization and operation of an EEE waste collection program. The degree to which each of these individual costs affects the total cost for the program depends on the type of collection model. The costs range from short term (up front costs) to long term (operational costs), and can be highly variable. Unlike the demanufacturer, the collection agency does not have many options available to offset these costs, except possibly from the implementation of a user fee (the arrow leading into the box). All of these issues will be discussed in the following sections. page 56 Transport Costs Up Front Costs Operational Costs * Collection Labor * Collection Transport * Promotion * Equipment Maintenance * Storage * Program Staff * Property Acquisition * Facility Construction/ Acquisition * Collection Equipment * Program Promotion * Transport to the Demanufacturer User Fees Participant Revenue from Demanufacturing Collection Agency Demanufacturing Fees Demanufacturer Disposal Costs Demanfacturing Costs Figure 12: Cost and Revenue Streams for the Collection Agency 5.3.1 Role The collection agency plays the central role in the design of a collection program since it organizes the program around its own needs and motivations. Prior to beginning the design and implementation of a program, the collection agency determines its overall goal. Determining the goal requires formulating not only the motivation (the `why') behind the collection program but also the `what to collect' and "how much to collect." The following table recaps what was covered in Section 3, and also outlines some of the motivations behind setting up a collection program.

Table 37: Motivation Behind Collection Programs: Summary Table Motivation for the Program Program 1. Feasibility of a program (CSI sponsored), resource conservation, Source Reduction Binghamton/ Somerville; San Jose 2. Source reduction, removal of heavy metals from MSW stream going to incinerator, resource conservation Hennepin County; Union County 3. General community interest in recycling Hennepin County; Naperville; Somerville (post pilot), Binghamton (post pilot), San Jose (post pilot)

4. Reduction in landfilled material, resource conservation Naperville/ Wheaton 5. Interest from / involvement with a demanufacturer Naperville/ Wheaton Not all of these motivations are relevant to all collection agencies; e. g., the removal of heavy metals from incinerator emissions and ash is of less concern to a community that landfills all of its waste. page 57 It is interesting to note that all three of the CSI sponsored events will be continuing. Since the impetus behind the continuation is public interest, it is possible that, over time, the net cost per pound collected will decrease for each of these programs.

While there are various motivations behind the creation of a program, there are essentially only three drivers behind "what to collect": the economic value of equipment, the environmental impact/ toxicity of equipment, and the volume of equipment. Economic value drives the collection program only if the collection agency is the demanufacturer or if the demanufacturer's participation is dependent on the value received from the items collected. A discussion of items to collect for economic reasons is covered in Section <IP_ADDRESS>.

For the programs concerned about the potential environmental burdens of EEE waste, the Union County and Hennepin County programs indicated that the items to target are those that contain metals such as cadmium, mercury, and lead. More specifically, these programs focused on:

· TVs · Monitors · computers · VCRs · keyboards · copiers · microwaves · audio/ stereo equipment · telephones Finally, if the motivation is to reduce the amount of material that is landfilled, large volumes of equipment, such as TVs, monitors, computers, and microwaves, should be targeted. Of course, to reduce the volume as much as possible, all available EEE waste should be collected.

The final element for a collection agency to consider, or "how much to collect," should be based both on how much the demanufacturer can accept, and what equipment exists within the community. As was outlined earlier, once the efficiency threshold of a demanufacturer is reached, additional inflows of equipment require additional manpower. If collecting as much equipment as possible is the goal, the collection agency will need to consider the storage requirements for excess equipment. This is the case in Hennepin County, where, if the secondary smelter or any other end market shuts down, it must store the collected equipment until the demand for equipment resumes. MOTIVATIONS FOR COLLECTION: HOUSEHOLD HAZARDOUS WASTE For Household Hazardous Waste (HHW) collection programs, one of the greatest benefits may be the fact that consumers are educated on HHW issues. According to a spokesperson for a hazardous waste handling firm, GSX Chemical Services, Inc "it is difficult to change peoples' behavior through public service announcements or pamphlets, …collection programs are attractive, and receive a lot of media attention".

This implies that collection programs have an inherent value in that they change people's behavior. The implementation of a collection program for EEE waste not only reduces the electronics in the MSW flow, but it also makes people aware of the importance of the issue and the benefits of recycling in general.

SOURCE: The Costs and Benefits of Household Hazardous Waste Collection Programs, Paddock, T., Academy of Natural Sciences, October 1989. page 58 One important tool for determining "what" and "how much" to collect is a survey of the participating community. For example, if the participating community consists of predominately low income residents, implementing a collection program that selectively targets computers will not likely return the greatest yield. Therefore, it is useful to determine what equipment exists in the community, and what volume is available. Unfortunately, the programs that were examined did not give much insight into the role of demographics in determining participation rates and the volume of equipment collected. All the same, it is suggested that the demographics of the community, as well as the existing solid waste infrastructure, be taken into account before the planning of a collection program.

5.3.2 Costs – Influence of Collection Method The costs related to the method of collection are of interest to collection agencies considering an EEE waste collection program. These costs can be broken down into three categories: up front, operational, and transport costs. Each of these categories is defined below.

<IP_ADDRESS> Up front Costs The up front, or setup, costs are the expenditures needed before the operation of a collection program. These costs can potentially include:

§ Promotion of the event and public education on the program; § Staff; § Equipment acquisition; § Building construction; and § Land acquisition.

These are one time outlays needed to cover the necessary infrastructure and setup for a program. Over time, these outlays are minimal in comparison to the operational costs. These costs are not all necessary; among the five EEE waste collection programs that were examined, only promotional costs were accounted for. In fact, the last three elements, equipment acquisition, building construction, and land acquisition are not likely to be costs that a collection agency will incur since no community would build an EEE waste collection program from scratch. They are included merely to give an idea of some of the potential costs.

<IP_ADDRESS> Operational Costs These costs cover the expenses of collecting, sorting, and storing the equipment, but exclude demanufacturing. They include:

§ Collection labor; § Collection transportation; § Additional publicity; § Storage; § Equipment maintenance; and § Waste management.

The operating expenses for a collection program are driven by the price of labor. The more manpower hours required collecting equipment, the greater the program cost. These labor costs can be reduced through the use of volunteer labor to cover traffic direction, vehicle unloading, equipment sorting, and the like. Additional publicity costs will undoubtedly be necessary throughout the life of the collection program. Operational costs relating to transportation, storage, and maintenance are dependent on the choice of collection model. The more action that is required by a collection agency to collect equipment, the higher these operational costs can be. page 59 One consideration that a collection agency should keep in mind is the potential to collect equipment that may need special management. Such is that case in Hennepin County where equipment containing PCBs, older batteries and mercury switches frequently are collected. The waste management costs, depending on regulations governing the material, can potentially be high.

<IP_ADDRESS> Transportation Costs Transportation costs relate to the expense of transporting equipment to demanufacturing facilities. The experience pulled from these examples is that the distance that items are transported is highly variable, and is dependent on the demanufacturing scheme. Considering that the number of demanufacturers in a community may be very small, the transportation portion of the costs can have significant impacts on the net cost. While the collection agency cannot generally control the transportation distance, they can control the size of the load, which can have an effect on the transportation costs per pound.

<IP_ADDRESS> Different Collection Models The following sections examine the relationship between different collection models and the cost categories that were outlined above. The collection models each have a range of up front, operational and transportation costs that depend on the specific structures of the programs. That is to say that not every drop off event is going to be the same. The discussion also presents a number of the perceived advantages and barriers to the implementation of each particular model ¨ Drop off Events A drop off event is a one day event that is usually held over a weekend to maximize resident participation. The event generally is organized using existing municipal facilities (e. g., a parking lot, waste collection facility) and the up front costs can be negligible. Publicity for the event is paramount since participation seems to require substantial advance warning of the event. The expense of this publicity depends on the size of the community, as well as the opportunities for free publicity. Volunteer participation during the event-for sorting, unloading, and stacking  can make operational costs minimal. Without volunteer help, the operating cost depends on the local labor rate and the turnout for the event. The transportation costs can vary greatly (see the transportation cost difference between Somerville and Binghamton) depending on the location of a suitable demanufacturer.

