MEC&F Expert Engineers : POTENTIAL OCCUPATIONAL OVEREXPOSURE TO LEAD, CADMIUM, CHROMIUM, MERCURY AND NOISE AT ELECTRONIC SCRAP RECYCLING FACILITIES

Potential Occupational Overexposure to Lead, Cadmium, Chromium, Mercury and Noise at Electronic Scrap Recycling Facilities – EMERGING GLOBAL THREATS FROM E-WASTE

Background

E-waste (electronic waste) is the fastest growing waste stream in many countries. The U.S remains the world’s largest e-waste polluter closely followed by China, according to a U.N think tank study.

E-Waste- which includes phones, televisions, laptops and computers, poses danger to humans and the environment alike due to lead, mercury and other poisonous toxins present in batteries.

The StEP initiative reports the U.S dumped more than 9.4 million metric tons of e-waste in 2012, more than 2 million metric tons more than its economic rival. Per Capita, each person in the U.S is responsible for 30 kilograms (66 pounds) compared to the global average of 7 kilograms (15 pounds) per person.

Recycling of the E-Waste

Go Green! Recycle! We have all heard the call to be more environmentally conscious. However, not everyone is aware of the many health and safety hazards facing employees who handle the recycling of electronics. Many recycled electronics can contain hazardous materials such as lead, cadmium and other toxic metals. In 2011, the U.S. e-scrap recycling industry contributed approximately $90 billion to the U.S. economy, compared with less than $1 billion in 2002 [ISRI 2014]. The ‘e-scrap’ recycling industry is also called ‘e-waste’ or ‘e-cycle.’ This industry sector generated about 138,000 direct jobs in 2011, up from 6,000 employees in 2002, and recycled more than 130 million metric tons of materials in 2010 [ISRI 2014]. To better document the hazards, the National Institute for Occupational Safety and Health (NIOSH) has completed exposure evaluations at several electronics recycling facilities and conducted a survey of electronics recycling facilities across the United States.

Recent NIOSH Health Hazard Evaluations

Through the NIOSH Health Hazard Evaluation (HHE) Program we have measured employee exposures to lead, cadmium, chromium, and noisein e-scrap recycling facilities. We found that employees in facilities that process cathode ray tube (CRT) glass, including employees in areas away from where the CRT glass is processed, can be overexposed to lead and cadmium. At some facilities, we have found lead, cadmium, and other toxic metals on surfaces outside of production areas, ineffective engineering controls, and poor employee work practices such as dry sweeping (causes dust laden with toxic metals to be swept back into the air). NIOSH has also found conditions that can lead to “take-home” exposures; for example, in some e-scrap recycling facilities the employees did not have access to showers or work uniforms. As a result, employees tracked contamination through the facility and to their personal vehicles, and potentially to their homes. More information and prevention recommendations can be found in the HHE reports listed below.

Given that results from hazard evaluations at individual sites might not be representative of an industry as a whole, we conducted a telephone survey of 47 facilities in the United States to provide a broader picture. Through the survey, we identified several types of occupational health hazards in the e-scrap recycling industry. We learned that responding facilities 1) had between 10 and 80 employees, 2) recycled a wide array of electronics, and 3) performed manual recycling processes. Some facilities had practices indicative of poor control of dust generated during recycling. The survey showed that e-scrap recycling has the potential for a wide variety of occupational exposures and that educating the industry about health and safety practices was needed to help protect employee health. More information can be found in the survey report

Recycled phones before being shredded.

NIOSH shared information from the HHEs and survey with the Institute for Scrap Recycling Industries, Incorporated (ISRI), R2 Solutions (now called Sustainable Electronics Recycling International [SERI]), and the Basel Action Network (BAN). These organizations administer the Recycling Industry Operating Standard™ (RIOS™), the Responsible Recycling Standard for Electronics Recyclers (R2,) and the e-Stewards® Standard for Responsible Recycling and Reuse of Electronic Equipment (e-Stewards®). These are voluntary certification standards for electronic recyclers. Continued efforts are needed to ensure that occupational health and safety considerations are an important component of voluntary certification programs.

Participate in a New NIOSH Study

Starting Fall 2014, NIOSH will begin a study to evaluate occupational exposures to metals and flame retardants in e-scrap recycling facilities and to recommend controls to reduce employee exposures. The HHE Program is looking for five facilities that would like to participate. We plan to observe work processes and practices, and evaluate exposure controls and employee health. During the visits, a team of industrial hygienists and medical officers will assess occupational exposures to workers at each facility, including metals (such as lead, cadmium, and indium) and flame retardants (such as polybrominated diphenyl ethers and newer alternatives). We will also evaluate engineering controls such as local exhaust ventilation, and the use of work practices and personal protective equipment at these workplaces. There is no cost to the facility to participate. The findings and recommendations from these evaluations will be shared with employer and employee representatives at each facility and will be posted on the NIOSH HHE Program website.

