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Meeting the Requirement of EO 13514 and GSA Bulletin FMR B-34

Dan Tobin, CPPS, FAA &Kim Doner, CPPM, SRA International

Introduction• The United States alone produces some

2.25 million tons of e-waste each year, and only about 18 percent of that is recycled; however, until now, there was no Federal requirement to recycle e-waste.

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Executive Order 13514• Executive Order

(E.O.) 13514; Federal Leadership in Environmental, Energy, and Economic Performance.

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EO 13514 Requirements• Accountability and Transparency • Strategic Sustainability Performance Planning • Greenhouse Gas Management • Sustainable Buildings and Communities • Water Efficiency • Electronic Products and Services • Fleet and Transportation Management • Pollution Prevention and Waste Reduction

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Pollution Prevention and Waste Reduction

• Minimize the generation of waste and pollutants through source reduction.

• Decrease agency use of chemicals where such decrease will assist the agency in achieving greenhouse gas reduction targets.

• Divert at least 50% of non-hazardous solid waste by the end of fiscal year 2013.

• Reduce printing paper use and acquiring uncoated printing and writing paper containing at least 30% post-consumer fiber.

• Increase the diversion of compostable and organic material from the waste stream.

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Interagency Task Force on Electronic Stewardship

• Established in the Presidential Proclamation for America Recycles Day, November 2010.

StrategyThe Task Force released the National Strategy for Electronics Stewardship report.

A copy of the strategy can be found at http://www.epa.gov/epawaste/conserve/materials/ecycling/taskforce/docs/strategy.pdf

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Introduction

GrowthMaturity

Decline

Four Goals

• Greening Incentives• Lead By Example• Increase Safety and Management• Reduce Harm

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B-34

• General Services Administration (GSA) Bulletin FMR B-34, Disposal of Federal Electronic Assets.• The bulletin recommends the use of R2

or e-Steward recyclers for the disposal of Federal Electronic Assets (FEA).

Quick Mini Lesson• A “rule” is a suggested change to a Federal

Management Regulation.

– “Rules” are distributed by GSA to all Executive Agencies for comments.

– Once all comments are reconciled, GSA issues a “Final Rule”.

– When GSA publishes revised or new regulations as a “Final Rule” in the Federal Register they are official.

• The FMR and the Federal Register must be used together to establish the

latest version of any given rule.

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GSA Bulletin FMR B-34 Highlights• Prohibits Federal agencies from disposing of

electronic waste in landfills or by incineration; • Defines specific categories of electronic items that

must be included in an annual report of transfers to non-federal recipients;

• Encourages maximum use of electronics within the Federal government and with state/local donation customers to minimize the waste stream;

• Steers agencies to sell only functional assets to the public,

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GSA Bulletin FMR B-34 Highlights

• Recommends agencies dispose of non-functional electronic assets only to certified recyclers or refurbishers;

• Enhances the reporting process so that the Federal government and the general public know where Federal electronics are being disposed of in a timely manner;

• Encourages down-stream recipients of Federal electronic property to dispose of the property through a certified recycler.

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Federal Electronic Assets (FEA)

FEA encompasses all federal electronic equipment to include:– Copiers (Federal Supply Class (FSC) 3610). – Telephones, fax machines, and communication equipment (Federal Supply

Group (FSG) 58). – Electronic Equipment Components (within FSG 59). – Electrical and Electronic Properties Measuring and Testing Instruments (FSC

6625). – Digital Cameras (within FSC 6720). – Desktop and laptop/portable computers, computer monitors, displays,

printers, peripherals, and electronic components (most of FSG 70). – Televisions and other displays (e.g., FSC 7730). – Other items that clearly utilize solid-state electronics.

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FEA• Is defined as “any item powered by electricity that has

logic circuitry enabling the item to perform its intended function.” – In other words “equipment that plugs into or may be plugged into

an electric power source or runs on batteries, including subsystems and components.”

• Must NOT be thrown in the trash.• Must be recycled by an R2 or e-Stewards Recycler

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Reporting Excess FEA to GSA• Report functional excess FEA, (FSG 58, 59, or 70, or FSC

3610, 6625, 6720, or 7730) to GSA for screening by eligible recipients.

• Do not report salvage (Condition Code X) or scrap (Condition Code S) to GSA for screening.– Use the abandonment/destruction authority (FMR § 102-36.305,

et seq.), for Condition Code X and S FEA and dispose of the property via a certified recycler.

Condition code 7 is a “gray” area.

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Condition Code Reporting

Code Description

1 New. Property that is in new or unused condition and can be used immediately without modifications or repairs.

4 Usable. Property that shows some wear, but can be used without significant repair.

7 Repairable. Property that is unusable in its current condition but can be economically repaired.

X Salvage. Property that has value in excess of its basic material content, but repair or rehabilitation is impractical and/or uneconomical.

S Scrap. Property that has no value except for its basic material content.

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Disposition of FEA• Attempts to reuse FEA in condition codes 1, 4, and 7

should be made prior to any other disposition action.

• FEA should not be disposed of in landfill or incinerators.