Barriers to the effectiveness of this model:

· Since the event is held on one day, ineffective or insufficient publicity can result in lower participation than is expected and desired.

· The timing of the event is essential to avoid creating conflicts with other events that might have a large attendance.

· Participation could be low if citizens are not used to participating in drop off events for other recyclables.

· Work tasks for volunteers must be restricted to reduce potential liabilities (i. e., volunteers do not do any heavy lifting).

Advantages of this model:

· The up front costs for this event can be low.

· The amount of material collected can be high, for a short amount of time.

¨ Regional Approach page 60 Using the regional approach, multiple communities host coordinated events on a rotating basis. This is essentially the same as a drop off event. The costs are similar to those for a drop off event, except that the participating collection agencies share the costs.

Barriers to the effectiveness of this model:

· The distribution of costs related to participation can be unequal since not all communities may contribute the same amount of items to the collection.

· Rotating the location of the event may reduce participation if residents do not want to drive too far to drop off their EEE waste.

· Work tasks for volunteers must be restricted to reduce potential liabilities (i. e., volunteers do not do any heavy lifting).

Advantages of this model:

· There are economies of scale for the regional approach compared to the drop off event model, since the cost per pound collected is split among the participating communities in the regional approach.

· Planning of the events is less complicated if the responsibility is shared.

· There is a larger base of residents from which EEE waste can be collected.

¨ Permanent Collection Depot A permanent collection depot is essentially a year round collection event. The up front costs could be high for this model if the depot is developed solely for EEE waste. However, this is not likely to be the case since acquiring land, constructing a storage facility, and hiring staff are too costly for the small yield that would come from EEE waste collection. Normally the program would co locate with a collection site for other items (glass, HHW, MSW), which would result in negligible up front costs. The same principle would apply to operational costs. There are no costs for collection, but other operational costs, such as sorting of the materials and utilities would be split among the multiple materials. The transportation costs, of course, depend on the location of the demanufacturer relative to the collection site.

Barriers to the effectiveness of this model:

· The size of the community may not warrant the extra expense of year round collection.

· The collection of data relative to the demographics of the participants and the type of equipment that is dropped off may require staff, which would increase operational costs.

Advantages of this model:

· Equipment can be collected year round, which could produce higher annual yields than would occur during periodic events; however, there was insufficient data to understand how much the yield would be affected. THE BENEFITS OF PERMANENT FACILITIES: HHW COLLECTION EXPERIENCES Some communities in the United States are moving away from typical one day collections for HHW and moving toward permanent centers that can accept the collected material. Experience from HHW programs indicates that permanent programs are more efficient because a person with waste can get rid of it properly when they have it, instead of having to wait until the next collection day. Permanent centers may also be cheaper in the long run because liaisons can be established for the reuse and recycling of wastes such as paint and used oil. The experience from HHW collection may help guide the development of programs for EEE waste collection. SOURCE: Proceedings of the Fifth National Conference on Household Hazardous Waste Management, Dana Duxbury & Associates, Andover, MA, November, 1990. page 61 · The collection model is more convenient for residents, who can drop off material when they prefer to do so.

· Economies of scale are possible since costs are reduced as the amount of equipment collected increases over time.

¨ Curbside Collection The curbside collection model consists of the collection of EEE waste either on a periodic basis or by request. Beginning a curbside collection model from scratch would result in substantial up front costs; however, the presence in the community of a curbside program for MSW or other recyclables would allow for an allocation of these up front costs among the various programs. Publicity costs could be low as well since the presence of an existing program would indicate that the residents were aware of a collection program. Considering the small percentage of residential solid waste that consists of EEE waste, construction of a curbside collection program solely for these items would not make sense.

Coexistence of the EEE waste collection with an existing curbside collection program could also substantially reduce the operational costs, assuming that EEE waste collection occurs at the same time as the collection of other items. Transportation costs, as with the other collection models, vary depending on the location of the demanufacturing facility.

Barriers to the effectiveness of this model:

· Equipment sitting on the curb could potentially be stolen for parts, with any remaining material being thrown away. This would certainly affect yield from the demanufacturing.

· Even if the operation of the collection program coincides with the collection of other material, operational costs can be much higher than for other collection models.

Advantages of this model:

· Curbside pickup minimizes the "hassle" for residents, especially if they are used to curbside collection for other recyclables.

· Residents without transportation can more easily participate in the collection program.

¨ Point of Purchase (Retail) Collection The point of purchase collection model implies that a retailer covers the costs for the collection and storage of EEE waste. Therefore, the only up front costs for the collection agency consist of those for event publicity. Operational costs are minimal for a collection agency since a retailer's employees handle the operation. The transportation costs can vary, depending on the location of the retailer relative to the demanufacturer. This cost could increase if the retailer is not be able to set aside adequate storage space for the collected material and more frequent collections are required.

Barriers to the effectiveness of this model:

· The active participation of the retailer is essential to ensure good resident participation.

· Collection of data on participation is dependent on the retailer, who may not be able to collect the information.

· Logistical issues (storage space, collection from participants, etc.) can complicate the implementation.

Advantages of this model:

· The collection agency has low up front and operational costs.

· There is the potential for a high yield, as was indicated by from the results of the San Jose pilot.

· The promotion of the program by retailers ensures high visibility. page 62 ¨ Combined/ Coordinated Collection Methods: This model is a combination of the various other collection models: drop off events, curbside collection, permanent drop off collection, and point of purchase drop off. The costs of such a program is really just the sum of the costs of the individual models, so the net cost for the combined collection model should be higher than for a singular method. This approach is good when maximum coverage is desired and there is a suitable population to support the mix of models, such as in Hennepin County.

Barriers to the effectiveness of this model:

· The economies of scale are uncertain.

· The large scale of this model requires a large population to be viable.

Advantages of this model:

· The gaps created by one collection model can be filled by another model– i. e., residents who are far from a drop off facility can participate in a local drop off event.

· The regime allows for year round collection of EEE waste.

· The combination may be good for a collection agency that has inhabitants spread over a large area.

Taking into consideration the analysis presented above on categories of cost, it is difficult to determine the most economical collection model. In fact, the choice of a model really hinges upon the goals of the program, the existing infrastructure for collection, and the demanufacturing capacity, rather than which model costs the least to run.

The following is a table summarizing the barriers and advantages of each collection model, as presented above.

Table 38: Summary of Advantages and Barriers to Collection Models Collection Model Barriers Advantages Drop off Events · Ineffective or insufficient publicity can result in low participation. · Conflicts with other events may affect participation. · Residents unfamiliarity with drop off events can affect participation. · Low up front costs. · Short timeframe but high collection amount.

Regional Approach · Potential unequal distribution of costs among communities. · Economies of scale over single community drop off event model. · Planning of the events is shared. · Larger base of residents to participate.

Permanent Collection Depot · Not effective for every community size. · Need for staff may increase operational costs. · Year round collection of equipment. · Convenient for most residents. · Economies of scale are possible.

Curbside Collection · Potential of theft of equipment for parts, and then abandonment. · Minimal hassle for residents. accustomed to curbside collection. page 63 · Operational costs can be higher than other models. · Residents without transportation can more easily participate.

Point of Purchase (Retail) Collection · Retailers active participation is essential. · Retailer may not be able to collect the data on participation. · Logistical issues. · Low up front and operational costs for the collection agency. · Promotion of the program by retailers ensures high `visibility. '

Combined/ Coordinated Collection Methods · The economies of scale are uncertain. · Requires large population to be viable. · The gaps created by one model can be filled by another model. · Year round collection is possible. · Good if inhabitants are spread over a large area.

5.3.3 Minimizing Costs The collection agency has some opportunities to minimize the cost of the collection that are not directly dependent on the collection model. The following points are relevant to nearly all collection models.

Use of Volunteers:

Using volunteers to assist with collection labor can be cost effective in that it reduces operational costs and allows more of the budget to be used for publicizing the program. The key to the effective use of volunteers is to clearly train them on their duties. This is especially true for volunteers who are charged with sorting equipment. Ineffective sorting could increase the cost of demanufacturing since the sorting would have to be done at the demanufacturing facility, which is not efficient. On the downside, liability issues related to the use of volunteers must be examined.

