Final Report to the U.S

New text

THE COLLECTION AND RECYCLING OF USED COMPUTERS USING A REVERSE DISTRIBUTION SYSTEM

A PILOT PROJECT WITH STAPLES, INC.

FINAL REPORT TO THE U.S. ENVIRONMENTAL PROTECTION AGENCY

Developed by: Product Stewardship Institute, Inc. 137 Newbury Street Boston, MA 02116 (617) 236-4855 www.productstewardship.us June 2005

Staples Pilot Project –Final Report to U.S. EPA

ACKNOWLEDGEMENTS

This report was written by Scott Cassel, Product Stewardship Institute Inc., with assistance from Mark Buckley, Staples, and Christine Beling, U.S. Environmental Protection Agency/New England.

The following people assisted in the development and implementation of this pilot project:

Mark Buckley Vice President, Environmental Affairs Staples, Inc. (508) 253-0510 [email protected]

Scott Cassel Executive Director, Product Stewardship Institute, Inc. (617) 236-4855 [email protected]

Christine Beling U.S. Environmental Protection Agency/New England (617) 918-1792 [email protected]

The following individuals provided technical information and assistance:

 Katharine Kaplan Osdoba and Clare Lindsay, U.S. Environmental Protection Agency  Tom Metzner, Connecticut Department of Environmental Protection  Diana McKenzie, Carole Cifrino, and Scott Whittier, Maine Department of Environmental Protection  Greg Cooper and James Paterson, Massachusetts Department of Environmental Protection  Pierce Rigrod and Mike Guilfoy, New Hampshire Department of Environmental Services  Mark Dennen, Rhode Island Department of Environmental Management  Tina Haley and Mike Tallon, Envirocycle, Inc.

Product Stewardship Institute, Inc. i FINAL June 2005 Staples Pilot Project –Final Report to U.S. EPA

TABLE OF CONTENTS Problem Statement ...... 1 Goal Statement ...... 1 Project Concept ...... 1 Collaborative Project/Partners ...... 2 Timeframe ...... 2 Products Accepted ...... 2 General Operations ...... 3 Retail Operations ...... 3 Commercial Operations ...... 3 Transportation to Recycler ...... 3 Project Results ...... 3 Data Collection ...... 3 Materials Collected: Units and Weights ...... 3 Retail Customer Surveys at Retail Locations ...... 4 Contract Customer Surveys at Commercial Locations ...... 5 Customer Satisfaction ...... 5 Promotion/Advertising and Customer Education ...... 6 project Costs...... 6 Retail Collection Costs ...... 7 Commercial Collection Costs ...... 8 Recycling Costs ...... 8 Other Costs...... 9 Regulatory Issues ...... 9 Federal Guidelines ...... 9 Pilot States Regulations ...... 9 Pilot Project Benefits ...... 9 Key Lessons Learned ...... 10 Recommendations ...... 11 Program Logistics ...... 11 Training And Regulatory Requirements ...... 13 Data Collection, contracts, and budget ...... 13 Education And Outreach ...... 14 Program Evaluation ...... 14

CHAPTER I. BACKGROUND ...... 16 Problem Statement ...... 16 Solution: Shared Responsibility ...... 16 Collaborative Project/Partners ...... 17 Staples, Inc.: Responding to the Needs of Business Customers ...... 17 Product Stewardship Institute, Inc...... 18 U.S. Environmental Protection Agency ...... 18

Product Stewardship Institute, Inc. ii FINAL June 2005 Staples Pilot Project –Final Report to U.S. EPA

Computer Manufacturers ...... 18 Envirocycle, Inc.: Project Recycler ...... 19 State and Local Government Agencies ...... 20 Participant Funding/Contribution ...... 20 Staples, Inc...... 21 Manufacturers ...... 21 Envirocycle ...... 22 State Agencies ...... 22 U.S. Environmental Protection Agency ...... 23 Product Stewardship Institute, Inc...... 23

CHAPTER II. PROJECT DESCRIPTION ...... 24 Goal Statement ...... 24 Retail Collection Locations...... 24 Commercial Collection Locations ...... 24 Internet/Catalogue Customers ...... 25 Timeframe ...... 25 Products Accepted ...... 26 General Operations ...... 26 Retail Operations ...... 26 Commercial Operations ...... 28 Transportation to Recycler ...... 28 Staff Training and Education ...... 28 Promotion/Advertising and Customer Education ...... 29

CHAPTER III. SELECTING THE RECYCLING SERVICES ...... 31 Logistical Concerns ...... 31 Regulatory Concerns ...... 31 Environmental Concerns ...... 31 Health and Safety Concerns ...... 32 Security Concerns ...... 32 Reuse Opportunities ...... 32 Selection Process ...... 33

CHAPTER IV. PROGRAM RESULTS ...... 35 Data Collection ...... 35 Materials Collected: Units and Weights ...... 35 Total Equipment Collected (retail and commercial) ...... 35 Customer Equipment Surveys at Retail Locations ...... 37 Contract Customer Surveys at Commercial Locations ...... 38 Perceptions of the Program ...... 39 Staples Staff ...... 39

Product Stewardship Institute, Inc. iii FINAL June 2005 Staples Pilot Project –Final Report to U.S. EPA

Customer Satisfaction ...... 40 Effectiveness of Promotions/Advertising ...... 44

CHAPTER V. PILOT PROJECT COSTS ...... 45 Total Costs ...... 45 Project Design and Implementation ...... 45 Recycling Costs ...... 45 Staples’ Costs ...... 46 Retail Collections ...... 46 Commercial Collections...... 47 Other Costs...... 48

CHAPTER VI. PILOT PROJECT COST PROJECTIONS ...... 50 Estimated Costs to Staples ...... 50

CHAPTER VII. REGULATORY ISSUES ...... 52 Federal Guidelines ...... 52 Pilot States Regulations ...... 52 Connecticut Regulations ...... 53 Maine Regulations ...... 54 Massachusetts Regulations ...... 55 New Hampshire Regulations ...... 55 rhode island Regulations ...... 55

CHAPTER VIII. PILOT PROJECT BENEFITS ...... 57

CHAPTER IX. KEY LESSONS LEARNED ...... 59

CHAPTER X. RECOMMENDATIONS ...... 61 Program Logistics ...... 61 Training And Regulatory Requirements ...... 64 Data Collection, contracts, and budget ...... 65 Education And Outreach ...... 67 Program Evaluation ...... 68

Product Stewardship Institute, Inc. iv FINAL June 2005 Staples Pilot Project –Final Report to U.S. EPA

TABLES

Table 1. Project Partners ...... 2 Table 2. Staples/PSI Pilot Project – Collection Summary/All Equipment ...... 4 Table 3. Staples/PSI Pilot Project Retail Survey Data ...... 5 Table 4. Pilot Project Costs by Phase and Funding Source...... 6 Table 5. Pilot Project Retail Collection Cost: Handling, Shipping, and Transportation ...... 7 Table 6. Average National Estimated Retail Collection Cost: Handling, Shipping, and Transportation ...... 8 Table 7. Pilot Project Contract Collection Cost: Handling, Shipping, and Transportation ...... 8 Table 8. Staples/PSI Pilot Project Collection Summary Total Cost By Brand And By Product ...... 22 Table 9. Recyclers Interviewed for Staples Pilot Project ...... 34 Table 10. Staples/PSI Pilot Project – Collection Summary/All Equipment ...... 36 Table 11. Percentage of Participating Manufacturers and Non-Participants by Equipment Type 36 Table 12. Total Equipment Collected By Brand And By Product – Retail Customer Surveys .. 37 Table 13. Total Equipment Units Collected by State – Retail Customer Surveys ...... 38 Table 14. Total Equipment Collected By Equipment Type and By Company – Contract Customer Surveys ...... 39 Table 15. Staples/PSI Pilot Project Retail Survey Data ...... 41 Table 16. Pilot Project Costs by Phase and Funding Source...... 45 Table 17. Pilot Project Retail Collection Cost: Handling, Shipping, and Transportation ...... 46 Table 18. Average National Estimated Retail Collection Cost: Handling, Shipping, and Transportation ...... 47 Table 19. Pilot Project Contract Collection Cost: Handling, Shipping, and Transportation ...... 48 Table 20. Factors Affecting Staples Costs ...... 51 Table 21. Quantity Data and Collection Method ...... 66 Table 22. Cost Data and Collection Method ...... 66

Product Stewardship Institute, Inc. i FINAL June 2005 Staples Pilot Project –Final Report to U.S. EPA

APPENDICES

Appendix A. Letter to Computer Manufacturers Appendix B. Contacts for Staples Pilot Project Appendix C. Standard MOU and Summary of Manufacturer MOUs Appendix D. Staples/PSI Pilot Project Cost Detail Appendix E. Project Summary Appendix F. Staples Retail Collection List Appendix G. Criteria for Selection of Retail Stores and Businesses for Pilot Project Appendix H. Staples Contract Collection List Appendix I. Retail and Commercial Electronics Drop-off Forms Appendix J. Staples Store Communications Package Appendix K. Calendar Listing – Promotional Announcement Appendix L. Natick Bulletin & Tab Article on Pilot Project Appendix M. Reviewing Electronics Recyclers Appendix N. Checklist For Electronics Recyclers Appendix O. Reuse Organizations In The Northeast Appendix P. Retail Equipment Collection Survey Data Appendix Q. Contract Equipment Collection Survey Data Appendix R. Retail and Contract Customer Satisfaction Surveys Appendix S. Staples Data Needs for Pilot Project Appendix T. Staples Internal Retail Collection Costs Appendix U. U.S. EPA Regulatory Guidelines for Plug In Partners Appendix V. Connecticut Department of Environmental Protection Appendix W. Maine Department Of Environmental Protection Appendix X. Massachusetts Department of Environmental Protection Appendix Y. New Hampshire Department of Environmental Services Appendix Z. Rhode Island Department Of Environmental Management Appendix AA. Computer Manufacturers

Product Stewardship Institute, Inc. ii FINAL June 2005 Staples Pilot Project –Final Report to U.S. EPA

APPENDIX TABLES

Table D1. Brand-Sorted Data -- Monitors Table D2. Brand-Sorted Data -- CPUs Table D3. Brand-Sorted Data -- Printers/Mfds/Fax/Desktop Copiers/Scanners Table D4. Brand-Sorted Data -- Laptops, Small Peripherals & Non Computer Equipment* Table P1. Equipment Type Collected By Store And By Brand Table P2. Total Equipment Type Collected By Store Table P3. Equipment Type Collected By Major Brand Table Q1. Staples Contract Customer Collection Data Total Number, Weight, And Cost By Brand Table T1. Staples Retail Pallet Costs

Product Stewardship Institute, Inc. iii FINAL June 2005 Staples Pilot Project –Final Report to U.S. EPA Executive Summary

THE COLLECTION AND RECYCLING OF USED COMPUTERS USING REVERSE DISTRIBUTION SYSTEMS: A PILOT PROJECT WITH STAPLES, INC.

1 EXECUTIVE SUMMARY

PROBLEM STATEMENT Used electronic products are one of the fastest growing waste problems in the world. A study by the National Safety Council found that only 11-15 percent of computers were being reused or recycled in 1998, and that electronics recycling is still unavailable or very expensive in many United States cities and towns. Lead is found in the cathode ray tubes (CRTs) in televisions and computer monitors. Electronic components contain other toxic substances, including cadmium and phosphorous in CRTs, lead solder and copper on circuit boards, mercury in laptop displays, lithium batteries, and brominated flame retardants in the plastic housing. These toxic materials can be released to the environment from waste management or recycling practices, making it imperative that discarded electronics are handled safely with regard to human health and the environment. In addition, reusing and recycling electronics creates economic value, saves resources and energy, and creates more jobs than disposal.

GOAL STATEMENT The goal of the project was to collect and recycle unwanted electronics from Staples’ retail and commercial customers using its existing product distribution network, and to evaluate whether this approach represents a sustainable business model for Staples.

PROJECT CONCEPT Since retailers are a direct connection to consumers of electronics, they are considered logical points for consumer education, and potential take-back sites for used products. Many retailers already manage used electronic products from returns, lease exchanges, and the replacement of their own equipment at a cost that could be reduced or eliminated through a national electronics management system. A few companies have even conducted voluntary take-back pilot projects from retail customers. However, none of the financial models for calculating costs for a national collection, transportation, and recycling infrastructure had considered the cost savings from backhauling used electronics by reversing the existing distribution system.

This project tested this collection model in the northeast, using Staples’ product delivery networks around the Killingly, Connecticut, distribution center (for retail products), the Putnam, Connecticut, fulfillment center (for commercial products), and the North Reading and Sharon transportation hubs in Massachusetts. Staples collected all brands of used computers at retail stores located in Maine, Massachusetts, New Hampshire, Rhode Island, and Connecticut, and from commercial customers in Massachusetts, New Hampshire, and Connecticut. The collected equipment was backhauled by Staples’ carriers and consolidated at its distribution and

1 This report is available at http://www.productstewardship.us/pilot_takeback_staples.html and www.plugintoecycling.org. Product Stewardship Institute, Inc. 1 FINAL June 2005

Staples Pilot Project –Final Report to U.S. EPA Executive Summary

fulfillment centers, then transported via Staples’ trucks to Envirocyle, an electronics recycler, in Hallstead, Pennsylvania.

COLLABORATIVE PROJECT/PARTNERS This project evolved from a joint meeting in April 2003 between representatives of Staples, Inc. (headquartered in Framingham, MA), the Product Stewardship Institute, Inc. (Boston, MA), and the U.S. Environmental Protection Agency/New England (Boston, MA). After PSI evaluated Staples’ potential financial exposure and showed how costs could be contained, the company contracted with PSI to design a pilot project for recovering computer equipment from its customers. PSI and Staples enrolled in EPA’s “Plug-In To eCycling” pilots, which added government financial and technical support, promoted cost-sharing incentives for manufacturers and recyclers, and brought greater recognition for Staples.

Prompted by a January 2004 Plug-In To eCycling press event at the annual Computer Electronics Show, the project gained the support of 10 manufacturer partners (see Table 1). Each partner signed a memorandum of understanding (MOU) that committed these companies to pay for the cost of recycling their brand of computer equipment and a share of the cost of recycling non- participant brands, including equipment manufactured by companies no longer in business, up to a $10,000 cap. Additional partners included a recycler and five state agencies.

Table 1. Project Partners

 Staples, Inc.  Apple Computer, Inc.  Product Stewardship Institute, Inc.  Brother International Corp.  U.S. Environmental Protection Agency/New  Dell England and Headquarters  Epson America, Inc.  Envirocycle, Inc.  HP  Connecticut Department of Environmental  Intel Protection  Lexmark International, Inc.  Maine Department of Environmental Protection  Panasonic  Massachusetts Department of Environmental Protection  Sharp Electronics Corporation  New Hampshire Department of Environmental  Sony Electronics, Inc. Services  Rhode Island Department of Environmental Management

TIMEFRAME The pilot collections ran for six weeks, from May 29 through July 11, 2004.

Product Stewardship Institute, Inc. - 2 - FINAL June 2005 Staples Pilot Project –Final Report to U.S. EPA Executive Summary

machines, desktop copiers, scanners), and small peripherals (e.g., keyboards, mice, speakers, cables).

GENERAL OPERATIONS Retail Operations Computer equipment was collected at no charge at a cross-section of 27 Staples retail stores in five states: Maine (10 stores), Massachusetts (8 stores), New Hampshire (5 stores), Connecticut (3 stores), and Rhode Island (1 store). Equipment was shipped in the same manner as returns (using reverse distribution) to the distribution center (DC) in Killingly, Connecticut.

Commercial Operations Computer equipment was collected at no cost from 14 commercial customers in three states that receive direct delivery of goods at their place of business by Staples’ trucks or common carrier. Staples either picked up the equipment upon delivery of new products, as part of Staples’ typical process for returning products that are defective, damaged, or otherwise unwanted, or scheduled a separate pick up. Other equipment was “live loaded.” Gaylords were transported back (using reverse distribution) to the fulfillment center (FC) in Putnam, Connecticut, or consolidated at either the Sharon or North Reading, Massachusetts, transportation hubs for a line haul the next day to the FC. Staples also took advantage of space on Envirocycle trucks from loads that were being hauled from other electronics collection events in Massachusetts and Connecticut back down to the Envirocycle facility.

Transportation to Recycler When a tractor-trailer load of equipment accumulated at either the DC or FC, Staples’ trucks transported the computers to Envirocycle in Hallstead, Pennsylvania. Typically, when Staples had more than 22 pallets collectively at the DC and FC, it arranged for joint shipment of commercial and retail mixed material to Envirocycle.

PROJECT RESULTS Data Collection The pilot project collected data that enabled Staples to understand the degree to which the reverse distribution collection approach could be part of the company’s sustainable business model, and how it could be implemented on a national scale. The retail and contract customer satisfaction surveys helped PSI to evaluate the program from the users’ perspective. The data collected will enable Staples to make adjustments and improvements to any future program expansion that it plans to undertake, in which case there will be an ongoing need for data systems to track equipment shipments, costs, and customer satisfaction.

Materials Collected: Units and Weights PSI collected data in three ways for the retail and commercial collections:

(1) Data provided by Envirocycle, which combined retail and commercial loads;

Product Stewardship Institute, Inc. - 3 - FINAL June 2005 Staples Pilot Project –Final Report to U.S. EPA Executive Summary

(2) Data tabulated from surveys filled out by customers at the retail locations; and

(3) Data tabulated from surveys filled out by commercial clients.

The total number of units of computer equipment collected was 4,522, weighing 107,360 pounds, and costing $7,983.10 to recycle (see Table 2). Although Staples advertised that it would only accept computer equipment, an additional 735 units of audio/visual and other equipment were collected, bringing the total number of units collected to 5,257. The non-computer related units represented approximately 14 percent of the total number of units collected. The total weight of all material collected was 115,028 pounds, costing $8,519.86 to recycle, for an average cost per pound of 7.4 cents, and an average weight per unit of 21.88 pounds. Between 38% and 50% of monitors, CPUs, and large peripherals returned by customers was manufactured by companies that were not partners in the pilot project.

Table 2. Staples/PSI Pilot Project – Collection Summary/All Equipment

Product Number Of Units Pounds Cost*

Computer Monitors 1,642 62,396 $6,568.00 CPUs 1,076 24,748 $0 Small Peripherals 649 10,386 $727.00 Printers/MFDs/Fax/Desktop 1,089 8,843 $619.01 Copiers/Scanners Laptops 66 987 $69.09 SUBTOTAL — COMPUTER EQUIPMENT 4,522 107,360 $7,983.10 Audio/Visual Equipment 645 4,516 $316.12 Other 90 3,152 $220.64 TOTAL – ALL EQUIPMENT 5,257 115,028 $8,519.86 * $4.00/monitor; no charge for CPUs; $.07/pound for all other products

Retail Customer Surveys at Retail Locations As part of the retail customer survey results that PSI tabulated (see Table 3), 1,351 retail customers (81%) said they brought equipment from their home and 308 retail customers (19%) said the equipment was from their business. Some of the customers operated a small business, or were municipal officials and school employees, while the vast majority were residents. Table 3 also indicates that the vast majority of equipment came from storage, most people are willing to pay a fee to recycle their computers, and a significant number of people heard about the program through a store flyer or display.

Product Stewardship Institute, Inc. - 4 - FINAL June 2005 Staples Pilot Project –Final Report to U.S. EPA Executive Summary

Table 3. Staples/PSI Pilot Project Retail Survey Data

Willing To Pay A Recycling Heard About The Equipment From Equipment Fee In The Future Program From Being From Store Store Home Office Used Storage Yes No Flyer Display Other

1351 308 529 1095 1008 507 260 483 845

Contract Customer Surveys at Commercial Locations Data from the 14 contract customers that participated in the pilot project were parsed into the following categories:

 Equipment type collected by business and by brand.  Equipment type collected by business.  Equipment type collected by major brand. There were 636 units of equipment collected, totaling 13,226 pounds, at a recycling cost of $752.

Customer Satisfaction PSI developed a Retail Customer Satisfaction Survey and a Contract Customer Satisfaction Survey, which it administered by phone to a limited number of pilot project participants.

Retail Customers

 Customer responses were overwhelmingly positive, and they wanted the program to continue. From an operational perspective, the program was easy to implement.  Customers that brought in equipment did not want to dispose of it in the garbage but were looking for an opportunity to recycle it. Staples provided that opportunity. Many cited environmental reasons (e.g., toxics) for why they did not want to put it in the garbage. Others stored the equipment in belief that there was still value to it.  Most customers were willing to pay a fee for the recycling service. (Even so, it must be kept in mind that those who participated in the recycling program are a subset of all those who have computers that need to be recycled. Those participating in recycling programs would be more likely to pay to participate than those who are not motivated to recycle their equipment.) Contract Customers

 Each company believed that Staples provided a valuable service and made it easy to collect the equipment. All wanted to see the program continue; the average need for service per company was estimated to be 1 or 2 times per year.

Product Stewardship Institute, Inc. - 5 - FINAL June 2005 Staples Pilot Project –Final Report to U.S. EPA Executive Summary

 The program cleared out space where the computers used to be stored, so employees were happy with the result. Employees were unaware of recycling options.  Most of the companies contacted said that they would be willing to pay to recycle their equipment in the future, since most understood that they were actually required to safely manage their products. However, almost all said that they would only use Staples for this service if their price was competitive with alternative options. With that said, many thought there was an added value to ordering supplies from the same company that took back the used computer equipment.  Several companies wanted to receive a certificate of data destruction to ensure that confidential information was wiped clear off the computers. Since this assurance was only possible for recycled, and not reused, equipment, Staples did not offer reuse.

PROMOTION/ADVERTISING AND CUSTOMER EDUCATION Staples took a cautious approach to promotion of the recycling program to keep from getting inundated with equipment. This allowed the company to remain under budget, keep its focus on the operations, develop buy-in from the whole Staples team, and develop a clear picture of what will be required to successfully roll this program out nationally. By design, Staples promoted the program slowly and ramped it up slowly. It never fully contacted all the media outlets, and kept the program low-key throughout the six weeks. Much of this focus was on an in-store flyer, store display, and banner. Six newspapers in Massachusetts, five papers in Maine, and one trade publication ran stories about the program.

PROJECT COSTS The cost of collecting, transporting, and recycling 115,028 pounds of retail and commercial equipment collected in this pilot project was $93,432, or 19.9 cents per pound (see Table 4).

Table 4. Pilot Project Costs by Phase and Funding Source.

