State E-waste Regulator Checklist for CRT Collections
WR3A assists USA companies in exporting working, repairable, and refurbishable computers and CRTs for reuse, as is allowed by the Basel Convention (Annex IX, B1110) and by USA EPA (with notification). While WR3A can provide the 3 years of record keeping requirement that CRTs you export are in fact for reuse and are reused, we also need you to qualify yourself for the collection of ALL CRTs.
Since most CRTs generated in western countries are not valued or repairable, you need to document that you either sent ALL of them to a USA destination capable and willing to remove BAD CRTs, or you must sort them yourself and document how the bad CRTs are managed. WR3A will not handle loads claimed to be 100% tested working without either a USA intermediary or a pre-inspection.
Since CRTs which are NOT collected under these conditions are, upon disposal, subject to HAZARDOUS WASTE (or, in some states, Universal Waste) regulation, you begin by collecting records. Here are some records which any reputable CRT manager should be able to produce:
[_] Records and documentation of storage (not to exceed 1 year)
[_] Purchase Orders detailing maximum quantity per month, minimum quantity per container, acceptable condition, acceptable brands and cosmetics, acceptable ages, prices, process for incidental breakage, etc.
[_] Sea container shipments by BOL, count, port, etc.
[_] Reconciliation report for each sea container actually received by the importer, detailing count, incidental breakage, quality report, and end-use.
With these records in hand, you are prepared for a "walk through" on CRT Enforcement.
[_] Does the site record the total number and tonnage of CRTs (TVs and monitors) you handled in the past period (year, calendar year, etc.)? If so, what is that tonnage?
[_] Does the site record the the total number of CRTs processed (broken, dismantled, shipped for legal export or domestic recycling) in the same period? If so, what is it, in tonnage and as a percentage of total volume?
[_] Does the CRT storage area meet rules for “commodity exemption?” To avoid being a “waste handler” (or universal waste handler) the site manager must show that they are managing the CRTs to preserve repair and reuse value. Otherwise, they are managing hazardous waste.
a. Stored indoors (3 walls and roof minimum) to minimize breakage
b. Handling (containers, stacking methods, etc.) to control and minimize scratching and breakage?
c. CRTs which are destined for recycling are kept on site for not more than one year
[_] Does the site manager keep records of each CRT shipment out of the facility? If they are exporting (directly or through a third party), have they notified EPA of their intent to export for reuse?
[_] If the site manager is exporting for recycling (broken, unrepairable, obsolete, exceeding PO for reuse), have they notified EPA 60 days in advance and obtained a consent order? If not, is the CRT glass separated by chemistry (panel barium, funnel leaded, shadow mask removed, cleaned of phosphor, etc.)?
[_] Is there speculative accumulation? Does the site manager keep records that shipments occur annually in the amount that the facility receives?
[_] If the site manager is exporting for reuse (tested working, repair or refurbishment), are the bad CRTs kept track of (including accidental and incidental breakage), returned to the USA, or does the manager have documentation they were retested for reuse or recycled in a legal and environmentally sound manner (not exported for disposal)?
[_] Does the site manager maintain a list of CRTs potentially containing cadmium phosphor (manufactured before 1972, and “whitish screen” televisions, to limit possible cadmium releases from certain pre 1972 TVs and military grade monitors? (Japanese made CRTs did not contain cadmium before 1972, so Sony, Panasonic, Sharp and Hitachi models are not suspected of containing cadmium).
CRTs have not just been "deregulated". They have been recognized as a potential commodity, but steps must be heeded to ensure that junk CRTs are not shipped as “toxics along for the ride”. Collectors and state agencies must work together to raise meet and enforce the standards already promulgated in federal law.