Assistance with Publicity:

The promotion of a collection event or program is essential to getting the maximum yield of EEE waste. The community newsletter, local chamber of commerce publications, and newspapers can be sources of free publicity. This will not only reduce the up front costs but also promote the program to a wide audience. As an example, the news conference put on by the OFFSETTING COSTS: HHW COLLECTION EXPERIENCES Some communities have imposed user fees to create a fund for the management of HHW. However, these fees can be a deterrent to participation since residents in many states can legally throw HHW in the trash. In Anchorage, Alaska, for example, when the modest drop off fee for HHW is waived during the month of May, the participation among residents jumps dramatically.

Rather than implement user fees, some states have instituted specific taxes for HHW programs. In New Hampshire, a tax on hazardous waste generators funds matching grants to communities for HHW collection. Retailers in Iowa selling products covered under a state shelf labeling law pay a $25 registration fee that covers HHW program costs.

Since it is legal to dispose of EEE waste in many states, the implementation of a user fee may lead to experiences similar to those for HHW collections. The experiences from HHW management programs should be considered when cost reduction options are examined.

SOURCE: Household Hazardous Waste Mangement: A Manual for One Day Community Collection Programs. Office of Solid Waste and Emergency Response, US page 64 U. S. EPA during the San Jose pilot received a large amount of free coverage from local papers and television stations, which sparked a surge in resident participation.

Piggybacking on Existing Recycling Program:

The existing waste collection infrastructure can make the setup costs of a curbside or permanent EEE waste collection program negligible. Operational costs can also be shared among the various collection programs, making the long term collection of EEE waste more feasible. In a number of communities in Union County, the curbside collection program is held in conjunction with the curbside collection of bulk items, which leads to lower collection costs than would occur if the collection were solely for EEE waste. In addition, piggybacking on programs that residents are already familiar with can help to boost the participation rate for the program.

Formulating a Relationship with a Demanufacturer:

Most demanufacturers, at least over the long term operation of a program, will charge a fee for demanufacturing services. However, if a demanufacturer becomes an integral part of the design of a collection program, it may be possible to convince that company to reduce or split any fee that they would charge. A demanufacturer would benefit from this through the ready access to a constant flow of equipment and the promotion of residential collection programs. The more collection programs that come into existence over the long run, the greater the potential economies of scale for a demanufacturer.

5.3.4 Revenue Unless a collection agency has direct control over the demanufacturing scheme, they generally have little ability to generate revenue from a collection program. One exception is through the implementation of user fees. User fees refer to charging the participant a set fee per pound or per item of equipment that is dropped off. The effectiveness of such a tool is highly dependent on the population's desire to recycle. User fees in a community with low interest in recycling may have a deleterious effect on the overall participation rate.

For example, the Binghamton pilot implemented user fees ($ 2 per vehicle) during their first collection event, for which turnout was noticeably low – only 47 households out of 25,000. The user fee was abandoned during the second event, and turnout improved substantially – 128 households, of which only 10 had participated in the first event. However, whether this user fee was a disincentive to participation or not is unclear since there were other mitigating factors (the climate, construction, etc.) that affected the first event and not the second event. It is interesting to note that a high percentage of program participants surveyed in Binghamton and Somerville (over 80% in each community) indicated their willingness to pay between $1 and $5 to dispose of their EEE waste.

There are some issues to consider before implementing a user fee, particularly what alternative residents might have to paying the fee. Anecdotal data from the collection programs highlighted in Section 3 indicates that much of the EEE waste is either stored in the home because of some presumed economic value (e. g., an old computer) or is disposed of via the residential solid waste stream. These choices are relatively easy for a resident to make, especially for someone who is not overly concerned about recycling. Paying a fee for disposal can be seen as a more difficult choice to make. 23 5.3.5 Avoided Costs 23 A number of municipalities charge fees for tire or appliance disposal, which may be more viable because unwanted appliances and car tires take up large amounts of space and disposing of them in the trash is normally not an option. page 65 Up to this point, the discussion of costs and revenue has focused on costs that were incurred either by the collection agency or the demanufacturer. There are, however, additional costs that are not easily quantifiable. These are termed the avoided costs. Avoided costs are defined as the reduction in costs of one MSW activity or path that results from use of a different MSW activity or path. Typically, avoided cost implies the reduction in the costs of collecting, transferring, transporting, and landfilling MSW that results from source reduction, recycling, composting, or waste to energy. The value of the avoided costs is dependent on whether the focus is on (1) specific MSW activities or paths, (2) the total costs of the entire system, (3) near term marginal changes, or (4) longer term major changes in the MSW program. 24 If the focus of an assessment of avoided costs is merely a comparison of specific waste management activities, in this case EEE waste recycling and landfilling, then it is incorrect to assume that the cost per pound of the recycling should be subtracted from the avoided cost of landfilling to calculate a `net cost' of recycling. That is, if the net cost for recycling is $100 per ton and the net cost of disposal is $90 per ton, then it is incorrect to say that the net cost of recycling is $10 per ton, taking into account the avoided cost of $90 per ton. The full costs per ton of recycling are not affected by any resulting avoided cost of landfilling. From this point of view, avoided costs for these programs cannot realistically be calculated.

However, if avoided costs are looked at on a larger scale, lower landfilling costs could occur as a result of the diversion of waste via an EEE waste collection program over a period of time. Over the long term, the recycling of EEE waste will reduce the collection agency's total outlay for landfilling. The reduction in total landfilling or incineration fees can be quantified; this value is the avoided cost. These avoided costs should not be considered as revenue, however, since they do not necessarily reduce the total costs of MSW management or the fees and taxes that residents must pay for solid waste management.

Even though the avoided costs for an EEE waste collection program should not be viewed in terms of the waste management costs that are offset, they are a good measure of the added value of a collection program. For the programs examined in Section 3, the avoided costs were associated with landfilling, whose cost per pound is small relative to that for collection and demanufacturing. However for the counties that use incineration, the avoided costs not only relate to the disposal of the ashes, but also to the avoided pollution.

Both Union County and Hennepin County initiated their EEE waste collection program based on their desire to reduce and eventually eliminate the environmental impacts of heavy metals in their incinerator ash. These programs seem to have had an effect, based on the data in the following table, which shows the calculated concentration of heavy metals in MSW, based on metals in the ash residue and air emissions. However, the specific contribution of the demanufacturing program to these reductions has not been calculated.

Table 39: Changes in Metal Concentration for Union County Incinerator Ash Period Cd (mg/ kg) Pb (mg/ kg) Hg (mg/ kg)

Baseline Feb 94 to Nov 96 6.49 210.1 2.46 24 Full Cost Accounting for Municipal Solid Waste Management: A Handbook. United States Environmental Protection Agency. Office of Solid Waste and Emergency Response. Washington, DC. September 1997. EPA 530 R95 041. pp. 52 55. page 66 Since Debut of Collections Dec 96 to Aug 97 5.43 141.27 2.15 Apr 97 to Feb 98 3.75 117.41 2.22 Disposal of incinerator ash is controlled via Toxic Characteristic Leaching Procedure analysis that is used to determine whether or not a material is hazardous. The tipping fee for incinerator ash is dependent on this determination. Disposal of ash is typically more expensive than disposal in a solid waste landfill and the avoided costs will reflect this. Removing toxic constituents (e. g., EEE waste containing lead or cadmium) from the MSW stream may reduce the toxicity of the ash, and subsequently lead to lower management and disposal costs.

5.3.6 The Collection Agency and Demanufacturing Just as there are drivers for a collection agency to develop an EEE waste collection program, there also are drivers that determine how the collected equipment should be demanufactured. a collection agency may take two approaches. The first is a private sector approach, which was the approach used in four of the case studies. The second is a public sector approach whose drivers are not solely economic. Both of these approaches are outlined below.

Private Sector:

The pilots have a unique relationship with the demanufacturer providing in kind services or being subsidized by grant funding. More typically, a collection agency would enter a contractual relationship with a local demanufacturer. Ideally this relationship would allow the collection agency to transfer the collected equipment for free or even receive a portion of the revenue yield. However, it is more likely that there will be a fee based upon the volume or weight of equipment that is accepted. In this situation, the net costs for the collection agency would depend on those costs that are associated with the collection of the items. It is not known what a demanufacturer would actually charge a collection agency for accepting EEE waste since not enough data was available.