Who Paid Project Phase Cost U.S. EPA Project Implementation/Evaluation $46,541 Staples Project Design $17,000 Handling/Collection – Retail (northeast region) $1,870 Transportation to DC and Envirocycle (northeast region) $11,355 Delivery of Pallets – Commercial (northeast region) $72 Pallet Pick Up/Delivery To FC and Envirocycle – Commercial $1,044 (northeast region) Promotion, Staff training, Administrative Staff $7,030 Manufacturers Recycling $8,520* TOTAL COST $93,432

* Envirocycle’s recycling costs for this pilot project (7.4 cents per pound, on average) were approximately one-third the market rate (about 20 cents per pound). Bolded items have been used to calculate the cost per pound.

Product Stewardship Institute, Inc. - 6 - FINAL June 2005 Staples Pilot Project –Final Report to U.S. EPA Executive Summary

Retail Collection Costs Staples internal cost for the 27 retail collections includes the cost of handling the computer equipment in the store, transporting to the DC, and transporting to Envirocycle in Pennsylvania. Staples treated retail returns of used electronics in the same manner as it treated other returns, and shipped equipment in its own trucks to the DC. Staples hauled 377 pallet loads of computers (equal to 17.14 trailer loads), at a handling cost of $4.96 per pallet and a cost to ship them to the Killingly DC of $9.67 per pallet. Staples also incurred costs of $450 per trailer load to transport to Envirocycle from the DC, equal to $20.45 per pallet. The total cost, therefore, to collect and transport 377 retail pallet loads to Envirocycle through the DC was $13,225.16, or $35.08 per pallet (see Table 5). The cost to collect and transport this retail equipment to Envirocycle prior to recycling was 8.9 cents per pound. Adding to that the average price per pound to recycle the equipment of 7.4 cents per pound, the total cost to collect, transport, and recycle retail equipment in this pilot project was 16.3 cents per pound. If Staples had to pay the market recycling rate (estimated at 20 cents per pound delivered at the facility gate), this total cost would equal about 28.9 cents per pound.

Table 5. Pilot Project Retail Collection Cost: Handling, Shipping, and Transportation

Staples and PSI used the following Per Pallet Per Pound assumptions: Cost Type Cost Cost • 1 system = 3 units Handling $ 4.96 1.26 cents • 6 systems = 1 pallet (Gaylord) Shipping to Distribution Center $ 9.67 2.45 cents • 22 pallets = 1 trailer load Transport to Envirocycle $20.45 5.19 cents  1 unit = 21.88 pounds (from Table 2)  1 pallet = 393.84 pounds TOTAL COST $35.08 8.90 cents To calculate the following: • $771.76/trailer load • $ 35.08/pallet • $ 5.85/system • $ 1.95/unit

Costs in the New England corridor, however, are lower than the company’s nationwide average given the northeast’s proximity to the DC and short transit times to stores. The national average cost to ship a pallet of computer equipment from the store to the DC is estimated to be $28.53 per pallet (see Table 6). Therefore, if the pilot was expanded nationally, the cost to handle each pallet and transport it to a qualified recycler through one of the company’s four DCs would be $53.94, or 13.7 cents per pound. This cost assumes that the handling cost is $4.96 per pallet, and that a qualified recycler will be within a 250-mile radius from a DC, which was the distance from the Killingly DC to Envirocycle in this pilot project. Since Staples will seek to find a recycler at a closer distance, this 13.7 cents per pound figure should be considered an upper amount. Adding to that the average price per pound to recycle the equipment of 7.4 cents per pound, the total cost to collect, transport, and recycle retail equipment nationally would be 21.1 cents per pound. However, if Staples paid the market recycling rate (estimated at 20 cents per pound delivered at the facility gate), this total cost would equal about 33.7 cents per pound.

Product Stewardship Institute, Inc. - 7 - FINAL June 2005 Staples Pilot Project –Final Report to U.S. EPA Executive Summary

Table 6. Average National Estimated Retail Collection Cost: Handling, Shipping, and Transportation

Per Pallet Cost Type Per Pound Cost Cost Handling $ 4.96 1.26 cents Shipping to Distribution Center $28.53 7.24 cents Transport to Qualified Recycler (<250 miles) $20.45 5.19 cents TOTAL COST $53.94 13.69 cents

As Table 6 indicates, in a national effort, there would be a marked difference in cost from the northeast pilot project. The cost to recycle in other regions of the country would vary from the national average depending on the distance to the DC from a retail location and the distance from the DC to a qualified recycler. There are four Staples’ DCs in the country – in Connecticut, Maryland, Indiana, and California.

Commercial Collection Costs Staples also calculated its internal costs for collecting 636 units of equipment from 14 contract customer locations. Based on the data in Table 7, the full cost to collect and transport 35.33 pallet loads to Envirocycle through the FC would be $1,116, or $31.59 per pallet. Using an estimated weight of 21.88 pounds per unit (393.84 pounds per pallet) of equipment collected (from Table 2), the cost to collect and transport this commercial equipment to Envirocycle prior to recycling is 8.0 cents per pound. Adding to that the average price per pound to recycle the equipment of 7.4 cents per pound, the total cost to collect, transport, and recycle commercial equipment was 15.4 cents per pound. At an estimated market recycling rate of approximately 20 cents per pound, this total cost would equal about 28 cents per pound.

Table 7. Pilot Project Contract Collection Cost: Handling, Shipping, and Transportation

Per Per Staples and PSI used the following Pallet Pound assumptions: Cost Type Cost Cost Cost • 1 system = 3 units Delivery of Pallets $72 $2.04 0.52 • 6 systems = 1 pallet (Gaylord) cents • 22 pallets = 1 trailer load Pallet Pick Up/Delivery To FC $324 $9.17 2.33  1 unit = 21.88 pounds (from Table 2) cents  1 pallet = 393.84 pounds Transport to Qualified Recycler $720 $20.38 5.17 (<250 miles) cents To calculate the following costs: TOTAL COST $1,116 $31.59 8.02 • $694.98/trailer load cents • $ 31.59/pallet • $ 5.27/system • $ 1.76/unit

Recycling Costs The 10 participating manufacturers contributed a total of $8,519.86. Envirocycle offered the following discounted rates for equipment processing as project partner: $4.00 per monitor; no

Product Stewardship Institute, Inc. - 8 - FINAL June 2005 Staples Pilot Project –Final Report to U.S. EPA Executive Summary

charge for CPUs; and $.07 per pound for large peripherals, small peripherals, laptops, and non- computer equipment.

Other Costs Promotion, staff training, and administrative staff costs were estimated to be approximately $7,030. Staples did not believe that storage space for used electronics was a factor that added cost to the project. Backhaul opportunities on Staples’ trucks are frequent, and the equipment was treated as a "cross dock shipment" when it got to the DC, where it went immediately into a trailer with equipment from the FC for shipment to Envirocycle. The time taken by Staples’ technical and managerial staff to plan and implement the pilot project was not estimated.

REGULATORY ISSUES Federal Guidelines Under federal regulations, any unwanted electronic equipment containing a cathode ray tube (CRT), including computers and televisions, is currently considered a hazardous waste under federal regulation (40 CFR Part 260). Hazardous waste regulations do not apply to household sources of electronics, or to businesses that generate under 7-8 CRTs per year. States can have more stringent regulations governing the handling of electronics, and there is no one set of standards that applies to all states. Therefore, the result is a patchwork of regulations that must be considered when setting up a program to accept used electronics. This situation might be alleviated to some degree when the federal regulations for CRT electronics are finalized, as expected in the fall of 2005, and adopted by the states. The proposed rule is available on the PSI website, at http://productstewardship.us/pilot_takeback_staples.html. In the interim, the U.S. EPA has provided guidelines for the safe management of materials (available at http://www.epa.gov/epaoswer/osw/conserve/plugin/pdf/guide.pdf) for its “Plug In” partners who collect electronic equipment for the purpose of recycling.

Pilot States Regulations States have some ability to streamline regulations for electronics product stewardship efforts, and PSI worked with Staples and state agency officials to identify and comply with the states’ regulatory interpretations. None of the state regulations added significantly to the cost and complexity of this project. To standardize the handling procedures for all Staples facilities and associates in the five pilot states, Staples adopted the general guidelines for universal waste handling, transport, and storage.

PILOT PROJECT BENEFITS There were numerous benefits to conducting this pilot project, many of which should be considered when evaluating a national expansion. Each of the following benefits is discussed in greater detail in the full document, as are the key lessons learned.

 Solves a Pressing Environmental Need  Provides a Known Collection Location and Education Opportunity

Product Stewardship Institute, Inc. - 9 - FINAL June 2005 Staples Pilot Project –Final Report to U.S. EPA Executive Summary

 Creates Good Will  Demonstrates Collaborative Problem Solving  Provides One Stop Shopping  Offers Staples a Promotional Opportunity  Offers Manufacturers a Promotional Opportunity  Establishes Staples as a Brand Leader  Provided an Impetus for Other Retailers to Engage  Enabled Data/Information Sharing

KEY LESSONS LEARNED  Program was Logistically Feasible: It is feasible for a retailer to take back unwanted computer equipment at a retail store, or from businesses, using a reverse-logistics collection, transportation, and recycling model.  Program was Successful. Staples staff, retail customers, and contract customers were enthusiastic about the program and want it to continue. Over 57.5 tons of equipment was collected in six weeks from both retail and commercial customers at a cost that was competitive with other electronics collections.  Staples’ Customers are Environmentally Aware. Retail and commercial customers are savvy about environmental concerns from electronic wastes. Few questioned the need for collection.  Staples Customers are Willing to Pay for Computer Recycling (Note: This should not be used as a reason to charge in the long-term, since there are still a significant number of people who will not pay. But it can provide funds to start or supplement a program.)  There is a Backlog of Equipment. There is a significant backlog of equipment that needs to be collected initially from customers, particularly among businesses, making a simple “back haul” of equipment difficult for a “first time” recycling effort.  Computers Returned from Non-participating Companies were Significant. A significant percentage of computer equipment returned to the collections came from those that did not contribute financially to recycling costs.  Manufacturer MOUs Were Time Consuming to Negotiate. Most manufacturers wanted to change some aspect of the standard MOU, and a few wanted individualized agreements that were much different from the basic template.  Communication Miscues were Costly. Communication between the recycler and the Project Team resulted in missed data gathering opportunities and extra time and cost to extrapolate data (e.g., leaving one company out of the brand sort).  Commercial Collections were Unique. Whereas retail collections followed a noticeable pattern, Staples needed to arrange contract customer collections individually owing to a

Product Stewardship Institute, Inc. - 10 - FINAL June 2005 Staples Pilot Project –Final Report to U.S. EPA Executive Summary

variation in pick up locations and equipment quantities and types. Over time, models should evolve within these collections, making contract customer service delivery easier.  A Little Promotion can go a Long Way. Taking a low-key promotional approach worked well for Staples employees and management, even if additional customers could have benefited by the initial pilot.  Expect Business Equipment. There was a small, but significant, segment of retail customers who brought equipment used for business, including municipal offices.  Recyclers were Staples Shoppers. Most of those interviewed who returned equipment to retail stores said that they typically shop at Staples. Few people came into the store only because of the recycling program, largely owing to the focus on in-store promotion.  Data Quality was Not High. Allowing retail and contract customers to fill out their own data sheets did not provide high quality data.  Beware of Municipal Regulations During Outreach. Some municipalities would not allow Staples to advertise using a banner on the exterior of the store.

RECOMMENDATIONS Whether to expand this computer recycling project nationwide is a decision for Staples management. However, from the data developed from this project, there appears to be little doubt that there is a clear need, and opportunity, to expand the collections both at retail outlets and contract customer locations. The computer recycling service was well received; there are numerous benefits to expansion; and Staples’ internal costs were reasonable. In addition, any costs incurred by Staples could be offset by a fee charged to customers, many of whom are willing to pay to recycle, and/or by manufacturers’ contributions. Adding computer recycling service to Staples’ growing environmental products and services will solidify Staples’ position as a company that not only provides quality office products and services, but one that cares about the company’s impact on the environment and the community served by its retail stores. Expanding this recycling service would further enhance Staples’ image as a sustainable business.

Those seeking electronics collection service, however, should not place an over-reliance on retail take-backs, since these programs are undertaken at a company’s discretion. If Staples, for example, decides to end the program, for whatever reason, this might pull the plug on recycling if this were the only, or most significant option, available to consumers. Therefore, while the Staples pilot project should be understood as a significant opportunity for Staples and other retailers, these retail programs need to become part of a more comprehensive collection and recycling infrastructure. Listed below are specific recommendations that Staples should consider in expanding computer recycling services to other areas of the country, or making it permanent in the five New England states that were part of the pilot project. Each is discussed in more detail in the full document.

Program Logistics  Treat Used Computers Like A Return. Typical retail product returns are brought to a customer service representative, who records vital information directly into a computer

Product Stewardship Institute, Inc. - 11 - FINAL June 2005 Staples Pilot Project –Final Report to U.S. EPA Executive Summary

database and takes possession of the product. Used computers should follow a similar procedure, which will ensure quality data, reduce the likelihood of equipment breakage, and provide a greater level of service. Staples could handle computer returns from businesses at the point at which orders are placed.  Charge a Recycling Fee. Until a state or national financing system comes into existence, charge a fee to collect and recycle computer equipment from both retail and commercial customers. The fee charged to customers will need to be competitive with other recycling services, particularly among commercial customers, although there is an added value in having one company – Staples – provide office supplies and recycling services (on the backhaul) to these commercial customers. Providing a tangible community benefit, as it did in a separate pilot project for retail customers in the Northwest, would add to the acceptance of the retail fee.  Recover the Full Recycling Cost in the Recycling Fee. Do not rely on a cost share from manufacturers in setting the recycling fee owing to the large percentage of computers collected from non-participating manufacturers. There is a question as to whether participating manufacturers will continue to cover the costs imposed by manufacturers that are not taking responsibility for their fair share, and put themselves at a competitive disadvantage.  Expand the Limit on Equipment Allowed per Retail Customer. Instead of restricting residents to one computer system, consider expanding the limit on retail customers to 4 or 6 units per customer, as was successfully demonstrated in Staples’ Northwest pilot project. Some limit will be needed if Staples will want to discourage business equipment.  Identify Business Equipment. Since some states may require that equipment from businesses be identified and treated differently from equipment from households, ask a question on the in-take survey as to the origin of the equipment of those entering retail stores.  Phase Collections — Cleanout and Maintenance. Before a maintenance program can be put in place, anticipate that a large initial amount of material will be generated in areas without past collections. Conducting equipment clean outs, phasing collections, or ramping up service will ensure that the program is not inundated with equipment.  Implement a Commercial Equipment Pick-up System: Ensure a chain of custody to better track equipment and report to customers by assigning a bar code or other identification to shipments at the point at which the recycling service is ordered.  Develop a Standard MOU with Manufacturers with Few Variations. Dictate the terms of an agreement and only allow variations in very special circumstances. If a business wants to collect its own material, it should be required to pay for the cost of separating and recycling its own equipment.  Assign a Dedicated Staples Daily Contact. Consider assigning an internal dedicated staff person that could serve as the daily point contact to retrieve data, contact Core Team personnel, and communicate preferences and decisions.  Promote Reuse. Ask potential recyclers being interviewed for future collections to provide the cost of adding reuse to the services provided, and the method by which data will be

Product Stewardship Institute, Inc. - 12 - FINAL June 2005 Staples Pilot Project –Final Report to U.S. EPA Executive Summary

destroyed. Use domestic reuse organizations until a credible system is put in place for the return or proper management of electronics sent for reuse to other countries.  Enhance Data Security to Allow for Reuse: In the future, electronics from companies should be tagged with a noticeable sticker or other identifier to signal to the recycler that special handling is required (e.g., scrubbing the hard drive to allow for reuse). By instituting a rigorous procedure that ensures data destruction, reuse might increase for companies that have newer and, therefore, more marketable, equipment.  Incorporate Recycler Selection Criteria. If expanding computer collections across the U.S., use the recycler selection criteria developed for the pilot project and determine the relative importance of the proximity of a recycler to a consolidation point, among other issues.  Collect Additional Items. Consider collecting and recycling other electronic items that Staples sells but doesn’t now collect, such as computer discs and other electronic media. These items should be phased in along an established timetable.

TRAINING AND REGULATORY REQUIREMENTS  Provide Training For Contract Customers. Many of Staples’ contract customers started recycling their computer equipment during this pilot project. Consider developing training specific for companies that will need to educate their own employees to start recycling computers instead of throwing them away.  Handle All Materials Using General Guidelines For Universal Waste. Adopt general guidelines to abide by the universal waste requirements if expanding the program nationwide or making it permanent in the five New England states that were part of the pilot project.  Seek to Standardize Regulatory Requirements. Although complying with state regulatory requirements was not overly burdensome, and PSI received excellent assistance from state regulatory officials, the process was time-consuming. Standardized regulations will lower the costs to collect, transport, and recycle electronics. However, if the regulatory requirements prove to be too cumbersome in some states, consider limiting the initial program to states with a more relaxed interpretation of how electronics can be safely managed.  Develop a Tracking System for Collected Computers. Staples’ automated return system already tracks customer information, product type, brand name, and other data. Explore adapting this return system to accommodate customers bringing used electronics.  Standardize Computer Handling Guidelines And Training For Staples Associates. Refine and standardize training for the national rollout to ensure that it will meet the regulatory requirements in all states.

Product Stewardship Institute, Inc. - 13 - FINAL June 2005 Staples Pilot Project –Final Report to U.S. EPA Executive Summary

assignment of bar codes to individual items using methods comparable to Staples’ current return and exchange procedures.  Calculate Other Costs To Staples. Calculate and budget for total costs that will likely be part of the national expansion of the collection system, including associate and management time, storage, equipment and supplies, advertising, and promotion.  Budget for Non-computer Equipment. Expect, and budget for, a certain percentage of related non-computer equipment, even if it is specifically not accepted as part of the program.  Develop Detailed Contract with Recycler. Develop a detailed contract with the recycler regarding expectations about the companies for which brand sorts should take place, whether retail and commercial loads will be tracked separately, the forms used for data collection, how manufacturer cost shares are to be calculated, who invoices manufacturers for their cost share, average weights used per equipment type, and which equipment types will be sorted by brand.

PROGRAM EVALUATION  Evaluate Customer Satisfaction. Staples should train its customer service staff to survey retail and contractor customers to learn valuable lessons about the program.  Provide for Internal Feedback. Staples associates familiar with the recycling program should provide important feedback on needed improvements.

Product Stewardship Institute, Inc. - 14 - FINAL June 2005 Staples Pilot Project –Final Report to U.S. EPA Executive Summary

 Communicate Project Results. Holding a briefing at critical junctures in the project timetable will ensure that project results and implications are understood, and that the feeling of participating in a joint project is enhanced.

Product Stewardship Institute, Inc. - 15 - FINAL June 2005 Staples Pilot Project –Final Report to U.S. EPA Background

CHAPTER I. BACKGROUND

PROBLEM STATEMENT Used electronic products are one of the fastest growing waste problems in the world. A 1997 study by Carnegie Mellon University estimated that by 2005, one computer would be disposed of for every two that were purchased.2 A later study by the National Safety Council estimated that more than 20 million personal computers became obsolete in the United States in 1998, and that 61.1 million computers could become outdated in 20043. This same study found that only 11-15 percent of computers were being reused or recycled in 1998, and that electronics recycling is still unavailable or very expensive in many United States cities and towns. The study also reported that many computers could be reused, refurbished, or harvested for parts if collected soon after replacement, although too many are stored until the technology becomes obsolete.

In 1999, researchers at the University of Florida tested the leachability of lead from the cathode ray tubes (CRTs) found in televisions and computer monitors. They found average concentrations of 18.5 mg/L of lead were released from crushed CRTs, more than three times the 5.0 mg/L limit set by the U.S. Environmental Protection Agency.4 These findings determined that many CRTs that were disposed of had to be managed as hazardous waste. In addition, electronic components contain other toxic substances, including cadmium and phosphorous in CRTs, lead solder and copper on circuit boards, mercury in laptop displays, lithium batteries, and brominated flame retardants in the plastic housing. These toxic materials can be released to the environment from waste management or recycling practices, making it imperative that discarded electronics are handled safely with regard to human health and the environment. Reusing and recycling electronics creates economic value, saves resources and energy, and creates more jobs than disposal.

SOLUTION: SHARED RESPONSIBILITY “Product Stewardship” is a principle that directs all those involved in the life cycle of a product to take shared responsibility for reducing the health and environmental impacts that result from the production, use, and end-of-life management of the product. Since April 2001, a multi- stakeholder group involved in the National Electronics Product Stewardship Initiative (NEPSI) worked to develop a cooperative agreement that would share responsibility for the end-of-life management of electronic products. Those involved in the dialogue included federal, state, and local governments, manufacturers, recyclers, environmental organizations, and others. Retailers were largely absent from the NEPSI discussions and, as a result, their capabilities have gone largely unexplored – until now. Retailers, along with product manufacturers, have been viewed

2 Matthews, H.S., M.C. McMichael, C.T. Hendrickson, D.J. Hard. 1997. Disposition and End of Life Options for Personal Computers, Green Design Initiative, Technical Report #97-10. Carnegie Mellon University, Pittsburgh. 3 National Safety Council’s Environmental Health Center. 2001. Electronic Product Recovery and Recycling Baseline Report. Available from EHC, 1025 Connecticut Ave, NW, Suite 1200, Washington, DC 20036, 202-293- 2270 4 Townsend, Timothy G, Stephen Musson, Yon Chul Jang, Il-Hyun Chung. 1999. Characteristics of Lead Leachability from Cathode Ray Tubes Using the Toxicity Characteristic Leaching Procedure, Report #99-5. University of Florida, Center for Solid and Hazardous Waste Management, Gainesville FL. Product Stewardship Institute, Inc. 16 FINAL June 2005

Staples Pilot Project –Final Report to U.S. EPA Background

as a critical component of the electronics recycling infrastructure. Since retailers are a direct connection to consumers of electronics, they are considered logical points for consumer education, and possible take-back sites for used products. Many retailers already manage used electronic products from returns, lease exchanges, and the replacement of their own equipment at a cost that could be reduced or eliminated through a national electronics management system.

COLLABORATIVE PROJECT/PARTNERS This project evolved from a joint meeting in April 2003 between Mark Buckley (Vice President of Environmental Affairs, Staples, Inc.), Scott Cassel (Executive Director, Product Stewardship Institute, Inc.), and Christine Beling (U.S. Environmental Protection Agency/New England). Staples had an interest in providing added service to its customers and wanted to take advantage of its existing product distribution network. PSI was heavily involved in the national electronics dialogue and believed that reducing collection and transportation costs would solve a key problem for local government agencies collecting electronics. EPA was also committed to the national dialogue, and had a great depth of experience in the logistics and cost of electronics collections.

