Requirements and Best Practices for Electronics Collection - DNR ELECTRONICS COLLECTOR VIRTUAL WORKSHOP - MARCH 23, 2021 MARCY MCGRATH, WISCONSIN ...
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Requirements and Best Practices for Electronics Collection DNR ELECTRONICS COLLECTOR VIRTUAL WORKSHOP – MARCH 23, 2021 MARCY MCGRATH, WISCONSIN DNR, E-CYCLE WI COMPLIANCE SPECIALIST
Importance of Best
Management Practices
(BMPs)
Maintain recyclability of materials
Site safety for both staff and customers
Provide better efficiency for site
management
Protect human and animal health
Protect the environment
Reduces hazardous waste requirements for
electronics destined for recycling if certain
conditions are met
https://dnr.wi.gov/files/pdf/pubs/wa/wa1736.pdf
State statutes and code applicable
to electronics recycling
S. 287.07(5), Wis. Stats. – Electronics disposal bans
S. 287.17, Wis. Stats. – Electronics recycling law that
governs E-Cycle Wisconsin
S. 289.05(1), Wis. Stats. – Solid waste rulemaking authority
Ch. NR 500, Wis. Adm. Code – General solid waste
management requirements
Ch. NR 502, Wis. Adm. Code – Solid waste storage,
transportation, transfer and processing
Ch. NR 520, Wis. Adm. Code – Solid waste management
fees and financial responsibility requirements
NR 600 series of administrative code – hazardous waste
requirements
https://dnr.wi.gov/files/pdf/pubs/wa/wa1307.pdf
Site selection • A building is best • Enclosed trailers work too • If storing outdoors, remove materials frequently • Broken CRTs MUST BE containerized OR stored indoors • Think about view from the road
Site security
Gated
Cameras
Hours posted
Citations posted Electronics containing
sensitive data need
additional security
Best alternatives to buildings
Outdoor storage
No protection from weather,
vandalism or theft
Difficult to clean up broken
materials
If outdoor storage is only option:
Place on pallets and prepare for
shipping
Use a paved area
Arrange for more frequent
shipping
Consider closing collection site in
the winter
Preparing
electronics for
recycling
Talk to your recycler
Any steps you can take to reduce
costs?
What do they provide for
packaging?
Keep site safety in mind
Consider height of stacks
Watch for cords
Stability of Gaylords and
palletized materials
Maintain aisle space
Prepare and train staff on site
safety plan
Minimize chance for breakage
Consolidate smaller electronics in Gaylords
Larger electronics can be placed on pallets
Place flat panel screens facing inward
Cardboard placed between screens provides
cushioning
Secure with shrink wrap
Stacks should not exceed 5-7 feet
Send materials off-site to a legitimate
downstream vendor within 1 year!
Sorting electronics
Label containers with contents and date
that you started placing items in it
Keep non-eligible electronic devices
(non-EEDs) separate
Eligible items must come from households
and K-12 schools
Not on the list of eligible devicesSite operator
training
Establish a procedure for
broken and damaged
electronics
Electronics contain some
hazardous materials that
require special
management
Older style TVs contain
cathode ray tubes
with high lead content
LCD TVs and monitors
contain fluorescent
tubes with mercuryBroken CRT glass Storage – Must be in a building with a roof, floor, and walls or a container constructed to minimize releases Label - “Used cathode ray tubes - contains leaded glass” OR “Leaded glass from televisions or computers” AND “Do not mix with other glass materials” May not be accumulated speculatively
Devices containing Li batteries
• Fire risk when batteries are damaged
• Watch for swelling/visibly damaged batteries
and place in a container with material to
prevent a thermal event: sand, kitty litter or
CellBlockEX (product is available through
Call2Recyle)
• Call2Recycle battery safety training and
resources: ttps://www.call2recycle.org/
• USDOT transportation requirements:
https://www.phmsa.dot.gov/lithiumbatteries
• DNR battery resources:
dnr.wi.gov/topic/recycling/batteries.htmlKeep clear separation between eligible and non-
eligible materials
Keep records of where materials go downstream—
including end markets for hazardous materials
BMP—keeping your own records on top of what the
Recordkeeping recycler provides
Record all collection events or sites
Maintain records for minimum of 3 yearsLandfill and incinerator ban enforcement
https://dnr.wi.gov/files/PDF/pubs/wa/wa1494.pdf Notify clients of recycling requirements upon
contract and annually thereafter (required)
Develop a plan on how to manage program
When to inspect loads
Waste haulers’ When to reject loads
Fee structure for violations
responsibilities
Reject loads that clearly contain electronics
Tag and leave at the curb
Send a notice with information on how to recycle
Pick up and charge a fee Develop plan to enforce disposal ban
Question vehicle drivers about what their load
contains
Reject loads that are clearly in violation of the
electronics disposal ban
If load cannot be rejected, notify hauler of
Waste facility
violation and charge appropriate fees
operators’ For significant cases, consider contacting DNR to
investigate
responsibilities Remove electronics if it can be done safely
Designate a recycling area
Work with a recycler to accept materials
Take enforcement action against illegal dumping
Note: DNR allows electronics to count for program
credit if they appear to be household materialsSurviving tough economics
Consider collection frequency
Hold special collection events one or more
times/year
Operate a permanent collection site (could be
limited hours)
Additional options for either events or permanent sites:
Restrict access (only customers or residents of
certain area)
Restrict number of items per visit
Restrict type of items
Charge a feeFee options
Price/lb
Matches how recyclers charge, but requires a scale
and more labor at site
Less predictable for customers
Price/item
Requires staff at site to tally items, but deal with
predictable, whole dollar amounts
Many do a graduated scale for different size/type of
TVs
Flat fee for access to site
Easy to administer, but might not cover all costs
Could charge a flat fee for a limited number of items,
add per-item fee if someone brings additional
electronicshttps://dnr.wisconsin.gov/topic/AirQuality/Refrigerants.html
Resources for collectors Collector best management practices handouts and videos “What happens when I e-cycle?” video Tips for choosing a responsible electronics recycler “Your role” overview for RUs Updated collector FAQs https://dnr.wi.gov/topic/Ecycle/collectors.html
DNR website: https://dnr.wi.gov/topic/ecycle Sarah Murray, E-Cycle WI coordinator sarah.murray@wisconsin.gov 608-234-0533 Marcy McGrath, E-Cycle WI compliance specialist marcy.mcgrath@wisconsin.gov 920-632-3076 Ashley Hoekstra, E-Cycle WI compliance specialist ashley.hoekstra@wisconsin.gov 608-381-4011
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