Edition 86
Selecting an ITAD (IT Asset Disposition) Service Partner
by Sharon Baker, Technology Conservation Group

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Most, if not all, electronic equipment contains potentially harmful materials that require special handling. The toxic components in e-waste are the main material of concern when it comes to ITAD and electronics recycling and is sometimes referred to as Focus Material.

Focus Material (FM): It is critical you receive proof of how the vendor processes FM’s in their operations and transparency in any audited down-stream vendors they send FM’s to. Focus materials are:

• CRT Glass or intact CRT monitors
• Printed circuit boards containing batteries and/or mercury devices
• Mercury containing devices
• Batteries- All Types
• Polychlorinated biphenyls (PCBs) Containing devices/equipment
• Printer cartridges and ink jets

As the generator of electronic waste, you are responsible for its on-site management, its off-site transportation, and its treatment, storage and recycling/disposal. The Environmental Protection Agency’s (EPA) regulations for the cradle to grave management of a waste apply most heavily to hazardous waste, but they also apply to hazardous e-scrap generated by a commercial or governmental entity, unless specifically exempted or excluded (check out the helpful links section for more info). If contamination occurs during any phase of this cradle to grave process, you can be held financially responsible for the cleanup costs.

Keep these long-term liabilities in mind when choosing an ITAD partner. This guide has been created to assist you in the selection and vetting process of choosing a long-term, transparent ITAD partner for your business needs.



ITAD Vendor Options
When selecting an ITAD service vendor there are several factors that should be taken into account. Luckily, there are a few ways to narrow down your options and make your decision significantly easier while still ensuring you will get the best possible service and protection for your organization.

1. Public Auctions and Open Bids
a. While holding a public auction or open bid might seem like the best way to earn the largest amount of money for your IT assets, that is not always the case and it is by far the riskiest option. By allowing anyone, including non-certified entities, to take your products, your material may be improperly handled and your organization can be held liable for the improper disposal of material or for a data breach.

2. Brokers and Local Scrap Companies
a. While some brokers may work with certified ITAD companies to supply you with services, the brokers are simply middle men that may never touch or even see your product before selling it or sending it to one of their partner organizations. In almost all cases, brokers will request a list of working equipment upfront. Why pay someone to move your material when you can establish a relationship with an ITAD organization directly and earn greater returns?

b. Your local scrap companies may be very good at what they do, but often they are not specialized for electronic material and are most likely not certified. Ask yourself if the difference in shipping cost is worth the added protection that comes from working with an organization built to handle your equipment and reduce your risk- especially if it means a higher return on your material.

3. Non-Certified ITAD/Electronics Recycling Vendors
a. Third-party certifications require a capital investment to obtain and maintain for any ITAD vendor. Certifications can save you from conducting a large amount of research on key areas of concern when it comes to ITAD/electronics recycling services. There are two major certifications in the industry- R2 and e-Stewards. The certifications cover/verify areas such as:

• Data management/destruction
• Security
• Health & Safety
• Legal Requirements
• Resale Requirements
• Insurance
• Traceability



4. Verify Certifications
a. Determine which processes and locations are actually certified. Does the certified vendor retain control of all equipment from your organization or do they outsource any portion of processing to a partner? Just because one location is certified does not mean that the entire organization is certified. Some organizations will attempt to pass off a single location’s certification as a certification for the entire company. Certified recyclers can be verified at the following links:

• https://sustainableelectronics.org/recyclers (R2)
• http://e-stewards.org/find-a-recycler/ (e-Stewards)

b. It is highly recommended that you conduct an on-site audit of a potential ITAD vendor. View the security protocols, their processes, and ask employees about health & safety- find out if they put their written system into action at all times. If you can’t go on site, conduct a thorough desk audit to view policies, understand how they track and handle your equipment, and how they continually work to improve their systems and processes. A check with local and federal government agencies can usually provide a good overview of any major violations that may affect the services you are seeking.

• U.S. EPA Echo Report (Environmental Compliance History Online)
• OSHA Violation Report (Occupational Safety and Health Administration)

c. Determine if your organization has any requirements that go beyond the minimum required by the certifications. If yes, ensure that the organization is capable of meeting your needs and can document its addition to their policies.

5. Value Adds
At this point you will have narrowed down your options significantly but there may be several options still remaining for you. Now it’s time to look for the additional offerings an organization might provide and see if they are important to you and your organization.
a. Does the organization have a full-time Quality, Environmental, Health & Safety Team?

b. Does the organization have additional insurance policies to protect your company? Additionally, does the organization’s amount of coverage meet the needs of your products and company? Some insurance coverages to consider:

• Pollution Liability: covers pollution conditions that result from ITAD provider operations, non-owned disposal sites (downstream recyclers) and transportation
• Cyber Liability: covers internal IT breaches within the company, IT breaches that result from outside the facility, and also covers data destruction services for loss of data on material sent to ITAD provider
• General Liability: covers bodily injury and property for 3rd parties
• Auto: covers vendor owned and operated vehicles as well as 3rd party carriers
• Workers Comp: covers injuries/illnesses that result from vendor operations on or off-site

c. Can the organization customize a data destruction plan to meet your needs? Special considerations might include:
• Witnessed destruction of data containing devices
• On-site data sanitization (wiping the data on the drive) and destruction (physically rendering the drive inoperable- shredding, crushing, etc.)
• Locked hard drive bins
• Sealed/Secure transport
• Chain of Custody reporting

d. Aside from destroying data contained in hard drives, does the vendor accept and destroy Disc Media, Flash Media, Tape Media, etc.?

e. Can the organization perform on-site services your company may need? Examples include pack & ship, on-site data destruction, and data center decommissioning.

f. Can the organization provide alternative reuse strategies such as donations or employee buy-back programs?

g. Can the organization work with your IT/Environmental/Sustainability departments to customize a program that fits your needs? Additional requirements might include certificates of recycling/destruction/information destruction, customized reports, and specialized processing for certain product lines.

h. Does the organization offer a revenue share on resold parts or whole equipment?

Selecting an ITAD service provider may seem overwhelming, however by following the recommendations listed you can ensure that your products are handled safely, securely, and with the highest potential for return on investment.

If you have any questions or even if you would like help establishing your entire ITAD and electronics recycling program, Technology Conservation Group and our team of experts are available to help.

Additional Helpful Links
• U.S. EPA Hazardous Waste Recycling Regulations
• U.S. EPA Universal Waste Recycling Information
• Comparison of United States Universal Waste and Hazardous Waste Requirements
• U.S. CRT Rule
• U.S. State-specific Universal Waste Regulations
• ERCC- Links to states with electronics recycling regulations
• Basel Convention Website - Search by country for import/export restrictions, and country contacts.
• Basel Convention Country Fact Sheets
• OECD Import/Export Country Information
RLM
Sharon Baker
Technology Conservation Group

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