Public Sector/ Non profit:

This approach is the development of a public sector program to cover the demanufacturing of equipment. This could entail, for instance, the creation of a job training program for lower income residents or outsourcing of work to an association for the handicapped. Creating jobs and promoting job training are clear advantages to this approach. Another benefit is that any revenue from the demanufactured material can go toward offsetting the program costs. Additionally, it is possible that funding from social programs could offset some of the cost of this labor.

The difficulty with this method for most collection agencies is that they will bear all of the costs that were originally covered by the demanufacturer. As was pointed out earlier, demanufacturing costs are a substantial portion of the net costs for collection programs. The additional financial burden might be too large for most small and medium sized collection programs.

The following factors also influence the development of an EEE waste collection program:

Government Regulations Regarding CRTs:

The designation of some CRTs as hazardous waste by the federal Resource Conservation and Recovery Act, may limit the viability of an EEE waste collection program since items containing CRTs seem to make up a large portion of the total number of items collected. These regulations can affect the implementation of a program since permit requirements for the handling of hazardous waste restrict the page 67 number of firms that can recycle CRTs. This leads to higher overall demanufacturing costs because of high transportation and permitting costs if a remote demanufacturer is used. In the absence of an available demanufacturer to handle CRTs, the material will need to be disposed of by other means.

While this is the current situation for CRTs, some changes are occurring that may remove this barrier. In early 1999, the U. S. EPA expects to propose a rule under the Resource Conservation and Recovery Act that may streamline the requirements for managing CRTs while retaining controls to protect human health and the environment. The rule will also specify that once the CRT glass is processed such as to be usable as a raw material in CRT glass manufacturing, it is not subject to hazardous waste regulations (Appendix A). In addition, states have adopted their own policies and regulations for CRT management.

Limited Market for Demanufactured Material:

The quality and type of the equipment gathered in residential collections may also limit the market for recovered material. Currently, many local demanufacturers do not want to manage TVs. A large amount of the material that is recovered is plastic, which at the moment has little economic value compared to most of the other materials that are extracted. Additionally, few OEMs are willing to accept recycled material for use in their production processes. This is mainly due to incompatibility between different types of plastics, technical difficulties in sorting plastics, and problems with matching the colors of recycled and virgin material. In addition, some materials are a cost to market, including CRTs and lowgrade boards, as well as the plastics.

5.3.7 Retailers Retailers are crucial in the implementation of a point of purchase collection program, which, as presented in the case study, is really a partnership between retailers and government agencies. In this type of collection model, the retailer acts as the collection agency. The retailer absorbs many of the operational costs associated with the collection program, such as labor for sorting and storage costs. This shift allows the cooperating government agencies to focus on increasing participation to generate greater yields. Full cooperation is essential between the retailer and the interested government agencies to forge a public/ private partnership.

For the retailer, there are number of benefits to participating in the collection program, namely:

· An inflow of potential customers who are disposing of used equipment;.

· A source of spare parts for equipment repair;

· Positive public relations – a "green" image; and · Free publicity for the store via the collection agency's promotion of the event.

The benefits retailers receive from this cooperation obviously depend on the participation rate for the program. Therefore full coordination with the collection agency is in the retailer's best interest. In San Jose, the extensive publicity from the press conference had a marked effect on participation, which reflects an overall positive local attitude towards EEE waste collection in the area. The positive attitude of the public has motivated one the participating chains (Fry's Electronics) to continue the program at a number of its other stores. page 68 5.4 THE PARTICIPANT Transport Costs User Fees Disposal Costs Participant Up Front Costs Operational Costs Revenue from Demanufacturing Collection Agency Demanufacturing Fees Demanufacturer Demanfacturing Costs Figure 13: Cost and Revenue Streams for the Participant Participants are essential to a collection program since strong resident turnout is vital for a program to generate sufficient amounts of equipment. A participant's involvement usually comes without any cost burden, aside from the situation where there is a user fee for the drop off of equipment (see discussion in Section 5.3.4). However, a free recycling program is not in and of itself a motivator for participation. Resident participation depends on more qualitative elements such as a predisposition toward recycling or adequate publicity for the program.

Some elements that may motivate a resident to participate may include:

· Easy access to events or drop off facilities;

· Timing of the event to avoid poor weather or conflicting events (to the degree possible);

· Coordination of the event with other collection programs such as for tires, books, or bulky items; and · Incentives, such as discount coupons for the purchase of new electronics or electrical equipment made available when equipment is dropped off.

The most important driver for participation is the promotion of the collection program; awareness is fundamental to a program's effectiveness. The programs that were profiled in Section 3 used a variety of methods to ensure that there was sufficient public knowledge of the event. These methods included (not an exhaustive list):

· Door hangers;

· Flyers sent to area schools;

· Articles promoting the program in local community newsletters;

· Newspaper coverage; and · Flyers added to government employees' paychecks.

One of the methods that seemed to have the most impact on participation was the staging of a press conference in San Jose, which resulted in both television and newspaper coverage of the pilot. This allowed the program to reach a wide range of potential participants. The free press from this event provided a real boost to the collection event, which up to that point had collected no equipment. Whether any collection agency can duplicate the effectiveness of such an event is uncertain, however, since there were a number of dignitaries present at the San Jose publicity event that helped boost the coverage of the event. page 69 According to a number of the collection program coordinators, one of the keys to effective publicity for a collection event is planning. This is certainly the case for drop off events when a specific date has set aside for the collection. The experience of the San Jose pilot is that the lack of adequate publicity before the beginning of the event led to the zero yield during the first week.

5.5 OTHER STAKEHOLDERS The previous sections outlined the roles that the collection agency, demanufacturer, and participant play in the development of an EEE waste collection program. Beyond these three essential stakeholders are some other actors who can have an effect on the design and function of an EEE waste collection program.

5.5.1 Government In the context of this analysis, the federal government sponsored the discussion of EEE waste management programs under the Common Sense Initiative Computer and Electronics Sector. However, no formal policy recommendation has been made at this time. In addition, a number of states are currently considering banning the landfilling of EEE waste or CRTs. Such a regulation would lead to the need for alternative waste management practices for such materials. This may actually force many communities to quickly implement programs that end up being costly to them in the short term. The advantage may be that over time, an increase in the number of collection programs will lead to economies of scale as more demanufacturing firms are created to meet the demand for labor.

5.5.2 Private Industry For the Union County program, Sharp Electronics, Lucent Technologies, Panasonic, and the Electronic Industries Alliance all provided in kind support for the design and implementation of the pilots. However, aside from this program, private industry 25 did not play a direct role in the development of the EEE waste collection programs. Rather its influence has been on the upstream and downstream ends of the collection model, i. e., during the manufacturing of equipment, through the purchasing of recycled material, or in developing the demanufacturing sector to manage off specification or return products. However, the Union County experience indicates that private industry will work directly with a collection agency to assist with the design and implementation of a collection program. Private industry could also become the collection agency via equipment take back schemes, although the economics of this collection model is outside the scope of the study.

Private industry's indirect impacts are examined below.

Upstream Impacts:

25 Private industry is includes Original Equipment Manufacturers (OEMs), their suppliers and primary materials manufacturers. page 70 Changes in both consumer demand and technology can affect the lifespan of consumer equipment. While some of the EEE waste collected was mechanically sound, the technology was obsolete or undesirable, making reuse at end of life less viable than demanufacturing or disposal. Considering this, private industry has the greatest potential to make an impact on the end of life of this kind of waste by affecting the disassembly of the equipment. A modification in manufacturing methods, such as minimizing the number of fasteners in an item, could lead to a reduction in the amount of time required to demanufacture equipment. This reduction in time would eventually result in a decrease in the cost of demanufacturing.

Another production change that would assist the recycling of EEE waste would be the use of fewer heavy metal components in equipment. This could also have the effect of reducing many of the environmental concerns about landfilling or incinerating EEE waste. Realistically, however, OEMs and their suppliers face some limitations in how their equipment and components are designed. These upstream changes would not have an immediate impact; current changes in manufacturing will not affect collections for a number of years because of the time lag between equipment purchase and disposal. Over the long term, however, the impact on the net costs of such a collection program would be favorable.

