Clearing up the CRT rules

The proposed changes to rules governing the recycling of Cathode Ray Tubes were a topic of hot conversation in Las Vegas last month.

William Damico, a Region 5 EPA Enforcement Officer, spoke at the recent Institute of Scrap Recycling Industries’ annual Convention and Expo in Las Vegas, hoping to offer the EPA’s viewpoints on the rule and to clear up any confusion on what the government agency is trying to accomplish by revising its regulations.

The electronics recycling industry is currently operating under a CRT rule passed on July 28, 2006.

“There was a misconception that the rule brought the cathode ray and other monitor tube devices in the realm of regulation of hazordous waste,” Damico said. “Actually, they always were. We weren’t very active in enforcing those rules.”

The rule didn’t clearly address many of the realities of exporting CRTs for recycling, Damico said.. A revision by the EPA in 2011 hopes to clarify the government’s position on management of the materials and how the EPA plans to enforce the regulation.

“CRTs are a limited commodity, not going to be with us forever and it’s possible the market will disappear before amount of CRT disappears,” Mark Murray, Californians Against Waste. “It’s not just about CRTs, it’s about other hazardous materials we can use in this way.”

In order for others to utilize those recyclable items, it’s a must for recyclers to dismantle the product before shipping it out of the United States’ borders, Murray said. He noted his organization is supporting barring the trans-state shipping of non-dismantled CRTs for recycling.

“The recycler won’t get paid unless they’ve demonstrated they’ve dismantled the device or demonstrate sending to an approved dismantler.”

If that isn’t done, some recyclers may just hold on to those items for an infinite amount of time and, if enough stack up enough, they might be on the next episode of A&E’s “Hoarders.”

Leaded glass found in the CRTs must be included in the recycling loop, but the markets for the material are drying up. Prices have declined drastically in recent years, said David Cauchy of Closed Loop Recycling.

“It’s a significant change economically,” Cauchy said. “The market hasn’t adjusted to it, in my opinion. It’s a serious issue, when you talk about the tonnage that’s available and the technologies that are available to recycle it. It’s a serious issue in the e-waste industry.”

Cauchi said the CRTs need to be recycled as a whole and not just end up a fodder for a landfill.

“We feel there should be places where CRTs are processed in their entirety and make a profit at that facility so it could compete with landfills,” he said.

EPA’s proposal to impose additional notification requirements on exporters handling used, intact CRTs intended for re-use raises jurisdictional issues, according to the Institute of Scrap Recycling Industries.  Despite RCRA (Resource Conservation and Recovery Act) jurisdiction being limited to materials that have been “discarded,” the proposal intends to expand EPA’s reach to also cover used, functioning CRTs exported for reuse.  The rationale is based on the grounds that the export of such used products might actually be intended for some purpose other than re-use and therefore raising a concern that the CRT’s might be improperly discarded at a future date and place.  This assertion is contrary to US law as RCRA’s jurisdiction does not extend to reusable CRTs, especially functional units, ISRI says.

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