Disposal of Old Computer Equipment

By Meyer, Michael J.; Ella, Waleed Abu El et al. | The CPA Journal, July 2004 | Go to article overview

Disposal of Old Computer Equipment


Meyer, Michael J., Ella, Waleed Abu El, Young, Ronald M., The CPA Journal


A Mounting Environmental Problem

Most organizations have been collecting obsolete computers for years. The U.S. Environmental Protection Agency (EPA) has estimated that 45 million computers will become obsolete annually by 2005. California, Massachusetts, and Minnesota have already outlawed the disposal of computer waste in landfills; in 2003 alone, 23 states initiated legislation to address the mounting problem of computer waste (Exhibit).

Most of the environmental concerns with computers lie with the monitor, specifically its cathode ray tube (CRT). Each color monitor contains, on average, four to five pounds of lead, considered hazardous waste when disposed of, according to EPA standards. Computers also contain other hazardous materials, including mercury, cadmium (a known carcinogen), and hexavalent chromium (shown to cause high blood pressure, ironpoor blood, liver disease, and nerve and brain damage in animals). The Utah Department of Environmental Quality estimates that 314 million computers will be thrown away by the end of 2004, containing 1.2 billion pounds of lead, 2 million pounds of cadmium, 1.2 million pounds of hexavalent chromium, and 400,000 pounds of mercury.

Imagine a worst-case scenario: Groundwater near a landfill becomes contaminated. In a search for potentially responsible parties, a company that had disposed of computers at the site (identified by a control tag or manufacturer's number) could be subject to potentially costly criminal and civil litigation (i.e., SARA, formerly CERCLA, litigation). All of this could happen even if the organization had donated the equipment to a charity or paid a company to recycle it.

Federal Environmental Law

The Resource Conservation and Recovery Act (RCRA) has been updated recently to include guidelines regarding the disposal of computer monitors. Computer monitors are different from most computer equipment because of the concentration of lead: 27% of the weight of a CRT monitor is due to its lead content. The threshold for establishing refuse as hazardous waste is the toxicity characteristic leaching procedure (TCLP) of the waste. The EPA guidelines indicate that waste having a TCLP of 5mg/l of lead qualifies as hazardous waste. Color monitors have on average 18.5mg/l of lead-more than 3 ½ times this threshold.

The RCRA classifies waste generators into four categories: households; conditionally exempt small quantity generators (CESQG); small quantity generators (SQG); and large quantity generators (LQG). In general, all households are exempt from federal EPA rules regarding computer disposal (although state regulations often include households). Organizations disposing of less than 100 kg (220 lbs) of hazardous waste in a month are classified as CESQG; those dumping between 100 kg and 1,000 kg (2,200 lbs) are classified as SQG; and those dumping more than 1,000 kg are classified as LQG.

CESQG organizations are exempt from most of the RCRA disposal standards. If a company disposes of more than seven to eight monitors in a given month, it may exceed the threshold and be classified as an SQG. In that case, the organization will be required to follow many of the hazardous waste standards set forth in the RCRA. These standards include documentation of proper recycling (including manifesting each disposal), which can be expensive. LQG organizations face the most restrictions and costs.

As an example of the documentation requirement set forth by the EPA, in 2000 AT&T agreed to pay a penalty of $195,000 for not properly responding to an agency request for information about its computer-disposal practices. An investigation by the EPA was initiated by a tip that a New Jersey plant was incinerating hazardous waste, including computers and other equipment. Although AT&T eventually provided all of the information requested, the EPA believed that the company did not fully answer inquiries about how it managed waste computers and electrical equipment in a timely manner.

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