Downstream Impacts:

The most direct effect that private industry (predominantly parts suppliers and primary material producers) has on an EEE waste collection program is through the purchase of recycled material and parts. The market for some of the materials that are extracted from electronics is governed by demand from companies that produce the parts or the materials used in electronics or electrical equipment. Demand, however, is affected by concerns about the quality and quantity of the extracted material. In fact, it has become a Catch 22 since the insufficient supply of a recycled material leads to low demand by private industry, which in turn leads to fewer demanufacturers and less output of material. For private industry to assist in the expansion of EEE waste collection programs, demand for the recycled material needs to be increased. With the expansion of EEE waste collection programs, the supply of useful material will at least be guaranteed. EEE WASTE COLLECTION AND PRODUCER RESPONSIBILITY IN EUROPE Currently in the European Union there are discussions as to what role OEMs should play in the collection of EEE waste. Debates on a new directive on waste electrical and electronic equipment initially focused on placing most of the financial burdens of collection and demanufacturing on equipment producers. However, current plans have changed to place the burden of residential EEE waste collection on municipalities, while OEMs would still be obligated to accept the collected equipment.

Although this directive has not yet been finalized, the current debate indicates that the approach to EEE waste collection in Europe is to incorporate OEMs into the process, which will distribute the costs of the collection program.

SOURCE: Product Stewardship Advisor, Cutter Information Corp., September 4, 1998. page 71 6. CONCLUSION The focus of this report is to examine different collection programs and develop some general conclusions about the dynamics of an EEE waste collection program. All five of the case studies provided a large amount of information on demanufacturing costs, publicity, the volume of materials collected, etc., and although no clear picture was formed as to the best collection method, some general conclusions were reached. The precision of these conclusions, however, is limited by the data that was available. The following sections cover data gaps, future areas of research, and the general conclusions.

6.1 DATA GAPS AND FUTURE RESEARCH One reason that a more in depth assessment of these collection programs was not possible is that the data that was gathered for the study was not uniform. As was mentioned at the beginning of Section 4, the net cost for these programs was calculated using both demanufacturing and collection program costs. The advantage of this approach is that it gives a better picture of the true cost of managing such a program. The disadvantage is that costs that are specific to the collection agency or the demanufacturer are hidden in this net cost value. Therefore, it was difficult to break out what specific costs were the drivers for the program.

To provide for a more concise analysis in the future, the data gaps should be filled in. This would require more specific data from the collection agency on the following costs:

· Up front costs – · Publicity · Staff;

· Operational costs – · Staff time allocated to the program · Costs of publicity for a program, including work that is completed in house · Maintenance costs for facilities;

· Transportation to the demanufacturer;

· Fees paid to the demanufacturer (aside from transportation costs); and · Ultimate disposal practices including CRT export for demanufacture and disposal.

This additional data would provide the collection agency with a clearer assessment of the real costs associated with the implementation of a collection program. This detailed information would also allow a collection agency to track the progress of its collection program.

The limitations on data also prevented an analysis of the effects that economies of scale can have on a program. With the existence of economies of scale, the expansion of a local collection program either in participation, frequency of events, or volume collected would result in a reduction in the net cost per pound collected. While this seems intuitively correct, there was not enough long term data available to confirm that greater size leads to lower expenses. Data on changes in the program costs during the growth of a program would also be needed to accurately determine the effect of program size. Determining the effects of economies of scale would be important in helping to define the appropriate size of a collection program for a community.

Aside from the evident data gaps, there were a couple of areas of research, outside the scope of this report, that would provide information useful in the implementation of a residential EEE waste collection program. page 72 One area is an analysis of the potential markets for many of the materials that are extracted from EEE waste. This would certainly be useful in the case of plastics, since a lot of the engineered plastics that are generated from EEE waste have no value in the marketplace. An analysis of potential markets for these secondary materials would allow a collection agency to determine whether the revenue from the extracted material may offset more of the program costs.

Parallel to this would be analysis of the equipment that was collected, and cost and revenue associated with each type of equipment. The results could be useful in structuring a collection program. Unfortunately, much of the data necessary for such a study was unavailable for this report.

An assessment of the environmental impact of EEE waste was also beyond the scope of this study, but could be useful in calculating the avoided or added costs associated with a collection program. It could also indicate what equipment a program should target. Considering that all of the collection programs operated at a net cost, more data on avoided costs could provide more complete information on the relative costs or benefits of initiating a collection program. An environmental life cycle assessment could also be useful in presenting the environmental trade offs that exist for different EEE waste management options.

Finally, an investigation into the value of the regulation of demanufacturers could be another subject for future research. Representatives from both Hennepin County and the New Jersey Department of Environmental Protection have indicated that demanufacturers may be tempted to accept EEE waste and store it in warehouses, without having legitimate markets for the extracted materials. While there was no indication from the five case studies that this could be the case, the potential exists if EEE waste collection becomes a mandate in some areas.

6.2 CONCLUSIONS While these differences in net costs among programs would seem to imply that some programs were more successful than others, differences in how the data was collected and provided for each programs makes such a judgment difficult. However, while making a comparison between these programs is not possible based a comparison of the net costs, it was still possible to use this data to make a limited assessment of the economics and dynamics of these collection programs:

Ø The net costs of the programs were driven by the demanufacturing costs; the operational costs for many of the case studies were either not accounted for or very small. However, since a number of these collection programs were pilots, this may not be the case for programs operating over longer periods.

Ø In terms of pounds of material collected per resident, the curbside collection programs appeared to be more efficient than the other collection models, while the one day collection events appeared to the least efficient. More and better collection data is necessary to confirm this.

Ø In contrast to the previous point, the number of items collected per dollar of collection program cost was higher for the curbside events than for the other collection models. This was evidently due to the high transportation costs associated with collection. For the one day collection events, the cost per item collected was lower than the other collection models. However, the one day collection events that were studied did not incur any operating costs, which would likely narrow the differences between the two collection models.

Ø A weighted average of all of the collection programs indicates that over 75% of the equipment that was collected fell into five categories: 36% of the items were televisions, 16% consisted of audio page 73 and stereo equipment, 11% were monitors, 8% were computers and CPUs, and 6% were VCRs. The remaining equipment consisted of keyboards (5%), printers (4%), telephones (3%), peripherals (1%), microwaves (1%), and miscellaneous other equipment (9%).

Ø The residential EEE waste collected by these programs was generally outdated and in poor condition. Consequently, the material was expensive to manage and little valuable scrap was extracted from this equipment. Of the equipment that was collected, computers and CPUs provided most of material that generated revenue for the programs.

Ø Items that contained CRTs (e. g., televisions and monitors) predominated in the five collection programs. Since the cost to manage these materials is quite high, the large number of CRTs had a substantial impact on the net cost values.

Ø Promotion and planning of the events was essential to the effectiveness of the collection programs. This was made evident by the lack of turnout for the first week of the San Jose pilot, for which there was little prior publicity. Additionally, the first Binghamton collection event was affected by a number of factors, including a local football game that was being held at the same time.

Ø There is apparent public interest in EEE waste collection programs. This is evident from the fact that the amount of equipment that was collected increased over time for all the programs that had more than one collection. In addition, the CSI sponsored events (Somerville, Binghamton-one day drop off model and San Jose-retail collection model) will be continuing due to the positive public reception in their communities.

In addition to the specific conclusions from the analysis of these collection models, more general points were drawn from the information provided by these case studies. Since these general comments are based on qualitative information, additional research on these points would be beneficial.

Ø Most demanufacturers focus exclusively on commercial EEE waste. According to Hennepin County, the low quality of the residential equipment inhibits many demanufacturers from getting involved in a residential collection program. A collection program that takes in both residential and small business waste may generate more interest from demanufacturers, simply because the quality of EEE waste may be better.

Ø Total transportation, demanufacturing, and disposal costs may overwhelm all other program costs. These costs relate to the variety of material collected, local labor market, the distance required to transport materials to a demanufacturing facility, the distance to end markets, and the disposal costs of unmarketable materials.

