1.3 Use of These Recycling/Material Recovery Guidelines

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1 CTIA GUIDELINES FOR RECYCLING/MATERIALS RECOVERY FROM END-OF-LIFE WIRELESS DEVICES 1. INTRODUCTION 1.1 Purpose 1.2 Scope These Recycling/Materials Recovery Guidelines ( Guidelines ) are intended to encourage facilities that recover materials from retired wireless devices to conduct such operations in a manner that is protective of the environment and worker safety and health. These Guidelines address the recovery of basic materials (e.g., metal, plastic, and leather) or useful electronic components from retired wireless devices. Refurbishment and reuse of such devices are addressed separately under the CTIA Guidelines for the Refurbishment of Used Wireless Devices. For the purpose of these Recycling/Materials Recovery Guidelines, wireless devices includes handsets, personal digital assistants ( PDAs ), wireless computer cards, and their accessories (e.g., head sets, power packs, cases and clips) that operate on the Cellular Radiotelephone Service (as defined in title 47, part 22, subpart H of the Code of Federal Regulations), Specialized Mobile Radio (as defined in title 47, part 90, subpart S of the Code of Federal Regulations), or broadband Personal Communications Services (as defined in title 47, part 24, subpart E of the Code of Federal Regulations) and are provided for a profit (i.e., with the intent of receiving compensation of monetary gain) (collectively CMRS ), or operate on the standard developed by the Institute of Electrical and Electronics Engineers ( IEEE ) and one of the CMRS standards enumerated above. Such devices are used if they are relinquished by the original user after having been put in service. 1.3 Use of These Recycling/Material Recovery Guidelines Companies can encourage materials recovery facilities to conduct their operations in a manner that is protective of both workers and the environment by pledging to send materials only to facilities that satisfy these Guidelines.

2 Note: The Commentaries following certain provisions in these Guidelines provide additional information and are intended to provide additional background and context but should not be read as establishing additional requirements. For example, a may explain the purpose of the specific provision and provide examples of how the provision might be met at some facilities. In addition, it may list factors that can affect the selection of appropriate measures to satisfy the Guidelines at a particular facility. The Commentaries, however, are not an integral part of the Guidelines and do not form an independent basis for evaluating facilities. 2. TECHNICAL AND OPERATIONAL REVIEW 2.1 Overall Process Design Materials recovery processes should be designed to minimize the amount of materials that must be land disposed or incinerated, to the extent technically and economically practicable. Materials recovery facilities can generally be expected to recover as much value as possible from the materials they process, because it is in their economic interest to do so. Nevertheless, it may be useful for facilities to engage in a more formal review of opportunities for waste minimization. Such reviews may be conducted prior to operation or at periodic intervals during operation, and may entail one or more of the following: inventories of wastes generated, tracking of waste changes over time, consideration of process changes that might reduce wastes, review of relevant literature, participation in trade associations and conferences, contacts with regulatory authorities, and investigation of facilities that might be capable of recycling process residuals. 2.2 Acceptance of Materials Materials recovery facilities should take steps to verify that all materials received are suitable for processing at the facility, and that any unsuitable materials are either returned to the originating facility or routed to an appropriate facility. Materials recovery facilities are generally able to process only a certain range of materials. Thus, it is important that the facilities accept only materials that they are capable of handling and ensure that any non- 10/22/03 2