These three entities formed the Project Team, which reached out to other potential partners. Through PSI and EPA contacts, computer manufacturers were encouraged to sign a memorandum of understanding (MOU) with Staples as a commitment to share in the recycling costs. Following PSI research and subsequent interviews, Staples chose Envirocycle, Inc. as the project recycler. In addition, PSI asked the five state agencies in which the pilots were to be held to join as pilot partners. These agencies, all of which are PSI members, became partners. The roles and responsibilities of each of the project partners are described below.

Staples, Inc.: Responding to the Needs of Business Customers Businesses disposing of even a few computers can be liable for mishandling hazardous waste. Large businesses usually generate sufficient volumes of usable electronics to attract recycling services, but small and medium-size businesses are left with few choices other than replacing equipment and waiting for an affordable recycling opportunity. Even then, the burden is on the business to ensure that the recycler operates in compliance with local, state, national, and international requirements. Some businesses have unwittingly paid sham recyclers to handle their old computers only to be informed later that the equipment was found in an illegal dump or in a poor, developing nation.

Staples viewed this need by businesses as an opportunity to offer its customers a valuable service that other office product retailers did not provide, and to help minimize the environmental impact from electronics. Staples realized that, if its customers could return used computers through the same ordering and delivery systems by which they purchase new products, small and medium- size businesses could appreciate the same convenience and lower management prices now available only to large businesses. Additionally, Staples could incorporate “best management practices” to handle used electronics from its customers and facilities, thereby preventing future environmental liability and unfavorable publicity. For the project, Staples committed its own labor, transportation equipment, and storage capacity for consolidating the equipment and shipping it to a recycler, and it also promoted the program.

Product Stewardship Institute, Inc. - 17 - FINAL June 2005 Staples Pilot Project –Final Report to U.S. EPA Background

Staples Core Team: To enhance communication within the company, Staples’ Mark Buckley coordinated an internal Core Team, which included representatives from Industrial Engineering, Marketing, Operations, Merchandising, Logistics, Small Business Advantage (commercial customers, also called “contract customers”), and corporate offices. Other Staples departments were included as needed. The team consisted of 10-15 people who were directly involved with various phases and functions of the pilot project implementation. This group met once for strategic planning purposes, and was authorized to devote the time and resources necessary for the planning, implementation, and evaluation of the pilot project. Lines of communication were defined so that representatives from different departments were able to work together during program planning and delivery. Mark Buckley was responsible for coordinating the Staples Core Team and communicating with the Team.

Product Stewardship Institute, Inc. The Product Stewardship Institute, Inc. (PSI) held the country’s first Product Stewardship Forum in December 2000 to address priority waste streams, including electronics. Following the momentum created by this and other government-sponsored forums, the National Electronics Product Stewardship Initiative, or “NEPSI,” was formed to focus a broader stakeholder dialogue around electronics management. PSI coordinated the participation of over 25 state agencies and numerous local agencies in this dialogue. Staples approached PSI in recognition of the Institute’s national role in the electronics discussions, and expressed a willingness to share responsibility for recovering electronics from its customers. PSI was aware that none of the NEPSI financial models for calculating costs for a national collection, transportation, and recycling infrastructure had considered the cost savings from backhauling used electronics by reversing the existing distribution system. Staples and PSI agreed to partner on this project, and PSI was contracted by Staples in the spring of 2003 to design a sustainable business model for recovering electronics from its customers. PSI became the manager and coordinator of the pilot project to test the design for national application.

U.S. Environmental Protection Agency Staff working on the U.S. Environmental Protection Agency (EPA) Innovations Work Group, as well as EPA Region 1/New England, are also partners in this pilot project. The partnership between Staples and PSI drew more interest as EPA Headquarters launched a series of highly visible, pilot electronic take-back projects under the banner of Plug-In to eCycling. After the Staples pilot project was designed, PSI recommended that the Staples project become one of the “Plug In” pilots, thereby enhancing government support, promoting cost-sharing incentives for manufacturers and recyclers, and bringing greater recognition for Staples. (See http://www.epa.gov/epaoswer/osw/conserve/plugin/pdf/staples.pdf for more on the Staples/PSI eCycling Project.) In addition, PSI competed for, and secured, additional funding under EPA’s Spring 2003 IWG grant competition.

Computer Manufacturers Ten computer manufacturers agreed verbally to sign a memorandum of understanding (MOU) with Staples that offered to pay for the cost of recycling their brand of computer equipment. In addition, most of the companies agreed to pay for a share of the cost of recycling non-participant

Product Stewardship Institute, Inc. - 18 - FINAL June 2005 Staples Pilot Project –Final Report to U.S. EPA Background

brands. The following manufacturers announced their intent to participate in the Staples pilot project at a January 2004 Plug-In To eCycling press event at the annual Computer Electronics Show:

 Apple Computer, Inc.  Intel  Brother International Corp.  Lexmark International, Inc.  Dell  Panasonic  Epson America, Inc.  Sharp Electronics Corporation  HP  Sony Electronics, Inc. PSI and Staples only approached manufacturers of computers and computer peripherals, since the pilot collections focused on those materials. PSI and Staples drafted a letter that was sent by Peter Scala, Staples Merchandising Department, and Mark Buckley to the managers of the Staples account for each computer supplier – Brother, Canon, Epson, Hewlett-Packard, Lexmark, Minolta, Panasonic, and Sharp (see Appendix A: Letter to Computer Manufacturers). While Staples contacted the manufacturers’ account representatives, PSI phoned the policy and legal advisors for the same companies to seek their partnership. This dual approach emphasized the importance of the Staples pilot project in the context of other national electronics management efforts. PSI also contacted computer manufacturers that are not currently suppliers for Staples, recognizing that the pilot collections would recover all brands of computer equipment, including those from companies no longer in business. PSI’s intent was to engage as many partners as possible to reduce each participant’s cost burden.

While PSI and Staples were contacting manufacturers, EPA held several meetings with manufacturers of electronics equipment, including computers and televisions, to develop formal commitments for sharing costs for Plug-In To eCycling projects, including the Staples project. EPA offered participating manufacturers incentives such as favorable publicity and recognition.

To formalize agreements with the 10 manufacturers, PSI drafted a model agreement and sent it to each manufacturer. PSI asked each manufacturer to pay for processing its own equipment plus a portion of the equipment manufactured by companies no longer in business, and by manufacturers not participating in the pilot. Based on the projected amount of equipment to be collected, PSI was able to calculate a reasonable projected cost for the pilot project collections. Based on this estimate, Staples agreed to cap each manufacturer’s total cost at $10,000. This cost ceiling helped to gain the commitment to participate from the 10 manufacturers.

Envirocycle, Inc.: Project Recycler National Context: Staples, as well as participating manufacturers, were concerned about their potential liability in the pilot project. Prior to the time that the pilot was being implemented, the Basel Action Network released a compelling video showing improper computer recycling overseas. Staples and PSI wanted to make sure that the recycler chosen for the project would handle the equipment in an environmentally and socially responsible manner. Staples decided that the recycler chosen would not transport materials overseas, but would only use domestic markets. In addition, environmental groups and some government agencies expressed concern

Product Stewardship Institute, Inc. - 19 - FINAL June 2005 Staples Pilot Project –Final Report to U.S. EPA Background

over the use of prison labor to process electronics, which they claim results in a competitive disadvantage for private electronics recyclers. Since this issue was unresolved at the time of project implementation, Staples chose not to use prison labor. These decisions were taken so that the project would not be delayed, and were not definitive policy positions taken by Staples or the Project Team.

Summary of Selection Process. To select a recycler, PSI compiled databases of active recyclers from officials in the five pilot project states, as well as from WasteCap of Massachusetts, the Northeast Recycling Council, and EPA. PSI then worked in conjunction with a graduate student intern at the Massachusetts Institute of Technology’s Materials Systems Lab, who reviewed company websites to narrow the list to full-service recyclers that provided disassembly, data removal, reuse, and recycling. To further screen recyclers, PSI developed criteria, in conjunction with Staples, and assisted Staples in interviewing three recyclers that met the criteria.

PSI asked electronics manufacturers and state officials if they had worked with any of the three recyclers being interviewed. Several of the computer manufacturers responded that they would only participate as pilot project sponsors if Envirocycle, located in Hallstead, Pennsylvania, was the chosen recycler. These companies had established a partnership with Envirocycle, had toured the recycling plant, and performed audits of the company’s environmental performance. After Envirocycle presented a proposal to become a full partner in the eCycling pilot project by providing services at a vastly reduced recycling rate, Staples and PSI determined that Envirocycle offered the best choice at this time. (For more information about the recycler selection process, see Chapter III.)

State and Local Government Agencies PSI obtained support for the pilot project from environmental officials in the five northeast states in which the pilot was being implemented – Connecticut, Maine, Massachusetts, New Hampshire, and Rhode Island. PSI and EPA also compiled a list of municipal recycling contacts in the towns where pilot stores were located, as well as key state and federal agencies and organizations in the pilot regions (see Appendix B: Contacts for Staples Pilot Project).

PARTICIPANT FUNDING/CONTRIBUTION PSI reduced Staples’ costs for the pilot project by developing cost-sharing arrangements with manufacturers and the recycler, and by drawing on the resources of state and local government agencies. PSI also obtained EPA funding for a significant portion of its own involvement in the pilot project development, monitoring, and evaluation.

Product Stewardship Institute, Inc. - 20 - FINAL June 2005 Staples Pilot Project –Final Report to U.S. EPA Background

Staples, Inc. Staples costs for the pilot project included initial pilot design; equipment handling at the 27 retail locations and 14 commercial locations; shipment to the Distribution Center and Fulfillment Center in Connecticut; and transportation to the Envirocycle facility in Hallstead, Pennsylvania. Staples also incurred minimal costs to promote and plan the project. These costs, which are detailed in Chapter V, were calculated to be $38,371, including $17,000 for the pilot design, $14,341 for the collection and transportation of retail and commercial equipment, and $7,030 for program promotion, staff training, and administrative staff.

Manufacturers MOUs. PSI attempted to obtain signed memorandums of understanding (MOUs) from each of the 10 manufacturer partners. The standard agreement developed by PSI and Staples required partners to pay for the cost of recycling their own computer equipment, and a share of computer equipment from non-participating manufacturers, up to a cap of $10,000. The percentage share of non-participants was based on the percentage of the participating manufacturers’ equipment collected in the pilot. (See Appendix C for a standard MOU.)

After several months of discussions with representatives from each of the manufacturers, PSI obtained signed agreements with Apple, Epson, Panasonic, and Sharp. Draft MOUs were developed with Brother, Dell, Lexmark, and Sony. HP made a verbal commitment to join the project, but requested that Envirocycle separate out HP products and ship them to HP. Dell originally agreed to pay only for its brand products and a percentage of non-participating brands for commercial collections only, and not for retail collections. Later, Dell also requested that its products be sorted and transported to one of its approved recyclers.

Sharp’s MOU capped its payment at $5,000 and did not allow payment for a percentage of non- participating brands, expressing concern over the fairness of certain large companies not participating in the program. After the pilot, however, Sharp did agree to pay for a percentage of equipment from non-participants owing to the low cost of the pilot. Panasonic also expressed similar concerns, but agreed after the pilot to pay for its share of non-participant equipment, again owing to the low pilot cost. (For a summary of manufacturer MOUs, see Appendix C.)

Cost Share. The 10 participating manufacturers contributed a total of $8,519.86. A summary of these costs appears by brand and by product in Table 1 below, with brand-sorted cost details appearing in Appendix D. Envirocycle sorted the brands of two non-participating manufacturers (Gateway and IBM), which were also included in the data analysis. PSI used standard equipment weights provided by Envirocycle and discounted rates for equipment processing. PSI also calculated each brand’s share of the cost for recycling the products of non-participants. Envirocycle conducted brand sorts only on monitors, CPUs, and large peripherals. For those equipment types, each brand’s cost share for non-participants was calculated directly. However, for laptops, small peripherals, and non-computer equipment, PSI averaged the brand shares for monitors and large peripherals and applied that average percentage to the three other categories in which no brand sort occurred.

Product Stewardship Institute, Inc. - 21 - FINAL June 2005 Staples Pilot Project –Final Report to U.S. EPA Background

Table 8. Staples/PSI Pilot Project Collection Summary Total Cost By Brand And By Product

Large Other Brand Monitors CPUs Peripherals Equipment* Total Cost

Apple $3,794.00 $0 $127.11 $521.74 $4,442.85 HP/Compaq $1,599.00 $0 $310.86 $496.95 $2,406.81

Gateway (NP) - - - - - IBM (NP) - - - - - Dell $742.00 $0 $0.00 $75.31 $817.31 Sony $269.00 $0 $0.00 $27.32 $296.32 Epson $33.00 $0 $118.89 $131.35 $283.24 Panasonic $82.00 $0 $52.13 $64.38 $198.51 Brother $33.00 $0 $8.22 $12.20 $53.42 Sharp $16.00 $0 $1.80 $3.60 $21.40 Lexmark ** - - - - - Other - - - - - TOTAL $6,568.00 $0.0 $619.01 $1,332.85 $8,519.86

(NP) Non-Participant * Includes Laptops, Small Peripherals and Non-Computer Equipment ** Lexmark’s share was extrapolated based on data provided by Envirocycle to Matt Russell, Lexmark, about a collection involving Best Buy eCycle events and other east coast gov’t collections. The total pounds collected of all electronics were 2 million pounds. Envirocycle estimated that events typically are 25% computers and 75% TV’s. Further, Lexmark’s share of this event was 274 pounds of equipment. Therefore Lexmark’s estimated share of that event for computer equipment only was .055% (274 lbs divided by 500,000 lbs.) PSI used the same percentage for Lexmark’s percentage in the Staples pilot, resulting in a cost share of $6.66 (.00055x$12,103.28). PSI also used brand-sorted data provided by the FL Department of Environmental Protection. For its electronics collection, computers represented 42% of the total by weight. PSI used this percentage to derive Lexmark’s percentage in comparison to all computer equipment collected, which was 1.45%. PSI used this percentage to derive a second data point for Lexmark’s cost share in the Staples pilot: $175.50. PSI averaged the two cost figures to derive the $91.08 cost share. This share was not added to the total, since it was calculated outside of the total costs.

Envirocycle also did not conduct a sort of Lexmark products, a project partner. To develop a cost share for Lexmark, PSI used the average percentage share that Lexmark products represented in two electronics collection pilot projects – one conducted by Envirocycle and the other conducted by the Florida Department of Environmental Protection. The analysis for this calculation appears at the bottom of Table 8.

Envirocycle One of the factors in choosing Envirocycle as the pilot project recycler was its offer to provide a discounted recycling rate. Envirocycle offered the following discounted rates for equipment processing: $4.00 per monitor; no charge for CPUs; and $.07 per pound for large peripherals, small peripherals, laptops, and non-computer equipment. These rates provided greater certainty for Staples and manufacturers that costs would be contained.

State Agencies All five state agencies pledged staff resources to ensure a successful pilot, and offered planning and promotional support, technical assistance, and regulatory guidance regarding the handling of

Product Stewardship Institute, Inc. - 22 - FINAL June 2005 Staples Pilot Project –Final Report to U.S. EPA Background

collected materials. The greatest amount of assistance came from Connecticut and Maine owing to those states’ regulatory requirements.

U.S. Environmental Protection Agency EPA recognized that the data collected in this pilot project would be of significant value in the development of a national electronics management system. In recognition of the importance of the pilot project, EPA awarded PSI with an “Innovations Work Group (IWG) Grant” of $46,541 to support the development, implementation, and evaluation of the project. EPA Headquarters staff lent technical assistance to ensure that the project provided relevant data and visibility for its partners. They provided the template for data collection that was used by Envirocycle and PSI to report on the pilot collection. In addition, staff from EPA New England provided project technical support, and assisted in program outreach.

Product Stewardship Institute, Inc. As a full project partner, PSI coordinated project partners, collected and analyzed data, and completed tasks needed to provide the best information possible for this pilot project. Many of these tasks were beyond the scope of EPA or Staples funding, and became PSI’s financial contribution to the project.

Product Stewardship Institute, Inc. - 23 - FINAL June 2005 Staples Pilot Project –Final Report to U.S. EPA Program Description

CHAPTER II. PROJECT DESCRIPTION

As part of the Plug-In To eCycling project, PSI developed a Project Summary that described the initial design of the pilot project (see Appendix E). Early in the design phase, Staples and PSI decided that the collection model would be tested in the northeast, using Staples’ product delivery networks around the Killingly distribution center (DC) and the Putnam fulfillment center (FC) in Connecticut, and the North Reading and Sharon transportation hubs in Massachusetts. These routes cover retail stores and commercial customers in northeastern states, and were in close proximity to Staples’ main office in Framingham, Massachusetts, the Product Stewardship Institute’s office in Boston, Massachusetts, and EPA/New England’s office in Boston.

RETAIL COLLECTION LOCATIONS Computer equipment was collected at no charge at a cross-section of 27 Staples retail stores in five states: Maine (10 stores), Massachusetts (8 stores), New Hampshire (5 stores), Connecticut (3 stores), and Rhode Island (1 store). Appendix F lists the retail stores selected for the pilot project. For the pilot, PSI developed criteria to select a representative sample of retail stores that could provide adequate data for a potential nationwide expansion. Appendix G outlines the criteria developed by PSI and Staples for retail store selection, which includes population density, electronics retailer density, availability of existing electronics collection programs, state regulations for managing cathode ray tubes, and distance from the store to the distribution center.

In selecting the pilot stores, Staples and PSI also considered ways to prevent possible problems in the implementation phase. Consideration was given to the size of the stores, the amount of storage space, and accessibility for customers dropping off electronics. By limiting the pilot to two Staples distribution regions, program promotion was localized, and the number of incidents of customers bringing electronics to non-participating stores was minimized. Staples’ Mark Buckley made the final selection of participating stores, after a meeting with regional store managers.

COMMERCIAL COLLECTION LOCATIONS Computer equipment was collected at no cost from 14 commercial customers in three states (see Appendix H). Contract customers, particularly small businesses, comprise the largest percentage of Staples customers. The 14 business customers for the pilot project were selected from the Staples Business Advantage (SBA) program. SBA customers order merchandise from Staples on-line or by phone/catalogue, and receive direct delivery of goods at their place of business by Staples trucks or common carrier.

Product Stewardship Institute, Inc. - 24 - FINAL June, 2005 Staples Pilot Project –Final Report to U.S. EPA Program Description

To ensure that the pilot collection provided a representative sample of project volumes and costs for a nationwide program, PSI and Staples identified several selection criteria, listed in Appendix G. Staples ultimately selected a cross section of contract customers – large and small, hi- technology users and those not technology driven, and those that were likely to be receptive to the pilot program.

INTERNET/CATALOGUE CUSTOMERS Staples and PSI originally planned to collect from Internet and catalogue customers for this pilot project. However, owing to the complexity involved in developing the retail and commercial collections, and the added complexity of an Internet segment, Staples decided not to proceed with this aspect of the pilot project at this time. However, it may be instructive to consider the approach that PSI and Staples had discussed.

A growing number of Staples customers are small business owners and individuals who order on-line and receive merchandise through common carriers, such as United Parcel Service (UPS). PSI and Staples originally planned to include a sample of 24 customers from this category in the pilot study. These customers were to have had the option of returning used computers to a participating retail store, or to return equipment by common carrier (at their own expense) either to Staples’ Distribution/Fulfillment Centers or directly to the recycler.

To acquire a sample of on-line customers, Staples considered developing a customer interface on its website that would have allowed customers to self-select from specific zip codes or geographic regions when they searched the Staples on-line catalogue and queried or purchased certain computer products. The communication, either by email, a pop-up window, or other method, was to include the following:

 A description of the Staples Electronics Collection Pilot Project;  An offer for the Internet customer to participate in the limited pilot program (free recycling of the customer’s electronics equipment); and  A description of the methods by which the customer would bring or ship their electronic equipment to Staples (via participating Staples retail stores or UPS shipping). Customers choosing to ship their computer equipment by common carrier would have been assigned a bar code or other form of identification that identified them as a pilot project participant. As an alternative, Internet customers could have been directed to a Staples toll-free number, and the service order and data collected by telephone. In that case, the recycler would have tracked the quantities of equipment that arrived by common carrier from Internet customers.

TIMEFRAME The pilot collections ran for six weeks, from May 29 through July 11, 2004.

Product Stewardship Institute, Inc. - 25 - FINAL June 2005 Staples Pilot Project –Final Report to U.S. EPA Program Description

PRODUCTS ACCEPTED The pilot project accepted computer equipment, including computer processing units (CPUs), computer monitors, laptops, large peripherals (e.g., printers, multi-fax devices, facsimile machines, desktop copiers, scanners), and small peripherals (e.g., keyboards, mice, speakers, cables). Non-computer equipment and other electronics were not advertised as being accepted, although Staples’ staff did not turn away customers bringing these other types of electronic equipment. In fact, 14% of the units collected were non-computer equipment. Officially, Staples advertised that it would accept the following: Recyclable items [such as] computer hardware and business machines--printers, copiers, scanners, faxes--sold by Staples (no TVs or radios). Customers were limited to one computer system per person per store per day.

In the initial phase of the pilot project design, Staples and PSI considered the entire list of electronic items and supplies sold by Staples as candidates for the collection program. Since the focus of the national electronics dialogue was on computer systems and televisions, it was determined that computers and related equipment would definitely be included in the collection. Staples, however, does not sell televisions, so these were eliminated from the list. PSI and Staples, therefore, decided that the pilot project would collect only computers and computer peripherals because these constitute larger office equipment with recycling potential. Of the material collected, only CRTs are regulated as a hazardous waste in some states. PSI advises further research into the markets for the other electronic products.

GENERAL OPERATIONS Retail Operations Customers entering Staples retail stores were instructed to place computer equipment in a bulk cargo container called a “Gaylord box” (4 feet wide by 4 feet long by 4 feet high) that was positioned in the front of the store, and to fill out a short survey (see Appendix I). Staples staff assisted those needing help to bring equipment from their cars and to place it into the Gaylord. When a Gaylord became full, Staples staff would move it to the back room for shipping in the same manner that returns are shipped. Gaylords were labeled as to the store they originated from, and shipped (using reverse distribution) to the DC in Killingly, Connecticut.

Staples was interested in an electronics collection model that could be sustained as part of its ongoing business operation. There are three basic types of electronics collections that were considered for this pilot: (1) ongoing collections, (2) one-time collection “events,” and (3) a hybrid system that combined ongoing collections and events. Staples decided to proceed with Option 1: Ongoing Collections.

Ongoing Collection: In this model, which PSI recommended and Staples ultimately chose, customers were encouraged to bring computers to participating retail stores during normal business hours any day during the six-week period. This approach spread out the program over a longer period of time, provided greater convenience to customers, and eliminated the need to coordinate activities outside the store. In addition, it was most compatible with ongoing business operations at retail stores, and did not require additional staffing to manage the used computers entering the stores. In-store signage directed customers where to take the equipment within the

Product Stewardship Institute, Inc. - 26 - FINAL June 2005 Staples Pilot Project –Final Report to U.S. EPA Program Description

store, and promotional materials outlined program restrictions (e.g., acceptable material types and quantity limitations).

