Environmental Compliance¶
Last Updated: February 2026 Target Audience: Operations Manager, Warehouse Staff, Team Leaders, Management
This guide covers the environmental regulations and procedures that apply to Scott Recycling's e-waste processing operations. Proper handling of electronic waste protects our employees, our community, and the environment -- and is required by federal and state law.
Overview¶
Electronic waste contains a mix of valuable recoverable materials and hazardous substances. As a processor of computers, monitors, printers, servers, and other electronics across 10 states, Scott Recycling must comply with EPA regulations, state-specific e-waste laws, and industry best practices for handling hazardous components.
EPA Regulations for E-Waste¶
The Environmental Protection Agency (EPA) regulates e-waste primarily through the Resource Conservation and Recovery Act (RCRA). Key requirements:
RCRA and Universal Waste¶
Many e-waste components are classified as Universal Waste under RCRA, which provides a streamlined (but still regulated) management framework:
| Component | Why It's Regulated | Classification |
|---|---|---|
| CRT monitors/TVs | Lead in glass, phosphor coatings | Universal Waste (some states) or Hazardous Waste |
| Batteries (all types) | Lead, cadmium, lithium, mercury | Universal Waste |
| Mercury-containing devices | Mercury in LCD backlights, switches, thermostats | Universal Waste |
| Circuit boards | Lead solder, heavy metals | May be exempt if recycled; regulated if disposed |
| Toner/ink cartridges | Carbon black, potentially hazardous residues | Generally not hazardous; check SDS |
| Capacitors (large, pre-1980) | May contain PCBs | Hazardous Waste if PCBs present |
| Refrigerants | CFCs, HCFCs in cooling systems | Regulated under Clean Air Act |
Generator Status¶
Scott Recycling's generator status determines which RCRA requirements apply:
| Status | Quantity Limit | Key Requirements |
|---|---|---|
| Conditionally Exempt SQG | < 220 lbs/month | Minimal requirements |
| Small Quantity Generator (SQG) | 220 - 2,200 lbs/month | EPA ID number, manifests, basic training, 270-day storage limit |
| Large Quantity Generator (LQG) | > 2,200 lbs/month | EPA ID number, manifests, training, contingency plan, biennial reporting, 90-day storage limit |
Know Your Generator Status
Generator status is determined by the total amount of hazardous waste generated per month. As our volume fluctuates, our status may change. The Operations Manager must track monthly hazardous waste generation to ensure we meet the requirements for our current status.
CRT Monitor Handling¶
CRT (Cathode Ray Tube) monitors are one of the most hazardous items Scott Recycling processes. The glass contains lead (up to 4-8 pounds per monitor), and some contain mercury in internal components.
Lead Exposure
CRT glass contains lead oxide. Broken CRT glass releases lead dust, which is toxic when inhaled or ingested. Always wear required PPE when handling CRTs, and NEVER break CRT glass intentionally outside of a controlled processing area.
PPE Required for CRT Handling¶
| PPE Item | Requirement |
|---|---|
| Face shield or safety goggles | Protect against glass fragments |
| Respirator (N95 minimum; P100 for broken glass) | Protect against lead dust |
| Heavy-duty cut-resistant gloves | Protect against glass cuts |
| Long sleeves and pants | Minimize skin exposure |
| Steel-toe boots | Protect feet from dropped monitors |
CRT Storage Requirements¶
- Store CRTs upright on pallets to prevent breakage
- Do not stack CRTs more than 2 layers high (with cardboard between layers)
- Broken CRTs must be placed in a lined, covered container immediately
- Keep CRT storage area dry to prevent lead leaching
- Label CRT storage area: "UNIVERSAL WASTE -- CRT MONITORS -- DO NOT BREAK"
- Do not store CRTs for more than 1 year (Universal Waste time limit)
CRT Processing¶
- Only trained and authorized personnel may process CRTs
- Process CRTs in a designated area with proper ventilation
- Clean up any broken glass immediately using wet methods (not dry sweeping)
- Dispose of CRT glass through a licensed CRT glass recycler or lead smelter
- Maintain records of all CRT glass shipments (weight, destination, date)
Battery Handling and Storage¶
Scott Recycling encounters batteries in nearly every type of electronic device. Different battery chemistries present different hazards.