3 conforming materials that are inadvertently received are shipped to an appropriate off-site facility. Different materials recovery facilities may take different steps to achieve this goal, depending upon the source of the materials, the range of materials that can be processed at the facility, and other factors. Among the approaches that may be utilized are the following: establishment of specifications for materials that can be handled at the facility; preapproval of materials based on sampling, material profiles prepared by the originating facilities, certifications, or knowledge of the operations of the originating facilities; confirmation of the contents of individual shipments through visual inspection, testing, certifications, or descriptive shipping documents; arrangements with alternative facilities for the receipt of non-conforming materials; procedures for notifying originating facilities about non-conforming shipments and asking such facilities to determine the disposition of the materials; and mechanisms for identifying and addressing any facilities that repeatedly ship inappropriate materials. 2.3 Storage and Handling of Materials Materials recovery facilities should store and handle materials prior to processing in a manner that minimizes the potential for releases into the environment, injuries to workers, or reductions in the amounts of basic materials or useful electronic components that can be recovered from the materials received. The materials received at a materials recovery facility may pose certain risks, for example due to the presence of lead in solder, corrosive battery electrolytes, brominated fire retardants in the plastics, and various other metals in the circuit boards, batteries, and connecting points. Because of these potentially hazardous materials, it is important that the materials received at a materials recovery facility be handled in a manner that is protective of workers and the environment. Careful handling is also necessary to ensure that the economic value of the materials is preserved. Facilities may employ different strategies to satisfy these goals, depending on such factors as the physical form of the materials being handled (e.g., solid pieces, fine particles, or liquids), the potential hazards associated with such materials, the amount of materials, the rate of processing, and the layout of the facility. Indeed, a single facility may employ different methods for different materials. Among the techniques that may be utilized are the following: indoor or covered outdoor storage areas, impermeable containers, covers and seals for the containers, foundations 10/22/03 3

4 free of gaps or cracks, secondary containment, dust suppression and control equipment, run-on and run-off controls, elevated storage racks or platforms, segregation of materials, and labeling or marking of containers and storage areas. 2.4 Disassembly Materials recovery facilities that are engaged in dismantling of retired wireless devices (or components of such devices) should carry out these functions in a manner that preserves the value of the resulting materials, to the extent practicable, and protects workers and the environment. The risks associated with disassembly operations are generally minimal, because the materials are in the form of solid pieces that are unlikely to be dispersed into the workplace or the environment. In addition, the disassembled components are either still useful (in which case they have value that the facility would not want to lose) or resemble usable components (and therefore can be handled in similar ways). Nevertheless, certain precautions may be necessary or desirable, depending on the nature of the materials being disassembled, the extent of the disassembly, and the manner of disassembly. Precautions may include: floors that are impermeable and free of gaps or cracks; regular floor sweeping; dust suppression and control systems; suitable lighting and ventilation; ergonomically designed work stations and equipment; eye protection and gloves; magnifying lenses for intricate operations; and readily accessible bins or containers for each component removed or residual. Where heat is used to facilitate the removal of components, precautions should be taken to avoid worker exposure to harmful fumes. 2.5 Physical Processing Materials recovery facilities engaged in physical processing operations (e.g., grinding, crushing, screening, sorting, magnetic separation, or separation by weight) should perform such operations in a way that preserves the value of the materials and protects workers and the environment. Once a wireless device is disassembled, any components that are not directly reusable may need to be physically processed to facilitate the recovery of basic material resources, such as metal or plastic. Such 10/22/03 4

5 processing may change the physical form of the materials received at the facility in such a way that any hazardous constituents they might contain are more easily released into the workplace or the environment. In addition, the processing may pose additional safety risks to workers, due to noise, moving machinery parts, and other hazards. Thus, it is important that the processing be performed in a way that preserves the value of the materials and protects both workers and the environment. The measures taken at any given facility to serve these goals may vary, depending upon such factors as the nature of the materials being processed, the type of processing performed, and the ultimate disposition of the recovered materials. Specific controls that might be used at some facilities include dust suppression and control systems, noise abatement systems, worker safety guards, eye protection, and gloves. 2.6 Chemical or Thermal Processing Materials recovery facilities engaged in chemical or thermal processing operations (e.g., smelting, leaching, or chemical deactivation of reactive materials) should perform such operations in a way that maximizes and preserves the value of the materials recovered and protects both workers and the environment. Although disassembly and physical processing may be a necessary or useful part of the process for recovering basic materials from retired wireless devices, chemical or thermal processing is frequently necessary to complete the recovery process. Such processing has the potential to mobilize hazardous constituents which may be contained in wireless device components. For example, a smelter used to recover metal values may cause toxic metals to be released into the atmosphere. In addition, the reagents or equipment used to perform the processing may pose other risks to workers or the environment. Accordingly, it is important that the operations be conducted in a safe and environmentally sound manner. Appropriate measures to meet this goal may vary widely, depending upon the nature and quantity of the materials being processed and the type of processing being performed. For a smelter, numerous precautions may be used, such as trial burns, careful control of material inputs, limitations on various process parameters (e.g., temperature), specific air pollution control devices, and continuous emission monitors. For chemical processing, very different controls might be used, including ventilation, respiratory protection, goggles, gloves, secondary containment, and wastewater treatment systems. 10/22/03 5

