Progress in U.S. Government Information Technology by Michael Erbschloe - HTML preview

U.S. Government Efforts to Manage E-Waste

“E-waste”, “electronic waste”, “e-scrap” and “end-of-life electronics” are terms often used to describe used electronics that are nearing the end of their useful life, and are discarded, donated or given to a recycler. Though “e-waste” is the commonly used term, the U.S. Environmental Protection Agency (EPA) considers e-waste to be a subset of used electronics and recognizes the inherent value of these materials that can be reused, refurbished or recycled to minimize the actual waste that might end up in a landfill or improperly disposed in an unprotected dump site either in the U.S. or abroad.

An undetermined amount of used electronics is shipped from the United States and other developed countries to developing countries that lack the capacity to reject imports or to handle these materials appropriately. Without proper standards and enforcement, improper practices may result in public health and environmental concerns, even in countries where processing facilities exist.

There are serious concerns about unsafe handling of used electronics and e-waste, in developing countries that result in harm to human health and the environment. For example, there are problems with open-air burning and acid baths being used to recover valuable materials from electronic components, which expose workers to harmful substances. There are also problems with toxic materials leaching into the environment. These practices can expose workers to high levels of contaminants such as lead, mercury, cadmium and arsenic, which can lead to irreversible health effects, including cancers, miscarriages, neurological damage and diminished IQs.

EPA estimates that, in 2009, U.S. consumers and businesses discarded televisions, computers, cell phones and hard copy peripherals (including printers, scanners, faxes) totaling 2.37 million tons. Approximately 25 percent of these electronics were collected for recycling, with the remainder disposed of primarily in landfills, where the precious metals cannot be recovered.

Accurate information about the amounts, types of materials and destinations of used electronics exported will provide valuable information for the Federal government, private industry and other stakeholders. To this end, EPA funded UNU-StEP to lead a study on US exports of used electronics in an attempt to better define the U.S. contribution to the overall e-waste problem. StEP collaborated with the Massachusetts Institute of Technology (MIT) and the National Center for Electronics Recycling (NCER). In December 2013 the final study, Quantitative Characterization of Domestic and Trans-boundary Flows of Used Electronics, was released. It presents a methodology for using existing trade data to calculate U.S. exports and lays out challenges and options for future data-gathering efforts.

The National Strategy for Electronics Stewardship (NSES) provides recommendations on steps the federal government, businesses, and all Americans can take toward achieving the goals identified by President Obama in Executive Order 13693, “Planning for Federal Sustainability in the Next Decade.”

The NSES results from collaboration among 16 federal departments and agencies, collectively known as the Interagency Task Force on Electronics Stewardship, as well as consultation with stakeholders from the electronics, retail, and recycling industries; environmental organizations; state and local governments; and concerned citizens. It has the following goals:

• Build incentives for design of greener electronics and enhance science, research, and technology development in the United States.
• Ensure that the federal government leads by example.
• Increase safe and effective management and handling of used electronics in the United States.
• Reduce harm from U.S. exports of electronics waste (e-waste) and improve handling of used electronics in developing countries.

Interagency Task Force on Electronics Stewardship Members:

•White House Council on Environmental Quality

•U.S. EPA

•General Services Administration

•Office of Management and Budget

•Office of the U.S. Trade Representative

•U.S. Department of Commerce

•U.S. Department of Defense

•U.S. Department of Education

•U.S. Department of Energy

•U.S. Department of Justice

•U.S. Department of State

•U.S. Department of Veterans Affairs

•Federal Communications Commission

•U.S. Customs and Border Protection

•U.S. Postal Service

 

EPA estimates that, in 2009, 438 million electronic products were sold in the United States, and 2.4 million tons were ready for end-of-life management. Both numbers are increasing substantially each year. If properly executed, NSES can increase our domestic recycling efforts, reduce the volume of e-waste that is managed unsafely (both domestically and abroad), strengthen both domestic and international markets for viable and functional used electronic products, and prevent health and environmental threats at home and abroad. As discussed in the NSES and in the subsequent 2014 accomplishments report, federal agencies are working together on various initiatives that will further progress towards these goals. NSES Accomplishments and Ongoing Activities include:

• National Strategy for Electronics Stewardship: Interagency Task Force on Electronics Stewardship - July 20, 2011, strategy to lay the groundwork for improving the design of electronic products and enhancing our management of used or discarded electronics.
• Moving Sustainable Electronics Forward: An Update to the National Strategy for Electronics Stewardship - Interagency Task Force on Electronics Stewardship’s August 2014 update to the 2011 strategy. This accomplishments report highlights some of the key achievements made under the NSES.
• Agency Benchmarks to the Federal National Strategy for Electronics Stewardship - Annex of benchmarks listing each project, the primary agency responsible for the project, any supporting agencies, and the target completion date.
• Implementation Study of the R2 & e-Stewards® Recycling Standards - EPA completed a limited study evaluating the implementation of the two third-party certification programs for electronic waste recyclers in the U.S. - R2 and e-Stewards®. The study fulfills a key commitment under the 2011 National Strategy for Electronics Stewardship for the federal government to lead by example in encouraging the greener design and responsible management of used electronics.

