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COMMON
SENSE
INITIATIVE
(CSI)
COUNCIL
RECOMMENDATION
ON
CATHODE
RAY
TUBE
(CRT)
GLASS­
TO­
GLASS
RECYCLING
Based
on
in­
depth
work
conducted
by
the
CSI
Computers
and
Electronics
Sector
Subcommittee,
the
CSI
Council
has
determined
that
properly
conducted
Cathode
Ray
Tube
(CRT)
glass­
to­
glass
recycling
is
a
cleaner,
cheaper,
smarter
approach
to
waste
CRT
management
that
should
be
increased.
To
facilitate
accomplishing
that
goal,
the
CSI
Council
recommends
that
the
Environmental
Protection
Agency:

1.
Revise
the
applicable
Resource
Conservation
and
Recovery
Act
(RCRA)
hazardous
waste
management
regulations
to
facilitate
CRT
glass­
to­
glass
recycling
as
outlined
in
Attachment
1.
The
revised
CRT
glass­
to­
glass
recycling
regulations
should
be
clear
and
simple
to
understand.
The
Council
asks
that,
as
appropriate,
EPA
discuss
with
members
of
the
Computers
and
Electronics
Sector
Subcommittee
any
new
issues
that
arise
during
rule
development
and
implementation.

2.
Complete
and
implement
this
CRT
rulemaking
as
soon
as
possible,
and
in
the
intervening
period,
take
appropriate
steps
to
realize
the
environmental
benefits
of
CRT
glass­
to­
glass
recycling.

Finally,
the
CSI
Council
recognizes
that
there
may
be
CRT
glass
recycling
methods
or
end
uses
other
than
CRT
manufacturing
that
are
also
cleaner,
cheaper,
and
smarter
approaches
to
waste
CRT
management.
On
the
other
hand,
some
recycling
methods
or
end
uses
may
pose
risks
to
human
health
and
the
environment.
The
Computers
and
Electronics
Subcommittee
will
be
working
to
determine
which
recycling
methods
and
end
uses
are
preferable
and
to
propose
appropriate
standards
for
such
methods,
but
the
Council
is
aware
that
the
future
of
the
Common
Sense
Initiative
is
undefined
at
this
time.
Thus,
the
Council
asks
that
EPA
consider
any
additional
work
completed
by
the
Sector,
and
if
appropriate,
design
the
CRT
glass­
to­
glass
rule
so
that
other
legitimate
recycling
methods
or
end
uses
may
be
added
in
the
future,
including
standards
tailored
to
the
risks
and
benefits
of
the
recycling
method
or
end
use.
The
Council
takes
no
position
on
the
question
of
whether
states
should
be
allowed
to
add
additional
recycling
methods
or
end
uses
without
a
prior
determination
by
EPA.
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1
Processed
CRT
glass
is
glass
that
has
been
separated
from
non­
glass
components
(e.
g.,
TV/
monitor
plastic
and
metal
components,
implosion
band,
shadow
mask,
deflection
yoke,
electron
gun,
inner
shield)
and
which
has
been
cleaned
to
remove
coatings
(e.
g.,
day,
phosphors).

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ATTACHMENT
1
COMMON
SENSE
INITIATIVE
COUNCIL
RECOMMENDATION
CATHODE
RAY
TUBE
(CRT)
GLASS­
TO­
GLASS
RECYCLING
1.
Add
to
the
Resource
Conservation
Recovery
Act
(RCRA)
hazardous
waste
management
regulations
new
standards
specific
to
CRT
glass­
to­
glass
recycling
which
will
apply
in
place
of
the
standard
RCRA
hazardous
waste
requirements.
These
new
standards
are
to
be
structured
in
a
manner
similar
to
the
Universal
Waste
rule
(40
CFR
Part
273).
The
regulation
will
include
an
exclusion
from
the
definition
of
solid
waste
clarifying
that
processed
CRT
glass
1
that
is
to
be
reused
in
CRT
glass
manufacturing
is
not
a
solid
waste
subject
to
the
RCRA
hazardous
waste
regulations
(including
the
new
CRT
standards
described
here).
The
Council
recommends
that
EPA
promulgate
this
exclusion
because
the
processed
CRT
glass
is
sufficiently
commodity­
like
based
on
the
following
factors:
1)
the
degree
of
processing
the
material
has
undergone
is
such
that
it
requires
little,
if
any,
further
processing,
2)
the
material
has
economic
value,
3)
the
material
is
like
an
analogous
raw
material,
and
4)
there
is
a
guaranteed
end
market
for
the
material.
Based
on
the
information
currently
available
to
it,
the
Council
also
believes
that
the
material
is
handled
to
minimize
loss,
but
requests
that
EPA
conduct
whatever
investigation
EPA
determines
is
appropriate
to
reach
a
final
conclusion
regarding
this
factor.