The disadvantage to this model was that it required Staples associates on all shifts to be aware of the program and informed in how to manage computers that were received. There was also a possibility that assistance to customers bringing used computers into the store could divert retail associates away from shoppers or from other regular duties, although there were no reports of this taking place.

One-Time Collection Events: These events typically last one or two days, during which participants can drive through the collection site (usually a parking lot), with their materials being off-loaded from vehicles into trailers or containers. The advantage of collection events is their short duration, for which store associates can be temporarily reassigned. The disadvantages include the need to coordinate the collection activities outside the store. These events require a parking lot or other outdoor area capable of handling an ongoing stream of traffic and potential lines of vehicles waiting to be served. The event cannot interrupt business operations or obstruct emergency vehicles, school busses, or access to area homes.

An event requires an adequate workforce to handle the volume, and additional staffing may be needed. Events also require coordinated publicity, a plan for inclement weather, and often a plan for moving collected materials off the site immediately after the event. Depending on local population and other factors, events have drawn up to 1,000 vehicles. To employ this type of collection for the Staples pilot, Staples would have had to coordinate with property management (if store properties were leased or shared), local traffic enforcement, local recycling groups, and other volunteers to staff the events. PSI also advised Staples that it would have had to address liability concerns should damage to person or property occur as a result of the collection event. A collection event, however, could be simplified by contracting with a recycler to set up and staff the event. Many recyclers now offer this service and are experienced in how to move traffic and materials in an efficient manner. This option was not recommended, and was ultimately not chosen.

Hybrid Collection Option: A third collection option is a hybrid of the collection event and ongoing collection. Staples could have collected computers in the store on specific days (e.g., Saturdays and Sundays) throughout the pilot project. A more visible collection area (e.g., at the front of the store), promotional materials, and the concentration of customers bringing computers on those days would lend to the atmosphere of an “event.” An advantage of this model is that store associates would only have to be concerned with the collections on specific days, and additional staffing could be assigned during those days, if needed. The disadvantages are that any required additional staffing would present an additional program cost to Staples. A collection limited to one or two days a week, or month, is not as convenient to customers and would increase the possibility that customers would bring materials on non-collection days.

PSI recommended that Staples explore a hybrid model (in-store collections restricted to certain days) in a few retail stores to determine if this type of collection would have less impact on staffing needs, and whether it would impact customer participation and shopping patterns. To simplify the pilot, however, this option was ultimately not chosen.

Product Stewardship Institute, Inc. - 27 - FINAL June 2005 Staples Pilot Project –Final Report to U.S. EPA Program Description

Commercial Operations Staples’ contract customers scheduled an appointment to have their computer equipment picked up by Staples trucks. Staples provided survey forms to each customer, which provided information on the type of equipment to be collected and the number of items. Staples used this information to determine how to collect the equipment. Prior to pick up at most locations, Staples dropped off Gaylord boxes, labels, pallets, and packing materials, and asked that equipment be packaged, labeled, and brought to the loading dock. For some of the contract customers, Staples picked up the equipment upon delivery of new products. For other contract customers, Staples had to schedule a separate pick up. To accommodate pallet-sized pickups, Staples used its own furniture trucks with drop-gate equipment. Some customers required that Staples “live load” them either at their dock or on the street owing to space and/or time constraints. Others were picked up as part of Staples typical process for returning products that are defective, damaged, or otherwise unwanted.

Gaylords were transported back (using reverse distribution) to the FC in Putnam, Connecticut. In some cases, Staples trucks went straight from the business to the FC, although in other cases, Staples consolidated the loads at either the Sharon or North Reading, Massachusetts, transportation hubs for a line haul the next day to the FC. Most of the Connecticut customers went directly to the FC. Staples also took advantage of space on Envirocycle trucks from loads that were being hauled from other electronics collection events in Massachusetts and Connecticut back down to the Envirocycle facility.

STAFF TRAINING AND EDUCATION PSI, in conjunction with Staples, coordinated an internal Core Team meeting with Staples employees who manage its retail and commercial operations. Those in attendance were Staples district managers with jurisdiction over the 27 stores selected for the pilot, as well those managing SBA customers. This meeting was held in January 2004, during which Staples and PSI presented the program, answered questions, established a kick-off date, and assigned staff responsibilities. Once key Staples employees were informed about the program and participated in its design, they were able to communicate program goals and implementation procedures to their employees.

Staples district managers, who oversee the retail stores, trained their employees about customer relations, equipment handling, and in-store promotion. Staples associates at participating retail stores (as well as those in non-participating stores in the surrounding area) were made aware of the pilot project, although not every associate was involved in the collection effort. During each staff shift, associates helped to receive and stack computer equipment, distribute the equipment collection survey, and ensure the collection of data. Staples associates involved in the handling

Product Stewardship Institute, Inc. - 28 - FINAL June 2005 Staples Pilot Project –Final Report to U.S. EPA Program Description

of used computers received training to minimize the potential for problems of injury, breakage, and customer dissatisfaction. SBA delivery associates also received similar training prior to the collection period.

Staples developed a Store Communications Package that consisted of a two-page information sheet, an in-store flyer, and two sizes of labels to affix to Gaylords that were to hold the equipment. The information sheet explained the project, products accepted/limitations, alternative recycling options, what to do when customers entered the store with equipment, store layout and materials, logistics, and frequently asked questions. (See Appendix J for the information sheet, flyer, and banner.)

PSI determined the training required by regulatory officials in the pilot project states, and outlined the recommended content for a Staples associate training session. Staples had to abide by training regulations in one of the pilot states. Regulations from the Maine Department of Environmental Protection (ME DEP) require that “…each person handling Universal Waste should be trained for the particular job that they are doing and be aware of the clean up procedures in the event of breakage.” The ME DEP offered to hold training sessions for Staples’ employees involved in the take-back program, although this was deemed unnecessary.

Staples trained a coordinator at each store who was responsible for training store associates, reporting on the pilot program, answering procedural questions, and communicating with the Core Team. Staples internal information delivery systems (e.g., “General Manager Review” and “Staples at Work”) were effective at distributing information about the pilot project, its goals, progress made, and problems encountered. Staff was trained regarding:

 Regulations – to ensure that all associates were thoroughly familiar with the proper electronics handling procedures.  Ergonomics – pertaining to how to lift and carry heavy computer equipment.  Customer Relations – to avoid potential problems and deal with actual problems (e.g., customers bringing in unacceptable materials, too many units, etc.).  Non-participating Stores – the procedures to follow when equipment turned up at non- participating stores.  Data Collection and Management – procedures for administering and managing questionnaires, and other data collection and management procedures.

PROMOTION/ADVERTISING AND CUSTOMER EDUCATION To prepare for the launch of the pilot project, PSI contacted state officials in each of the five states in which the collections were to occur. In addition, EPA/New England called the local recycling coordinators for the municipalities in which the 27 stores were located. (See Appendix B for a list of local contacts in the communities targeted for pilot collections.)

Staples’ marketing department developed and distributed promotional and educational materials prior to the pilot collections. To minimize customer confusion in non-participating areas,

Product Stewardship Institute, Inc. - 29 - FINAL June 2005 Staples Pilot Project –Final Report to U.S. EPA Program Description

promotion was highly targeted to Staples customers in the pilot areas, rather than broadcast in regional newspapers or other media. Staples did not want residents in adjacent communities whose stores were not serving as pilot locations to think that they, too, could bring back their equipment to the stores in their communities.

To advertise the retail program, Staples developed an in-store flyer, store display, and banner. Many customers who recycled equipment heard about the program when they were shopping for products, prompting them to come back at another time with their computer equipment. Staples also developed and distributed a two-page “Calendar Listing” to local newspapers throughout the New England states announcing the retail pilot (see Appendix K). Staples’ Owen Davis conducted phone interviews with press who called for more information. The following publications developed an article on the pilot program:

 Massachusetts  Natick Bulletin & Tab, June 11, 2004 (weekly circ 3,369)  Natick Bulletin & Tab, July 2, 2004 (weekly circ 3,369)  Daily Times Chronicle Reading, June 9, 2004 (daily circ 14,797)  Daily Times Chronicle Winchester, June 9, 2004  Daily Times Chronicle Wakefield, June 9, 2004  Daily Times Chronicle Woburn, June 9, 2004  Maine  Cape Courier, July 3, 2004 (semi-monthly circ 4,000)  Biddeford-Saco Courier, July 2, 2004 (weekly circ 23,000)  Southern Forecaster, July 2, 2004 (weekly circ 10,000)  Gorham Times, July 2, 2004 (bi-weekly circ 4,000)  Current, July 8, 2004 (weekly)  Greenbiz.com, June 14, 2004 (See Appendix L for a comprehensive article about the pilot program and the larger issue of electronics recycling written by Philip Maddocks of the Natick Bulletin & Tab, July 2, 2004.)

Product Stewardship Institute, Inc. - 30 - FINAL June 2005 Staples Pilot Project –Final Report to U.S. EPA Selecting the Recycling Services

CHAPTER III. SELECTING THE RECYCLING SERVICES

Selecting an electronics recycler required PSI and Staples to consider several important logistical, regulatory, environmental, health and safety, and security issues.

LOGISTICAL CONCERNS Staples used its own carriers, or contracted carriers, to transport collected computers to the recycler from consolidation points at Staples DC and FC in Connecticut. Since a sustainable business model minimizes fuel consumption, Staples requested that PSI narrow the selection of recycling companies to those within close proximity to the DC and FC. Staples intended to match the delivery of used computers to the recycler with the pick up of new product from nearby suppliers so that otherwise empty trucks could be used on the back haul. For the pilot project, PSI considered recyclers within a 200-mile radius of the Staples DC and FC.

REGULATORY CONCERNS Chapter VII of this report addresses state requirements for managing used electronics as either a hazardous waste or universal waste. Staples had a responsibility to ensure that the company it selected was in compliance with all local, state, and federal regulations pertaining to materials recovery, waste management, transport of hazardous materials, and worker protection. Staples wanted to select a company with a good compliance record.

The best way to select a recycler is by conducting a “due diligence” review or by conducting a paper and physical audit of the facility. With limited resources, Staples and PSI were unable to conduct on-site facility audits for the pilot project. To protect itself from potential liability, Staples considered only those recyclers for which a thorough investigation into the processes, by- products, and end markets was conducted by pilot state regulators or the electronics manufacturers involved in the pilot. PSI also developed guidelines for screening recyclers that were reviewed by regulatory agencies in the pilot states. Appendix M contains the document that was used by Staples and PSI to evaluate recyclers during and after each interview, while Appendix N is the document that was provided in advance to recyclers to help them prepare for the interview.

ENVIRONMENTAL CONCERNS Environmental concerns related to electronics management go beyond guarantees of regulatory compliance. Compliance, for the most part, means that companies have the appropriate state permits, environmental controls, and insurance coverage for the activities that are conducted by the company. However, Staples’ corporate goals include minimizing waste, maximizing reuse and recycling, and conserving energy. Because of these goals, Staples and PSI developed additional criteria that were also incorporated into the screening process. Companies were asked about their own waste minimization practices (e.g., ISO 14000 certification, internal and third- party audits) and how they assure that downstream vendors are reducing waste. Company

Product Stewardship Institute, Inc. - 31 - FINAL June, 2005 Staples Pilot Project –Final Report to U.S. EPA Selecting the Recycling Services

processes were compared to determine which methods would enhance reuse and recycling of the materials (e.g., front end sorting, demanufacturing, resale and reuse programs).

HEALTH AND SAFETY CONCERNS One contentious issue discussed in the NPSI dialogue is the practice of using prison labor or exporting whole electronics or electronic components to cheap labor markets in poor developing nations. The prison labor issue is as much about creating unfair market advantages using taxpayer-supported labor at prisons as it is about concern over prison workers’ health and safety. Since this issue had not been resolved by NEPSI at the time of this pilot project, Staples did not want to use prison labor to process any materials collected as part of the project.

The export of materials to developing countries was another unresolved issue. While a closed loop recycling process advocates for returning materials for reuse in the manufacture of new materials, many electronics are manufactured in countries that may not enforce health and environmental protection standards. Some U.S. companies export scrap material to these countries, where lower labor costs contribute to lower processing costs. Countries that are part of the Organization for Economic Cooperation and Development (OECD, www.oecd.org) have agreed to control exports to protect developing countries. These controls dictate high standards for environmental management.

For the pilot project, Staples and PSI determined that there should be no export of the collected electronics or their hazardous components (e.g., CRTs, circuit boards) to non-OECD countries in order to eliminate the potential negative impact on the environment and human health in developing nations. Companies screened for the pilot project were asked to describe how they would ensure that no hazardous materials would be sent to developing nations by downstream vendors, and Envirocycle, the selected recycler, provided documentation of end markets for the project.

SECURITY CONCERNS Staples and PSI ensured that Envirocycle offered secure data removal as an option for businesses participating in the pilot project. Envirocycle destroyed hard drives as part of the recycling process.

REUSE OPPORTUNITIES Staples wanted to maximize the reuse of working computers that were of recent technology. These computers usually originate from businesses, rather than households, as businesses tend to upgrade equipment more frequently and to replace all equipment at once. In considering sending computers for reuse, however, concerns arose about confidential information that still might be contained on the hard drive, even after business personnel remove files. In worst cases, confidential information in the wrong hands could cause significant harm to the business and its clients, or even threaten homeland security. Since several businesses were not comfortable with the data security options available to them through the pilot, the project did not reuse any equipment. Customers, therefore, could be assured that there was complete control over the final

Product Stewardship Institute, Inc. - 32 - FINAL June 2005 Staples Pilot Project –Final Report to U.S. EPA Selecting the Recycling Services

destination of the material. In the future, if reuse becomes part of the services offered, Staples expects that the hard drives of reusable computer components will be “scrubbed” in accordance with U.S. Department of Defense requirements for those requesting a Certificate of Destruction. (For additional information on reuse, see Appendix O.)

Prior to project implementation, Staples was approached by World Computer Exchange, Inc. (WCE), a non-profit organization with offices in Massachusetts, and whose purpose is to provide working computers to schools and other organizations in developing countries. WCE claimed to have put thousands of Pentium and Power Mac computers into use by people who would otherwise not have had access to the technology. Many of the computers being shipped abroad are outdated and not desirable in U.S. reuse markets. The WCE is concerned about the proper disposal of computers in the recipient countries and, at the time of this pilot, was developing a task force of representatives from several international organizations to investigate possible solutions. However, when this pilot was ready for implementation, its practice was to harvest usable parts and dispose of the rest by whatever means were locally available. The need to ensure the proper management of reused computers, especially abroad, was another factor in Staples not including reuse in this initial pilot project.

SELECTION PROCESS Three recyclers were interviewed after PSI determined that they met the selection criteria developed with Staples, even though one was outside of the preferred transportation radius from the Connecticut DC and FC. These recyclers appear in Table 9 below, along with how they address logistical, regulatory, health/safety, and security issues. Following the interviews, Envirocycle was selected owing to the familiarity that many of the manufacturers had with the company, and because of its proposal to become a full partner in the pilot project by providing services at a vastly reduced recycling rate.

Product Stewardship Institute, Inc. - 33 - FINAL June 2005 Staples Pilot Project –Final Report to U.S. EPA Selecting the Recycling Services

Table 9. Recyclers Interviewed for Staples Pilot Project

Regulatory Compliance/ Health and Company Logistical Environmental Safety Security Electronicycle, Inc. 45.8 miles from the Permitted by MA; Can guarantee no Can provide Dick Peloquin (877-829-6209) Distribution Center in audit by New prison labor or assurances for data 461-471 West Broadway Putnam, CT; Jersey; used for export to non- removal and Gardner, MA 01440 approximately 55 miles the Northeast OECD countries documentation for all Phone: 800-829-5082 from the Fulfillment Center Recycling through detailed reused computers Local: 978-632-7666 in Killingly, CT Council’s pilot tracking Fax: 978-632-1651 collections [email protected] http://www.electronicycle.com Envirocycle Approximately 198 miles Compliance Can guarantee no Can provide Greg Voorhees (570-879-2862) from the Distribution assurances; prison labor or assurances for data Rt. 81 Exit 230- Center in Putnam, CT and audits completed export to non- removal and PO Box 899 the Fulfillment Center in by several OECD countries documentation for all Hallstead, PA 18822-0899 Killingly, CT electronics through detailed reused computers Phone: 800-711-6010 manufacturers tracking Local: 570-879-2862 Fax: 570-879-2008 [email protected] http://www.enviroinc.com/ Metech, International Approximately 12 miles Compliance Can guarantee no Can provide Chris Ryan (978-772-4897) from the Distribution assurances and prison labor or assurances for data 120 Mapleville Main Street Center in Putnam, CT; permits from the export to non- removal and Mapleville, RI 02839 approximately 15 miles State of OECD countries documentation for all 401-568-0711 from the Fulfillment Center Massachusetts; through detailed reused computers [email protected] in Killingly Center ISO 9001 and tracking 14001

Product Stewardship Institute, Inc. - 34 - FINAL June 2005 Staples Pilot Project –Final Report to U.S. EPA Program Results

CHAPTER IV. PROGRAM RESULTS

DATA COLLECTION The pilot project collected data that enabled Staples to understand the degree to which the reverse distribution collection approach could be part of the company’s sustainable business model, and how it could be implemented on a national scale. It also assisted PSI, EPA, and pilot partners in learning how reverse distribution systems can affect costs of a national electronics collection infrastructure. Finally, the retail and contract customer satisfaction surveys helped PSI to evaluate the program from the users’ perspective. The data collected will enable Staples to make adjustments and improvements to any future program expansion that the company plans to undertake. If Staples decides to expand this program, there will be an ongoing need for data systems to track equipment shipments, costs, and customer satisfaction.

The responsibility for collecting and analyzing the various types of data was divided among pilot project partners to maximize the use of existing capabilities, minimize program costs, and ensure that the data were useful and accurate. The following entities were involved in the data collection effort: PSI, Envirocycle, Staples’ retail management and associate level support, and Staples’ logistics managers for pallet placement and transport.

MATERIALS COLLECTED: UNITS AND WEIGHTS PSI collected data in three ways for the retail and commercial collections – (1) Data provided by Envirocycle, which combined retail and commercial loads; (2) Data tabulated from surveys filled out by customers at the retail locations; and (3) Data tabulated from surveys filled out by commercial clients.

Total Equipment Collected (retail and commercial) Envirocycle collected data on the following equipment: computer monitors, CPUs, laptops, large peripherals (e.g., printers, multi-fax devices, facsimile machines, desktop copiers, scanners), and small peripherals (e.g., keyboards, mice, speakers, cables). The number of units collected, their associated weights, and the cost of recycling by component are listed in Table 10 below. The total number of units of computer equipment collected was 4,522, weighing 107,360 pounds, and costing $7,983.10 to recycle. Although Staples advertised that it would only accept computer equipment, an additional 735 units of audio/visual and other equipment was collected, bringing the total number of units collected to 5,257. The non-computer related units represented approximately 14 percent of the total number of units collected. The total weight of all material collected was 115,028 pounds, costing $8,519.86 to recycle. (See Table 16 in Chapter V for a complete breakdown of collection, transportation, and recycling costs.)

Product Stewardship Institute, Inc. - 35 - FINAL June, 2005 Staples Pilot Project –Final Report to U.S. EPA Program Results

Table 10. Staples/PSI Pilot Project – Collection Summary/All Equipment

Product Number Of Units Pounds Cost*

Envirocycle also tracked the number of units collected by major brand for monitors, CPUs, and large peripherals (see Appendix D). For monitors, Apple is by far the brand that was returned most often and, for large peripherals, HP is the brand most often returned if Compaq products are also included. For CPUs collected, HP and Apple were the brands most often returned. Envirocycle did not brand sort for laptops, small peripherals, and non-computer equipment. To estimate the percentage share for each of these product categories, PSI averaged the percentage shares for each brand for monitors and large peripherals (the two equipment types for which there is a cost to recycle) and used this as the percentage share for a combination of the three other categories. These extrapolated shares appear in Appendix D. Envirocycle tracked 8 of the 10 eCycling partners, but did not track products from the Lexmark brand. The cost share for Lexmark was derived as shown in Table 8. Intel, another partner, sells its computer memory chips to computer manufacturers and, therefore, does not have its own brand computer. (For further discussion of manufacturer costs, see Chapter I.)

PSI calculated the percentage of equipment that was derived from participants compared to the percentage derived from non-participants. Only actual, and not extrapolated data, are used. These data are summarized in Table 11 below. As shown in the table, between 38% and 50% of monitors, CPUs, and large peripherals returned from customers has come from companies that did not participate in the pilot project.

Table 11. Percentage of Participating Manufacturers and Non-Participants by Equipment Type

Monitors CPUs Large Peripherals

Participating Manufacturers 50% 50% 62% Non-Participants 50% 50% 38%

Product Stewardship Institute, Inc. - 36 - FINAL June 2005 Staples Pilot Project –Final Report to U.S. EPA Program Results

Customer Equipment Surveys at Retail Locations Approximately 1,800 customers who returned equipment to Staples’ 27 retail locations filled out a survey (see Appendix I) providing information about the manufacturer of the computer equipment being returned, the type of equipment (e.g., laptop, CPU, monitor, etc.), the number of units returned, and their age. These forms were collected by Staples and entered into a master spreadsheet that was provided to PSI, which parsed the data to determine the following:

1. Equipment type collected by store and by brand. 2. Total equipment type collected by store. 3. Equipment type collected by major brand. These data appear in Appendix P, and are summarized below in Table 12.