Battery Types and Hazards¶
| Battery Type | Found In | Primary Hazard | Storage Requirement |
|---|---|---|---|
| Lithium-ion (Li-ion) | Laptops, phones, tablets, UPS | Fire, explosion, thermal runaway | Individual terminal taping; fireproof container |
| Lithium polymer (LiPo) | Phones, tablets, wearables | Fire, explosion (especially if swollen/damaged) | Same as Li-ion; extra caution with swollen batteries |
| Lead-acid | UPS systems, servers | Acid burns, lead exposure | Upright in acid-resistant secondary containment |
| Nickel-cadmium (NiCd) | Older laptops, power tools | Cadmium toxicity | Tape terminals; standard battery collection |
| Nickel-metal hydride (NiMH) | Older electronics | Low hazard | Tape terminals; standard battery collection |
| Alkaline (AA, AAA, etc.) | Peripherals, remotes | Low hazard (leaking electrolyte) | Standard battery collection |
Lithium Battery Fire Risk
Lithium-ion and lithium polymer batteries can enter thermal runaway if damaged, punctured, shorted, or exposed to heat. A thermal runaway event produces intense fire, toxic fumes, and can spread to adjacent batteries. Lithium battery fires CANNOT be extinguished with standard water or ABC extinguishers.
Lithium Battery Safety Procedures¶
- Inspect all batteries removed from devices for damage (swelling, punctures, dents, corrosion)
- Tape terminals on every battery with electrical tape or use individual plastic bags to prevent short circuits
- Store in a fireproof container (metal drum or battery-rated container) away from other combustibles
- Separate damaged/swollen batteries -- place in sand bucket or designated fireproof isolation container
- Do not stack batteries -- store in a single layer
- Keep a Class D fire extinguisher AND a sand bucket at every battery storage location
- Limit storage quantities -- do not accumulate excessive quantities; ship to the battery recycler regularly
Lithium Battery Fire Response¶
Lithium Battery Fire
If a lithium battery catches fire or enters thermal runaway:
- Evacuate the immediate area -- alert all nearby personnel
- Do NOT use a standard ABC fire extinguisher -- it will not extinguish a lithium fire
- Use the sand bucket to smother the battery if the fire is small and contained
- Use a Class D fire extinguisher if available
- If the fire spreads beyond the single battery, evacuate the building and call 911
- Ventilate the area -- lithium fires produce toxic fumes (hydrogen fluoride)
- Report the incident immediately to the Operations Manager
Battery Shipping¶
- Ship batteries to a licensed battery recycler (downstream vendor must be qualified per R2)
- Package batteries per DOT requirements (see DOT Compliance)
- Maintain shipping records (weight, count by type, destination, date)
Hazardous Materials Identification¶
Warehouse and processing staff must be able to identify common hazardous components found in electronics.
Common Hazardous Components in E-Waste¶
| Component | Hazardous Substance | Where Found | What to Do |
|---|---|---|---|
| CRT glass | Lead | Monitors, TVs | Segregate for CRT recycler |
| LCD backlights (older) | Mercury | Flat-panel monitors, laptops | Remove carefully; store as Universal Waste |
| Batteries | Lead, cadmium, lithium | All device types | Sort by chemistry; handle per battery procedures |
| Toner cartridges | Carbon black, potentially hazardous residues | Printers, copiers | Seal open cartridges; store in lined container |
| Large capacitors (pre-1980) | PCBs (polychlorinated biphenyls) | Old industrial equipment, large CRTs | Do not open; segregate; dispose as hazardous waste |
| Mercury switches | Mercury | Some older equipment, thermostats | Do not break; store in sealed container |
| Refrigerants | CFCs, HCFCs | Air conditioning equipment, some server room units | Must be recovered by certified technician |
| Fluorescent tubes | Mercury | Backlighting in scanners, copiers | Do not break; store as Universal Waste |
| Beryllium | Beryllium oxide | Ceramic components in some electronics | Do not grind or sand; handle intact |
| Brominated flame retardants | PBDEs | Plastic housings, circuit boards | Handle normally; avoid burning |
When in Doubt, Ask
If you encounter a component or substance you cannot identify, do not attempt to process it. Set it aside, label it, and notify your team leader or the Operations Manager.