6 2.7 Handling of Recovered Materials Materials recovery facilities should handle recovered materials on-site in a manner that preserves their value and ensures that the materials are either returned to the market as commodities or safely transferred to another appropriate materials recovery facility for further processing. The recovered materials produced by different facilities may include useful electronic components (for incorporation into new or refurbished products), shredded plastics (for use as fuels or ingredients to make recycled plastic products), shredded metal-containing components (for further recovery of metals), and dust or ingots consisting of recovered base or precious metals. In the case of materials that are directly usable as commodities, the materials recovery facility should handle the materials consistent with their value, for example in a manner similar to that used for the virgin commodities for which they substitute. In the case of materials that require substantial further processing before becoming commodity-like, the facility should handle the materials consistent with the provision in 2.3, regarding storage and handling of materials prior to processing. The specific methods used for the partially recovered materials may differ from those used for the materials received at the facility, because of their higher value, different composition, physical form, or other factors. In any event, the partially recovered materials should be transported to another appropriate materials recovery facility, such as a facility that itself satisfies these Materials Recovery Guidelines. 2.8 Handling of Process Residuals Materials recovery facilities should handle residual materials on-site in a manner that protects against releases into the environment and ensures that they are safely transported to an appropriate disposal or incineration facility. Although materials recovery facilities are designed to obtain useful resources from retired wireless devices, such processes inevitably generate some quantity of residuals that must be land disposed or 10/22/03 6

7 incinerated. These residuals may contain some of the hazardous constituents that were initially of concern in the retired wireless devices. Indeed, the recovery process may concentrate certain hazardous constituents or introduce new constituents of concern. Thus, it is important that any residuals be assessed and handled properly. Different process residuals will generally require different measures to be taken both on-site and off-site. Accordingly, facilities should characterize their process residuals carefully, using testing or knowledge of the materials and processes used at the facility. Any residuals that qualify as hazardous wastes may be subject to stringent requirements for design and operation of storage units, labeling, manifesting, transport, pretreatment, and delivery to a permitted hazardous waste facility. Although non-hazardous residuals will not be subject to such requirements, certain management techniques may be appropriate for such materials. For example, some of the on-site controls discussed above in provision 2.3, regarding storage and handling of materials received at the materials recovery facility, may be appropriate for the process residuals (although the residuals may be handled in a different manner due to their lack of value, different composition or form, and other factors). In addition, the materials recovery facility should ensure that the residuals are delivered to a land disposal or incineration facility that is suitable for the specific residual, properly authorized by relevant regulators, well-maintained, and well-operated. Any residues from the landfill or incinerator operations (e.g., landfill gas, leachate, incinerator ash, or scrubber water) should also be handled in an environmentally protective manner. 2.9 Transport Of End-Of-Life Wireless Devices, Components and Residuals Materials recovery facilities handling end-of-life wireless devices should ensure that any devices, components (e.g., batteries), or accessories that are transported to or from the facility are prepared for shipment and transported in a safe and secure manner that complies with any applicable hazardous materials transport regulations. Certain used wireless devices, components, and accessories may contain constituents or exhibit properties that may pose a hazard during transportation. In order to minimize such hazards and protect against 10/22/03 7

8 releases into the environment, it is essential that the materials be shipped in a safe and secure way. Such handling is also important to preserve the materials being shipped so that they can be refurbished or recycled properly. Depending upon the nature of the used wireless devices, components, or accessories, they may qualify as hazardous materials under the U.S. Department of Transportation s Hazardous Materials Regulations ( HMR ). For example, certain types of batteries are specifically listed as hazardous materials, as are certain types of equipment containing such batteries. To the extent that any collected materials may be hazardous materials, the applicable regulations (if any) will depend upon various factors such as the nature of the hazards, the quantities shipped, the packaging utilized, and the modes of transportation employed (e.g., truck or aircraft). Relevant requirements may address such issues as packaging, hazard communication (e.g., labeling, marking, or placarding), shipping papers, emergency response, registration, training, and security. Additional transportation requirements may also apply to the extent that the materials may qualify as hazardous wastes under federal regulations. Although materials recovery facilities should ensure that the materials they are receiving or sending off-site are prepared for shipment and transported properly, they may need or want to work with the relevant carrier(s) used to transport materials to determine the specific measures that are required under the regulations or are otherwise appropriate. In some cases, one or more of these measures may also be implemented by the carrier used to transport materials Exports of End-of-Life Wireless Devices, Components and Residuals Materials recovery facilities should ensure that any end-of-life products, components or residuals exported from the U.S. for recovery are managed in an environmentally sound manner, consistent with applicable requirements and guidelines under the laws of the receiving country and international law. End-of-life products, components or residuals should not be exported with the primary aim of landfilling or incineration. 3. ADMINISTRATIVE AND MANAGEMENT ASSESSMENT MEASURES 3.1 Environmental Management Systems Materials recovery facilities should have systems in place for defining specific environmental, health, and safety objectives, developing plans to 10/22/03 8