Electronic devices and technologies continue to advance and increase in number. It is likely that our society will continue to incorporate these devices into our daily activities and that the number of electronic devices in our homes and offices will increase. With the prevalence of electronics in mind, the federal government is committed to being a responsible consumer of electronics and a leader of electronics stewardship in the US. This report serves to increase the awareness of the importance of electronics stewardship and recognize the opportunities and challenges created by the exponential growth of electronics in the US. This report focuses on the major achievements under the NSES as of July 2014, as well as the impacts of improved electronics stewardship and the significance of upcoming commitments within the NSES. The report is organized according to the goals established in the NSES:

1. Build Incentives for Design of Greener Electronics, and Enhance Science, Research and Technology Development in the United States;

2. Ensure that the Federal Government Leads By Example;

3. Increase Safe and Effective Management and Handling of Used Electronics in the United States; and,

4. Reduce Harm from US Exports of E-waste and Improve Safe Handling of Used Electronics in Developing Countries.

 

Under each goal, completed and upcoming key accomplishments are highlighted to demonstrate the variety of actions that have been and are being taken under the NSES to create a comprehensive strategy for electronics stewardship. While specific federal agencies are responsible for each action, most would not be accomplished without action by industry, non-governmental organizations (NGOs) or other stakeholders. Recent accomplishments range from the increased number of green design standards and electronics devices that meet them to the expanding the number of third-party certified recyclers and the increased amount and quality of used electronics export information. These initiatives have benefited the environment, public health, and the economy.

The United States Environmental Protection Agency (EPA) conducted a limited study evaluating the implementation of the two third-party certification programs for electronic waste recyclers in the U.S.: the Responsible Recycling Standard for Electronics Recyclers and the e-Stewards Standard for Responsible Recycling and Reuse of Electronic Equipment©. The study suggests that the accreditation, certification and implementation process of the R2 and e-Stewards® standards are working well. Though limited in scope, the study also identifies opportunities for improvement in key areas, including improving stakeholders’ knowledge of health and safety risks, understanding of legal requirements, and awareness of hazardous substances in electronics. The study offers specific strategies for addressing the opportunities for improvement identified in each of the 20 topic areas assessed in the study, which are included in Section 2 of the report and are compiled in Appendix A. Through an analysis of patterns and trends, EPA also developed top recommendations to address the root causes of many of the opportunities for improvement that were identified in the study.

The top recommendations are:

• Provide additional training and guidance materials to grow the knowledge base. Growing the base of knowledge for all stakeholders, including auditors and facilities, is important for ensuring the Standards are implemented properly. In total, 85% of all interviewees – including 100% of Certifying Bodies and 91% of auditors – indicated that more robust training programs are needed in order to strengthen knowledge of health and safety risks, legal requirements – particularly related to exports and management of CRTs - and best operational practices in many of the 20 topic areas.
• Provide regular updates to the Standards to ensure they continue to evolve alongside this rapidly changing industry. E-Stewards and R2 are both relatively new standards and their recent updates went smoothly. Updating and revising the Standards on regular, well-publicized timetables is important to address areas that could benefit from clarification in a Standard or lessons learned from prior audits. Support for more systematic, well-publicized plans and/or timetables for subsequent updates was indicated in 69% of all Top Recommendations
• Increase audit time to allow for more thorough auditing of the Standards. Inadequate audit time was mentioned in 56% of all interviews as a limiting factor, particularly for integrated audits where R2 and e-Stewards are being audited at the same time as other standards, such as RIOS and ISO 14001. In interviews where the adequacy of the amount of time allowed for audits was questioned specifically, 75% of interviewees indicated a desire for increased audit times, as did five of the nine facilities audited. Audit time for ISO 14001-based standards is specified in “IAF MD 5: Duration of QMS and EMS Audits.” To better reflect the complexity of electronics recycling operations, there is a need to fine-tune the formulas found in the R2 Code of Practices and e-Stewards Appendix C to ‘right-size’ audit time. Many facilities can have multi-faceted downstream material flows, export situations, regulatory status, reuse practices, and other variables that pose challenges to the most efficient auditors to adequately review materials and follow audit trails in the allotted time. Moreover, many audits cover multiple standards simultaneously. Increasing audit time would allow auditors to more closely examine health and safety monitoring, measurement, record-keeping, and communication issues in order to give facilities critical feedback on their health and safety systems.
• Explore and address perceived conflict of interest issues to enhance overall rigorousness of the audits. Study participants expressed a concern that there is a perceived conflict of interest between CBs wishing to retain their clients (who are the recycling facilities) and the recycling facilities themselves; that is, the CB auditors may not be as stringent or thorough in their audits in an effort to retain a competitive business relationship. When asked specifically whether they feel that the perception of a conflict of interest exists, 63% of stakeholders interviewed said that they did. Exploring ways in which the key players in the system – Certifying Bodies, recycling facilities, the Standards owners, and ANAB – could potentially address these perceptions of conflict of interest, such as implementing new or different funding mechanisms, could enhance the implementation of the Standards.