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FEA Located Overseas• FEA located overseas and designated as foreign

excess must follow FMR § 102-36.390.

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Recycling Methods

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Reuse• Reutilization within your agency• Transfers under the Stevenson-Wydler Technology

Innovation Act; • Transfers to other Federal agencies • Donations to schools and educational

organizations under E.O. 12999• Donations (through GSA) to states and public

airports• Sales to the public. • Donations to Public Bodies in lieu of A/D

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Take Back Programs• Replacement through exchange or sale;• Return to manufacturer

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Demanufacturing and Remanufacturing

• Demanufacturing is the disassembly and recycling of the components contained within an item. • The goal is to reuse the materials that make up the

component rather than throwing the components away.

• Remanufacturing is a process where the asset is taken apart, repaired, and reassembled to be used again.

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Recyclers“Recyclers” can include electronics resellers, refurbishers, demanufacturers, asset recoverers, brokers, or leasing companies that engage in these activities.“Certified Recyclers” must have an R2 or e-Stewards certification.

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R2 Recyclers • Responsible Recycling (R2) was facilitated

by the EPA and developed by the Institute of Scrap Recycling Industries (ISRI) which represents the Recycling industry.

• The recycler must be certified through an R2 Certifying Body.

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R2 Certification BodiesThe ANSI-ASQ Accreditation Board (ANAB) has issued a rule providing for the accreditation of Certification Bodies (CBs) to offer certification for the R2 Practices. Six CBs are currently accredited and certifying e-recyclers.– AQA International– Orion Registrar, Inc.– Perry Johnson Registrars– QMI-SAI Global– SGS– TÜV SÜD America Inc.

Where to find them

A listing of R2 certified recyclers can be found at http://www.r2solutions.org/certified/electronic-recyclers-with-r2-certified-facilities/.

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e-Stewards Recyclers• e-Stewards is a stricter standard than R2 and was

spearheaded by the Basel Action Network (BAN).• e-Stewards focuses on three key principles:– Recycling instead of landfill or incineration – No exports of e-waste to developing countries – Zero prison labor allowed anywhere in the supply chain– Worker safety practices

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E-Stewards Certification Bodies

The following certification bodies are accredited by the ANSI-ASQ National Accreditation Board (ANAB) to certify companies to the e-Stewards Standard. – AQA International– Orion Registrar, Inc.– QMI – SAI Global

Where to find them

A listing of e-Stewards recyclers can be found at http://e-stewards.org/find-a-recycler.

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Certification Costs• Each certifying body establishes their own audit

and inspection costs.• e-Stewards certification also requires a fee be

paid to BAN. • Certification fees range from $500 to $90,000.• A one time application fee from $500 to $10,000 also

applies for e-Stewards certification.

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Transfers of FEA to RecyclersUse the following statement in documentation transferring ownership or custody of FEA:

“The Federal Government has determined that improper disposal of used electronics may have potentially harmful effects on human health and the environment. This/these electronic product(s) must be disposed of at their end of useful life in accordance with all Federal, state, and local laws.

The Federal Government strongly encourages recycling these products through certified recyclers, even when such recycling is not required by Federal, state or local laws. Information regarding certified recyclers is available at http://www.federalelectronicschallenge.net/resources/links.htm#five.”

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Media Sanitization• Follow the recommendations of National Institute of

Standards and Technology (NIST) 800-88, Guidelines for Media Sanitization.– Develop consistent agency practices to clean hard drives and

other storage devices in order to protect sensitive data and maximize reuse potential by using the least destructive sanitization procedures wherever appropriate.

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Reporting RequirementsYou must report the disposition of FEA in accordance with GSA FMR Bulletin B-27 (July 22, 2010).

– A reporting tool has been developed to capture disposal information for FEA.

– The tool can be found at https://gsa.inl.gov/property– Submit annual reports online at https://gsa.inl.gov/property by October

15th of each year for the FY

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Report Data RequirementsReport data includes the recipient name, zip code, authority, FSC Group, and the Original Acquisition Cost.

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You Do NOT have to Report• Interagency transfers• Transfers to other federal agencies• Donations or transfers allocated through GSAXcess (GSA

will report those)• Sales of surplus conducted by GSA (GSA will report

those)• Property transferred to DLA Disposition Services• Property transferred to FPI Unicor (Donation in lieu of

A/D)• Exchange under FMR 102-39• CFL transfers reported in the GSA CFL PTM module

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You DO have to Report– Donations to Public Bodies– Donations to schools (CFL not recorded in the GSA CFL

PTM module and Stevenson Wydler)– Sales conducted outside of GSA (there should not be

any of these without a waiver, but we are aware that they do happen)

– Transfers to recyclers (will also need to know if they are R2 or e-Stewards certified)

– Transfers to landfills (shouldn’t be any of these either)– Donations, transfers, or sales to any non-federal

agency if the transaction is made outside of a GSA system

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Report Example

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Report Example Cont.

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Report SubmissionFollow the guidelines in GSA BULLETIN FMR B-27, Annual Executive Agency Reports on Excess and Exchange/Sale Personal Property dated July 22, 2010.

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QuestionsQuestions….questions….questions….questions