How to manage electronics waste (e-waste) has emerged as a big and ongoing recycling challenge for a lot of American businesses. State and federal regulations around recycling seem to shift all the time. Many Massachusetts businesses are still adjusting to the food and textile waste bans that were implemented a few months ago. So, it might be hard to keep track of things like whether electronics disposal is something that’s governed by law or not.
The electronic devices that your business needs in order to function hold data you can’t afford to let anyone else access, and you might only get a few years of use out of them before they need to be replaced.
Electronics disposal laws do apply to commercial businesses in many states; so knowing whether or not they apply to you and adhering to strict standards around electronics recycling is always a good idea. Mismanaging the way you dispose of your business’s electronics could expose your sensitive data to outsiders and have a negative environmental impact.
One good way to gauge whether your business is correctly managing e-waste is to compare your electronics disposal procedures to the guidelines that the General Services Administration (GSA) has for federal agencies.
What the GSA Says About Electronics Disposal
The GSA is the body that oversees “electronics stewardship” for the federal government. Its policies tell federal employees how to use and dispose of federally-owned electronic equipment. Here’s an overview of how the current policies were created and what the GSA currently requires for proper disposal of electronics.
- In 2011, an Interagency Task Force on Electronics Stewardship was formed, led by the GSA and the EPA. The task force created the National Strategy for Electronics Stewardship. “The Strategy” set several goals for the federal government to address. One goal was to develop a government-wide policy about e-waste reuse and disposal, including guidance about using certified recyclers to properly manage electronics disposal.
- In 2012, the GSA published Bulletin B-34 (Disposal of Federal Electronic Assets) to establish electronics disposal standards for all federal agencies to follow. The Bulletin lays out a list of acceptable ways to dispose of any electronic assets owned by the federal government.
Federal agencies are urged to first try to reuse functioning electronics, like by transferring them to other agencies, donating them to schools or nonprofits or even selling them to the public. If none of those disposal methods is feasible, federal agencies are required to dispose of electronics through manufacturer take-back programs or via certified recyclers. The Bulletin also notes that hard drives and other storage devices should be sanitized (aka, wiped of data) before disposal, and that electronics should never be landfilled or incinerated.
- In 2021, President Biden signed Executive Order 14057, “Catalyzing Clean Energy Industries and Jobs Through Federal Sustainability.” This order established a range of new goals and requirements for federal agencies designed to reduce their impact on the environment. For example, agencies are challenged to divert at least half of their non-hazardous solid waste away from landfills by 2025 and reduce greenhouse gas emissions by 65% by 2030. Electronics disposal isn’t specifically mentioned, but the EO does note that agencies are required to promote environmental stewardship by “prioritizing products that can be reused, refurbished, or recycled.”
- In August 2022, the White House Council on Environmental Quality published instructions for implementing EO 14057. These instructions reiterated that federal agencies should follow Bulletin B-34 for electronics disposal best practices. In other words, federal employees are still expected to follow the same e-waste procedures they’ve been expected to follow since 2012.
Electronics Disposal Guidelines for Non-Government Organizations
The GSA’s e-waste disposal policies don’t apply to any entities except federal agencies. How your business manages electronic waste might be covered by state or local laws depending on where you’re located. About half the states have an electronics disposal law of some kind. (For example, in New York, electronics recycling is mandatory. Manufacturers are required to provide free take-back services for individuals and small businesses but may charge larger businesses for this service.)
Massachusetts doesn’t currently have any commercial e-waste recycling laws that businesses have to follow. This gives Massachusetts-based businesses the freedom to handle electronic disposal on their own terms, but it also means there isn’t as much e-waste recycling infrastructure in Massachusetts as there is in some states that mandate e-waste recycling. Without any state laws telling your business how to recycle electronics, the best strategy is to follow the same general strategy that the GSA requires for federal agencies.
First, you might want to look for ways to donate usable electronics to nonprofits, schools and other organizations for a possible tax deduction. (That said: your business should have a policy that only allows the donation of things like TVs or cell phones with their sim cards removed. Devices like laptops and scanners might retain sensitive data that can be recovered by future owners, even if you wipe the memory before donating.)
Next, you can check to see if the manufacturer of any of your electronics has a take-back program. For data security purposes, remove the hard drives before sending devices back and have these drives shredded.
Finally, electronics that don’t work and/or contain private data should be handed directly to a recycler equipped to manage these items. Electronics should never be put in trash bins or recycling bins with other mixed recyclables. They need to be handled separately from other materials because electronics are typically made of many recyclable components that can be disassembled and sorted.
Need help with electronics disposal for your business?
Miller Recycling meets a wide range of recycling needs for our commercial clients, while our sister company Northeast Data Destruction provides secure data destruction services for shredding hard drives and other data-storing devices. If you have questions about the right way to manage electronic disposal for your company, contact me today!