 

In practice, many stakeholders will continue to influence and shape the development of responsible recycling in the U.S. As such, EPA encourages all organizations that have a role to play in shaping the standards and certification process to consider the suggested strategies for improvement and top recommendations in the study. This broader group of stakeholders includes:

• The Standard owners (SERI for R2 and the Basel Action Network (BAN) for e-Stewards);
• ANAB;
• The Certifying Bodies;
• Industry trade associations;
• EPA and other federal agencies, including the Occupational Safety and Health Administration, the National Institute for Occupational Safety and Health, and the Department of Transportation;
• State regulators;
• Original equipment manufacturers;
• Academic researchers;
• Non-governmental organizations; and
• Private sector electronics recyling/reuse companies and facilities.

The most effective way to reduce waste is to not create it in the first place. Making a new product requires a lot of materials and energy - raw materials must be extracted from the earth, and the product must be fabricated then transported to wherever it will be sold. As a result, reduction and reuse are the most effective ways you can save natural resources, protect the environment and save money. Benefits of Reducing and Reusing include:

•Prevents pollution caused by reducing the need to harvest new raw materials

•Saves energy

•Reduces greenhouse gas emissions that contribute to global climate change

•Helps sustain the environment for future generations

•Saves money

•Reduces the amount of waste that will need to be recycled or sent to landfills and incinerators

•Allows products to be used to their fullest extent

 

Ideas on How to Reduce and Reuse:

•Buy used. You can find everything from clothes to building materials at specialized reuse centers and consignment shops. Often, used items are less expensive and just as good as new.

•Look for products that use less packaging. When manufacturers make their products with less packaging, they use less raw material. This reduces waste and costs. These extra savings can be passed along to the consumer. Buying in bulk, for example, can reduce packaging and save money.

•Buy reusable over disposable items. Look for items that can be reused; the little things can add up. For example, you can bring your own silverware and cup to work, rather than using disposable items.

•Maintain and repair products, like clothing, tires and appliances, so that they won't have to be thrown out and replaced as frequently.

•Borrow, rent or share items that are used infrequently, like party decorations, tools or furniture.

 

Donation: One person's trash is another person's treasure. Instead of discarding unwanted appliances, tools or clothes, try selling or donating them. Not only will you be reducing waste, you'll be helping others. Local churches, community centers, thrift stores, schools and nonprofit organizations may accept a variety of donated items, including used books, working electronics and unneeded furniture. Benefits of Donation include:

•Prevents usable goods from going into landfills

•Helps your community and those in need

•Tax benefits may be available

 

Electronics donation and recycling is a great way to help conserve resources and natural materials. It is important to make sure you are donating and/or recycling electronics safely and correctly. Electronic products are made from valuable resources and materials, including metals, plastics, and glass, all of which require energy to mine and manufacture. Donating or recycling consumer electronics conserves our natural resources and avoids air and water pollution, as well as greenhouse gas emissions that are caused by manufacturing virgin materials. For example:

•Recycling one million laptops saves the energy equivalent to the electricity used by more than 3,500 US homes in a year.

•For every million cell phones we recycle, 35 thousand pounds of copper, 772 pounds of silver, 75 pounds of gold and 33 pounds of palladium can be recovered.

 

Before Donating or Recycling Used Electronics:

•For computer or laptop, consider upgrading the hardware or software instead of buying a brand new product.