2.
The
new
CRT
glass­
to­
glass
recycling
standards
will
explain
that
they
apply
only
to
materials
that
are
currently
regulated
hazardous
waste.
However,
the
standards
will
explain
that
the
goal
is
that
the
standards
be
simple
enough
that
one
infrastructure
develops
for
voluntarily
managing
all
CRT
materials
in
the
same
system.

3.
The
new
CRT
glass­
to­
glass
recycling
standards
will
define
the
following
three
categories
of
regulated
entities:

Collectors:
Persons
who
collect/
store
whole
TVS/
monitors.
Within
this
category,
some
requirements
will
apply
only
to
large
collectors
(those
who
store
40
tons
or
more
(~
4,000
units)
on­
site
for
longer
than
7
consecutive
days).

Processors:
Persons
who:
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2
EPA
will
consider
other
refurbishing
activities
that
should
be
addressed
in
the
same
manner.

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­­
intentionally
break
CRTs;
­­
manage
intentionally
broken
CRT
glass
or
cullet;
or
­­
clean
coatings
(e.
g.,
dag,
phosphors)
from
CRT
glass.

Transporters:
Persons
who
transport
TVS/
monitors,
whole
CRTs,
broken
CRT
glass,
or
cullet.

Entities
involved
in
refurbishment
and
disassembly
of
products
containing
CRTs
(not
to
include
taking
apart
the
CRT
2
)
are
not
subject
to
this
standard
or
the
RCRA
hazardous
waste
regulations
(40
CFR
Parts
260
through
270)
(on
the
basis
of
the
CRT
itself)
until
it
is
determined
that
these
materials
are
not
repairable
or
reusable.
EPA
will
consider
what
safeguards
are
necessary,
if
any,
to
address
environmental
concerns
associated
with
accumulation
of
large
volumes
of
CRTs.

4.
The
new
CRT
glass­
to­
glass
recycling
standards
will
include
the
provisions
illustrated
in
the
following
Table
and
detailed
in
Annex
1.
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PROVISIONS
APPLICABLE
TO
CRT
GLASS­
TO­
GLASS
REGULATED
ENTITIES
REGULATED
ENTITY
PROVISION
Collector
Processor
Transporter
1.
Notification
large
collectors
only
X
2.
Marking
(on­
site
and
for
transport)
X
X
3.
Storage
Limit
X
X
X
4.
Shipping
CRT
Glass
Materials
large
collectors
only:
shipments
out
X
5.
General
Performance
Standard
X
X
X
6.
Prevent
Releases
of
Glass
Particulate
X
7.
General
Good
Management
X
X
X
8.
Minimize
Breakage
X
X
9.
No
Cross
Contamination
X
10.
Manage
Residues
Appropriately
X
11.
Environmental
Justice
Provision
X
12.
Package
for
Transport
X
X
13.
Exports
X
X
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ANNEX
1:
CRT
GLASS­
TO­
GLASS
RECYCLING
PROVISIONS
1.
Notification:
One­
time
notice
to
the
agency
implementing
the
hazardous
waste
regulations
(EPA
or
the
state)
of
company
name,
location,
activities,
etc.

2.
Marking:
Materials
must
be
marked
in
accordance
with
either
(1)
or
(2)
below.

(1)
CSI/
CRT
approach:
(a)
Whole
TVS/
monitors
visible
when
looking
at
primary
packaging
(container
or
vehicle
body):
no
marking
required.
(b)
TVS/
monitors,
bare
CRTs,
and
glass
in
packages
(i.
e.,
containers
or
vehicle
bodies)
or
storage
areas:
mark
container
or
storage
area
with
the
following
words:
"Cathode
ray
tubes
(CRT)
or
CRT
glass
to
be
used
in
CRT
glass
manufacturing.
Contains
lead.
Do
not
mix
with
other
glass
or
materials."