State-Specific Regulations¶
Scott Recycling collects materials in 10 states and processes them in Tennessee. Each state may have additional requirements beyond federal regulations.
Tennessee (Processing Facility)¶
- Tennessee Solid Waste Disposal Act governs waste management
- TDEC (Tennessee Dept. of Environment and Conservation) is the primary regulatory agency
- Electronics recyclers must comply with TDEC rules for solid waste processing
- No state e-waste law mandating manufacturer take-back (as of 2026)
- CRT monitors and TVs are classified as Universal Waste
- Hazardous waste generators must register with TDEC and obtain an EPA ID number
Virginia¶
- Virginia Computer and Television Recycling Act -- manufacturers must provide recycling programs
- Collectors and recyclers must maintain records of materials handled
- CRT disposal restrictions apply
- Virginia DEQ oversees compliance
Kentucky¶
- Kentucky Electronics Recycling Act -- prohibits disposal of certain electronics in landfills
- Covered devices include computers, monitors, TVs, printers
- Recyclers must maintain records and report annually to the Kentucky Division of Waste Management
- Universal Waste rules apply to CRTs and batteries
Arkansas¶
- Arkansas Electronic Waste Management Act -- manufacturers must provide recycling
- Collectors must register with ADEQ (Arkansas Dept. of Environmental Quality)
- Record-keeping requirements for collected electronics
- Universal Waste rules apply
Other States (NC, SC, GA, WV, AL, AZ)¶
- Each state has varying levels of e-waste regulation
- North Carolina has a comprehensive e-waste law with manufacturer responsibility
- South Carolina prohibits landfill disposal of certain electronics
- Georgia has voluntary manufacturer recycling programs
- West Virginia has basic solid waste regulations; limited e-waste specific rules
- Alabama has no specific e-waste law; federal regulations apply
- Arizona has no specific e-waste law; federal regulations apply
Regulatory Updates
State e-waste regulations change frequently. The Operations Manager should review regulations in each operating state at least annually and update procedures accordingly. The R2 Certification process requires a legal compliance register that tracks all applicable regulations.
Waste Manifests and Tracking¶
When Manifests Are Required¶
Hazardous waste shipments require a Uniform Hazardous Waste Manifest (EPA Form 8700-22):
- Shipments of hazardous waste to a Treatment, Storage, and Disposal Facility (TSDF)
- Some Universal Waste shipments (check state requirements)
- Any shipment the receiving facility or transporter requires a manifest for
Manifest Procedure¶
- Prepare the manifest before the shipment leaves the facility
- Include all required information:
- Generator (Scott Recycling) name, address, EPA ID number
- Transporter name and EPA ID number
- Designated receiving facility name, address, and EPA ID number
- Waste description, quantity, container type
- Proper DOT shipping name and hazard class
- Sign the manifest and obtain the transporter's signature
- Retain generator copy -- the transporter takes the remaining copies
- Receive signed copy back from the designated facility within 35 days (SQG) or 45 days (LQG)
- File and retain manifests for a minimum of 3 years
Material Tracking (Non-Hazardous)¶
Even for non-hazardous materials, track all outbound shipments:
| Record | Required Information |
|---|---|
| Date shipped | When the materials left our facility |
| Material type | Category (e.g., steel, aluminum, circuit boards, plastic) |
| Weight | Total weight of the shipment |
| Destination | Name and address of the receiving facility |
| Transporter | Who transported the shipment |
| Bill of lading or receipt | Documentation from the transporter/receiver |
Spill Response Procedures¶