Table 12. Total Equipment Collected By Brand And By Product – Retail Customer Surveys Other Brand Monitors CPUs Laptop Printer Scanner Fax Copier Peripherals Total HP/Compaq 187 219 14 262 25 4 2 713

Apple 251 238 24 75 3 0 0 591 Dell 137 86 5 2 0 0 0 230 Gateway (NP) 112 105 3 8 1 0 0 229 IBM (NP) 74 82 9 13 0 0 1 179 Epson 7 3 0 81 1 0 0 92 Panasonic 8 4 0 27 0 5 0 44 Sony 30 5 1 0 0 0 0 36 Lexmark 1 1 0 27 1 0 0 30 Brother 2 0 0 10 0 6 0 18

Sharp 0 2 5 0 0 4 2 13 Other 0 TOTAL 1,600 1,363 99 727 85 32 18 1,497 5,421

* Other Peripherals: Keyboards, Mice, Speakers, etc. (NP) Non-Participant

A few interesting observations from Table 12 are that:

1. The total amount of equipment collected as recorded on the retail surveys is 5,421 units, slightly higher than the 5,257 units reported by Envirocycle. This discrepancy is significant since the retail surveys were for retail collection only, whereas Envirocycle data represented both retail and commercial equipment. The retail surveys also covered 25 of 27 retail stores. The reason for the discrepancy may be due to the poor quality of the data from retail customers and/or communication and reporting issues among partners as to which data were required to be tracked. 2. Data collected by brand were very similar, but not identical, to the brand-sorted data reported by Envirocycle. Table 13 below provides a summary of the data collected by the five state partners:

Product Stewardship Institute, Inc. - 37 - FINAL June 2005 Staples Pilot Project –Final Report to U.S. EPA Program Results

Table 13. Total Equipment Units Collected by State – Retail Customer Surveys

No. Of Stores Average Units State Collecting* Units Collected Collected Per Store Connecticut 2 180 90 Massachusetts 7 1,928 275 Maine 10 2,428 242 New Hampshire 5 649 130 Rhode Island 1 182 182 TOTAL 25* 5,367 215

* PSI received data from 25 of the 27 stores. Data were not available for New London, CT and Revere, MA.

These data show that Massachusetts and Maine lead the pilot states in the average units collected per store, which might correspond to electronics legislation in those states and a heightened public awareness about the hazards of electronics disposal. Comments from Staples store managers in Maine confirmed that customers were seeking electronics recycling options owing to their knowledge of state legislation. In addition, Massachusetts and Maine were the only two states in which local press articles appeared notifying residents about the opportunity to recycle their computers. These articles, presumably, could have contributed to additional computers being brought into the stores. One factor, however, must also be considered – store size. It is possible that those stores collecting fewer computers were smaller in size than those collecting a larger number of computers.

Contract Customer Surveys at Commercial Locations Data from the 14 contract customers that participated in the pilot project were parsed into the following categories:

 Equipment type collected by business and by brand.  Equipment type collected by business.  Equipment type collected by major brand. These data appear in Table 14 below and in Appendix Q.

Product Stewardship Institute, Inc. - 38 - FINAL June 2005 Staples Pilot Project –Final Report to U.S. EPA Program Results

Table 14. Total Equipment Collected By Equipment Type and By Company – Contract Customer Surveys Large Small Other

Monitors (1) CPU's (2) Laptops (3) Peripherals * (4) Peripherals ** (5) Equipment (6) Total Wgt Wgt Company # Wgt (lbs) # Wgt (lbs) # (lbs) # Wgt (lbs) # Wgt (lbs) # (lbs) # Wgt (lbs)

Verispan 8 304 0 0 0 0 3 24.36 1 15 5 52 17 395.36 DRS Techn 16 608 10 230 3 45 10 81.2 2 30 0 0 41 994.20 Stride & Assoc 5 190 33 759 18 270 5 40.6 0 0 0 0 61 1,259.60 Rogers Corp 0 0 22 506 9 135 0 0 0 0 2 20.8 33 661.80 Safety Ins 2 76 7 161 0 0 9 73.08 0 0 0 0 18 310.08 Mykrolis 14 532 20 460 0 0 7 56.84 1 15 1 10.4 43 1,074.24 Freudenerg NOK 13 494 27 621 0 0 4 32.48 0 0 0 0 44 1,147.48 Todd & Weld 6 228 0 0 2 30 0 0 0 0 0 0 8 258.00 Delta Education 0 0 0 0 0 0 8 64.96 0 0 2 20.8 10 85.76 Barnes Group 6 228 41 943 51 765 39 316.68 0 0 23 239.2 160 2,491.88 Riso, Inc 4 152 7 161 0 0 1 8.12 5 75 0 0 17 396.12 Texas Instruments 27 1026 32 736 0 0 7 56.84 22 330 2 20.8 90 2,169.64 Charles River 4 152 4 92 0 0 1 8.12 0 0 0 0 9 252.12 Zoots 26 988 14 322 0 0 21 170.52 0 0 0 61 1,480.52 TOTAL 131 4,978 217 4,991 83 1245 115 933.8 31 465 35 364 612 12,976.80

*Large Peripherals Include: Printers/Dot Matrix/Laser/Fax/Other ** Small Peripherals Include: Keyboard/Mice/Speakers/etc. (1) Average weight for pilot project collection calculation at 38 pounds/unit. (2) Average weight for pilot project collection calculated at 23 pounds/unit. (3) Average weight for pilot project colletion calculated at 15 pounds/unit. (4) Average weight for pilot project collection calculated at 8.12 pounds/unit. (5) Average weight for pilot project collection calculated at 15 pounds/unit.

(6) Average weight for pilot project collection calculated at 10.4 pounds/unit (based on an estimated percentage using full collection figures for non-computer equipment in this pilot).

A few interesting observations regarding Table 14 are that:

 612 units of equipment were collected, totaling 12,977 pounds.  The total cost to recycle this equipment was $735.  From Appendix Q, we see that the highest cost share belongs to HP/Compaq, by more than double that of the brand with the next highest cost.

PERCEPTIONS OF THE PROGRAM Staples Staff Mark Buckley received informal feedback from store managers and the four district managers responsible for the 27 stores in the five pilot project states. General comments were as follows:

 Customer responses were overwhelmingly positive.  Most customers were willing to pay a fee for the recycling service.  From an operational perspective, the program was easy to implement. Following the pilot project, PSI interviewed Bruce Christian, Staples District Manager for 11 stores (10 in Maine, 1 in New Hampshire). Mr. Christian believed that the recycling program was “absolutely successful.” He estimated that he personally talked to approximately 30 customers and received “a phenomenal response.” Customers were pleased that Staples provided

Product Stewardship Institute, Inc. - 39 - FINAL June 2005 Staples Pilot Project –Final Report to U.S. EPA Program Results

the service and have asked him to hold collections again. It provided good will with the customers. Even if they didn’t purchase supplies when they brought in equipment, Mr. Christian believed that they would likely do so at another time.

While the response was decidedly positive, there were some issues to work out. Mr. Christian and his staff were slightly overwhelmed by the amount of equipment brought back, and some people took advantage and brought more equipment than allowed. He believes, however, that once the first glut of material is taken out of people’s homes, the program will be more manageable. He believes that people want convenience and they are willing to pay for it. There is labor involved in collecting, transporting, and recycling, and he believes that Staples should charge a fee for collection.

Other issues experienced were that smaller stores, which lacked space, could not put the Gaylord collection box out front, making logistics more difficult. Also, at the end of the program, some staff at the stores complained that material was stored for 3-4 days without being collected. These problems, though, were minor in comparison to the positive results.

Mr. Christian suggested that Staples collect computer equipment on a year round basis. He believes that this arrangement would be more reliable in that people would know that they could bring their equipment anytime. He felt that he would be inundated if the collection happened only sporadically. Minimally, he suggested collection once per quarter.

Mr. Christian also suggested handling the equipment like a return so that there is an initial interaction with a Staples Associate when a customer enters the store. This procedure would be easier and smoother for Staples and the customer. This process would also reduce any possibility of breakage when placing the equipment in the Gaylord container, and customer data could be more accurately recorded. He also felt a need to control the drop off of equipment so that businesses did not unload too many units. He suggested that this could be accomplished by asking for identification. He also thought that Staples could possibly give a coupon toward new product sales to provide an incentive for customers to come back. Mr. Christian believed that there is a need to collect other electronics at Staples, so that there is one place that people can bring their equipment. Customers asked that Staples take back DVDs, fluorescent lamps, and other products. Staples sells some, but not all, of these products. In considering this request, Staples will have to evaluate the feasibility of accepting each product. Lamps, for example, could present some difficulties because they are fragile.

Customer Satisfaction PSI developed a Retail Customer Satisfaction Survey and a Contract Customer Satisfaction Survey (see Appendix R), which it administered by phone to a limited number of pilot project participants. PSI collected the data and evaluated the responses. The surveys sought responses related to:

 Customer satisfaction with the collection program (what worked well, suggestions for future improvements).  Customer motivation to participate (environmental, cost, other).

Product Stewardship Institute, Inc. - 40 - FINAL June 2005 Staples Pilot Project –Final Report to U.S. EPA Program Results

 Purchasing at time of collection services – did they make a purchase at Staples.  Willingness to pay for special computer management services in the future.  Other electronics they would like to recycle through Staples. Retail Customers. PSI attempted to survey one customer for each of the 27 stores in the pilot. Staples provided PSI with several hundred retail equipment collection surveys from those customers who provided at least some contact information. The surveys were grouped by store. From those surveys, PSI selected customers at random, but sought to reach those who provided at least their name, phone number, and minimum equipment collection information. Some of the customers operated a small business, or were municipal officials and school employees, while the vast majority were residents. As part of the retail customer survey results that PSI tabulated (see Table 15) 1,351 retail customers (81%) said they brought equipment from their home and 308 retail customers (19%) said the equipment was from their business. Phone calls were attempted during December 2004 and January 2005. PSI placed, on average, four calls per customer to reach a person who was available to answer the survey. PSI was able to reach 20 customers that returned equipment to 16 different locations in four states.

Table 15. Staples/PSI Pilot Project Retail Survey Data

Willing To Pay A Recycling Heard About The Equipment From Equipment Fee In The Future Program From Being From Store Store Home Office Used Storage Yes No Flyer Display Other

1351 308 529 1095 1008 507 260 483 845

The following analysis is derived from the Retail Customer Satisfaction Survey:

 Retail customers were overwhelmingly pleased with the recycling program, and wanted the program to continue on an ongoing basis, or at least several times each year. They found it simple and convenient. Placing the equipment in the box and filling out the survey was quick and easy.  Customers that brought in equipment did not want to dispose of it in the garbage but were looking for an opportunity to recycle it. Staples provided that opportunity. Many cited environmental reasons (e.g., toxics) for why they did not want to put it in the garbage. Others stored the equipment in belief that there was still value to it.  Some people were motivated to bring in their equipment owing to the Massachusetts state ban on CRTs or to avoid a town disposal fee.  Most people who found out about the program did so while they were in the store purchasing office supplies. Of those who filled out a survey in the store, 483 said that they heard about the program through a store display, the largest single source of information. Another 260 heard about the program from a store flyer, and 845 people heard about the program from “other means” (e.g., word of mouth, newspaper, website). (See Table 15 above.)

Product Stewardship Institute, Inc. - 41 - FINAL June 2005 Staples Pilot Project –Final Report to U.S. EPA Program Results

 Most of those interviewed said that they often buy their supplies at Staples, whether or not they purchased something when they dropped off their computer equipment. Some made a special trip to come back with their equipment on another day.  The vast majority of customers interviewed said that they would be willing to pay at least $5 per computer system to recycle, although many were willing to spend $10 or even $20. These data corroborate in-store survey data (e.g., forms filled out by retail customers) that showed that those willing to pay a fee to recycle outnumbered those who wouldn’t by a two to one margin (see Table 15). (Even so, it must be kept in mind that those who participated in the recycling program are a subset of all those who have computers that need to be recycled. Those participating in recycling programs would be more likely to pay to participate than those who are not motivated to recycle their equipment.)  Most people were satisfied by the number of items Staples collects, although some wanted Staples to also collect other electronic equipment (e.g., DVDs, PDAs, etc.); others were interested in Staples collecting fluorescent lamps. Most people did not know that Staples provided customers with recycling opportunities on an ongoing basis for hand-held electronics (including digital cameras, PDA's, Palm Pilots, and pagers), rechargeable batteries, toner cartridges, and cell phones. A small percentage of those surveyed did know of the toner cartridge recycling program offered by Staples.  The assistance provided by Staples staff was, for the most part, deemed informed and helpful. A few people reported that they were seeking more assistance or that the staff person they spoke with was not informed about the program.  Most of the equipment came from storage. From the in-store retail surveys (Table 15), 1,095 respondents (67%) said that the equipment came from storage, while 529 respondents (33%) said that the equipment was being used prior to bringing in for collection. This statistic supports the need for a one-time cleanout before a maintenance program is initiated. Retail customers provided PSI with the following recommendations as to how to improve the program:

 Greater advertising and promotion of the program, particularly through the town (e.g., website, newspaper, recycling coordinators, etc.).  Communicate better with municipal officials so they know about the program and can promote it.  Provide information on what happens to the equipment once it is collected (e.g., where recycled; what products are made from plastics, metals, glass, etc.).  Provide a reuse opportunity for the usable equipment.  Provide information on Staples’ other recycling opportunities, such as rechargeable batteries, cell phones, toner cartridges, and hand-held electronics.  Have Staples staff handle the incoming material like a return at the service desk so the customer does not have to handle material or fill out a form.

Product Stewardship Institute, Inc. - 42 - FINAL June 2005 Staples Pilot Project –Final Report to U.S. EPA Program Results

 Provide assistance, if needed, to take equipment out of cars and into the store, particularly for elderly customers.  Provide step-by-step instruction for the customer on what to do with the equipment when they come into the store.  Don’t put a limit on the number of items collected, since some residents had to make several trips. Contract Customers. Of the 14 contract customers that contributed computer equipment in the pilot project, PSI attempted to interview 12 companies (seeking a mix of small, medium, and large-size companies) and succeeded in reaching 9 of them. PSI placed, on average, three calls per company before reaching an individual who was able to answer the survey questions.

The following summary and analysis is derived from the Contract Customer Satisfaction Survey:

 There was unanimous interest and enthusiasm for this program from all those interviewed. Each of them believed that Staples provided a valuable service and made it easy to collect the equipment. The company provided a list of equipment, packaged it, put it in a staging area, and Staples came and took it away. Some said that this ease was due to Staples knowing about their company account, and Staples’ familiarity with the company’s customers, requirements, needs, and demands. This helped with scheduling, delivering products, turn around time, and paperwork. However, it should be noted that at least some of the enthusiasm for the recycling program came from the fact that is was free, saving the company money. Even so, one company employee commented that he felt that this was a fair arrangement since the company was taking part in a pilot program that was working out issues.  The program was also successful because it cleared out space where the computers used to be stored, so employees were happy with the result. Once again, Staples provided a solution for those looking to recycle their equipment and get it out of storage. No one really wanted to dispose of the equipment, but they didn’t perceive that they had another option.  Most of the companies contacted said that they would be willing to pay to recycle their equipment in the future, since most understood that they were actually required to safely manage their products. However, almost all said that they would only use Staples for this service if their price was competitive with alternative options. With that said, many thought there was an added value to ordering supplies from the same company that took back the used computer equipment.  All wanted to see the program continue; the average need for service per company was estimated to be 1 or 2 times per year.  Several companies wanted Staples to offer a certificate of data destruction to ensure that confidential information is wiped clear off the computers.  Three of the companies had a hard time scheduling a pickup, especially for larger items. One company cited a great deal of uncertainty as to whether or not the collection would even occur.

Product Stewardship Institute, Inc. - 43 - FINAL June 2005 Staples Pilot Project –Final Report to U.S. EPA Program Results

 One of the larger companies cited the difficulty in training their own employees to start recycling the computers instead of throwing them away. Once this education took place, the program went more smoothly. They offered that, if they were to do it over, they would have conducted a small pilot project first, and then scaled it up. Staples, however, was accommodating and wonderful to work with.  Some of the items suggested for Staples to recycle are: analog telephones, fluorescent light bulbs; paper; batteries; mixed plastics and Teflon; wood pallets.  One person interviewed wanted to know more about how the recycling was part of the reverse distribution system.

EFFECTIVENESS OF PROMOTIONS/ADVERTISING Staples took a cautious approach to promotion of the recycling program. Staples was concerned that employees would be inundated with equipment and that costs might exceed their program budget. Staples’ goal was to determine whether the costs of the program could be sustainable and fit within the company’s business model. Staples’ advertising and promotional program is summarized in Chapter II. Much of this focus was on in-store signage and flyers. By design, Staples promoted the program slowly and ramped it up slowly. It never fully contacted all the media outlets, and kept the program low-key throughout the six weeks.

This strategy, though, was a major reason for the internal success of the program. By keeping the focus on the systems and costs, Staples was able to develop a clear picture of what will be required to successfully roll this program out nationally. This information was obtained in a manner that gained the support of Staples staff. Staples associates were very supportive of the recycling program, as were retail and commercial customers. For the most part, the program did not overwhelm Staples staff, so that they could feel good about the recycling service they were providing and build on its success, rather than be concerned about making major mistakes, or taking a great deal of time away from their basic jobs. By reducing its promotion, Staples was able to meet one of its goals of developing a willing and eager staff that is ready to fully implement the program. Store employees interviewed by PSI after the program spoke favorably about the simplicity of the program, their ability to manage it properly, and customers’ overwhelmingly positive response.

Product Stewardship Institute, Inc. - 44 - FINAL June 2005 Staples Pilot Project –Final Report to U.S. EPA Pilot Project Costs

CHAPTER V. PILOT PROJECT COSTS

To determine the economic sustainability of the collection model, PSI attempted to measure true costs of the system. Some of the costs identified for the pilot are related only to planning, while others are ongoing. However, as the data indicate, even the pilot data can only be applied to the northeast region of the country.

TOTAL COSTS The total costs for this pilot project were $93,432, as detailed in the following table.

Table 16. Pilot Project Costs by Phase and Funding Source.

From the table above, the cost of collecting, transporting, and recycling 115,028 pounds of retail and commercial equipment collected in this northeastern pilot project was 19.9 cents per pound. Items from the table that are bolded have been used to calculate the cost per pound. These costs do not include project implementation/evaluation, design, and promotion/staff training/administrative staff. In addition, Staples did not quantify the cost of technical and managerial staff time to conceive of and implement the project.

PROJECT DESIGN AND IMPLEMENTATION Staples contributed almost $17,000 for the design of the pilot, while EPA contributed $46,541 for project planning, implementation, data collection, and analysis.

RECYCLING COSTS The cost to recycle 107,360 pounds of computer equipment collected was $7,983.10, while the total cost of collecting all equipment (115,028 pounds, including non-computer equipment) was $8,519.86. This recycling cost was based on Envirocycle’s special offer of $4.00/monitor; no

Product Stewardship Institute, Inc. - 45 - FINAL June, 2005 Staples Pilot Project –Final Report to U.S. EPA Pilot Project Costs

charge for CPUs; and $.07/pound for all other products. PSI estimates that this cost is about one- third the market rate. The average price, including all units collected, was 7.4 cents per pound.

STAPLES’ COSTS Retail Collections Staples internal cost for the 27 retail collections includes the cost of handling the computer equipment in the store, transporting to the DC, and transporting to Envirocycle in Pennsylvania. Staples treated retail returns of used electronics in the same manner as it treated other returns, and shipped equipment in its own trucks to the DC. The company has prearranged positions allotted to its stores for pallets, totes, corrugated bales, Gaylords, and product returns. Appendix T lists the internalized shipping and handling costs associated with the retail pilot, including the number of pallets collected per store.

As Appendix T indicates, Staples hauled 377 pallet loads of computers (equal to 17.14 trailer loads), at a handling cost of $4.96 per pallet and a cost to ship them to the Killingly DC of $9.67 per pallet. The average "return" cost per pallet was, therefore, $14.63. In addition to these costs, Staples incurred costs of $450 per trailer load to transport to Envirocycle from the DC, equal to $20.45 per pallet. The total cost, therefore, to collect and transport 377 retail pallet loads to Envirocycle through the DC would be $13,225.16, or $35.08 per pallet (see Table 17 below).

Using an estimated weight of 21.88 pounds per unit (393.84 pounds per pallet) of equipment collected (see Table 2; 5,257 units collected weighing 115,028 pounds), the cost to collect and transport this retail equipment to Envirocycle prior to recycling was 8.9 cents per pound. Adding to that the average price per pound to recycle the equipment of 7.4 cents per pound, the total cost to collect, transport, and recycle retail equipment in this pilot project was 16.3 cents per pound. If Staples had to pay the market recycling rate (estimated at 20 cents per pound delivered at the facility gate), this total cost would equal about 28.9 cents per pound.

Table 17. Pilot Project Retail Collection Cost: Handling, Shipping, and Transportation

Staples and PSI used the following assumptions: • 1 system = 3 units Per Pallet Per Pound • 6 systems = 1 pallet (Gaylord) Cost Type Cost Cost • 22 pallets = 1 trailer load Handling $ 4.96 1.26 cents  1 unit = 21.88 pounds (from Table 2) Shipping to Distribution Center $ 9.67 2.45 cents  1 pallet = 393.84 pounds

Transport to Envirocycle $20.45 5.19 cents To calculate the following: TOTAL COST $35.08 8.90 cents • $771.76/trailer load • $ 35.08/pallet • $ 5.85/system • $ 1.95/unit

Costs in the New England corridor, however, are lower than the company’s nationwide average given the northeast’s proximity to the DC and short transit times to stores. As indicated in Appendix T, the national average cost to ship a pallet of computer equipment from the store to

Product Stewardship Institute, Inc. - 46 - FINAL June 2005 Staples Pilot Project –Final Report to U.S. EPA Pilot Project Costs

the DC is estimated to be $28.53 per pallet. Therefore, if the pilot was expanded nationally, the cost to handle each pallet and transport it to a qualified recycler through one of the company’s four DCs would be $ 53.94, or 13.7 cents per pound. This cost assumes that the handling cost is $4.96 per pallet, and that a qualified recycler will be within a 250-mile radius from a DC, which was the distance from the Killingly DC to Envirocycle in this pilot project. Since Staples will seek to find a recycler at a closer distance, this 13.7 cents per pound figure should be considered an upper amount. Adding to that the average price per pound to recycle the equipment of 7.4 cents per pound, the total cost to collect, transport, and recycle retail equipment nationally would be 21.1 cents per pound. However, if Staples paid the market recycling rate (estimated at 20 cents per pound delivered at the facility gate), this total cost would equal about 33.7 cents per pound.

Table 18. Average National Estimated Retail Collection Cost: Handling, Shipping, and Transportation

As Table 18 indicates, in a national effort, there would be a marked difference in cost from the northeast pilot project. The cost to recycle in other regions of the country would vary from the national average depending on the distance to the DC from a retail location and the distance from the DC to a qualified recycler. There are four Staples’ DCs in the country – in Connecticut, Maryland, Indiana, and California.