(2)
Universal
Waste
approach
for
materials
in
transportation:
If
the
state
in
which
the
shipment
originated
has
Universal
Waste
marking
standards
(i.
e.,
labeling
with
text)
for
the
material:
mark
(label)
the
material
as
required
under
the
originating
state's
Universal
Waste
program.

3.
Storage
Limit:
Collectors
­­
1
year+
as
described
in
40
CFR
273.15.
Processors
­­
1+
year
as
described
in
40
CFR
261.1(
c)(
8).
Transporters
­­
10
days
as
described
in
40
CFR
273.53.

4.
Shipping
CRT
Materials:
Maintain
records
for
3
years.
No
specified
form
for
records.

Small
and
large
collectors
­­
may
send
shipments
only
to
other
collectors
or
to
processors
in
CRT
system.

Large
collectors
­­
for
each
outgoing
shipment,
keep
records
of
quantity,
date,
name
and
address
of
person
shipped
to,
and
an
acknowledgment
of
receipt
from
the
recipient.

Processors
­­
1)
all
TC
hazardous
glass
that
is
technically
and
economically
usable
in
CRT
glass
manufacturing
must
be
sent
to
a
CRT
glass
manufacturer
for
use
in
CRT
glass
manufacturing.
2)
for
each
incoming
and
outgoing
shipment,
keep
records
of
quantity,
date,
name,
and
address
of
person
shipped
to,
and
an
acknowledgment
of
receipt
from
the
recipient.
3)
Annually,
prepare
a
certified
statement
stating
that
all
TC
hazardous
glass
that
is
technically
and
economically
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usable
in
CRT
glass
manufacturing
was
sent
to
a
CRT
glass
manufacturer
for
use
in
CRT
glass
manufacturing.

5.
General
Performance
Standard:
Manage
and/
or
transport
CRT
materials
in
a
way
that
prevents
releases
to
the
environment
of
glass
pieces,
glass
particulate,
other
components,
and
materials
used
in
processing
(e.
g.,
cleaning
or
sorting
media).
Immediately
contain
any
releases
to
the
environment
and
manage
contained
material
under
applicable
waste
management
requirements.

6.
Prevent
Releases
of
Glass
Particulate:
For
any
storage
or
management
activities
involving
breaking
glass
or
managing
broken
glass,
install
and
maintain
systems
sufficient
to
minimize
releases
of
glass
and
glass
particulate
via
wind
dispersal,
runoff,
and
direct
releases
to
soil.
(Examples
of
wind
dispersal
control
systems
may
include:
a
good
condition
building;
closed
containers;
closed
tanks;
keeping
materials
stored
or
managed
outdoors
covered,
or
wet,
as
appropriate.
Examples
of
systems
for
preventing
releases
to
soil
directly
may
include:
an
impervious
floor
or
pad;
a
good
condition
building.
Examples
of
systems
for
preventing
releases
via
runoff
may
include:
a
good
condition
building;
implementing
an
approved
storm­
water
management
plan;
adequate
run­
off
controls.)

7.
General
Good
Management:
­­
Collectors,
Processors,
Transporters
­­
no
disposal
on­
site
­­
Collectors
and
Transporters
­­
no
dilution,
no
treatment
(dismantling,
intentional
breakage,
processing)
­­
Processors
­­
no
combustion
or
treatment
activities
using
temperatures
high
enough
to
volatilize
lead
from
CRT
glass,
no
storage
or
processing
in
surface
impoundments
8.
Minimize
breakage:
Collectors
­­
manage
to
minimize
breakage
of
TVS/
monitors.
Transporters
­­
transport
to
minimize
breakage
of
TVS/
monitors,
CRTs,
glass
pieces.

9.
No
Cross­
Contamination:
Do
not
mix
TC
hazardous
CRT
glass
with
other
glass
that
is
not
going
to
CRT
glass
manufacturing.
Blending
of
glass
that
is
going
to
glass
manufacturing
is
allowed.