Ø The loading of heavy metals in the Municipal Solid Waste stream was a fundamental driver for the two collection programs (Union County and Hennepin County) where most of the residential solid waste stream is incinerated. The counties advocate that the removal of EEE waste from the waste stream may play an important role in reducing the heavy metal burdens in the fly and bottom ash, which can result in an indirect economic benefit for the community by lowering ash disposal fees.

Ø The ultimate disposition of demanufactured materials should be evaluated to determine if these venues (e. g., glass to glass recycling, smelting, overseas disposition for CRTs) are in accordance with the objectives of the program.

Ø The advantages and barriers to different collection models are such that determining the best collection method is dependent on the motivations of the collection agency. page 74 To put the current situation for these collection programs in perspective, it is useful to examine the experiences of other recycling programs. The proliferation of recycling programs in the 1980s resulted in a supply driven market since the infrastructure required to accept recycled materials was still in development. 26 As a result, the net cost for many of these programs remained high since there was little revenue derived from the recycled materials. In the beginning, collection of recyclables tended to run ahead of capacity, with materials being made available to the recycling marketplace independent of the demand for the materials that were recovered. This mirrors the situation for EEE residential waste recycling today.

Today the issue of markets is still a critical issue. Public interest in recycling and private sector demand for products with recycled content have driven an increased industrial recycling capacity. While the capacity now exists, further market development still is needed to assure market stability and accessibility.

For the collection agency involved in recycling, it is important to understand that commodity like marketplaces can be very volatile, sometimes demanding more scrap, sometimes demanding less scrap. Movements are traditionally difficult to predict. This volatility is driven by a number of factors. For ferrous and non ferrous scrap metals, the price is generally related to the value of the virgin raw materials. For paper, plastic, and glass from MSW, the relationship is less direct, since it is dependent somewhat on the quality of the material. During the recovery of typical recyclables, some contamination is evident. Consequently, the recyclables may not be of as high a quality as the market demands.

The experiences collected from appliance or white goods recycling programs have some relevance to EEE waste collection. With space at a premium in the early 1990s, at least 16 states banned the disposal of white goods in landfills. This led to a jump in the recycling rate, which went from 20% in 1988 to 75% in 1995. 27 A similar growth in the recovery rate for EEE waste would not be surprising.

Like EEE waste, white goods have a high initial cost, and because of their perceived value, many people simply kept their old appliances rather than disposing of them. This is apparent when you consider that the typical age at disposal is from 10 to 20 years. Many municipalities rely on curbside collection, either through appointment or on designated days, as a means of collecting this material. However, according to a representative of the Appliance Recycling Centers of America, one day collection events remain a popular method of collecting old units from the public.

For appliance recycling, not including the use of an auto shredder, labor costs account for 84% to 86% of the total operation costs. The labor costs are insensitive to volume, and increasing throughput has a relatively minor impact on the total cost per unit. This coincides with the current situation for EEE waste demanufacturing since it is also very labor intensive. The difference between the two types of demanufacturing is the materials that are recovered. Appliances contain a lot of ferrous metals, but little else of economic value. Electronics include a number of precious metals that makes their disassembly more cost affective, especially if markets develop over time.

Experiences with other types of recycling programs indicate that EEE residential waste collection programs are in their infancy, and have the potential to evolve and eventually become more cost effective. It could be expected that as these programs expand, and markets for the recovered materials grow, the net cost per pound collected should decrease. The potential economies of scale from the 26 The Role of Recycling in Integrated Solid Waste Management to the Year 2000. Keep America Beautiful, Inc. Stamford, CT. 1994. pp. 5 1 to 5 6. 27 Handling Difficult Materials. Waste Age. Randy Woods. May 1994. pp. 71 73. page 75 expansion of these programs and the creation of demanufacturing businesses will also help to reduce costs. However, considering the quality and varied nature of the collected materials, it seems likely that the costs of these programs will remain high relative to other traditional solid waste disposal methods. page 76 7 APPENDIX A: US EPA CRT RECOMMENDATION COMMON SENSE INITIATIVE (CSI) COUNCIL RECOMMENDATION ON CATHODE RAY TUBE (CRT) GLASS TO GLASS RECYCLING Based on in depth work conducted by the CSI Computers and Electronics Sector Subcommittee, the CSI Council has determined that properly conducted Cathode Ray Tube (CRT) glass to glass recycling is a cleaner, cheaper, smarter approach to waste CRT management that should be increased. To facilitate accomplishing that goal, the CSI Council recommends that the U. S. Environmental Protection Agency:

1. Revise the applicable Resource Conservation and Recovery Act (RCRA) hazardous waste management regulations to facilitate CRT glass to glass recycling as outlined in Attachment 1. The revised CRT glass to glass recycling regulations should be clear and simple to understand. The Council asks that, as appropriate, EPA discuss with members of the Computers and Electronics Sector Subcommittee any new issues that arise during rule development and implementation.

2. Complete and implement this CRT rulemaking as soon as possible, and in the intervening period, take appropriate steps to realize the environmental benefits of CRT glass to glass recycling.

Finally, the CSI Council recognizes that there may be CRT glass recycling methods or end uses other than CRT manufacturing that are also cleaner, cheaper, and smarter approaches to waste CRT management. On the other hand, some recycling methods or end uses may pose risks to human health and the environment. The Computers and Electronics Subcommittee will be working to determine which recycling methods and end uses are preferable and to propose appropriate standards for such methods, but the Council is aware that the future of the Common Sense Initiative is undefined at this time. Thus, the Council asks that EPA consider any additional work completed by the Sector, and if appropriate, design the CRT glass to glass rule so that other legitimate recycling methods or end uses may be added in the future, including standards tailored to the risks and benefits of the recycling method or end use. The Council takes no position on the question of whether states should be allowed to add additional recycling methods or end uses without a prior determination by EPA.

ATTACHMENT 1: COMMON SENSE INITIATIVE COUNCIL RECOMMENDATION CATHODE RAY TUBE (CRT) GLASS TO GLASS RECYCLING 1. Add to the Resource Conservation Recovery Act (RCRA) hazardous waste management regulations new standards specific to CRT glass to glass recycling which will apply in place of the standard RCRA hazardous waste requirements. These new standards are to be structured in a manner similar to the Universal Waste rule (40 CFR Part 273). The regulation will include an exclusion from the definition of solid waste clarifying that processed CRT glass28 that is to be reused in CRT glass manufacturing is not a solid waste subject to the RCRA hazardous waste regulations (including the new CRT standards described here). The Council recommends that EPA promulgate this exclusion because the processed CRT glass is sufficiently commodity like based on the following factors: 1) the degree of processing the material has undergone is such that it requires little, if any, further processing, 2) the material has economic value, 3) the material is like an analogous raw material, and 4) there is a guaranteed end market for the material. Based on the information 28 Processed CRT glass is glass that has been separated from non glass components (e. g., TV/ monitor plastic and metal components, implosion band, shadow mask, deflection yoke, electron gun, inner shield) and which has been cleaned to remove coatings (e. g., day, phosphors). page 77 currently available to it, the Council also believes that the material is handled to minimize loss, but requests that EPA conduct whatever investigation EPA determines is appropriate to reach a final conclusion regarding this factor.

2. The new CRT glass to glass recycling standards will explain that they apply only to materials that are currently regulated hazardous waste. However, the standards will explain that the goal is that the standards be simple enough that one infrastructure develops for voluntarily managing all CRT materials in the same system.

3. The new CRT glass to glass recycling standards will define the following three categories of regulated entities:

Collectors : Persons who collect/ store whole TVS/ monitors. Within this category, some requirements will apply only to large collectors (those who store 40 tons or more (~ 4,000 units) onsite for longer than 7 consecutive days).

Processors : Persons who: - intentionally break CRTs; - manage intentionally broken CRT glass or cullet; or - clean coatings (e. g., dag, phosphors) from CRT glass.

Transporters: Persons who transport TVS/ monitors, whole CRTs, broken CRT glass, or cullet.

