1. California’s E-waste Efforts
A Decade of Operation…
…What’s Next?
Jeff Hunts, Manager
CalRecycle E-waste Program

2. Covered Electronic Waste (CEW) Program
Intended to fund average end-of-life management costs of certain video display devices (TVs, monitors)
Decrease inappropriate disposal
Improve compliance with State hazardous waste rules
Return resources to economic mainstream

3. Covered Electronic Waste (CEW) Recycling System
Insert Conference Name Here
Insert Presentation Title
Insert Speaker Name Here
Covered Electronic Waste (CEW) Recycling System

4. Program Participants ~ 470 approved collectors ~ 33 approved recyclers
Fewer than 40 approved collectors are local government agencies
(1/3 from rural counties)

5. CEW Program Status By who? How much? ~ 4% by local government
~ 185 million pounds in 2014
~ 97% by weight CRT devices
~ 1.9 billon pounds total
By who?
~ 4% by local government
~ 26% by designated collectors*
~ 70% by private enterprise
* Form 303 implications?

6. Covered Electronic Waste (CEW) Program

7. Recent Initiatives
CDFA / Weighmaster Enforcement Program Interagency Agreement
CRT Glass Management Regulations - Approved
Civil Liability Regulations - Approved
Designated Approved Collector Reform -- Upcoming

8. Cathode Ray Tubes (CRTs)
Composition and Components
In general:
Funnel contains lead
Panel contains barium

9. Q: Where Has the CRT Glass Gone…?
In 2014, over 100 million pounds were shipped from CA…
A: Arizona to …?
A: India

10. Possible CRT Markets / Dispositions?
CRT Manufacturing
CRT Reuse
Lead/Copper Smelting
Glass Furnaces
Ceramics
Chemical Extraction
Concrete
Retrievable Storage
ADC
Disposal

11. Civil liability initiative
Statutory Authority: PRC, 42474(d)
“Civil penalties in an amount of up to twenty-five thousand dollars ($25,000) per violation may be administratively imposed by the Department of Resources Recycling and Recovery against a person, including an authorized collector or covered electronic waste recycler, that makes a false statement or representation in any document filed, submitted, maintained, or used for purposes of compliance” with the Electronic Waste Recycling Act and associated regulations, including those related to the CEW program.

12. Civil liability initiative
Examples of Potential False Statements(I):
Source documentation: incorrect names and addresses, non-existent sources, misstated amounts
Transfer documentation: misstated amounts, inactive collector represented as active
Designation: altered POD, validity dates, or other information, misuse of Designation

13. Civil liability initiative
Examples of Potential False Statements(II):
Cancellation records: false cancellation dates and/or weights, non-CEW material claimed as CEW material, non-CRT material portrayed as CRT material
Shipment records: inconsistent information
End-use destination receipts/documentation: false statements regarding CRT glass ultimate disposition

14. Civil liability initiative
Penalty determination:
Minor: first-time violations where the gravity is severe ($500-$4,000)
Moderate: subsequent or multiple violations ($4,000-$15,000)
Major: pattern and practice of non-compliance or intentional ($15,000-$25,000)

15. Civil liability initiative
Administration:
Notice of violation (NOV):
Issued prior to the imposition of penalties
Process may stop with a NOV
Accusation:
Seeking an administrative penalty or penalties
Issued following the issuance of a NOV for repeated violations OR
Issued directly if warranted by circumstances (no prior NOV required)

16. Civil liability initiative
Administration:
Administrative Hearing:
Notice of Defense must be filed within 15 days
Held before a hearing officer
Final decision issued within 30 days
Settlement:
Anytime before a decision is issued

17. Designation Reform Current Provision:
A Designated Approved Collector may provide CEW recovery service on behalf of a California local government
Collections / Clean-ups
A designation specifies scope
Timeframe(s)
Location(s)
Activities

18. Designation Reform Anticipated or Possible Adjustments:
Clarify designating authority / delegated officials
Cities, counties, districts, authorities(?)
Strengthen LG – DAC relationship
Contracts? Reporting? Form 303 compliance?
Limit / Refine Scope and Use
Geography? Sources? Timeframes?
Consequences for misuse?

19. CEW Program Future? Solving the CRT problem will be “easy”
Non-CRT devices harder to dismantle, less material value
Regulatory considerations for CCFLs, LEDs, plasma glass, etc
Documenting sources, flow, and “cancellation”
Setting adequate payment rates / equitable fee levels
Will current model work into the future…?

20. Comments, Concerns, Questions?
Anticipate an upcoming workshop on Designations
Possibly December 16…
Troubles? Contact me anytime:
Jeff Hunts, Manager