Seeking Feedback

NIOSH is interested in learning more about employee exposures to other harmful materials, physical hazards, or other stressors at e-scrap recycling facilities. Let us know what e-scrap health and safety hazards you think have not been well studied. We also want to learn about measures that have been effective in preventing or minimizing these workplace hazards.

Regulations/Standards

Legislative Recycling Mandates

Federal Legislative Mandates for Electronics Recovery: At present, there is no Federal mandate to recycle e-waste. There have been numerous attempts to develop a Federal law. However, to date, there is no consensus on a Federal approach.

State Mandatory Electronics Recovery Programs: Many states have instituted mandatory electronics recovery programs. The following website provides regularly updated information on state e-waste legislation:

National Electronics Recycling Infrastructure Clearinghouse

Regulations Governing Management of Used Electronics

Some electronics (such as color CRT computer monitors, color CRT TV tubes, and smaller items such as cell phones and other hand-helds) test hazardous under Federal law. If so, they are subject to special handling requirements under Federal law, subject to certain exemptions. It is the generators' responsibility to determine if their materials are hazardous waste. For more information on hazardous waste identification, see the Waste Determination webpage.

EPA encourages reuse and recycling of used electronics, including those that test hazardous. To facilitate more reuse and recycling of these products, EPA has less stringent management requirements for products bound for reuse and recycling. Specifics follow:

Resale or Donation: Computer monitors and televisions sent for continued use (ie. resale or donation) are not considered hazardous wastes.

Federal Regulatory Requirements for Recycling of CRTs: EPA encourages recycling of CRTs. Thus, CRTs sent for recycling are subject to streamlined handling requirements. For more information on the CRT Rule, including export requirements and frequent questions please see Cathode Ray Tubes Final Rule.

Federal Regulatory Requirements for Circuit Boards within the United States: Circuit Boards are subject to a special exemption from Federal hazardous waste rules.

Whole unused circuit boards are considered unused commercial chemical products, which are unregulated.
Whole used circuit boards meet the definition of spent materials but also meet the definition of scrap metal. Therefore, whole used circuit boards that are recycled are exempt from the hazardous waste regulations.
Shredded circuit boards are excluded from the definition of solid waste if they are containerized (ie., fiberpaks) prior to recovery. These shredded circuit boards cannot contain mercury switches, mercury relays, nickel-cadmium batteries, or lithium batteries. If these materials are not treated this way, then they are considered hazardous waste and must be treated as such.

Note: This discussion summarizes relevant federal regulatory requirements. For the complete federal hazardous waste requirements for generators, consult 40 CFR Parts 260-262.

Federal Regulatory Requirements for Disposal CRTs and Other Electronics that Test Hazardous

Large Quantities Sent for Disposal: Wastes from facilities that generate over 100 kilograms (about 220 pounds) per month of hazardous waste are regulated under Federal law when disposed. CRTs from such facilities sent for disposal (as opposed to reuse, refurbishment or recycling) must be manifested and sent as hazardous waste to a permitted hazardous waste landfill.

Small Quantities Exempt: Businesses and other organizations that send for disposal (as opposed to reuse, refurbishment or recycling) less than 100 kilograms (about 220 pounds) per month of hazardous waste are not required to handle this material as hazardous waste. If a small-quantity generator wishes to dispose of a small quantity of CRTs or other used electronics that test hazardous under Federal law, these materials can go to any disposal facility authorized to receive solid waste (eg. a municipal landfill), unless state law requires more stringent management (eg. CA).

Household Exemption for Electronics Sent to Disposal: Used computer monitors or televisions generated by households are not considered hazardous waste and are not regulated under Federal regulations. State laws may be more stringent as reqards electronics from households (eg. CA).

State Regulatory Requirements for Disposal of Electronics that Test Hazardous

State regulatory requirements for e-waste can be more stringent than the Federal requirements, and vary from state to state. California considers CRTs to be spent materials and regulates all CRT as hazardous waste, ie. they are banned from landfills. Other states, such as Massachusetts and Florida, have taken steps to streamline hazardous waste regulations for CRTs, reducing special handling requirements if these products are directed to recycling. Many states are developing Universal Waste exemptions for CRT which also streamline management of CRTs bound for recycling. If you are planning on disposing used CRTs (or other electronics that test hazardous under state or Federal law), check relevant state requirements, which might be different from federal regulatory requirements.

Presentation

EPA's Regulatory Program for E-Waste (PDF) (19 pp, 126K, about PDF)

E-WASTE RECYCLING IN CANADA

Servers were the size of refrigerators and a single CPU chip had about $300 of gold when Montreal-based electronics recycling company FCM Recycling started harvesting precious metals from computers’ circuit boards and memory. Last week, I chatted with FCM representatives Chris and Andrew about the the work they’re doing and the e-waste climate in Canada.

FCM was founded as a small metals recycling facility in 1991, when electronic waste was a new enough problem that it hadn’t been legislated or regulated. They would dissolve circuit board fiberglass in big vats of caustic acid, to collect the gold, silver, and palladium left behind. Any materials they couldn’t use were discarded.