Entities involved in refurbishment and disassembly of products containing CRTs (not to include taking apart the CRT 29 ) are not subject to this standard or the RCRA hazardous waste regulations (40 CFR Parts 260 through 270) (on the basis of the CRT itself) until it is determined that these materials are not repairable or reusable. EPA will consider what safeguards are necessary, if any, to address environmental concerns associated with accumulation of large volumes of CRTs.

4. The new CRT glass to glass recycling standards will include the provisions illustrated in the following Table and detailed in Annex 1.

29 EPA will consider other refurbishing activities that should be addressed in the same manner. page 78 Table 40: Provisions Applicable To CRT Glass To Glass Regulated Entities REGULATED ENTITY PROVISION Collector Processor Transporter 1. Notification large collectors only X 2. Marking (on site and for transport) X X 3. Storage Limit X X X 4. Shipping CRT Glass Materials large collectors only: shipments out X 5. General Performance Standard X X X 6. Prevent Releases of Glass Particulate X 7. General Good Management X X X 8. Minimize Breakage X X 9. No Cross Contamination X 10. Manage Residues Appropriately X 11. Environmental Justice Provision X 12. Package for Transport X X 13. Exports X X page 79 ANNEX 1: CRT GLASS TO GLASS RECYCLING PROVISIONS 1. Notification: One time notice to the agency implementing the hazardous waste regulations (EPA or the state) of company name, location, activities, etc.

2. Marking: Materials must be marked in accordance with either (1) or (2) below.

(1) CSI/ CRT approach:

(a) Whole TVS/ monitors visible when looking at primary packaging (container or vehicle body): no marking required.

(b) TVs/ monitors, bare CRTs, and glass in packages (i. e., containers or vehicle bodies) or storage areas: mark container or storage area with the following words: "Cathode ray tubes (CRT) or CRT glass to be used in CRT glass manufacturing. Contains lead. Do not mix with other glass or materials."

(2) Universal Waste approach for materials in transportation: If the state in which the shipment originated has Universal Waste marking standards (i. e., labeling with text) for the material: mark (label) the material as required under the originating state's Universal Waste program.

3. Storage Limit: Collectors  1 year + as described in 40 CFR 273.15. Processors  1+ year as described in 40 CFR 261.1( c)( 8). Transporters  10 days as described in 40 CFR 273.53.

4. Shipping CRT Materials: Maintain records for 3 years. No specified form for records.

Small and large collectors  may send shipments only to other collectors or to processors in CRT system. Large collectors  for each outgoing shipment, keep records of quantity, date, name and address of person shipped to, and an acknowledgment of receipt from the recipient. Processors  1) all TC hazardous glass that is technically and economically usable in CRT glass manufacturing must be sent to a CRT glass manufacturer for use in CRT glass manufacturing. 2) for each incoming and outgoing shipment, keep records of quantity, date, name, and address of person shipped to, and an acknowledgment of receipt from the recipient. 3) Annually, prepare a certified statement stating that all TC hazardous glass that is technically and economically usable in CRT glass manufacturing was sent to a CRT glass manufacturer for use in CRT glass manufacturing.

5. General Performance Standard: Manage and/ or transport CRT materials in a way that prevents releases to the environment of glass pieces, glass particulate, other components, and materials used in processing (e. g., cleaning or sorting media). Immediately contain any releases to the environment and manage contained material under applicable waste management requirements.

6. Prevent Releases of Glass Particulate: For any storage or management activities involving breaking glass or managing broken glass, install and maintain systems sufficient to minimize releases of glass and glass particulate via wind dispersal, runoff, and direct releases to soil. (Examples of wind dispersal control systems may include: a good condition building; closed containers; closed tanks; keeping materials stored or managed outdoors covered, or wet, as appropriate. Examples of systems for preventing releases to soil directly may include: an impervious floor or pad; a good condition building. Examples of systems for preventing releases via runoff may include: a good condition building; implementing an approved storm water management plan; adequate run off controls.) page 80 7. General Good Management:  Collectors, Processors, Transporters  no disposal on site  Collectors and Transporters  no dilution, no treatment (dismantling, intentional breakage, processing)  Processors  no combustion or treatment activities using temperatures high enough to volatilize lead from CRT glass, no storage or processing in surface impoundments 8. Minimize breakage: Collectors  manage to minimize breakage of TVS/ monitors. Transporters

transport to minimize breakage of TVS/ monitors, CRTs, glass pieces.

9. No Cross Contamination: Do not mix TC hazardous CRT glass with other glass that is not going to CRT glass manufacturing. Blending of glass that is going to glass manufacturing is allowed.

10. Manage Residues Appropriately: Manage any components removed during dismantling, any residues separated from glass (e. g., coatings), and residues from processing glass (e. g., blast media, cleaning media, dust, floor sweepings, glass fines) under applicable waste management requirements (hazardous waste, solid waste).

11. Environmental Justice: For new processors  implement a procedure for advising the local community of the nature of the activities to be conducted, including the limited potential for resident and worker exposure to lead or chemical coatings. This procedure should include notice to the community, and a public meeting if requested by the community. A local, state, or federal governmental authority must approve the text of the notice and the notice procedure, and must conduct the meeting, if any. If preexisting state or local siting/ zoning or other procedures meeting these standards are followed, no additional action is necessary.

12. Package for Transport: Materials must be packaged in accordance with either (1) or (2) below.

(1) CSI/ CRT approach:

(a) Package TVs, monitors, or whole CRTs in a way that minimizes breakage during normal shipping conditions. The packaging must minimize releases to the environment if unintentional breakage does occur. For example, if TVs and monitors are shrink wrapped onto pallets in such way that broken pieces of glass might not be contained, the packed pallets should be placed in an outside package (e. g., a box or vehicle body) that will minimize releases.

(b) Package broken CRTs, CRT glass pieces, or CRT glass cullet in siftproof packaging (i. e., a container or vehicle) that is constructed, filled, and closed so that: (I) There will be no identifiable releases of CRT glass to the environment, and (II) The effectiveness of the package will not be reduced during normal shipping conditions. For example, packages should be resistant to puncture by glass pieces.

(2) Universal Waste approach for materials in transportation: If the state in which the shipment originated has Universal Waste packaging standards for the material: package the material as required under the originating state's Universal Waste program.

13. Exports: For shipments of materials that are hazardous waste, other than processed CRT glass (without coatings)  comply with 40 CFR 262 Subparts E or H (export notice and consent procedures for non OECD and OECD countries), revised to specifically identify the recipient as a page 81 CRT glass manufacturer, or a collector/ processor shipping to a CRT glass manufacturer (also identify the manufacturer). page 82 8 APPENDIX B: THE SAN FRANCISCO AREA COLLECTION PROGRAM Collection data for the San Francisco Area collection program was not available in time for this report. However, a summary of the program's structure and the general summary data that was available is presented below.

Collection Method: Drop off event and curbside collection Number of Collections: 10 days (Oakland and San Francisco), 1 day Hayward Collection Dates: March 28, 1998 and May 11 22, 1998 Demanufacturer: East Bay Conservation Corps (EBCC) in Oakland Motivation Behind Collection:

Materials for the Future Foundation, a San Francisco area NGO, initiated three collection programs in the San Francisco Bay Area with the help of local community based organizations and businesses. The collection program consisted of a drop off event in the City of Hayward, a Residential Super Recycling Day in San Francisco, curbside collection in San Francisco, and curbside collection paired with bulky waste pickup in Oakland. At the time of publication, detailed information was only available for the Oakland collection pilot.

The motivation behind all of the collection pilots was to document the flow of electronic and electrical products into the residential waste stream and to determine if the recovered EEE waste could be recycled in a cost effective manner. In addition, the collection program in Oakland was designed to determine:

· Whether a youth employment training organization (East Bay Conservation Corps) can recycle materials for the Oakland Bulky Waste Collection Program; and · Whether Oakland residents would participate in a curbside EEE waste collection program.

Demographics:

The end of life electronic and electrical waste was collected in three communities. The area is a mixture of blue collar and white collar workers. The Oakland collection program was organized so that the collection would cover a diverse range of household income and property values.