9 meet the objectives, implementing such plans, and monitoring progress towards achievement of the objectives. Some facilities may also wish to have their environmental management systems reviewed and certified by an appropriate third party to assure stakeholders that effective management systems are in place. Environmental management systems are an important way for materials recovery facilities to demonstrate their commitment to continuous improvement in environmental, health, and safety performance. However, the particular goals and management systems employed by different companies may vary significantly. In many cases, facilities will satisfy this goal by developing and implementing their own clear objectives. In some cases, however, facilities may adopt and pursue objectives developed by trade associations, professional organizations, or independent entities. Some facilities may also opt to have their environmental management systems reviewed and certified by one or more of such groups. 3.2 Regulatory Authorizations Materials recovery facilities should have all permits, licenses, or other authorizations required by federal, state, and local regulatory authorities. Because retired wireless devices contain potentially hazardous constituents, facilities that recover basic materials or useful electronic components from such devices may require permits, licenses, or other authorizations from federal, state, or local regulatory authorities. The extent to which this is the case will depend upon various factors, such as the nature of the materials processed, the manner of processing, and applicable regulations. In any event, conformance with this provision can be verified in several ways, including discussions with regulatory authorities, review of agency records, certification by the materials recovery facility, specific inquiries to the facility, review of any authorizations that have been issued to the facility, and an independent evaluation of the facility operations and potentially applicable permitting or licensing requirements. 3.3 Regulatory Compliance 10/22/03 9

10 Materials recovery facilities should be in compliance with all applicable federal, state, and local regulations and permits or other authorizations that are related to the environment or worker health and safety. Compliance with applicable regulations, permits, and authorizations is legally required and is generally important to ensure that workers and the environment are adequately protected. Thus, it is essential that materials recovery facilities be in compliance at all times. 3.4 Emergency Planning and Reporting Materials recovery facilities should have mechanisms in place to minimize the potential hazards from any emergencies or unplanned releases of hazardous constituents that may occur. Reporting protocols should be developed to ensure that any unpermitted releases of hazardous substances into the environment are reported to federal, state and local authorities, as appropriate. Materials recovery facilities should coordinate with local governmental authorities to ensure that they are aware of the general nature of the facility operations and can prepare for and respond to any emergencies that might arise from facility operations. Even well designed and well-operated facilities may experience unplanned events (e.g., fires, spills, or severe storm events) that may pose significant hazards to workers and the environment. Materials recovery facilities should therefore have mechanisms in place to address such events, for example by limiting the duration or extent of the events, protecting people and property, and dealing with any aftermath (e.g., contamination). The specific mechanisms used to satisfy this provision may vary significantly from site to site, depending upon such factors as the nature and quantity of the materials handled, the type of processing performed, and the facility design and location. Among the mechanisms that might be used at some sites are the following: evacuation or other contingency plans; internal communication systems or alarms; designated emergency response coordinators; arrangements with local emergency response authorities; external communication systems to notify appropriate federal, state or local authorities; and accessible emergency response equipment. Different combinations of these mechanisms and other mechanisms may be capable of achieving the goal of minimizing hazards. 3.5 Personnel Training 10/22/03 10

