Photovoltaic - Solar Modules Proposed As California Universal Waste

California Department of Toxic Substance Control has proposed regulations to add photovoltaic - solar modules as a category under the Universal Waste regulations. Solar modules are a form of photovoltaic technology where a semiconductor material, such as silicon, cadmium telluride or copper indium selenium, is encapsulated between two sheets of tempered glass. Solar modules are relatively simple, being comprised predominantly of a silicon or semiconductor substrate, which for thin–film modules is a thin layer of two or more metal– based semiconductors applied to the surface of glass. Solar modules are likely to exhibit the characteristic of toxicity due to heavy metals (such as cadmium, copper, lead, and selenium) and thus would be classified as hazardous waste, if disposed.

Currently, the volume of waste solar modules in California is very small with the exact number unknown. However, with the increase in deployment of solar modules throughout the state to meet its increasing energy needs, as well as meet the renewable energy goals established by the Governor, that volume of waste solar modules is anticipated to increase at a steady rate over the next 20 years.

The broad objectives of the DTSC regulations are to:

• Establish a conditional exemption in section 66261.6 (recyclable materials) for non–RCRA hazardous waste solar modules that are collected, transported and recycled by being reclaimed as part of a reclamation program administered by a solar module vendor (as defined in the proposed regulations).
• Designate hazardous waste solar modules, that are either RCRA hazardous waste or non–RCRA hazardous waste, as universal waste provided that the solar modules are recycled, not disposed, and are managed in accordance with the existing requirements of chapter 23 (Standards for Universal Waste Management).
• Maintain the existing hazardous waste requirement for recycling activities, including reclamation activities and other forms of hazardous waste treatment activities, which require a hazardous waste facility permit or other grant of authorization from DTSC.

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OSHA Guidance On Protecting Workers During Crushing & Recycling Fluorescent Bulbs

OSHA has issued two new educational resources to help protect workers from mercury exposure while crushing and recycling fluorescent bulbs. Compact fluorescent bulbs are more efficient than incandescent bulbs, but the shift to energy-saving fluorescents, which contain mercury, calls for more attention to workers who handle, dispose of, and recycle used fluorescent bulbs.

An OSHA fact sheet explains how workers may be exposed, what kinds of engineering controls and personal protective equipment they need, and how to use these controls and equipment properly. In addition, a new OSHA Quick Card alerts employers and workers to the hazards of mercury and provides information on how to properly clean up accidentally broken fluorescent bulbs to minimize workers' exposures to mercury.

According to OSHA, fluorescent bulbs can release mercury and may expose workers when they are broken accidentally or crushed as part of the routine disposal or recycling process. Depending on the duration and level of exposure, mercury can cause nervous system disorders such as tremors, kidney problems, and damage to unborn children.


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Illinois Electronic Products Recycling and Reuse Act

Illinois Environmental Protection Agency has notified computer, television and printer manufacturing companies doing business in Illinois of statewide collection and recycling requirements as they implement recycling programs for excess electronic waste (e-waste). The Illinois Electronic Products Recycling and Reuse Act requires electronic manufacturers and retailers to properly manage discarded and unwanted electronic products, if they sell their products in the state. They must establish a system for recycling and/or reusing computers, monitors, televisions and printers discarded from residences. Beginning January 1, 2012, computers, monitors, televisions and printers will be banned from landfill disposal.

Each year, the Illinois EPA sets a statewide goal for the amount of e-waste that must be recycled and then allocates that goal among electronics manufacturers based on various formulas included in the Act. The statewide recycling goal for 2010 is 31 million pounds of e-waste. Manufacturers are required to pay for e-waste recycling and/or refurbishment up to the amount of their annual goal.

The law does not specify methods for manufacturers to meet these obligations, allowing a free market approach to determine over time the most cost-effective means of annual goal achievement.

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Missouri DNR Electronics Scrap Management Rule

The Missouri Department of Natural Resources (DNR) has completed rulemaking under to regulate the collection and recycling of computers under 10 CSR 25-19.010 Electronics Scrap Management. These rules were required in the Manufacturer Responsibility and Consumer Convenience Collection and Recovery Act. The Act requires manufacturers of computers to implement recovery plans for the collection and recycling or reuse of their obsolete equipment. The recovery plan must be implemented and a copy of the plan submitted to the Department of Natural Resources before the manufacturer can sell its computers in Missouri. Manufacturers must also label their equipment to identify themselves as the manufacturer.

Requirements for the recovery plan and reporting by computer manufacturers are listed in the Act. Retailers are prohibited from selling new computers in Missouri unless the equipment contains a manufacturer's label and the manufacturer is listed by the department as having a recovery plan.

The Act required the DNR to promulgate rules by July 1, 2009 to implement the law. Although many of the details are found in the law itself, the intent of the rule is to implement the act by further defining some of the terms used, clarifying who the law applies to, clearly stating the requirements for both manufacturers and retailers and establishing the standards for handling equipment covered by the law. The proposed rule was published in the Missouri Register on Aug. 3, 2009.

The final rule scheduled to be published in the March 30 update of the Code of State Regulation and will be effective on April 30, 2010.

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Proposed Rules on Air Transport of Lithium Batteries

The U.S. Department of Transportation (DOT) has proposed new requirements for air shipments of lithium batteries and cells, including when they are packed with or contained in equipment. The proposed changes intended to ensure that lithium batteries are designed to withstand normal transportation conditions and that they are packaged to reduce the possibility of damage that could lead to an unsafe incident.

DOT’s Pipeline and Hazardous Materials Safety Administration (PHMSA), in coordination with the Federal Aviation Administration (FAA), developed this Notice of Proposed Rulemaking to comprehensively address the safe transportation of lithium cells and batteries when being shipped on aircraft.