•Delete all personal information from electronics.

•Remove any batteries from electronics because they may need to be recycled separately.

•Check for recycling facilities in your state or community.

 

Federal personal property disposal is regulated under the Federal Management Regulation (FMR), Subchapter B - Personal Property 41 Code of Federal Regulations (CFR) 102. Disposition of federal electronic assets is specifically addressed in GSA FMR Bulletin B-34, Disposal of Federal Electronic Assets. Federal agencies and facilities should also be aware of, and adhere to, relevant federal, state and local laws related to electronics reuse, recycling, and disposal.

The GSA recommends following the reuse process for all federal electronic equipment with condition codes 1 (new), 4 (usable), and 7 (repairable). The GSA recommends following the recycling process for all electronic equipment declared for abandonment and destruction, generally equipment with condition codes X (salvage) and S (scrap). The GSA recommends avoiding disposal of federal electronic equipment and components in landfills or incinerators. These steps are described in further detail below.

1. Reuse Internally. Internal reuse is the first option for disposition of used federal electronics. Some federal agencies and facilities have processes in place to track, redistribute and reuse used electronics within a facility or agency. Look for opportunities to give your electronics a second (or third or fourth) life within your facility or agency.

2. Declared Excess and Reported to GSA. If your used electronics cannot be reused inside your agency, they are considered excess personal property. Generally, excess property must be reported to GSA for possible transfer to and utilization by other federal agencies or authorized recipients.

GSAXcess® is a web-enabled platform that provides authorized users a means of electronically recording, tracking and controlling their worldwide inventory of federal excess and surplus property. Report excess electronics through GSAXcess®. Other options for reporting excess equipment, and exceptions to reporting requirements, are detailed in GSA’s Personal Property Disposal Guide.

3. Donation through Computers for Learning The Computers for Learning (CFL) program allows transfer of excess federal computer equipment to schools and educational nonprofit organizations, giving special consideration to those with the greatest need. The CFL program implements Executive Order (E.O.) 12999, Educational Technology: Ensuring Opportunity for All Children in the Next Century. E.O. 12999 directs federal agencies to give “highest preference to schools and nonprofit organizations in the transfer of educationally useful federal equipment.”

• Excess electronics entered into GSAXcess® may be offered to eligible schools and educational nonprofits through the CFL program.
• Federal entities may opt to directly transfer electronic equipment to eligible schools and educational nonprofits These direct transfers should be reported through CFL’s Post Transaction Module.

 

4. Transfer to Eligible Federal Entities. Excess electronics entered into GSAXcess® that are not transferred under the CFL program are offered to eligible federal entities for reuse. Federal agencies, to the maximum extent practicable, must fill requirements for personal property by using existing agency property or by obtaining excess property from other federal agencies in lieu of new procurements.

• If excess electronics entered into GSAXcess® are not transferred under the CFL program, they are offered to eligible federal entities for transfer.
• Federal entities may opt to directly transfer excess personal property to eligible federal entities.

 

5. Declared Surplus. If your used electronics are not transferred under the CFL program and cannot be reused by another federal entity, they are considered surplus personal property. Generally, surplus personal property is offered through the State Agencies for Surplus Property (SASPs) for further distribution. If excess electronics entered into GSAXcess® are not transferred to eligible CFL recipients or federal entities, they are declared surplus.

Direct transfers: In lieu of reporting excess personal property to GSA, used electronics may be directly transferred to eligible CFL recipients or eligible federal entities. Certain restrictions and reporting requirements apply to direct transfers. See GSA’s Personal Property Disposal Guide for more information.

 

6. Donation to States or Nonprofit Organizations. Surplus electronics may be donated to state and local governments and eligible nonprofit organizations through the SASPs. The SASPs determine eligibility for participation in the donation program and assist eligible donees in locating, screening, and acquiring needed equipment. Surplus electronics in GSAXcess® are offered to state and local governments and eligible nonprofit organizations through the SASPs. Other options for donating surplus equipment are detailed in GSA’s Personal Property Disposal Guide.

 

7. Public Sales. Surplus electronics that are not donated may be offered to the public for sale. Property sales give individuals and businesses an opportunity to buy items the federal government no longer needs. GSA Auctions® is a web-enabled auction site that allows all registered participants to bid electronically on surplus personal property. Offer surplus electronics through GSA Auctions®. Other options for selling surplus equipment are detailed in GSA’s Personal Property Disposal Guide.