Commercial Collections Staples also calculated its internal costs for collecting equipment from contract customers, which were as follows:

(1) DELIVERY OF PALLETS: $9.00 for each delivery of pallets/Gaylords to the customer to prepare for the pickup. Eight of the 14 contract customers required the delivery of pallets/Gaylords since this was only done for those customers with greater than 10 systems (30 units).

a. $9/pallet X 8 deliveries = $72 (2) PALLET PICK UP/DELIVERY TO FC (includes the cost to pick up the pallets and transport them back to the Fulfillment Center in Connecticut):

a. $27.00 per pickup (4 pallet average/2 workers) OR b. $18.00 per pickup (less than 4 pallet average) • $27/pickup X 8 pickups = $216 (full pallet loads) • $18/pickup X 6 pickups = $108 (partial pallet loads) • TOTAL: $324

Product Stewardship Institute, Inc. - 47 - FINAL June 2005 Staples Pilot Project –Final Report to U.S. EPA Pilot Project Costs

For the eight businesses at which pallets were dropped off in advance, Staples truck pickup costs were at the higher end -- $27 per pickup. For the six pickups where Gaylords were not used, Staples either live loaded the equipment (owing to space constraints) and packaged the equipment on pallets right on the trucks, or had the business box the equipment prior to a Staples pickup. Based on this experience, Staples found that it would be best, in the future, to continue using Gaylords for full pallet loads, but to live load all other pickups so as to reduce packaging cost and time needed for pickups for less-than-full pallet loads.

(3) TRANSPORT TO ENVIROCYCLE: $450 per trailer load X 1.6 loads = $720.

From Table 14 in Chapter IV, we see that 636 units of equipment were collected at the 14 contract customer locations. Based on the above data, therefore, the full cost to collect and transport 35.33 pallet loads to Envirocycle through the FC would be $1,116, or $31.59 per pallet (see Table 19 below):

Using an estimated weight of 21.88 pounds per unit (393.84 pounds per pallet) of equipment collected, the cost to collect and transport this commercial equipment to Envirocycle prior to recycling is 8.0 cents per pound. Adding to that the average price per pound to recycle the equipment of 7.4 cents per pound, the total cost to collect, transport, and recycle commercial equipment was 15.4 cents per pound. At an estimated market recycling rate of approximately 20 cents per pound, this total cost would equal about 28 cents per pound.

Table 19. Pilot Project Contract Collection Cost: Handling, Shipping, and Transportation

Per Pallet Staples and PSI used the following Cost Type Cost Cost assumptions: Delivery of Pallets $72 $2.04 • 1 system = 3 units Pallet Pick Up/Delivery To FC $324 $9.17 • 6 systems = 1 pallet (Gaylord) Transport to Qualified Recycler (<250 $720 $20.38 • 22 pallets = 1 trailer load miles) To calculate the following costs: TOTAL COST $1,116 $31.59 • $694.98/trailer load • $ 31.59/pallet • $ 5.27/system • $ 1.76/unit

Other Costs  Storage space for used electronics – Staples did not believe that this was a factor that added cost to the project. Backhaul opportunities on Staples’ trucks are frequent, and the equipment was treated as a "cross dock shipment" when it got to the DC, where it went immediately into a trailer with equipment from the FC for shipment to Envirocycle.  Promotion and marketing – the cost of the banner and in-store signage was estimated to be $150 per store, or $4,050 for the 27 stores.

Product Stewardship Institute, Inc. - 48 - FINAL June 2005 Staples Pilot Project –Final Report to U.S. EPA Pilot Project Costs

 Staff training was estimated to cost approximately $ 1,180. This cost was divided into retail training costs of $ 1,072 (for staff at the 27 stores) and other training costs of $ 108 (for staff at the 3 main consolidation facilities – the DC, FC, and the transportation hub in Massachusetts). Staff training was not necessary at the 14 commercial businesses, since equipment was either packed by the business or included as part of Staples’ pallet delivery or pickup cost. Staples derived the retail training costs by accounting for associate training and educational materials (estimated at $100 for all 27 stores) and associate training labor (estimated at $972; $12/hour x 1 hour total training/staff person x 3 staff/store x 27 stores). There was minimal training needed to service the 3 main consolidation facilities; this was estimated to be $108 ($12/hour x 1 hour total training/staff person x 3 staff/facility x 3 facilities).  Administrative staff time was estimated to be about $1,800 to collect the data forms and input data. The time taken by Staples’ technical and managerial staff to plan and implement the pilot project was not estimated.

Product Stewardship Institute, Inc. - 49 - FINAL June 2005 Staples Pilot Project –Final Report to U.S. EPA Pilot Project Cost Projections

CHAPTER VI. PILOT PROJECT COST PROJECTIONS

ESTIMATED COSTS TO STAPLES Before agreeing to proceed with the design phase of this project, Staples requested that PSI estimate the costs associated with a pilot electronics collection program. They did not want to start this pilot without knowing that the costs would be reasonable and that the pilot would have a chance to become an ongoing national program. PSI was familiar with this need to limit financial obligations from its work with companies on the NEPSI dialogue. It was critical that concerns over “a blank checkbook” be alleviated, and that a degree of fiscal control be implemented so that Staples, and ultimately the project partners, could feel comfortable in their participation. Therefore, in the spring of 2003, PSI developed an extensive analysis of projected costs. Based on this estimate and calculations, and justifications provided by PSI, Staples was willing to proceed with the pilot project.

To conduct this assessment, PSI used data from electronics collections around the United States to make quantity and cost projections. PSI presented a high estimate of 154,600 pounds at a maximum cost of $0.25/lb. for a total of $38,960. These estimates were later refined based on new cost information from Envirocycle and an initial selection of retail locations for the pilot project. When Staples and PSI agreed to partner with Envirocycle, the recycler offered a reduced price for the processing of electronics collected during the pilot project. Envirocycle also provided PSI with a weight breakdown of electronics typically received at its collections, and shared a spreadsheet it developed for estimating participation at its collection events. The spreadsheet, which has proven to be a useful and accurate tool, is based on the population for the area served by the collection, a per capita recovery rate, and calculations based on participation rates ranging from .25% to .75% of the population.

To better estimate the quantities and costs for the Staples project, PSI multiplied these numbers by the population of the communities in which the participating retail stores are located. From U.S. Census and Atlas data, the total population of the original 26 communities considered for the pilot was 713,386. (The number of retail locations changed slightly prior to implementation.) A low, .25% participation rate, yielded an estimated 77,046 pounds of electronics, while a high participation rate of .75% yielded an expected 231,137 pounds of equipment for the original 26- store region. For the retail stores alone, these estimates translated into the following costs (based on pricing data provided by Envirocycle):

Low Range: 77,046 lbs @ $0.0834/lb* = $6,426

High Range: 231,137 lbs @ $0.0834/lb* = $19,277

Since this projection only covered costs from retail collections, PSI also wanted to consider the cost of processing used electronics returned from businesses that are part of the Staples Business

*The $0.0834/lb. figure was based on Envirocycle’s new cost figures, and an average breakdown by weight of what typically comes to a collection.

Product Stewardship Institute, Inc. - 50 - FINAL June, 2005 Staples Pilot Project –Final Report to U.S. EPA Pilot Project Cost Projections

Advantage program. However, Staples had not yet selected the participating businesses, so there was no way to estimate the quantity of used electronics that these customers might contribute to the pilot program. Even with these unknowns, PSI deduced that it was highly unlikely that the recycling costs for the pilot program would exceed the original projection of $38,960. In fact, the total cost of the retail and contract customer collections totaled $8,519.86 (based on Envirocycle’s special processing rate).

PSI made every attempt to offset Staples’ costs by securing funding toward PSI’s role in the pilot project, by engaging manufacturers and recyclers in cost-sharing, by tapping the resources of local and state agencies whose regions will benefit from the pilot, and by writing and receiving a grant from the U.S. EPA to conduct the project. Even so, there were many unknown variables that required conservative planning and a willingness to make decisions in the face of data and cost uncertainties. PSI attempted to put in place measures to control the extent of unforeseen costs. The following factors in Table 20 were seen to contribute to the cost of the project:

Table 20. Factors Affecting Staples Costs

Factor Potential Impact On Cost Estimates How It Was Addressed

Quantities • There is no way to predict what SBA • SBA customers were surveyed to customers will contribute. determine how much used equipment • If customers bring greater than average they have. quantities into retail stores, the costs will rise. Quantities and participation are • Staples imposed a limit of 1 system per directly correlated to program promotion. retail customer. In addition, program promotion was limited. Processing The 0.0834/lb. was based on an average The amount of materials accepted were Costs breakdown by weight of what typically kept low by limiting program promotion. comes to a collection. If more equipment comes into the pilot than projected, the overall cost will increase.

Cost sharing The number of partners will impact the Obtaining the partnership of 10 costs that Staples will have to bear. manufacturers decreased an already low program cost.

In-house The more capabilities (e.g., data PSI picked up several data management Capabilities management, training) Staples can develop tasks that will be assumed by Staples internally, the less the cost. and/or the recycler in the future.

Product Stewardship Institute, Inc. - 51 - FINAL June 2005 Staples Pilot Project –Final Report to U.S. EPA Regulatory Issues

CHAPTER VII. REGULATORY ISSUES

FEDERAL GUIDELINES Under federal regulations, any unwanted electronic equipment containing a cathode ray tube (CRT), including computers and televisions, is currently considered a hazardous waste under federal regulation (40 CFR Part 260). Hazardous waste regulations do not apply to household sources of electronics, or to businesses that generate under 7-8 CRTs a year. New proposed EPA regulations for CRT electronics were posted in the Federal Register of June 12, 2002, and EPA is expected to finalize them in the fall of 2005. The proposed rule is available on the PSI website, at http://productstewardship.us/pilot_takeback_staples.html. Proposed changes would designate as a “commodity” all CRT electronics that are destined for recycling at a permitted or approved facility. In the interim, the U.S. EPA has provided guidelines for the safe management of materials (available at http://www.epa.gov/epaoswer/osw/conserve/plugin/pdf/guide.pdf) for its “Plug In” partners who collect electronic equipment for the purpose of recycling (see Appendix U).

PILOT STATES REGULATIONS States can have more stringent regulations governing the handling of electronics, and many states place some responsibility on the collector. Unfortunately, there is no one set of standards that applies to all states, so the result is a patchwork of regulations that must be considered when setting up a program to accept used electronics or any other material that might be considered “waste,” including some solid wastes (e.g., paper, cardboard) or those considered universal wastes, such as rechargeable batteries and fluorescent lamps.

As designed, the Staples pilot project collected all brands of used computers at retail stores located in Maine, Massachusetts, New Hampshire, Rhode Island, and Connecticut, and from commercial customers in Massachusetts, New Hampshire, and Connecticut. The collected equipment was backhauled by Staples’ carriers and consolidated at Staples’ distribution and fulfillment centers in Connecticut. Staples trucks then transported the materials to Envirocyle, an electronics recycler, in Hallstead, Pennsylvania. State agency officials in the pilot area identified several applicable regulations (below) that pertained to the Staples project. States have some ability to streamline regulations for electronics product stewardship efforts, and PSI worked with Staples and state agencies to identify and comply with the states’ regulatory interpretations.

None of the state regulations added significantly to the cost and complexity of this project. Under state interpretations of the regulations, Staples had to meet the following requirements:

 Obtain EPA ID numbers for participating stores in Maine;  Obtain EPA ID numbers for participating distribution and fulfillment centers in Connecticut;  Provide employee training (which states offered to provide) in universal waste handling in Maine and Connecticut, and transportation hubs;

Product Stewardship Institute, Inc. - 52 - FINAL June, 2005 Staples Pilot Project –Final Report to U.S. EPA Regulatory Issues

 Obtain EPA ID number for shipping electronics across Maine;  Track materials through a state-approved shipping log (Staples standard log met approval); and  Document collection program participants (e.g., name, address, indicate if they are a business) through a sign-in log or other information tracking system. On behalf of Staples, PSI sent a formal letter to the key regulatory official in each of the five pilot states requesting a return letter stating the specific requirements for the pilot project. The letter to the agencies included a description of the project. These letters, along with the responses from the state officials, appear in Appendix V through Appendix Z, along with state regulatory materials. In summary, Massachusetts and New Hampshire did not consider computers collected for recycling in the pilot to be waste, so universal waste regulations did not apply there. However, Connecticut, Maine, and Rhode Island did conclude that universal waste regulations applied to the Staples collected materials.

To standardize the handling procedures for all Staples facilities and associates in the five pilot states, Staples adopted the general guidelines for universal waste handling, transport and storage. These general guidelines include:

 Storing used electronics in buildings with a roof and four walls or in a cargo-carrying portion of a truck.  Labeling containers or pallets containing the electronics as “Used Electronics.”  Storing electronics for no more than a year before shipping to a recycler.  Documenting the pilot project participation through a modification of Staples current information systems (e.g., as a dummy “return”) or use a sign-in log to document that they managed their computers through the Staples program.  Getting approval for the current or slightly modified tracking systems (e.g., bill of lading) to document that collected materials reach the recycler. States that have designated electronics as a universal waste also have storage and handling requirements. To standardize the Staples collection program for all states, electronics collected at retail stores were stacked in Gaylord boxes and labeled.

CONNECTICUT REGULATIONS The Connecticut Department of Environmental Protection determined that Staples had to apply to its agency for an EPA identification number as a large quantity universal waste handler for the distribution center and fulfillment center that consolidated the collected computers, since these sites were expected to consolidate more than 5,000 kg (approximately 11,000 pounds) of equipment at any given time. Retail stores collecting equipment from consumers were designated as small quantity handlers of universal waste, since they were expected not to store more than 5,000 kg at any one time. The key difference between the requirements is that no disassembly is allowed for those designated as a large quantity universal waste generator without a state permit.

Product Stewardship Institute, Inc. - 53 - FINAL June 2005 Staples Pilot Project –Final Report to U.S. EPA Regulatory Issues

According to Connecticut regulations as they apply to the stores, the distribution center, and the fulfillment center, collected equipment can be stored for no longer than one year from the date it is received. Storage requirements state that each container, package, or pallet of used electronics must be labeled clearly with any of the following: “Universal Waste - used electronics,” or “Waste Used Electronics,” or “Used Electronics.” Used electronics must be stored in a building with a roof and four walls or in a cargo-carrying portion of a truck, in a manner to prevent used electronics from being exposed to the environment. The used electronics must be handled, stored, and transported in a manner that maintains the reuse or recyclability of the used electronic. A handler must immediately clean up and contain any broken cathode ray tube and place it in a container that is closed, structurally sound, and compatible with the CRT. It should prevent leakage, spillage, or releases of broken CRTs, glass particles, or other hazardous constituents from such broken tubes to the environment.

Since Staples used its own carriers to transport materials to the recycler, Staples needed to comply with regulations for universal waste transporters. The Connecticut guidelines are further detailed in Appendix V, along with correspondence between PSI and state officials. CT DEP assisted greatly with the application process. PSI assisted Staples in filling out the paperwork to apply to the CT DEP for an EPA identification number for the DC and FC. Contact Tom Metzner, Connecticut Department of Environmental Protection, (860) 424-3242, [email protected].

MAINE REGULATIONS Maine considered computers collected in the pilot to be hazardous (universal) waste. However, on a case-by-case basis, there is flexibility for the state to streamline these regulations for “manufacturer sponsored, product stewardship” collection efforts. Under the Maine Universal Waste Rule for CRTs, each store participating in the pilot collection was required to apply to the Maine Department of Environmental Protection (ME DEP) for a State identification number identifying the store as a universal waste handler. PSI assisted Staples in this application process, and was allowed to apply once for all stores involved. In the future, if Staples decides to conduct this program permanently, a federal EPA identification number will need to be obtained for each participating store location. Also, additional requirements would apply if Staples were to accept computers from businesses.

Trucks that transported the collected materials were required either to be licensed hazardous (universal) waste transporters, common carriers that are equipped to ship universal waste, or self- transporters that track materials using the state’s approved bill of lading. Staples’ carriers and shipping forms met the state requirements, but had to be reviewed and approved by the ME DEP before transporting materials in Maine. Since Staples transported the computers (as universal waste) out of state, it needed to use a Universal Bill of Lading (UBOL) for shipping. PSI assisted Staples in receiving UBOLs from the DEP.

The retail collections were not expecting to take equipment from businesses, although Staples staff did not prohibit those who used the computers in small businesses from participating. As reported in Chapter IV, approximately 19% of the retail-collected equipment came from small businesses. It is important to note that Maine requires businesses that bring computers to a

Product Stewardship Institute, Inc. - 54 - FINAL June 2005 Staples Pilot Project –Final Report to U.S. EPA Regulatory Issues

collection to sign a log in order to document that they properly managed their equipment. Maine officials also recommend that households sign a log. Staples must keep the log on file for 3 years, in the event of a state audit. In any case, all participants were asked to fill out a survey that included their contact information and equipment returned. The survey that PSI developed for Staples was considered acceptable by Maine DEP officials.

Maine officials also required store employees handling the computer equipment to receive training, and offered to provide it to Staples staff. The state also had labeling and storage requirements. Storage limitations required that equipment be shipped within one year of collection, which it was. Maine’s Universal Waste Guidelines can be found at: http://www.maine.gov/dep/rwm/hazardouswaste/uwhandbook2004.doc. Correspondence between PSI and state officials appears in Appendix W. Contact Maine Department of Environmental Protection, Division of Oil & Hazardous Waste Facilities Regulation. Diana McKenzie (207) 287-7880, [email protected].

MASSACHUSETTS REGULATIONS The Massachusetts Department of Environmental Protection (MA DEP) regulations mirror the proposed federal rule on CRTs. Since Staples only collected the materials, and did not make a determination whether the equipment was working (therefore suitable for reuse), then it was not considered a waste. The MA DEP also did not regulate the equipment at the two in-state transportation hubs that were used as cross-dock facilities for the collection of commercial equipment en route to the FC in Putnam, Connecticut. Material stayed at the hubs for less than 24 hours and, in many cases, just a few hours, before being backhauled to the FC. The MA DEP provided guidance for the management of computer monitors regarding the care that should be taken in handling, storing, and shipping the collected materials to prevent breakage or release to the environment. Appendix X contains frequently asked questions and answers on Massachusetts’ regulation of CRTs, along with correspondence between PSI and state officials. Contact James Paterson, Massachusetts Department of Environmental Protection, (617) 556- 1096, [email protected].

NEW HAMPSHIRE REGULATIONS New Hampshire identifies used CRTs as universal waste. However, since Staples was not the entity making a determination of reusability, it did not have to comply with universal waste handler requirements. Regarding storage, Staples could not store collected materials for more than a year. Appendix Y contains guidance from the state on the Universal Waste Rule and CRTs, along with correspondence between PSI and state officials. Contact Pierce Rigrod, New Hampshire Department of Environmental Services, (693) 271-3713, [email protected].

RHODE ISLAND REGULATIONS Rhode Island regulated Staples as a small quantity handler of universal waste for the computer equipment collected at the one participating retail location in Rhode Island. These regulations are found under Section 13 of the Rules and Regulations for Hazardous Waste Management.

Product Stewardship Institute, Inc. - 55 - FINAL June 2005 Staples Pilot Project –Final Report to U.S. EPA Regulatory Issues

Correspondence between PSI and state officials appears in Appendix Z. Contact Mark Dennen, Rhode Island Department of Environmental Management, (401) 222-2797.

Product Stewardship Institute, Inc. - 56 - FINAL June 2005 Staples Pilot Project –Final Report to U.S. EPA Pilot Project Benefits

CHAPTER VIII. PILOT PROJECT BENEFITS

There were numerous benefits to conducting this pilot project, many of which have already been discussed in the preceding text. However, it is useful to highlight those that should be considered when evaluating a national expansion.

 Solves a Pressing Environmental Need: At its basic root, the pilot showed that Staples, as a company, was perceived as offering a viable solution to residents and businesses that had equipment that they knew should not be disposed. The system set up worked for both retail and commercial customers. Over 115,000 pounds of unwanted computer equipment was recycled.  Provides a Known Collection Location and Education Opportunity: Millions of people already shop at Staples stores worldwide. They know where the stores closest to their home or business are located, and have worked those locations into their transportation patterns, as well as office supply purchasing habits. By collecting computers at these locations, people do not need to change these pre-existing patterns of behavior. These locations also offer an ideal opportunity to notify people about the collections and to educate them about why collection is important, where products are taken once collected, and other Staples environmental services.  Creates Good Will: These collections create good will with residents in the neighborhood who come to see Staples as not only a business that provides office supply services but one that cares about their environmental well being. The collections also assist state and local government officials by providing another outlet for the collection of computer equipment, which places a heavy burden on public works departments nationwide. The service provided also creates a connection to Staples employees, who are now perceived not only as someone who can help choose the right printer for one’s home office needs, but also as someone providing a socially positive service to customers. Employees were thanked for the service, and this can only develop loyalty to the employer.  Demonstrates Collaborative Problem Solving: This pilot project brought together a retailer (Staples), a non-profit (PSI), a federal agency (EPA), a recycler (Envirocycle), computer manufacturers, state agencies, and local agencies to provide a joint solution to a problem in which they all share a responsibility. It enabled all participants to understand their unique roles in helping to solve a pressing environmental problem. Success on this project will allow for the opportunity for success on other similar projects with these same participants, or a different configuration of partners.  Provides One Stop Shopping: By providing residents and businesses with one company that sells office supplies and recycles them when no longer usable, it simplifies an already complicated daily existence. Contract customers particularly will seek one company to provide both services, which will save on accounting transaction costs.

Product Stewardship Institute, Inc. - 57 - FINAL June, 2005 Staples Pilot Project –Final Report to U.S. EPA Pilot Project Benefits

 Offers Staples a Promotional Opportunity: Combining a recycling service with sales of new products allows for a joint promotional opportunity when re-launching stores or promoting other store specials.  Offers Manufacturers a Promotional Opportunity: By Staples using their infrastructure to collect equipment made by another company, Staples actually provides that manufacturer with an opportunity to share in the promotional benefits and good will created by the collection. There is tremendous pressure on manufacturers to provide a solution to the environmental problems created by computer equipment waste. It also creates a marketing opportunity for those companies to sell new products.  Established Staples as a Brand Leader. Through this project and other environmental programs, Staples has established itself as a retail leader regarding the provision of environmental solutions for its customers. This project set a benchmark against which other retailers will measure their performance.  Provided an Impetus for Other Retailers to Engage: After Staples announced that it would conduct a retail reverse-distribution pilot, Good Guys and Office Depot followed with similar electronics collection programs. These were the first retail efforts to collect and recycle electronics. By showing that such a collection could take place, and that it was willing to act, Staples created momentum among retailers so that others are considering how to make their businesses into sustainable companies. Ultimately, this is one of the biggest benefits to the current pilot effort. As Staples expands its environmental services, other companies will likely follow or risk losing a competitive advantage based on added social value.  Enabled Data/Information Sharing: The project provided an opportunity to contribute data so that others working on solutions to electronics management, particularly regarding the retailers’ role, can benefit.