10.
Manage
Residues
Appropriately:
Manage
any
components
removed
during
dismantling,
any
residues
separated
from
glass
(e.
g.,
coatings),
and
residues
from
processing
glass
(e.
g.,
blast
media,
cleaning
media,
dust,
floor
sweepings,
glass
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3
`Siftproof'
packaging
means
packaging
impermeable
to
dry
contents,
including
fine
solid
material
produced
during
transportation,
or
packaging
that
prevents
particles
from
being
released
from
the
package.

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fines)
under
applicable
waste
management
requirements
(hazardous
waste,
solid
waste).

11.
Environmental
Justice:
For
new
processors
­­
implement
a
procedure
for
advising
the
local
community
of
the
nature
of
the
activities
to
be
conducted,
including
the
limited
potential
for
resident
and
worker
exposure
to
lead
or
chemical
coatings.
This
procedure
should
include
notice
to
the
community,
and
a
public
meeting
if
requested
by
the
community.
A
local,
state,
or
federal
governmental
authority
must
approve
the
text
of
the
notice
and
the
notice
procedure,
and
must
conduct
the
meeting,
if
any.
If
preexisting
state
or
local
siting/
zoning
or
other
procedures
meeting
these
standards
are
followed,
no
additional
action
is
necessary.

12.
Package
for
Transport:
Materials
must
be
packaged
in
accordance
with
either
(1)
or
(2)
below.

(1)
CSI/
CRT
approach:
(a)
Package
TVS,
monitors,
or
whole
CRTs
in
a
way
that
minimizes
breakage
during
normal
shipping
conditions.
The
packaging
must
minimize
releases
to
the
environment
if
unintentional
breakage
does
occur.
For
example,
if
TVS
and
monitors
are
shrink
wrapped
onto
pallets
in
such
way
that
broken
pieces
of
glass
might
not
be
contained,
the
packed
pallets
should
be
placed
in
an
outside
package
(e.
g.,
a
box
or
vehicle
body)
that
will
minimize
releases.

b)
Package
broken
CRTs,
CRT
glass
pieces,
or
CRT
glass
cullet
in
siftproof
3
packaging
(i.
e.,
a
container
or
vehicle)
that
is
constructed,
filled,
and
closed
so
that:
(I)
There
will
be
no
identifiable
releases
of
CRT
glass
to
the
environment,
and
(II)
The
effectiveness
of
the
package
will
not
be
reduced
during
normal
shipping
conditions.
For
example,
packages
should
be
resistant
to
puncture
by
glass
pieces.

(2)
Universal
Waste
approach
for
materials
in
transportation:
If
the
state
in
which
the
shipment
originated
has
Universal
Waste
packaging
standards
for
the
material:
package
the
material
as
required
under
the
originating
state's
Universal
Waste
program.
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13.
Exports:
For
shipments
of
materials
that
are
hazardous
waste,
other
than
processed
CRT
glass
(without
coatings)
­­
comply
with
40
CFR
262
Subparts
E
or
H
(export
notice
and
consent
procedures
for
non­
OECD
and
OECD
countries),
revised
to
specifically
identify
the
recipient
as
a
CRT
glass
manufacturer,
or
a
collector/
processor
shipping
to
a
CRT
glass
manufacturer
(also
identify
the
manufacturer).

For
shipments
of
processed
CRT
glass
(without
coatings)
to
OECD
countries:
annual
report
to
EPA
summarizing
the
number
of
shipments
and
volume
sent
to
each
recipient
(by
country),
and
identifying
the
recipient
CRT
glass
manufacturer.

For
shipments
of
processed
CRT
glass
(without
coatings)
to
non­
OECD
countries:
annual
notification
to
EPA
90
days
prior
to
first
shipment
to
each
recipient,
identifying
the
country,
the
recipient
CRT
glass
manufacturer,
and
the
expected
number
and
volume
of
shipments
to
be
sent
that
year.

Imports:
Once
a
shipment
of
CRT
materials
that
is
to
be
used
in
CRT
glass
manufacturing
enters
the
country,
comply
with
the
CRT
glass­
to­
glass
standards.
