A Survey of Local Government References to Free Manufacturer
TakeBack Recycling Options for Obsolete E-Waste

conducted by Public Research Works in conjunction with Texas Campaign for the Environment
November 2009

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SUMMARY
Electronic waste, or “e-waste,” is the fastest-growing portion of the U.S. waste stream and contains an array of toxic materials. A typical old-style, cathode ray tube television or computer monitor contains four to eight pounds of lead, which harms virtually all systems in the human body.¹ Flat panel LCD displays contain mercury, known to disrupt the central nervous system, damage brain development, impair chromosomal function and cause birth defects.² Most electronics also contain brominated flame-retardants, which have demonstrated harmful neurological, reproductive and developmental effects in animal studies and are considered a possible human carcinogen.³ These toxic flame retardants have been detected in mother’s milk samples from all women tested in the U.S.⁴ The U.S. EPA estimates that 81% of our e-waste ends up in domestic landfills or incinerators.⁵ Consumer electronics already make up an estimated 40% of the lead and 70% of heavy metals in landfills,⁶ potentially contaminating municipal water supplies. Burning plastics releases carcinogenic dioxins into the air. According to EPA, over 2.5 million tons of e-waste were trashed in 2007 alone while only 410,000 tons were recycled.⁷

In 2007, the 80th Texas State Legislature passed unanimously the Texas Computer TakeBack Law (H.B. 2714), with the intent to divert toxic e-waste from Texas landfills and incinerators through a “comprehensive, convenient, and environmentally sound program for the collection, recycling, and reuse of computer equipment that has reached the end of its useful life.”⁸ The law requires all computer manufacturers to provide their consumers with access to free and convenient recycling for obsolete computers and monitors in order to sell products in Texas. The law went into effect on September 1, 2008. The legislation directed the Texas Commission on Environmental Quality (TCEQ) to educate Texas consumers about the new law and to set up a website with links to each manufacturer’s recycling program as well as “computer equipment collection events, collection sites, and community computer equipment recycling and reuse programs.”⁹ However, the law did not allocate funding for the agency’s mandate nor did it direct manufacturers, retailers or other stakeholders to participate in public outreach efforts. As a result, most Texans are not aware that free producer takeback recycling options exist. Although e-waste recycling options in general have become more widely available since 2007, particularly in urban population centers,¹⁰ this study shows that free producer takeback programs continue to receive little or no mention on local government websites and among local government officials.

Local government often functions as the “recycler of first resort” for its residents, a kind of information clearinghouse for instructions on responsible solid waste management. Therefore, educating municipal officials regarding producer takeback programs and policies is critical for the development of a long-term, sustainable e-cycling infrastructure in Texas. As the data in this survey indicates, local governments throughout the state still have a long way to go.

DATA ANALYSIS
Data was collected from two hundred Texas municipalities representing over fifteen million people. The survey documented references to free producer takeback recycling programs on municipal websites and in follow-up calls to local government staff. In the two hundred cities surveyed:

83.5% of municipal websites do not reference free producer takeback recycling options
The overwhelming majority of municipal websites surveyed contain no reference to free producer takeback programs  (83.5%), and most contain no reference to e-waste recycling options in general (64.0%). Thus, approximately two in three people served by the examined cities do not have access to information on mandatory or voluntary manufacturer recycling programs through their local government website (66.3%, serving 10,405,797 of 15,691,781 total residents).

80.5% of follow-up calls to city officials were not referred to free producer takeback programs, 95.5% of city officials did not reference Texas Computer TakeBack Law
Follow-up phone calls to local government representatives revealed only a slightly higher percentage of references to free producer takeback programs (19.5% compared to 16.5% via web). However, city officials referenced the Texas TakeBack Law a substantially lower rate (4.5% compared to 12.0%). Over nineteen in twenty residents (14,722,427 residents, 93.8%) received no information from local officials during follow-up calls about the TakeBack Law. By contrast, approximately seven in ten residents (10,812,031 residents, 69.9%) received no information about the law via municipal websites.