11 Materials recovery facilities should ensure that all of their employees are thoroughly familiar with proper procedures for carrying out their responsibilities during normal facility operations and emergencies. In order to ensure that a materials recovery facility is properly operated and prepared for any emergencies, it is essential that the employees be trained to understand their responsibilities. The amount and type of training that might be warranted will vary from site to site, and perhaps from employee to employee. However, factors that may be relevant in determining the appropriate training include the number of employees, their responsibilities, their background and experience, and the amount of supervision they are provided. Training may take a variety of forms, including the following: on-the-job instruction, formal classroom courses, computerized training, detailed written instructions, short summaries or cheat sheets, signs with specific directions for employees, and testing or observation to ensure that lessons are learned. 3.6 Inspections and Monitoring Materials recovery facilities should monitor their operations to ensure that they are effective and efficient, and are performed in a manner that is protective of workers and the environment. It is important that materials recovery facilities take concrete steps to monitor their own performance, so as to ensure that any issues are promptly identified and addressed. The appropriate level of monitoring will depend upon a number of factors, including the nature and quantity of materials handled, the type of processing performed, the design of the facility, the specific parameters to be monitored, and the nature of any hazards. Monitoring techniques may include inspections, self-audits, electronic surveillance, record reviews, spot checks, sampling and testing, and automatic alarms or system cutoffs. The frequency of monitoring may also vary significantly. Some parameters may require continuous monitoring, while others require only periodic review (e.g., hourly, daily, weekly, monthly, or annual). Facilities should take corrective measures whenever issues are identified through the monitoring process. 3.7 Recordkeeping 10/22/03 11

12 Materials recovery facilities should maintain records of all wireless devices or related materials received and their disposition. Such records should include: the number of wireless devices received; the date and location from which the wireless devices were shipped; the amount (by weight) of materials received and processed; the disposition of all wireless devices received by the facility; and the disposition of all components, accessories or residuals received by the facility. Records should be kept for a period of three years. Materials recovery facilities should keep sufficient records to track the materials being handled or produced and to facilitate monitoring of operations by both the facilities themselves, interested Companies, and by regulatory authorities. Recordkeeping is necessary for materials recovery facilities to track their own performance and for regulatory authorities to carry out their oversight functions. However, the types of records that need to be maintained may vary significantly, depending upon such factors as the range of materials received and the type of processing performed. For example, a facility that receives only handsets from a single source and does nothing more than grind them for shipment to a single metals recovery facility might keep track of just the weight of the materials entering and exiting the facility. On the other hand, a facility receiving a wide variety of items and subjecting them to several different operations might record the types, amounts, and sources of incoming materials; the time that each batch of materials completes each processing step; relevant process control parameters; the types and quantities of recovered materials and process residuals produced; and the timing, transporter, and destination facility for each off-site shipment. Where appropriate, recovery facilities may wish to track each wireless phone received using its electronic serial number ( ESN ) or equivalent identifier. 4. FACILITY CLOSURE AND FINANCIAL ASSURANCE 4.1 Closure Assurances Materials recovery facilities should provide assurances that hazardous materials will not be abandoned or otherwise left behind when operations cease. 10/22/03 12

13 Historically, recycling facilities have sometimes in rare istances had to cease operations due to financial or other reasons, leaving behind significant quantities of hazardous materials that are unattended and pose a risk to human health and the environment. Materials recovery facilities should therefore be able to provide financial or other assurances that such problems will be avoided. However, the nature and degree of the assurances may vary significantly from site to site, depending upon such factors as the maximum amount of material that may be present at the facility at any one time, available options for handling such materials, the costs of each option, and the track record of the facility. 4.2 Liability Assurances Materials recovery facilities should provide assurances that adequate funds will be available to cover reasonably foreseeable liabilities that may arise for personal injury or property damage due to sudden or non-sudden occurrences. As noted above, even well-designed and well-operated facilities may sometimes experience unplanned events that may pose a risk to workers and the environment. Accordingly, materials recovery facilities should ensure that funds will be available to address personal injury or property damage that may result from such an event. The nature and extent of the assurances may vary significantly from site to site, depending upon such factors as the types of materials handled at the facility, the kinds of operations employed, the precautions taken to minimize the occurrence and effects of any potential incidents, and the proximity of neighboring populations and structures. Although liability insurance may be the most common form of assurance, some facilities may use other forms of assurance, including a bond, letter of credit, trust fund, or a financial guarantee from a corporate parent. 10/22/03 13