In part, DOT proposes to:

• Eliminate regulatory exceptions for small lithium cells and batteries when included in an air shipment; and require their transportation as Class 9 materials, meaning they could pose a hazard when transported;

• Subject packages of small lithium batteries to well-recognized marking and labeling requirements for hazardous materials;

• Require transport documentation to accompany a shipment of small lithium batteries, including notifying the pilot in command of the presence and location of lithium batteries being shipped on the aircraft;

• Require manufacturers to retain results of satisfactory completion of United Nations design-type tests for each lithium cell and battery type;

• Limit stowage of lithium cell and battery shipments aboard aircraft to cargo locations accessible to the crew or locations equipped with an FAA-approved fire suppression system, unless transported in a container approved by the FAA Administrator; and

• Apply appropriate safety measures for the transport of lithium cells or batteries identified as being defective for safety reasons, or those that have been damaged or are otherwise being returned to the manufacturer, and limit the transportation of defective or damaged cells or batteries to highway and rail.

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NY Proposed Rules for Used Electronic Equipment - CRT

The New York State Department of Environmental Conservation (NYSDEC) is currently drafting a proposed rules for the management of used electronic equipment. Posting of the preliminary draft regulation is anticipated for Spring 2009, followed by further opportunity for public comment.

The resulting proposed rulemaking will amend NYSDEC regulations to streamline the management of used electronic equipment, whether regulated as hazardous waste or solid waste. The main issues to be addressed in the proposed rulemaking are:

• Adopting provisions of the Federal Cathode Ray Tube (CRT) Rule


• Adopting management standards for Collectors, Dismantlers, and Recyclers of Used Electronic Equipment


• Adopting provisions of the New York State Wireless Telephone Recycling Act


• Amending the requirements of New York's current Generator "c7" Notification

Currently in NYS, intact CRTs destined for recycling are eligible for the hazardous scrap metal exemption. However, when the CRT glass is no longer adherent to the metal, CRT glass could be regulated hazardous waste. The Federal CRT Rule contains the provisions to conditionally exclude this CRT glass from hazardous waste rules.

The current c7 notification requirements require generators (other than CESQGs) sending used electronics for recycling under the hazardous scrap metal exemption to file notifications. In the rulemaking, the NYSDEC is proposing to change the requirement to “[generators] must maintain on site, for a period of three years from the date of each shipment, the names and locations of the dismantling or recycling facilities and any intermediate receiving facilities."

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Battery Recycling Requirements - New European Union Rules

New EU-wide rules to boost the collection and recycling of used domestic batteries came into force recently. The rules are intended to reduce the environmental and health hazards posed by mercury, lead, cadmium and other metals in batteries.

The targets, agreed by EU member states, are the collection of 25 % of discarded household batteries by 2012. This target will rise to 45 % in 2016.

By September 26, 2009 all batteries collected should be recycled, with exceptions in certain circumstances. Batteries containing mercury, lead and cadmium are classified in Europe as "hazardous waste". The new rules also cover industrial and vehicle batteries, ensuring that users have the possibility of returning used batteries for collection. The new rules also include restrictions on the use of mercury in all batteries and on the use of cadmium in portable batteries.

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EU Proposes Revision To WEEE Directive

The Waste Electronics and Electric Equipment (WEEE) Directive came into force in 2003. Soon after a number of technical, legal and administrative difficulties became apparent; therefore the WEEE Directive was thus called out for up-date and simplification.

The WEEE Directive aims to 1) prevent the generation of electrical and electronic waste and 2) to promote reuse, recycling and other forms of recovery to reduce the quantity of waste discarded. It requires the collection of waste electrical and electronic equipment and the recovery and reuse or recycling of waste collected.

The directive is based on producer responsibility; producers of equipment used by private households are responsible for providing financing for the collection, treatment, recovery and environmentally-sound disposal of WEEE deposited at collection facilities. Producers of equipment used by others than private households are financially responsible for the costs of collection, treatment, recovery and environmentally-sound disposal.

Member States are required to draw up a register of producers and collect information on an annual basis on the quantities and categories of electrical and electronic equipment placed on their market, collected, re-used, recycled and recovered within that Member State and on collected waste exported.

Since 2003 data have shown that the Directive's goals could not be achieved at current collection and recycling rates. An EU review of the Directive required the Commission to propose new mandatory WEEE collection target and new targets for recovery and re-use or recycling, including for reusing whole appliances as appropriate, and targets for electrical and electronic medical devices. A new provision is added to harmonize producer registration and reporting in the EU by making national registers inter-operable.

Experience with the WEEE Directive also points to implementation problems resulting in a high percentage of WEEE not handled according to the requirements of the directive. It also shows that a significant amount of illegal shipments of polluting E-waste finds its way to developing countries where is has an impact on the health of local populations. To close the implementation gap, the EU proposes to strengthen the enforcement of the WEEE Directive.

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Washington WEEE Recycling Law - E-Cycle Washington

Beginning January 1, 2009, the E-Cycle Washington program kicks-off and provides no cost recycling of many waste electronic and electrical equipment (WEEE). The program is available to households, small businesses, schools & school districts, small governments, special purpose districts, and nonprofits & charities who can recycle electronic products free of charge.

E-Cycle Washington is one outcome of the Washington Electronic Product Recycling Law and Department of Ecology rules passed in 2007. These rules include:

• Manufacturer requirements
• Transporter requirements
• Recycler requirements
• Retailer requirements
• Reporting requirements
• Education and outreach

Caltha LLP assists manufacturers in meeting their internal product stewardship goals and regulatory requirements.

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