What’s the Risk of “No Cost” Computer Recycling?

“It’s not recycling. It’s used equipment resale”

Recycling of electronics costs money. The recovery value of the materials used in electronic manufacturing does not cover the costs of the recovery effort. A number of materials used in the manufacturing of electronics are potentially hazardous to humans if improperly disposed of. Because of this 25 States including CT, NY, NJ, PA require the recycling (not remarketing) of to-be disposed of electronics and this effort must be done by a qualified recycler.

You, as the original owner, always retain a financial responsibility for the proper disposal of your computer

equipment.

Remarketing of you obsolete computer equipment, rather than recycling it, extends the life cycle of the equipment. You have no control over where the equipment will wind up. If the equipment is eventually disposed of improperly you can be held financially liable for the cleanup. This is a very real risk. Over the last several years there have been numerous business failures by computer recycling companies that have illegally accumulated leaded CRT glass amounting to millions of pounds hoping the cost of recycling of the glass would go down. Recycling customers of these businesses are being accessed portions of the costs to dispose of the accumulated hazardous material.

Why does this type of thing happen?

Used computer reseller’s business profitability is based upon maximizing the resale value of the equipment they acquire and minimizing handling costs and the costs associated to the disposal of non-reusable material. These objectives can and do result in a conflict of interest between what’s in their best financial interest and your organization’s IT disposal desires and responsibilities. Recently a number of computer resellers were caught illegally exporting non reusable electronics rather than pay for US based recycling in clear conflict with their customers desires. Resellers will also seek to maximize the resale value of the reusable equipment. A computer with a hard drive in it is a lot more valuable than a computer without a hard drive. It costs money to properly sanitize a used hard drive and sanitization doesn’t always work. There is very little risk to the reseller to minimize their cost and maximize their profit by short cutting the sanitization effort. Evidence that this regularly happens is shown in recent studies that have found that over 80% of all used hard drives purchased over the internet still contain recoverable data. The reseller recognizes the financial rewards and you inherit all of the risk, hardly a good bargain.

What Should I do to protect my company?

• Use a “qualified” recycler. This can be a significant challenge. Each of the 25 states has their own definition for qualified computer recyclers located in their state. 7 States have classified electronics as a form of hazardous waste known as universal waste. (Arkansas, California, Colorado, Connecticut, Louisiana, Michigan, Nebraska, New Jersey). These states follow the US EPA universal waste handling regulations and require that any entity physically processing a universal waste must be a licensed universal waste destination facility. Computer recycling, electronic recycling, e-waste recycling. IT asset recycling is the disassembly and separation of components and raw materials of waste electronics and is considered processing. All 50 states have adopted the Federal EPA universal waste handling regulations. Using a licensed universal waste electronics recycling destination facility is a simple and efficient way of eliminating all the different state e-waste recycling definitions of qualified recycler.
• As a licensed universal waste electronic recycling destination facility (CDG120002) we are legally recognized as a qualified computer recycler in all 50 states and have the US EPA authority (NJR000075416) to issue a legally valid environmental compliance certificate that terminates your environmental liability.
• R2 and E-Steward electronic recycling standards are voluntary handling standards that are also designed to provide a solution to the confusion over the lack of a national computer recycling standard. While these standards are a valuable vendor due diligence measuring tool they do not offer any legal authority to protect you from environmental regulatory liabilities. It should be noted that R2 and E-Steward certified computer recyclers are regularly fined by the Federal EPA for circumventing CRT disposal regulations. If these recyclers go out of business, and many of them do, you could be held financially responsible for the significant cost of the leaded glass clean up even though they were R2 and E-steward certified. You would have no financial liability if you used a universal waste destination facility.
• Have a serial number chain of possession audit trail for computer disposal activity. The ability to match an electronic equipment serial number chain of possession listing to a legally valid environmental compliance certificate is fundamental to closing your environmental liability. We provide an “EPA audit” report for every IT recycling project identifying the manufacturer, model, serial number and weight of each item of IT equipment recycled. This document along with all other project documents is store in our cloud based document archive “Compliance Library” You will never need to worry about where your IT asset disposal documents are again.
• Recognize the risk of asset remarketing. Recycling your obsolete IT equipment destroys the serial number tracking of your equipment. Remarketing a serial number device continues your environmental liability and you lose control of your serial number “chain of possession” audit trail.

Is a short term budgetary advantage worth a long term organizational liability?

Back Thru The Future is the only onsite hard drive shredder in the US that is a licensed Universal Waste Destination Facility for electronics and also NAID AAA certified secure data destruction facility. These are important data privacy regulatory compliance qualifications.