Spill Kit Requirements¶
Spill kits must be maintained at the following locations:
- Battery storage area
- CRT processing area
- Toner/ink storage area
- Loading dock
- Chemical storage area (if applicable)
Spill Kit Contents¶
| Item | Purpose |
|---|---|
| Absorbent pads and pillows | Soak up liquid spills |
| Absorbent granules (kitty litter or commercial absorbent) | Cover and absorb larger spills |
| Plastic bags (heavy-duty) | Contain contaminated absorbent for disposal |
| Nitrile gloves | Hand protection during cleanup |
| Safety goggles | Eye protection during cleanup |
| Dustpan and brush | Collect dry spill material |
| Caution tape or cones | Cordon off the spill area |
| Spill response instruction card | Quick-reference cleanup steps |
Spill Response Steps¶
Large or Unknown Spills
If the spill is large (more than 1 gallon), involves an unknown substance, or you are unsure how to handle it: evacuate the area, prevent others from entering, and call 911 and the Operations Manager immediately. Do not attempt to clean up a spill you are not trained to handle.
For small, known spills (e.g., battery acid, toner, minor chemical):
- Alert nearby workers and keep them clear of the area
- Put on PPE from the spill kit (gloves, goggles)
- Contain the spill -- place absorbent materials around the edges to prevent spreading
- Absorb the spill -- apply absorbent granules or pads to soak up the liquid
- Clean up -- collect all contaminated absorbent material with the dustpan and place in a heavy-duty plastic bag
- Label the bag with the contents and date
- Dispose of properly -- contaminated cleanup materials may be hazardous waste; consult the Operations Manager
- Report the spill to your team leader and the Operations Manager
- Restock the spill kit immediately after use
Proper Disposal Channels¶
Where Materials Go After Processing¶
| Material Stream | Disposal/Recycling Channel | Notes |
|---|---|---|
| CRT glass (leaded) | Licensed CRT glass recycler or lead smelter | Must be shipped as Universal Waste |
| Batteries (lithium) | Licensed battery recycler | Ship per DOT hazmat requirements |
| Batteries (lead-acid) | Licensed lead-acid battery recycler | Ship per DOT hazmat requirements |
| Batteries (NiCd, NiMH, alkaline) | Licensed battery recycler | Universal Waste |
| Circuit boards | Precious metals refiner | Valuable material; track carefully |
| Steel/aluminum | Scrap metal processor | Standard commodity recycling |
| Copper (wire, components) | Scrap metal processor | Standard commodity recycling |
| Plastics | Scott Plastics division or downstream plastics recycler | Sort by resin type (HDPE, PET, PP, etc.) |
| Mercury-containing components | Licensed mercury recycler | Universal Waste |
| Toner cartridges | Toner recycler or return to manufacturer | Some manufacturers have take-back programs |
| Non-recyclable residual waste | Licensed solid waste facility | Minimize this stream |
Downstream Due Diligence
Under R2, every downstream processor must be qualified and audited. See R2 Certification -- Downstream Due Diligence for vendor qualification requirements. Maintain records of all outbound material shipments, including destination and weight.
Record Retention¶
| Record Type | Retention Period |
|---|---|
| Hazardous waste manifests | Minimum 3 years (federal); check state requirements |
| Universal Waste shipment records | Minimum 3 years |
| Non-hazardous material shipment records | Minimum 3 years (R2 requires retention through certification cycle) |
| Spill incident reports | Minimum 3 years |
| Environmental permits | Duration of permit + 3 years |
| Training records (environmental) | Duration of employment + 3 years |
| EPA generator registration | Maintain as long as generating waste |
Questions? Contact your supervisor or refer to the Getting Started guide.