Nearly half of all references to e-cycling generally were options provided or arranged by government
Among both websites and follow-up calls, e-cycling infrastructure provided or arranged by political subdivisions themselves (in the form of local e-waste collection events or collection centers) received more references than other options. City or county household hazardous waste/recycling centers comprised almost three of every ten references on municipal websites (21, 29.2% of total references to e-waste recycling generally) and slightly more than one of every three references by city officials (33, 33.7%). Collection events received roughly half as many references via websites (10, 13.9%) and via follow-ups (14, 14.3%). Combined, e-cycling options established by local government entities comprised nearly half of all references to e-cycling options in the survey.

Goodwill recycling program accounted for 61.5% of takeback references by local government officials
The statewide Dell-Goodwill recycling partnership, the Dell-Goodwill program in Central Texas and the MRM-Goodwill program in Tarrant County account for much of the increase in the number of references to free takeback recycling options during follow-up calls (24 references by local officials, 61.5% of total references to takeback overall). Without the Goodwill programs, the number of references to free takeback options by local officials during follow-up calls drops substantially (15 references, 7.5%).

Best Buy recycling program received twice as many references as the Texas Computer TakeBack Law during follow-up calls to local officials
The Best Buy e-waste recycling program was not considered a free producer takeback program for the purposes of this survey due mainly to the fact that Best Buy provides free recycling for its private house brand electronics (Insignia and Dynex), but charges a $10.00 fee to recycle other branded electronics.¹¹ Nevertheless, the Best Buy program is in many Texas locales the only available option for television recycling and therefore merits special attention. The Best Buy electronics recycling program received nearly double the total number of mentions received by the TakeBack Law during follow-up calls (16 references, 8.0%). Combined with Goodwill, these programs garnered over three in ten of total e-cycling references via web (23, 32.0%) and four in ten via phone (40, 40.8%). While some websites and local officials mentioned both programs—creating reference overlaps—data indicates a higher overall incidence of references to Goodwill and Best Buy e-cycling programs than any others on a statewide basis, including the Texas TakeBack Law. This suggests that producer takeback programs should link with existing infrastructure for the sales and donations of household e-waste.

28.0% of city officials serving 2,139,296 Texans recommended landfill among options for obsolete e-waste
Although only two municipal websites (serving 71,071 residents) recommend tossing e-waste in the trash, placing it on the curb or transporting it to the dump, over a quarter of follow-up calls resulted in city officials recommending landfill among the options for handling obsolete electronics (56 references, 28.0%). Thus, a follow-up call to a city official was twenty-eight times more likely than browsing a municipal website to elicit a recommendation or instruction to landfill old e-waste.

Over half of all follow-up calls yielded: 1) a recommendation to landfill obsolete e-waste, 2) no viable recommendation for e-waste recycling or 3) a referral to local trash haulers or landfill operators
Combined with follow-up calls that yielded no viable recommendation for proper e-waste handling with no additional referrals (33, 16.5%) and calls referred to local trash haulers or landfill operators (13, 6.5%), more than half of follow-ups resulted in either a recommendation for land disposal or no viable recommendation for proper e-waste disposition (102 combined, 51.0%). However, only about one-fifth of the population represented in the survey falls into the same category (3,307,731 residents, 21.1%), as most large cities did not direct residents to landfill electronics.

CONCLUSIONS AND RECOMMENDATIONS
1. Overall, the low percentage of references to free producer takeback recycling options on municipal websites and in follow-up calls suggests a glaring need for robust education efforts among local government officials. The high percentage of population served for whom municipal websites and city officials do not offer information on free takeback options or on e-waste recycling generally indicates a massive potential audience for additional public education and municipal-level outreach.

2. The extraordinary dearth of references or links to the Texas Computer TakeBack Law and the www.TexasRecyclesComputers.org website strongly suggests that the unfunded legislative mandate for public education by TCEQ is failing and that additional funding is required. A $1 million budget rider for e-waste recycling outreach proposed by Senator Kirk Watson failed during the legislative session. As a result, TCEQ should immediately initiate low-cost educational measures to assist Texas local governments in public education efforts. Policies that compel electronics manufacturers and retailers to participate in public outreach and dissemination of e-cycling information are also necessary. Governor Perry vetoed legislation passed during the 81st Regular Session that would have implemented such policies.

3. Despite the reassurance of landfill trade associations and the TCEQ about the ability of modern landfills to contain toxins, given the quantity of electronic waste it is clearly preferable to recycle rather than landfill e-waste. The high incidence of local government officials recommending landfill disposal for obsolete e-waste suggests an overwhelming need for immediate and aggressive outreach at all levels and in all departments of government if Texas is to succeed in diverting toxic e-waste from landfills. A statewide disposal prohibition for electronic products covered by the Texas TakeBack Law is a necessary step.