Product Stewardship Institute, Inc. - 58 - FINAL June 2005 Staples Pilot Project –Final Report to U.S. EPA Key Lessons Learned

CHAPTER IX. KEY LESSONS LEARNED

 Program was Logistically Feasible: It is feasible for a retailer to take back unwanted computer equipment at a retail store, or from businesses, using a reverse-logistics collection, transportation, and recycling model.  Program was Successful. Staples staff, retail customers, and contract customers were enthusiastic about the program and want it to continue. Over 57.5 tons of equipment was collected in six weeks from both retail and commercial customers at a cost that was competitive with other electronics collections.  Staples’ Customers are Environmentally Aware. Retail and commercial customers are savvy about environmental concerns from electronic wastes. Few questioned the need for collection.  Staples Customers are Willing to Pay for Computer Recycling (Note: This should not be used as a reason to charge in the long-term, since there are still a significant number of people who will not pay. But it can provide funds to start or supplement a program.)  There is a Backlog of Equipment. There is a significant glut of material needed to be collected initially from customers, since much had been in storage previously. For many of the contract customers, this was their first computer recycling effort. This initial backlog of equipment was especially significant for the business collection program, which made a simple “back haul” of equipment difficult for a “first time” recycling event. It is assumed that subsequent and/or periodic events would be more efficient.  Computers Returned from Non-participating Companies were Significant. A significant percentage of computer equipment returned to the collections came from those that did not contribute financially to recycling costs.  Manufacturer MOUs Were Time Consuming to Negotiate. The agreement process with potential manufacturer partners was time consuming, whether or not the company was a Staples vendor. Most manufacturers wanted to change some aspect of the standard MOU, and a few wanted individualized agreements that were much different from the basic template.  Communication Miscues were Costly. Communication between the recycler and the Project Team resulted in missed data gathering opportunities and extra time and cost to extrapolate data (e.g., leaving one company out of the brand sort).  Commercial Collections were Unique. Whereas retail collections followed a noticeable pattern, Staples needed to arrange contract customer collections individually owing to a variation in pick up locations and equipment quantities and types. Over time, models should evolve within these collections, making contract customer service delivery easier.  A Little Promotion can go a Long Way. Taking a low-key promotional approach worked well for Staples employees and management, even if additional customers could have benefited by the initial pilot. Staff were prepared for the program, were often cited as helpful

Product Stewardship Institute, Inc. - 59 - FINAL June, 2005 Staples Pilot Project –Final Report to U.S. EPA Key Lessons Learned

in the follow up surveys, and were enthusiastic about continuing the program. With little advertising and promotion, Staples can provide an added service to existing clientele, endearing them further to the company, since they are already Staples customers. It is possible, however, that Staples could have allowed more units to be collected per customer and collected more computer equipment over the pilot period, knowing now the number of units that were collected and the low cost of the project.  Expect Business Equipment. There was a small, but significant, segment of retail customers who brought equipment used for business purposes. Some equipment also came from municipal offices.  Recyclers were Staples Shoppers. Most of those who returned equipment to a retail store and were interviewed said that they typically shop at Staples. Few people came into the store only because of the recycling program. This was largely due to the focus on in-store promotion.  Data Quality was Not High. Allowing retail and contract customers to fill out their own data sheets did not work as well as had hoped. Many people dropped off equipment, scribbled some information, and left the store, or went shopping in the store. Only 282 of the approximately 1800 retail customer survey forms had contact information that was usable. Commercial data were better, but still incomplete and inconsistent.  Beware of Municipal Regulations During Outreach. Some municipalities would not allow Staples to advertise using a banner on the exterior of the store.

Product Stewardship Institute, Inc. - 60 - FINAL June 2005 Staples Pilot Project –Final Report to U.S. EPA Recommendations

CHAPTER X. RECOMMENDATIONS

Whether to expand this computer recycling project nationwide is a decision for Staples management. However, from the data developed from this project, there appears to be little doubt that there is a clear need, and opportunity, to expand the collections both at retail outlets and contract customer locations. The computer recycling service was well received; there are numerous benefits to expansion; and Staples’ internal costs were reasonable. In addition, any costs incurred by Staples could be offset by a fee charged to customers, many of whom are willing to pay to recycle, and/or by manufacturers’ contributions. Adding computer recycling service to Staples’ growing environmental products and services will solidify Staples’ position as a company that not only provides quality office products and services, but one that cares about the company’s impact on the environment and the community served by its retail stores. Expanding this recycling service would further enhance Staples’ image as a sustainable business.

PROGRAM LOGISTICS  Treat Used Computers Like A Return. Typical retail product returns are brought to a customer service representative, who records vital information directly into a computer database and takes possession of the product. Used computers should follow a similar procedure, which will ensure quality data, reduce the likelihood of equipment breakage, and provide a greater level of service. Staples could handle computer returns from businesses at the point at which orders are placed. If used electronics are handled as a special “return” in Staples’ electronic information system, the data could then be harvested for important information. It will be important to determine if Staples’ computer system can be adapted to collect the necessary data.  Charge a Recycling Fee. Until a state or national financing system comes into existence, charge a fee to collect and recycle computer equipment from both retail and commercial customers. The fee charged to customers will need to be competitive with other recycling services, particularly among commercial customers, although there is an added value in having one company – Staples – provide office supplies and recycling services (on the backhaul) to these commercial customers. Providing a tangible community benefit, as it did in a separate pilot project for retail customers in the Northwest, would add to the acceptance of the retail fee. In the Staples pilot project in Washington and Oregon, a portion of the fee charged to customers for computer recycling was donated to a local school chosen by the

Product Stewardship Institute, Inc. - 61 - FINAL June, 2005 Staples Pilot Project –Final Report to U.S. EPA Recommendations

customer to receive the donation. Staples will still need to determine how much to charge to cover costs and provide a return to the community. The initial fee should include the cost of recycling non-participants’ equipment, since participating manufacturers should not be expected to continue to cover the costs for non-participants, particularly as volumes collected increase.  Recover the Full Recycling Cost in the Recycling Fee. Do not rely on a cost share from manufacturers in setting the recycling fee owing to the large percentage of computers collected from non-participating manufacturers. There is a question as to whether participating manufacturers will continue to cover the costs imposed by manufacturers that are not taking responsibility for their fair share, and put themselves at a competitive disadvantage. As the cost for participating gets too great, these companies may cease to voluntarily participate in the program. If this potential impact is not factored into the program’s cost at the outset, it may require Staples to raise the fee later, which is not desirable. Instead, that fee should assume that the full recycling costs will be recovered through the fee, unless specific long-term arrangements are made in advance with participating manufacturers.  Expand the Limit on Equipment Allowed per Retail Customer. Instead of restricting residents to one computer system, consider expanding the limit on retail customers to 4 or 6 units per customer, as was successfully demonstrated in Staples’ Northwest pilot project. there should be no need for Staples staff to enforce an unpopular condition and overly limit the amount of computer equipment returned for recycling. During the pilot project, some residents complained that they had to make several trips, or left equipment in storage owing to the limitation allowing only one computer system. However, some limit will be needed if Staples wants to discourage business equipment.  Identify Business Equipment. Since some states may require that equipment from businesses be identified and treated differently from equipment from households, ask a question on the in-take survey as to the origin of the equipment of those entering retail stores.  Phase Collections — Cleanout and Maintenance. Before a maintenance program can be put in place, anticipate that a large initial amount of material will be generated in areas without past collections. This will particularly be the case in a business. Conducting equipment clean outs, phasing collections, or ramping up service will ensure that the program is not inundated with equipment. Consider promoting a clean out of equipment through dedicated retail collection events prior to implementing ongoing in-store collections. For contract customers, a similar phased collection schedule can be adapted so that the first pickup is expected to be a cleanout of stored computers prior to an ongoing maintenance schedule. Such a practice will reduce pressure on retail employees to learn new procedures and ensure that they are not inundated with equipment. It will also likely save Staples funds by consolidating services to a few days for each retail location. Another option is to more slowly ramp up in-store, ongoing collections. While phased collections should definitely be considered for contract customers, additional consideration will be needed before phased collections can result in a real benefit for retail customers. In areas with few computer collection options, a Staples retail collection will not alleviate the backlog of material from storage. However, if the Staples program is part of

Product Stewardship Institute, Inc. - 62 - FINAL June 2005 Staples Pilot Project –Final Report to U.S. EPA Recommendations

other collections, and these collections have taken place over several years, it is possible that Staples will see a shift to a maintenance mode. In the Northwest, however, this shift has not yet occurred even with the existence of ongoing, convenient computer recycling programs. Additional retail collections, therefore, will need to take place before an established pattern is detected.  Implement a Commercial Equipment Pick-up System: Ensure a chain of custody to better track equipment and report to customers by assigning a bar code or other identification to shipments at the point at which the recycling service is ordered. Consider setting up commercial collections so that businesses have the opportunity to pre-select used computer pick up from a menu of services and submit an “order form” describing the shipment (e.g., number of computer units, type of equipment). At that specific point, Staples could assign a bar code or other identification to shipments to track the materials from the source to the recycler.  Develop a Standard MOU with Manufacturers with Few Variations. Although PSI and Staples developed a standard MOU, manufacturers spent countless hours trying to manipulate it for their own particular circumstances. While a certain degree of flexibility is advisable, the time spent in negotiating individually was not worthwhile, particularly with companies that have their own special circumstances. Consider having one agreement that a manufacturer either signs or doesn’t sign. Also, dictate the terms of an agreement and only allow variations in very special circumstances. If a business wants to collect its own material, it should be required to pay for the cost of separating and recycling its own equipment. It is advisable to include in the MOU the name of the recycler and other important details to clarify expectations.  Assign a Dedicated Staples Daily Contact. Consider assigning an internal dedicated staff person that could serve as the daily point contact to retrieve data, contact Core Team personnel, and communicate preferences and decisions. This person could coordinate staff activities, take direction from senior staff, and be available to keep the project going. The person should take direction from a senior manager who has authority with senior staff across the company. Staples will need to include this staff time in its costs and, ultimately, the fee charged to the public at retail, or contract customers. If Staples expands nationwide, this would be a full-time position. However, if the expansion were to proceed in phases, this position would be a part-time position.  Promote Reuse. Reuse is a more environmentally sustainable practice than recycling. However, it takes more planning, and is more complicated regarding regulations and data destruction. Ask potential recyclers being interviewed for future collections to provide the cost of adding reuse to the services provided, and the method by which data will be destroyed. Sending working computers for reuse to developing nations poses no liability for Staples and is a worthy cause, but it may be interpreted by some environmental groups as another form of third world dumping. For any expansion of this pilot program, use domestic reuse organizations until a credible system is put in place for the return or proper management of electronics sent for reuse to other countries.  Enhance Data Security to Allow for Reuse: In the future, electronics from companies should be tagged with a noticeable sticker or other identifier to signal to the recycler that

Product Stewardship Institute, Inc. - 63 - FINAL June 2005 Staples Pilot Project –Final Report to U.S. EPA Recommendations

special handling is required (e.g., scrubbing the hard drive to allow for reuse). This procedure would allow for a greater level of certainty regarding data destruction. Staples could implement a system for scanning and numbering items, and translating them into SKUs, as part of a data security and unit tracking system. By instituting a rigorous procedure that ensures data destruction, reuse might increase for companies that have newer and, therefore, more marketable, equipment.  Incorporate Recycler Selection Criteria. If expanding computer collections across the U.S., use the recycler selection criteria developed for the pilot project and determine the relative importance of the proximity of a recycler to a consolidation point, among other issues.  Collect Additional Items. Consider collecting and recycling other electronic items that Staples sells but doesn’t now collect, such as computer discs and other electronic media. These items should be phased in along an established timetable.

TRAINING AND REGULATORY REQUIREMENTS  Provide Training For Contract Customers. Many of Staples’ contract customers started recycling their computer equipment during this pilot project. Some stored the computers, while others disposed of them in the garbage. For some companies, computer recycling is a major shift in practice. Consider developing training specific for companies that will need to educate their own employees to start recycling computers instead of throwing them away. Such a training would be a perfect opportunity for state regulatory officials to work in conjunction with Staples and its customers. Conduct a small pilot project first, and then scale it up if successful.  Handle All Materials Using General Guidelines For Universal Waste. Adopt general guidelines to abide by the universal waste requirements if expanding the program nationwide or making it permanent in the five New England states that were part of the pilot project.  Seek to Standardize Regulatory Requirements. Although complying with state regulatory requirements was not overly burdensome, and PSI received excellent assistance from state regulatory officials, the process was time-consuming. Standardized regulations will lower the costs to collect, transport, and recycle electronics. States, however, may want to regulate used electronics themselves, as many states do not agree with the current interpretations on electronic waste from EPA. Problems will only arise, though, if state regulations are functionally incompatible. However, if the regulatory requirements prove to be too cumbersome in some states, consider limiting the initial program to states with a more relaxed interpretation of how electronics can be safely managed. If states find they are missing out on a good pilot program because of their regulations, they may be inclined to change their regulations. Seek the support of EPA regional offices and headquarters to determine the most efficient regulatory approach depending on the future program.  Develop a Tracking System for Collected Computers. Staples’ automated return system already tracks customer information, product type, brand name, and other data. Explore adapting this return system to accommodate customers bringing used electronics. Universal waste transporter requirements include the keeping of a shipping log (bill of lading) to track

Product Stewardship Institute, Inc. - 64 - FINAL June 2005 Staples Pilot Project –Final Report to U.S. EPA Recommendations

materials. The Maine Department of Environmental Protection approved the shipping log developed by PSI for compliance in that state. In addition, Maine requires documentation of the source for the collected computers so that businesses can demonstrate that they managed their used computers in compliance with state laws. The automated system would satisfy regulatory tracking requirements, and customers could be provided with a receipt that would demonstrate that their equipment was handled in an appropriate manner. Additionally, the data gathered in an automated system could also provide important information on the equipment coming into the system and on the customer. If the automated tracking system cannot be employed, Staples can use the same type of forms used for the pilot project, which provided customer name and contact information, and indicated if the computers were from a business. Staples must keep these logs on file for a period of 3 years after the collection program. To standardize storage and handling requirements, follow the same procedures as was followed for the pilot project (see Chapter VII). Staples will have to verify that these proposed labeling and tracking systems meet the regulatory requirements of the states in which the program will take place.  Standardize Computer Handling Guidelines And Training For Staples Associates. For the pilot, Staples provided its personnel that handled computers with brief training and printed guidelines for how to handle equipment to prevent worker injury and breakage, and what to do during accidental breakage. The Connecticut DEP and Maine DEP offered to meet with Staples, provide training (or training materials) to Staples associates, and further define training recommendations and requirements. In an expansion effort, seek to identify and evaluate other training efforts developed for workers staffing electronics collections. Refine and standardize training for the national rollout to ensure that it will meet the regulatory requirements in all states.

DATA COLLECTION, CONTRACTS, AND BUDGET  Maximize Data Collection Capabilities Within Staples. Staples’ pallet-cost collection system should be supported by more specific methods of per-item accounting. Assigning bar codes to individual units (containers or pallets), using methods comparable to Staples’ current return and exchange procedures, will facilitate accounting of expenses as items move through the Staples small business delivery system (e.g., from business to delivery truck, transportation hub, fulfillment center, recycler) or the retail system (e.g., from household or small business to retail store/pallet to distribution center, to recycler). Coordinate bar code information with the recycler, so that all parties involved in materials handling will be able to calculate more precise costs for each stage of handling.  Calculate Other Costs To Staples. Calculate and budget for total costs that will likely be part of the national expansion of the collection system, including associate and management time, storage, equipment and supplies, advertising, and promotion.  Budget for Non-computer Equipment. Expect, and budget for, a certain percentage of related non-computer equipment, even if it is specifically not accepted as part of the program.  Develop Detailed Contract with Recycler. Develop a detailed contract with the recycler regarding expectations about the companies for which brand sorts should take place, whether

Product Stewardship Institute, Inc. - 65 - FINAL June 2005 Staples Pilot Project –Final Report to U.S. EPA Recommendations

retail and commercial loads will be tracked separately, the forms used for data collection, how manufacturer cost shares are to be calculated, who invoices manufacturers for their cost share, average weights used per equipment type, and which equipment types will be sorted by brand. This project involved many details at numerous stages of project development. Small details that were not resolved in advance caused significant time delays, uncertainty, and cost. For example, a brand sort was not conducted for one of the participating companies, requiring the development of a complex cost share calculation. Listed below are two charts that suggest the types of data that Staples could collect itself, and what it could require the recycler to provide.

Table 21. Quantity Data and Collection Method

Quantity Data Data Collection Method

Pounds and units of collected materials from retail Recycler provides data stores

Pounds and units of collected materials from SBA Recycler provides data businesses Pounds and units of collected materials from Recycler provides data Internet/catalog customers Quantities by brand Recycler provides data (either sample or true count) Number of business participants Staples calculates from SBA participants and from sign in logs at retail store collections Number of household participants Staples calculates from sign in logs at retail store collections Average pounds/units per participant Staples calculates from recycler and participation data Quantities compared to availability of other Staples calculates by matching questionnaire results collections and quantities brought in for each store and SBA business

Table 22. Cost Data and Collection Method

Cost Data Data Collection Method

Marketing and promotion Staples calculates costs related to promotions Processing and recycling computers Recycler provides costs, including waived costs Cost/value of electronics handling by Staples Staples calculates time related to the collection, including supplies and equipment Value of transportation services Staples calculates transportation costs on a per- pallet costs Associate training costs and materials Staples calculates actual training expenses Staff planning, implementation, and monitoring Staples calculates staff time related to planning, implementation, and monitoring

Product Stewardship Institute, Inc. - 66 - FINAL June 2005 Staples Pilot Project –Final Report to U.S. EPA Recommendations

EDUCATION AND OUTREACH  Phase Program Promotion. Continue the practice of phasing in the collection program concurrent with ramped up advertising and promotion to ensure that staff do not become overwhelmed by equipment and continue to support the program. Outreach should start small, but progress gradually to full promotion. Regarding retail collections, consider starting with in-store signage, then include an outside banner, flyers, and finally contact the news media and conduct local outreach through recycling coordinators after six months. To cap off an expansion effort, conduct media outreach to daily newspapers and trade press, for maximum press visibility. The concept driving this recommendation is that, if staff becomes overwhelmed, they will not be able to acclimate to the new service. A phased approach will ensure that they continue to feel good about offering this added service.  Provide Recycling Education to Staples Customers. When equipment is being collected, Staples has a unique opportunity to educate retail and commercial customers about why recycling computers makes sense, what happens to the equipment once it is picked up, what would happen if the equipment was not collected, and what other products Staples recycles. Consider developing two types of messages – one for the general public, and one for business owners. As discovered through the pilot, a percentage of small business customers shop in the store now, along with municipal fire/police/schools, and others whose equipment may be required by state law to be managed in a different manner. There is an opportunity to reach these customers with a different message than households.  Enhance Communication with Partners. Regular communication updates with partners will enhance project communication and reinforce the common goal toward which all partners are working – the recycling of computer equipment. Update bulletins provide steady information and answer questions that inevitably arise during the project.  Engage Pilot Partners in Outreach and Education. Pilot partners are interested in receiving press attention as a result of their participation. To increase project visibility, contact pilot partners early in the implementation planning to assess the promotional and outreach resources available through these organizations (e.g., newsletters, presentations, websites, hotlines, signage at recycling or household hazardous waste facilities). Consider jointly funded print and radio advertisements and joint press events and outreach.  Obtain Local Approval to Exhibit Store Banners. Seek a waiver from the prohibition in some municipalities to putting a banner on the exterior of the store.  Coordinate with America Recycles Day. Nearly every state has an America Recycles Day coordinator who would be receptive to a partnership on computer recycling. A list of state contacts can be found on the organization website at www.americarecyclesday.org. According to one coordinator, most of these activities are dormant in between the annual event (in November), but coordinators would likely welcome an opportunity to partner with Staples. These state contacts also have established communication channels that can be used for promoting the program when the program is ready to be ramped up.

Product Stewardship Institute, Inc. - 67 - FINAL June 2005 Staples Pilot Project –Final Report to U.S. EPA Recommendations

PROGRAM EVALUATION  Evaluate Customer Satisfaction. Staples should train its customer service staff to survey retail and contractor customers to learn valuable lessons about the program. Periodic surveys can be administered to randomly selected customers when they bring in their computers (retail), or when their equipment is picked up or when an order for pick up is placed on-line (contract). Alternatively, Staples staff can follow up within a week after the equipment has been brought to the store or picked up. Discount coupons can be provided to those who agree to assist with the survey.  Provide for Internal Feedback. Staples associates familiar with the recycling program should provide important feedback on needed improvements. PSI views this evaluation as an informal discussion with the Core Team based on feedback they receive from their employees. Consider developing a simple list of questions for Core Team staff to ask of their employees.  Communicate Project Results. Staples spent a great deal of time and effort to make this project successful. Project partners contributed time and resources. Holding a briefing at critical junctures in the project timetable will ensure that project results and implications are understood, and that the feeling of participating in a joint project is enhanced. Consider ending pilot projects, such as this one, with a press release announcing results and the availability of the final report.

Product Stewardship Institute, Inc. - 68 - FINAL June 2005 Staples Pilot Project –Final Report to U.S. EPA Appendix A

Appendix A. Letter to Computer Manufacturers

Date OEM Contact Name OEM Contact Title OEM Name OEM Address

Dear XXXXXXXX,

As a valued vendor partner, major manufacturer and supplier of electronic equipment to Staples, Inc., we are contacting you to participate in a project of national significance. Because we are a top retailer of electronics in the U.S., Staples is concerned about the volume and toxicity of electronics waste. We are developing, and will soon be testing, a business model to address this growing problem.

The business model will collect and recycle used electronic products from Staples’ retail, Internet and commercial customers. It will utilize the reverse distribution capacity of the Staples fleet to transport used electronics products from customers to regional distribution centers. Staples will design the system to be financially sustainable.

A pilot project will test the business model using various scenarios. We are aware that EPA is providing incentives for electronics manufacturers to be involved in collection and recycling. Therefore, one scenario we would like to explore is cost sharing with our top OEM suppliers. Staples is willing to absorb the costs of collection and transport of electronics to our regional distribution centers. We are seeking OEM support to cover the costs of transporting the materials from the distribution centers to processors, and the recycling.

The actual cost and the value of services will be measured in the pilot project to determine which scenarios are replicable for a national system. Involvement in the pilot project does not necessitate your continued involvement in the national system. Staples’ intent is to ultimately develop a business model for electronics that not only provides an important service to our customers, but that may also be replicated by other retailers.

Staples has contracted with the Product Stewardship Institute to assist with the design of the pilot project. Scott Cassel, Executive Director of the Product Stewardship Institute, will contact you soon to discuss the pilot project and your potential interest in participating. Please feel free to contact us directly if you have any questions. We look forward to working with you on this important initiative.

Sincerely,

______

Mark F. Buckley Peter J. Scala Vice President, Environmental Affairs Sr. V.P., GMM Office Technology Staples, Inc. Staples, Inc.