Eventually, as computers got smaller (and used less precious metal), FCM became a more traditional scrapyard. Then, in 2005, they were approached by Recyc-Québec, a government body that takes care of recycling mandates, about starting provincial electronics recycling programs. They installed their first shredder in 2007 and started processing e-waste in Québec.

Growing from Coast to Coast

Since then, they have expanded across the country: two facilities in Ontario (Cornwall and Toronto), two in Québec (and will be opening up a third in Québec City), one in the Maritimes (Halifax), and one in British Columbia. Their main shredder is in Montreal—other locations collect, sort, and dismantle electronics, and then send the materials to Montreal.

Today, thanks to regulation, urban mining, corporate participation, and better recycling practices, far less material ends up in landfills than 20 years ago. FCM now treats about 30 millions pounds of electronic goods per year, everything from cell phones and laptops to medical equipment. They trash less than 1% of all the material that goes through their facility, including all packaging material (shrink-wrap, gaylords, bags, skids—everything). The rest is recycled into various products: wire, ferrous and non-ferrous scrap, and a clean plastic shred. They have special processing lines for getting indium from flat screens and mercury from mercury switches.

How is E-Waste Different in Canada?

So what’s different about e-waste recycling in Canada? Not much, at one level. The tools and the process are pretty much identical to those used by US recyclers. Shredders like the one in the picture above can be found at almost any large e-waste recycling facility around the globe.

National regulations are fairly similar, too. Just like the US R2 and e-Stewards certifications, Canadian recyclers are certified by Electronics Product Stewardship Canada (EPSC), which lays out health and safety workplace guidelines, requirements for environmentally friendly e-waste processing, and regulations about what can be exported to other countries. EPSC, Chris and Andrew say, is maybe slightly more rigid about downstream accountability—they have to do a little bit more tracking of raw materials that leave their facility. Unlike the US, Canada has ratified the Basel Convention and prohibits export of unfinished goods to non-OECD countries (any country not on this list, that is).

E-waste management is funded somewhat differently in Canada. In the US, e-scrap is what Andrew calls “a commodity market”—in many states, people are paid for the materials they bring in. In Canada, he says, although individual recyclers are for-profit businesses, e-waste as a whole is “more of a social program supported by eco-fees.”

But the biggest difference between the US and Canada is in the way EPSC works to harmonize standards across provinces. Because the EPA encourages states to develop their own hazardous waste regulations, the requirements for US recyclers vary drastically from state to state. So far, 25 states have e-waste legislation, but the laws are conflicting and confusing. Sometimes recyclers pay, sometimes manufacturers pay, sometimes consumers pay. Because of the varying demands of different state laws, R2/RIOS, and e-Stewards, it’s difficult for a US recycler to expand into other states the way FCM has expanded into other provinces. Only a few US recyclers, such as Electronics Recyclers International, have locations in multiple states. Some attempts to harmonize US laws have been made—there’s an organization dedicated to harmonizing US e-waste laws called the Electronics Recycling Coordination Clearinghouse. No efforts, however, have been as effective as EPSC.

Harmonization does slow down the process of starting a new program a bit—Chris says that the biggest hurdle is that the entire collection, payment, and auditing system has to be set up before a program can launch. But it also enables companies like FCM to expand across the country, without having to meet vastly different standards from province to province.

Cell Phone Refurbishment

And the vast network of connections they’ve made by expanding—they are involved with national organizations like Big Brothers Big Sisters and the Scouts—helps them get the volume they need for new projects, such as the cell phone reuse and refurbishment program they are starting this year. Andrew says they receive more than 8,000 cell phones each month. Not all of those are reusable, of course. He points out that often it may not be worth the time, effort, and transportation costs involved in refurbishing a device, if it will end up in a landfill in six months anyway.

But many of the phones they receive could easily have a couple more years of useful life. Smartphone sales just overtook desktop sales for the first time last year, Andrew tells me, quoting a recent E-Scrap News article. Many of those sales are people upgrading from one smartphone to another. Our friends at Recellular, for example, say they always receive a big influx of phones on the day a new smartphone is announced. So FCM is taking steps to begin selling refurbished phones.

SUMMARY

The Internet and our current technology have changed how we live and communicate, but it also has a negative impact on our environment.

From computers, cell phones and tablets, to iPods and television sets – electronics are a part of our everyday, modern life. With our consumer culture and companies relying on “planned obsolescence” to ensure that we continually purchase more of these items, it equates to more e-waste piling up at landfills. And the cost is higher than the impact on your bank account.

Electronic waste isn’t just waste. It contains some very toxic substances, such as mercury, lead, cadmium, arsenic, beryllium and brominated flame-retardants. The toxic materials in electronics can cause cancer, reproductive disorders, endocrine disruption, and many other health problems if not properly managed. Scientists also say they also present risks to communities and the global ecosystem.