IMPORTANT NOTE: Electronics sold to the public, including electronics sold to electronics recyclers, may not necessarily be disposed of in an environmentally sound manner. Executive Order (E.O.) 13514, Federal Leadership in Environmental, Energy, and Economic Performance, requires all federal agencies to use environmentally sound practices with respect to disposition of agency electronic equipment. Under GSA FMR Bulletin B-34, federal organizations are strongly encouraged to only sell equipment in condition code 7 (repairable) if any needed repairs minimally impact equipment performance or repairs can reasonably be performed by a non-technical buyer. If your organization decides that electronic equipment in condition code 7 may be sold (rather than abandoned or destroyed), such equipment should be sold only as individual assets or as individual workstations to facilitate bidder inspection in the interest of encouraging continued use of the equipment after the sale.

 

8. Abandonment/Destruction. Abandonment or destruction of property is generally considered only when reuse, transfer, donation, or sale has been found to be impractical or not cost effective. Obsolete and broken electronics may also be labeled for abandonment/destruction prior to going through the GSA disposition process. This equipment is usually in condition code X (salvage) or S (scrap). Used electronics that have been labeled for abandonment/destruction should be recycled, following environmentally sound practices.

Exchange/Sales: When replacing personal property with similar items, the value of the old items may be used to reduce the cost of the replacement item either by exchange (trade-in) or sale. Certain restrictions and reporting requirements apply to exchange/sales. See GSA’s Personal Property Disposal Guide for more information.

Donating to UNICOR: In lieu of abandonment/destruction, federal entities may donate used electronics to a public body without GSA approval. This allows federal agencies to donate their used electronics to UNICOR for reuse and recycling. See GSA’s Personal Property Disposal Guide for more information.

• Designate electronics that are obsolete, broken or otherwise not able to be transferred, donated or sold for abandonment/destruction.
• Recycle electronics labeled for abandonment/destruction through a third-party certified electronics recycler or refurbisher (e.g., certified under the Responsible Recycling (R2) Practices for Use in Accredited Certification Programs for Electronics Recyclers, or the e-Stewards Standard for Responsible Recycling and Reuse of Electronic Equipment®).

In following this GSA disposition process, federal agencies and facilities may use manufacturer take-back services for electronics disposition through one of two methods:

• Exchange/Sales: When replacing personal property with similar items, the value of the old items may be used to reduce the cost of the replacement item either by exchange (trade-in) or sale with a manufacturer or vendor.
• Abandonment/Destruction: If the manufacturer is willing to take-back obsolete and/or broken equipment, federal agencies may declare the property for abandonment and destruction and use manufacturer take-back services.

An organization may choose to dispose of media by charitable donation, internal or external transfer, or by recycling it in accordance with applicable laws and regulations if the media is obsolete or no longer usable. Even internal transfers require increased scrutiny, as legal and ethical obligations make it more important than ever to protect data such as Personally Identifiable Information (PII). No matter what the final intended destination of the media is, it is important that the organization ensure that no easily re-constructible residual representation of the data is stored on the media after it has left the control of the organization or is no longer going to be protected at the confidentiality categorization of the data stored on the media.

Sanitization refers to a process that renders access to target data on the media infeasible for a given level of effort. This guide will assist organizations and system owners in making practical sanitization decisions based on the categorization of confidentiality of their information. It does not, and cannot, specifically address all known types of media; however, the described sanitization decision process can be applied universally.

Information disposition and sanitization decisions occur throughout the information system life cycle. Critical factors affecting information disposition and media sanitization are decided at the start of a system’s development. The initial system requirements should include hardware and software specifications as well as interconnections and data flow documents that will assist the system owner in identifying the types of media used in the system. Some storage devices support enhanced commands for sanitization, which may make sanitization easier, faster, and/or more effective. The decision may be even more fundamental, because effective sanitization procedures may not yet have been determined for emerging media types. Without an effective command or interface-based sanitization technique, the only option left may be to destroy the media. In that event, the media cannot be reused by other organizations that might otherwise have been able to benefit from receiving the repurposed storage device.

A determination should be made during the requirements phase about what other types of media will be used to create, capture, or transfer information used by the system. This analysis, balancing business needs and risk to confidentiality, will formalize the media that will be considered for the system to conform to FIPS 200.

Several factors should be considered along with the security categorization of the system confidentiality when making sanitization decisions. The cost versus benefit tradeoff of a sanitization process should be understood prior to a final decision. For instance, it may not be cost-effective to degauss inexpensive media such as diskettes. Even though Clear or Purge may be the recommended solution, it may be more cost-effective (considering t