4. Local e-waste collection events and household hazardous waste or recycling centers remain the dominant avenue for electronics recycling, usually at a cost to taxpayers, despite the viable market-based recycling options often available at no cost to taxpayers. Education initiatives aimed at local officials will facilitate and accelerate the transition from government-run, taxpayer-funded e-waste management options to market-based producer recycling programs, such as those required by the Texas TakeBack Law.

5. Data indicates a correlation between the size of municipality and the likelihood that city officials will to direct residents to some form of e-waste recycling program. Data also points to a correlation between the lack of available voluntary takeback programs in sparsely populated areas of the state and a lack of direction from local officials regarding responsible end-of-life care for toxic electronic products. Therefore, outreach regarding general e-waste recycling options must focus especially on less-populated political subdivisions throughout the state. If voluntary manufacturer recycling programs continue to disregard these locales, statewide producer takeback legislation covering additional electronic products is the only effective solution.

METHODOLOGY
Public Research Works (PRW) and Texas Campaign for the Environment (TCE) program staff and volunteers conducted this survey between August and November 2009. Survey results were obtained through an investigation and inventory of municipal websites and follow-up calls utilizing contact information provided by each website. In each case, the caller made the following inquiry: “I have an old TV and an old computer. How do I recycle them?” The caller then documented the content of each inquiry, including referrals to the Computer TakeBack Law and the TCEQ website, retailer recycling programs, non-profit organizations such as Goodwill, local recycling companies, taxpayer-funded household hazardous waste or recycling centers, landfill operators or trash haulers, city- or county-wide collection events and calls transferred to other officials.

PRW and TCE conducted the survey in two phases, the first of which focused solely on the major urban population centers: the Dallas-Fort Worth Metroplex, Central Texas and the Greater Houston-Gulf Coast region. Phase two expanded the survey to include cities spanning the various geographic regions of the state, ranging in size from El Paso (estimated population 563,662) to Eden (estimated population 2,377). Political subdivisions chosen for the survey represent a diverse cross-section of political, geographical, cultural, fiscal, historical and population factors that typically influence environmental decision-making by local government staff and elected officials.

Overall, the survey accounts for references to producer takeback programs and the 2007 TakeBack Law by political subdivisions representing 15,691,781 Texans, approximately sixty-five percent of the total estimated statewide population (24,326,974) and the majority of the estimated urban population (20,921,197),¹² in which most electronics recycling programs are concentrated. Data may not reflect recent changes to local government websites or personnel.

1 U.S. EPA: http://www.epa.gov/iaq/lead.html.
2 U.S. EPA: http://www.epa.gov/mercury/effects.htm.
3 “Computers, E-waste and Product Stewardship: Is California Ready for the Challenge?” report for U.S. EPA, 2001.
4 “Polybrominated Diphenyl Ethers (PBDEs) in U.S. Mothers’ Milk,” Environmental Health Perspectives, August 2003.
5 U.S. EPA: Electronics Management in the United States: Approach 1, July 2008.
6 “Computers, E-waste and Product Stewardship,” report for EPA, 2001.
7 “Municipal Solid Waste Generation, Recycling, and Disposal in the United States: Facts and Figures for 2007.” U.S. EPA, Office of Solid Waste, November 2008. Data is from Characterization Data Tables 12 – 14, beginning on page 71. See http://www.epa.gov/osw/nonhaz/municipal/pubs/msw07rpt.pdf.
8 Text of House Bill 2714, Enrolled Version, 80th Regular Session of the Texas State Legislature, p. 3, lines 5-8.
9 Ibid., lines 22-24.
10 Recent PRW data shows that the number of manufacturer takeback collection sites in Texas is now more than 160. There were zero at the beginning of 2007.
11 Best Buy does compensate consumers with a $10.00 gift card to be used at any Best Buy store. Although the program is not technically a “free producer takeback recycling” option, PRW and TCE applaud Best Buy’s efforts as well as references by municipal websites and officials to the Best Buy e-waste recycling program.
12 U.S. Census Bureau, Population Division, 2008 Estimates.