Table 41: San Francisco/ Hayward/ Oakland Demographics Municipality Population Households Median Income San Francisco 723,959 305,984 $40,561 Hayward 111,498 40,246 $40,246 Oakland 372,242 144,766 $37,000 Event Promotion: page 83 The Oakland Collection program was advertised using fliers for the Bulky Waste Pick up sent to Oakland neighborhoods approximately three weeks prior to the collection program. A special insert that outlined the EEE waste collection component was included within the flyer.

Informal interviews with residents during the collection programs indicated that the residents were aware of the EEE waste collection program. However, many appeared not to have separated the EEE waste from the other bulky waste, as was requested in the flyer.

Resident Participation:

The following table outlines the data that was collected on the participation of residents in the various collection pilots.

Table 42: Collection Program Participation Rates Municipality No. of Households Participation Rate San Francisco 13,392 4.4%

Hayward 222 0.6%

Oakland 3,692 2.6%

Collection:

The collection of EEE waste in Oakland coincided with the collection of residential bulky waste. Residents of Oakland can participate in an annual Bulky Waste Pick up day during which Waste Management, Inc. (the city contractor) collects white goods, tires, furniture, and yard trimmings. The program collects from approximately 300 households a day. The bulky waste collection is timed to correspond with residential garbage collection. Two trucks are allocated to the collection of white goods and tires, and the rest of the collected material is picked up by a garbage truck carrying a hopper.

Materials for the Future Foundation worked with the Oakland Recycling/ Solid Waste staff to coordinate the collection of the EEE waste. The collection program occurred over a period of 10 days. To accommodate the extra collection, a driver was added. The cost of the additional driver for the collection was given as $4,300 for the 10 day project. The EEE waste was collected from the curbside, and placed in Gaylords aboard a flat bed truck. When the collection truck was full, the material was transported to the EBCC location for demanufacturing. The following table outlines the equipment that was collected:

Table 43: Items Collected During Oakland Collection Pilot Computer s Vacuum s Heaters Fans TVs VCR s Microwav es Stereo s Oakland 55 93 23 31 198 20 54 117 In addition, the collection events also took in a number of toasters, carpet cleaners, answering machines, and other equipment. In total, 15,623 pounds of equipment was collected during the 10 day program.

Transportation: page 84 The transportation of the collected equipment occurred whenever the truck was full and generally took 15 to 25 minutes, depending on the location of the Bulky Waste collection in relation to EBCC (demanufacturing contractor). No data was available on the costs associated with the transportation.

Demanufacturing:

The East Bay Conservation Corps (EBCC), a youth employment training organization, was the demanufacturer. The collected EEE waste was off loaded at the EBCC facility, where the employees labeled and itemized the equipment. The employees had not been specifically trained to demanufacture EEE waste, and the volume of TVs and microwaves proved to be a challenge to disassemble.

The program required a total of 4 workers and a supervisor working 40 hours per week for two weeks to demanufacture the collected equipment. The off loading of equipment took time away from the dismantling, at least an hour per shipment. The itemizing of the equipment also took some time. Since the contract was for a limited duration, not all of the equipment was disassembled. No data was available on the cost of the demanufacturing of the collected equipment.

Revenue:

The EBCC initially anticipated that the circuit boards and other computer components might generate some revenue. However, since not enough time was available for them to disassemble the equipment, most of the material that was recycled consisted of scrap metal from vacuum cleaners, heaters, and small appliances.

Some of the plastics were sent to a company, MBA Polymers for recovery. Most of material that MBA Polymers was able to recover consisted of plastic from TV housings. No data was available on any revenue from the recovered materials.

Net Cost:

Since the only data available consisted of the additional cost of collection for the Oakland pilot ($ 4,300), net cost was not calculated for this collection pilot.

Project Comments:

The summary reports for all three collection pilots are not yet published, so data was not available for a more detailed analysis. According to the draft report on the Oakland collection program, there were a number of barriers and opportunities that came out of this collection program:

· The residents did not sort their material as requested in the flyers that were sent out, and subsequently the collection process took longer. The Waste Management, Inc. supervisor in charge of the Bulky Waste collection indicated that the drivers should not separate out the EEE waste.

· The demanufacturer was not prepared to demanufacture all of the equipment in the time period of the contract. A number of TVs were left on the curbside because of lack of space in the EPCC facility. In addition, off loading and itemization of the equipment took time away from the actual demanufacturing. The EPCC employees' inexperience with disassembly may have contributed to the partial demanufacturing of much of the equipment. page 85 · MBA Polymers, the company that accepted much of the plastic from EPCC's operations, indicated that the recovery of plastic from residential EEE waste was feasible. The television and computer housing appeared to be the best candidates for recovery. MBA stressed that a sufficient volume of material would be necessary to sustain such an operation, and that a proper level of dismantling would be required to make plastic recovery possible. page 86 9 APPENDIX C: CALCULATING NET COST The cost and revenue values for each of the five collection programs were calculated using data provided by the respective program organizers. No additional data was collected for this report. The total costs and revenue were calculated according to the way in which the data was provided by the participating collection agency:

Per Event Somerville; Binghamton; Wheaton; Naperville Per Period San Jose (5 week period); Union County Municipalities (6 month periods)

Per Year Hennepin County For calculation of the net cost, the following two equations were used:

Total Cost = CT + CD + CU + CO where CT = costs associated with the transport to the demanufacturer CD = costs from the demanufacturing of the equipment CU = upfront costs (publicity etc.)

CO = operating costs.

Total Revenue = RR + RS where RR = revenue from resale RS = revenue from scrap.

Only those costs and revenues for which data was available were used in the equations; that is, if no upfront costs were available (CU ), the value was assumed to be zero.

The net cost per program is essentially the difference between these two values:

Net Cost = Total Cost – Total Revenue The net cost per pound collected was calculated as the net cost divided by the number of pounds of material collected for the program.

The total cost per pound collected was calculated as the total cost divided by the number of pounds of material collected for the program. page 87 10 APPENDIX D: BIBLIOGRAPHY 1. U. S. Environmental Protection Agency, Residential Collection of Household End of Life Electrical and Electronic Equipment: Pilot Collection Project (EPA 901 R 98 002), prepared by Northeast Resource Recovery Association for the Common Sense Initiative – Computer and Electronics Sector, Region I, Boston, MA, February 1998.

2. US Environmental Protection Agency, San Jose Computer Collection and Recycling Pilot: Draft, prepared by Vista Environmental for the Common Sense Initiative – Computer and Electronics Sector, Region IX, San Francisco, CA, February 1998.

3. Union County Utilities Authority, Union County Demanufacturing Program  Semi Annual Report, Union County, NJ, October 1, 1997 March 31, 1998.

4. Bureau of the Census, Census of Population and Housing, 1990, Washington, DC, 1992.

5. U. S. Environmental Protection Agency, Household Hazardous Waste Management: A Manual for One Day Community Collection Programs (EPA 530 R 92 026), prepared by the Waste Watch Center for the Office of Solid Waste and Emergency Response, Washington, DC, August 1993.

6. United States Environmental Protection Agency, Full Cost Accounting for Municipal Solid Waste Management: A Handbook (EPA 530 R 95 041), Office of Solid Waste and Emergency Response, Washington, DC, September 1997.

7. European Commission, Recovery of Waste from Electrical and Electronic Equipment: Economic and Environmental Impacts (AEAT/ 2004 Issue 1), prepared by AEA Technology for the European Commission DGXI, Oxfordshire, UK, July 1997.

8. Keep America Beautiful, Inc., The Role of Recycling in Integrated Solid Waste Management to the Year 2000, prepared by Franklin Associates, Stamford, CT, 1994.

9. Dana Duxbury & Associates, Proceedings of the Fifth National Conference on Household Hazardous Waste Management, Andover, MA, November, 1990.

10. H. Veldhuizen and B. Sippel, "Mining discarded electronics", Industry and Environment, Volume 17, No. 3, United Nations Environment Program, July September 1994.

11. R. Woods, "Handling Difficult Materials", Waste Age. May 1994.

12. Cutter Information Corp., "Europe Moves Toward Integrated Product Policy", Product Stewardship Advisor, September 4, 1998.

13. T. Paddock, "The Costs and Benefits of Household Hazardous Waste Collection Programs", Academy of Natural Sciences, October 1989.