Product Stewardship Institute, Inc. - A1 - FINAL June, 2005 Staples Pilot Project –Final Report to U.S. EPA Appendix B

Appendix B. Contacts for Staples Pilot Project

Federal and State Government Contacts Connecticut Department of Environmental Maine Department of Environmental Protection Protection Tom Metzner, Environmental Analyst Carole Cifrino 79 Elm St, 4th Floor 17 State House Station Hartford, CT 06040 Augusta, ME 04333 (860) 424-3242 (207) 287-7720 [email protected] [email protected]

Maine Department of Environmental Maine State Planning Office Protection Sam Morris Diana McKenzie 38 State House Station Bureau of Remediation and Waste Augusta, ME 04333 Management 207-287-8054 17 State House Station [email protected] Augusta, ME 04333 (207) 287-7880 [email protected]

Massachusetts Department of Environmental Massachusetts Department of Environmental Protection Protection Brooke Nash, Recycling Grants Program Greg Cooper, Director of Consumer Programs Manager Office of Research & Standards 1 Winter St, 8th Floor 1 Winter St, 8th Floor Boston, MA 02108 Boston, MA 02108 (617) 292-5984 (617) 292-5988 [email protected] [email protected]

Massachusetts Department of Environmental New Hampshire Department of Environmental Protection Services James Paterson Phil O’Brien, Director 1 Winter Street, 9th Floor 6 Hazen Drive Boston, MA 02108 Concord, NH 03301 (617) 556-1096 (603) 271-2905 [email protected] [email protected]

Product Stewardship Institute, Inc. - B1 - FINAL June, 2005 Staples Pilot Project –Final Report to U.S. EPA Appendix B

New Hampshire Department of Environmental New Hampshire Department of Environmental Services Services Chris Way, Supervisor of Planning and Pierce Rigrod Community Assistance 6 Hazen Drive 6 Hazen Drive Concord, NH 03301 Concord, NH 03301 (693) 271-3713 603-271-3571 [email protected] [email protected]

Rhode Island Department of Environmental New England Waste Management Officials Management Association (NEWMOA) Mark Dennen Bill Cass, Executive Director 235 Promenade Street 129 Portland St. Suite 602, Providence, RI 02908-5767 Boston, MA 02114 (401) 222-2797 (617) 367-8558 x301 [email protected] [email protected]

Environmental Protection Agency (U.S. EPA) U.S. EPA/New England Clare Lindsay Christine Beling Office of Solid Waste (5306-W) One Congress Street Ariel Rios building Suite 1100, SPP 1200 Pennsylvania Ave., NW Boston, MA Washington, DC 20460 (617) 918-1792 (703) 308-7266 [email protected] [email protected]

Regional and State Recycling Organizations

Regional Northeast Recycling Council (NERC) Northeast Resource Recovery Association Mary Ann Remolador, Assistant Director (New England) 139 Main Street, Suite 401 Elizabeth Bedard, Executive Director Brattleboro, VT 05301 NNRC (802) 254-3636 9 Bailey Rd. [email protected] Chichester, NH 03258 603-798-5777 [email protected]

Product Stewardship Institute, Inc. - B2 - FINAL June, 2005 Staples Pilot Project –Final Report to U.S. EPA Appendix B

Gordon McCown, Recycling Specialist NNRC 9 Bailey Rd. Chichester, NH 03258 603-798-5777 [email protected]

Connecticut Connecticut Recyclers Coalition Connecticut River Estuary Regional Planning Winston Averill Agency P.O. Box 4038 Amy Cabaniss Old Lyme, Connecticut, 06371-4038 PO Box 778 860-423-7683 Old Saybrook, CT 06745 (860) 388-3497 [email protected]

Maine Maine Resource Recovery Association Kennebec Valley Council of Governments Victor Horton, Executive Director Sarah Flaks PO Box 1838 17 Main Street Bangor ME 04402-1838 Fairfield, MA 04937 207-942-6772 207-453-4258 [email protected] [email protected]

Massachusetts MassRecycle Municipal Recycling Assistance Coordinators, Jennifer Gitlitz, Executive Director Massachusetts DEP 25 West Street Carolyn Dann Boston, MA 02111 Kema Consulting Group (617) 338-0244 Three Burlington Woods [email protected] Burlington, MA 01803 (781)-273-5700 X298 [email protected]

Kate Gillooly Kathi Mirza City of Boston, DPW DPW One City Hall Plaza 90 Ingell Street Boston, MA 02201 Taunton, MA 02780 (617)-635-4959 (508) 821-9469 [email protected] [email protected]

Product Stewardship Institute, Inc. - B3 - FINAL June, 2005 Staples Pilot Project –Final Report to U.S. EPA Appendix B

Sharon Byrne Kishida Beverly Community Development 191 Cabot Street Beverly, MA 01915 (978) 921-8300 [email protected]

Rhode Island Rhode Island Resource Recovery Association John Trevor 65 Shun Pike Johnston, RI 02919 (401)-942-1430 [email protected]

Local Recycling Contacts in Pilot Store Locations South Portland, ME Bangor, ME Steve Johnson, Director of Public Works Jerry Hughes, Safety Coordinator 42 O’Neil St. 530 Maine Ave South Portland, ME 04106 Bangor, ME 04401 207-767-7635 207-942-0220 [email protected] [email protected]

Brunswick, ME Lewiston, ME Steve MacDonald Rob Stalford, Solid Waste Superintendent 9 Industry Rd. PO Box 479 Brunswick ME 04011 Lewiston, ME 04243 207-725-6654 207-782-4200 [email protected] [email protected]

Biddeford, ME Falmouth, ME Guy Casavant Anthony Hayes, Director of Public Works Public Works Dept 101 Woods Rd. 371 Hill St. Falmouth ME 04105 Biddeford ME 04005 207-781-3919 207-282-1579 [email protected] [email protected]

Product Stewardship Institute, Inc. - B4 - FINAL June, 2005 Staples Pilot Project –Final Report to U.S. EPA Appendix B

Waterville, ME N. Windham, ME Karl Morse Tony Plante Water Public Works Town Manager 6 Wentworth Court 8 School Road Waterville ME 04901 Windham, ME 04062 207-877-7530 [email protected] [email protected]

Woburn, MA Natick, MA Marlene Johnson, Board of Health George Russell, Supervisor of Sanitation 10 Common St. Dept. of Public Works Woburn, MA 01801 75 West St. Natick MA 01760 781-932-4409 508-647-6556 [email protected] [email protected]

Saugus, MA Danvers, MA Lorna Cerbone, Recycling Coordinator Pamela Irwin 298 Central St. 1 Sylvan St Saugus, MA 01906 Danvers, MA 01923 781-231-4145 978-777-0005 X1633 [email protected] [email protected]

Burlington, MA Needham, MA Syamal Chavohri, Superintendent of Public Kristine Charbonneau Works Solid Waste and Recycling 25 Center St 470 Dedham Ave Burlington MA 01803 Needham, MA 02492 781-270-1670 781-455-7548 X220 [email protected] [email protected]

(Somersworth) Dover, NH Rochester, NH Jack Jackman Melodie Esterberg, Public Works Director Department of Public Works or Lisa Clark 1 Government Way 45 Old Dover Rd Somersworth, NH 03878 Rochester NH 03867 603-692-4266 603-332-4096 [email protected] [email protected]

Seabrook, NH Portsmouth, NH John Starkey, Manager of Recycling Silke Psula, Manager of Recycling PO Box 456 Portsmouth Public Works Seaport NH 03874 680 Beverly Hill Rd 603-474-9771 Portsmouth, NH 03801 [email protected] 603-766-1454 [email protected]

Product Stewardship Institute, Inc. - B5 - FINAL June, 2005 Staples Pilot Project –Final Report to U.S. EPA Appendix B

N. Conway, NH Westerly, Rhode Island Eric Meador John Fusaro Department of Public Works Public Works PO Bo131 45 Broad Street Center Conway NH 03818 Westerly, Rhode Island 02891 603-356-2272 (401)—348-2539 [email protected] [email protected]

Old Saybrook, CT New London, CT Larry Bonin Ed Steward 302 Main Street Public Works Old Saybrook, CT 06475 111 Union Street (860) 395-3123 New London, CT 06320 [email protected] (860)-447-5250 [email protected]

Norwich, CT Kenneth Marshall 100 Broadway Norwich, CT 06360 (860) 823-3825 no e-mail

Product Stewardship Institute, Inc. - B6 - FINAL June, 2005 Staples Pilot Project –Final Report to U.S. EPA Appendix C

Appendix C. Standard MOU and Summary of Manufacturer MOUs

Plug-In To eCycling

Agreement between Staples and ______

DRAFT – April 29, 2004

Through this agreement, ______joins with Staples, Inc. to participate in a pilot project for the U.S. EPA Plug-In To eCycling Campaign. The Staples pilot and other eCycling projects are designed to encourage the reuse and recycling of used consumer electronics. ______agrees to assist Staples in covering the costs of processing electronics collected in 2004 from customers at 26 participating retail stores, and from selected Staples commercial and Internet customers. ______total expense for the Staples pilot project will not exceed $10,000.

______Commitments

For the Staples pilot project, ______is committed to taking action in the areas indicated below:

 Pay up to $10,000 for the processing and recycling costs for all ______products brought into the Staples pilot collections in 2004. Actual costs will be billed to ______at the end of the project on a per pound basis by Envirocycle, the pilot project recycling partner.

 Pay for a share of cost for processing “orphan” electronics (those for which the manufacturers is no longer in business or is a non-participant in the Staples pilot project). ______cost share will be determined by the share of equipment brought to the pilot program that is ______products (i.e., if 10% of the equipment coming to the pilot is ______, ______will also pay for 10% of the cost of processing orphan equipment).

Staples Commitments

For the pilot project, Staples is committed to the following actions:

 Assure that all collected electronics are handled and managed in a manner that protects Staples and all partners from liability, and protects human health and the environment;

 Pay for any costs for processing ______products and ______share of orphan electronics that exceed the $10,000 cap established by Staples;

 Promote pilot partners in promotional information associated with the pilot project;

Product Stewardship Institute, Inc. - C1 - FINAL June, 2005 Staples Pilot Project –Final Report to U.S. EPA Appendix C

 Provide ______with an opportunity to review promotional and press material about the program and to participate in any related press or public acknowledgement events;

 Adhere to terms of agreements with ______regarding the use of the ______logo and trademarks;

 Share pilot project results with partners in a report containing non-proprietary cost, logistical, participant, and quantity information.

Dispute Resolution ______and Staples will assume good faith as a general principle for resolving conflicts under the Plug-In To eCycling pilot project. Both parties will endeavor to resolve all matters informally, so as to preserve maximum public confidence in both companies and Plug-In To eCycling.

In the event informal channels do not produce a mutually agreeable resolution to a matter in dispute, either party to this Agreement shall notify the other in writing as to the nature of the dispute, the specific corrective action sought and their intent to terminate the Agreement, either as a whole or in part, unless specific corrective actions sought are undertaken:

 Within 20 days of receiving formal notification from Staples indicating intent to terminate the Agreement, either as a whole or in part, ______will reply, agreeing to either (1) undertake in a timely and effective manner the corrective actions sought by Staples, or (2) terminate the Agreement, either as a whole or in part;

 Within 20 days of receiving formal notification from ______indicating its intent to terminate the Agreement, either as a whole or in part, Staples will reply, either (1) agreeing to undertake in a timely and effective manner the corrective actions sought by ______, or (2) explaining why such corrective actions cannot be undertaken;

 If ______fails to respond within 20 days of receiving formal notification of Staples intent to terminate the Agreement, either as a whole or in part, or if ______responds but does not agree to undertake corrective actions sought by Staples, or if ______agrees but does not initiate the corrective actions in a timely manner, then this agreement is terminated, either as a whole or in part.

Entry into Force and Duration of Agreement Both parties concur that this agreement and the terms outlined in the supporting documents will become effective when signed by both parties and will continue through December 31, 2004, but may be extended if the parties agree to do so in writing.

The undersigned hereby execute this Agreement with Staples, Inc., on behalf of their party. The signatories of this agreement affirm that they have the authority to execute this agreement on behalf of ______and Plug-In To eCycling.

Product Stewardship Institute, Inc. - C2- FINAL June, 2005 Staples Pilot Project –Final Report to U.S. EPA Appendix C

Signatory for STAPLES, INC.: Signature: ______Date: Name: Title: Address: City: State: Zip: Phone: Fax: E-mail:

Signatory for ______: Signature: ______Date: Name: Title: Address: City: State: Zip: Phone: Fax: E-mail:

Product Stewardship Institute, Inc. - C3- FINAL June, 2005 Staples Pilot Project –Final Report to U.S. EPA Appendix C

STAPLES/PSI PILOT COMPUTER TAKE-BACK PROJECT Summary of Manufacturer MOUs March 21, 2005

Date Of Last Agreement Standard Date MOU (If Not Agreement Signed Signed) (Yes/No) Special Aspects Of Agreement

Apple Computer, Inc. May 12, N/A Yes Brian Miller 2004 Corporate Manager, EH&S [email protected] 408-974-7629 (ph)

Brother International Corp. N/A May 26, 2004 Yes Henry Sacco Chief Legal Officer [email protected] (908) 252-3029 (ph)

Dell N/A May 26, 2004 No Pay up to $10,000 for recycling Shari Carle of Dell computers from Sustainable Business Analyst commercial customers only [email protected] (NOT retail). Pay % of non- 512-728-4980 (ph) participants based on Dell’s 512-907-5700 (pager) share coming to facility. Products sorted and transported Mike Watson to one of Dells’ approved Program Manager, recycling partners. Dell Asset Recovery Services [email protected]

Epson America, Inc. June 1, 2004 N/A Yes Shelby Houston Manager, Customer Programs [email protected] 562-290-5445 (ph)

HP N/A Verbal only No Separate out HP products and Renee St. Denis ship to HP. [email protected] 916-785-8034

Intel N/A N/A No Intel gave $2,000 to the Allen Wilson Electronic Industries Alliance Manager, EH&S for the pilot project costs. [email protected] 480-715-2390 (ph)

Product Stewardship Institute, Inc. - C4- FINAL June, 2005 Staples Pilot Project –Final Report to U.S. EPA Appendix C

Date Of Last Agreement Standard Date MOU (If Not Agreement Signed Signed) (Yes/No) Special Aspects Of Agreement

Lexmark International, Inc. N/A May 24, 2004 Yes Tonya Jackson (date of Manager, EH&S December 10, [email protected] 2003, remains 859-232-7925 (ph) on Draft)

Panasonic April 30, N/A Yes Originally did not want to pay David Thompson 2004 for products from non- General Manager participating companies, but [email protected] later allowed this based on the 201-271-3486 (ph) low cost of the pilot

Sharp Electronics Corporation May 5, 2004 N/A No Pay up to $5,000 for recycling Frank Marella of Sharp computers from retail Manager, Corporate and commercial customers. Environmental Affairs MOU did not allow payment for [email protected] a % of non-participants share, 201-529-9408 but later allowed this based on the low cost of the pilot. Sony Electronics, Inc. N/A April 28, Yes MOU stipulated monthly Doug Smith 2004 (dated reports on amount and quantity [email protected] 12/12/03 on of Sony product collected and 858-942-2729 draft MOU) costs incurred, as well as the percentage of Sony product compared to the total product recovered.

Product Stewardship Institute, Inc. - C5- FINAL June, 2005 Staples Pilot Project –Final Report to U.S. EPA Appendix D

Appendix D. Staples/PSI Pilot Project Cost Detail

BRAND-SORTED DATA

Table D1. Brand-Sorted Data -- Monitors

Number Of % Of Total Cost Of Own Cost Of NP Brand Units Pounds* % Of Total Participants Brand** Share Total Cost Apple 465 17,670 28.32% 57.76% $1,860 $1,934 $3,794 HP/Compaq 196 7,448 11.94% 24.35% $784 $815 $1,599 Gateway (NP) 167 6,346 10.17% - - - - IBM (NP) 94 3,572 5.72% - - - - Dell 91 3,458 5.54% 11.30% $364 $378 $742 Sony 33 1,254 2.01% 4.10% $132 $137 $269 Panasonic 10 380 0.61% 1.24% $40 $42 $82 Brother 4 152 0.24% 0.50% $16 $17 $33 Epson 4 152 0.24% 0.50% $16 $17 $33 Sharp 2 76 0.12% 0.25% $8 $8 $16 Other 576 21,888 35.08% - - - TOTAL 1,642 62,396 100% 100% $3,220 $3,348 $6,568

* Average weight for pilot project collection calculated at 38 pounds/unit. ** At project discounted rate of $4.00/monitor. (NP) Non-Participant

Table D2. Brand-Sorted Data -- CPUs

Cost Of Own Brand Number Of Units Pounds* Brand** % Of Total HP/Compaq 217 4,991 $0 20.17% Apple 207 4,761 $0 19.24% Gateway (NP) 145 3,335 $0 13.48% IBM (NP) 84 1,932 $0 7.81% Dell 67 1,541 $0 6.23% Sony 7 161 $0 0.65% Epson 7 161 $0 0.65% Panasonic 3 69 $0 0.28% Brother 0 0 $0 0.00% Sharp 0 0 $0 0.00% Other 339 7,797 $0 31.51% TOTAL 1,076 24,748 $0 100.00%

* Average weight for pilot project collection calculated at 23 pounds/unit. ** No charge for CPUs. (NP) Non-Participant

Product Stewardship Institute, Inc. - D1 - FINAL June, 2005 Staples Pilot Project –Final Report to U.S. EPA Appendix D

Table D3. Brand-Sorted Data -- Printers/Mfds/Fax/Desktop Copiers/Scanners Cost Of Number Of % Of % Of Total Own Cost Of Brand Units Pounds* Total Participants Brand** NP Share Total Cost HP/Compaq 340 2,761 31.22% 50.22% $193.27 $117.59 $310.86 Apple 139 1,129 12.77% 20.53% $79.03 $48.08 $127.11 Epson 130 1,056 11.94% 19.21% $73.92 $44.97 $118.89 Panasonic 57 463 5.24% 8.42% $32.41 $19.72 $52.13 IBM (NP) 10 81 0.92% - - - - Brother 9 73 0.83% 1.33% $5.11 $3.11 $8.22 Sharp 2 16 0.18% 0.29% $1.12 $0.68 $1.80 Dell 0 0 0.00% 0.00% $0 $0.00 $0.00 Sony 0 0 0.00% 0.00% $0 $0.00 $0.00 Gateway (NP) 0 0 0.00% - - - - Other 402 3,264 36.91% - - - - TOTAL 1,089 8,843 100.00% 100.00% $384.86 $234.15 $619.01

* Average weight for pilot project collection calculated at 8.12 pounds/unit. ** At project discounted rate of $0.07/pound. (NP) Non-Participant

Table D4. Brand-Sorted Data -- Laptops, Small Peripherals & Non Computer Equipment*

Monitors % Large Peripherals % Other Equip Est. of Total Of Total % Of Total Est. Number Est. Est. Cost Of Brand Participants Participants Participants Of Units Pounds Own Brand

HP/Compaq 24.35% 50.22% 37.29% 541 7,099 $496.95 Apple 57.76% 20.53% 39.15% 568 7,454 $521.74 Epson 0.50% 19.21% 9.86% 143 1,876 $131.35 Gateway (NP) ------IBM (NP) ------Panasonic 1.24% 8.42% 4.83% 70 920 $64.38 Dell 11.30% 0.00% 5.65% 82 1,076 $75.31 Sony 4.10% 0.00% 2.05% 30 390 $27.32 Brother 0.50% 1.33% 0.92% 13 174 $12.20 Sharp 0.25% 0.29% 0.27% 4 51 $3.60 Other ------TOTAL 100.00% 100.00% 100.00% 1450 19,041 $1,332.85

* Envirocycle conducted brand sorts only on monitors, CPUs, and large peripherals. For those equipment types, each brand’s cost share for non-participants was calculated directly. However, for laptops, small peripherals, and non-computer equipment, PSI averaged the brand shares for monitors and large peripherals and applied that average percentage to the three other categories in which no brand sort occurred. (NP) Non-Participant

Product Stewardship Institute, Inc. - D2- FINAL June, 2005 Staples Pilot Project –Final Report to U.S. EPA Appendix E

Appendix E. Project Summary

Pilot Project to Collect and Recycle Used Computers Using Reverse Distribution Systems: A Partnership Between Staples and the Product Stewardship Institute

Introduction Staples, Inc., an $11.6 billion retail and commercial seller of a wide range of office products, including supplies, technology, furniture, and business services, has partnered with the Product Stewardship Institute (PSI) to launch a program to measure the success of retail-based electronics recycling. PSI is a national organization that seeks to reduce the health and environmental impacts from consumer products.

In this pilot project, Staples will collect and recycle used computers, peripherals and office equipment from its customers. The project will provide a model for other retailers and will be a shared responsibility partnership between Staples, its suppliers, manufacturers, and key program partners. The goal of the pilot is to create a sustainable business model for long-term electronics collection and recycling.

Pilot Area PSI will collect data from Staples’ retail and delivery operations. The project will include 26 collections at retail stores in the Dayville, CT distribution network; 24 collections from corporate customers surrounding the Putnam, CT warehouse; and 24 collections from Internet or catalog customers serviced by its North Reading or Sharon, MA delivery hub.

Partners Retail:  Staples, Inc. Government:  Massachusetts Department of Environmental Protection  Connecticut Department of Environmental Protection  EPA Region 1 Manufacturers:  Established Staples’ computer suppliers  Other manufacturers (based on returns) Organizations:  Product Stewardship Institute  WasteCap of Massachusetts  Local and national environmental organizations

Product Stewardship Institute, Inc. - E1 - FINAL June, 2005 Staples Pilot Project –Final Report to U.S. EPA Appendix E

Program Description Project partners will test and measure reverse distribution as a unique strategy for transporting old computers and other business equipment from consumers to recyclers. Partners will calculate the real costs of collecting and managing end-of-life electronics through the same channels that provide new products to consumers. PSI will compile and evaluate data, assess the potential to expand this program nationwide, and tie these findings into the developing nationwide collection and recycling system. If reverse distribution proves to be an efficient system, it could result in significant cost reductions for a national electronics program.

Contributions Staples will use its labor, transportation equipment, and storage capacity for this pilot project. Manufacturers that participate in the pilot will be asked to share the costs of transporting used electronics from consolidation points to the recycler, as well as a share of the recycling costs. Local and state government agencies in the pilot collection areas will be involved in designing the project, promoting the collections, and providing technical assistance and regulatory guidance regarding the handling of collected materials.

Contacts Mark Buckley Scott Cassel Vice President, Environmental Affairs Director, Product Stewardship Institute Staples, Inc. Kitson Hall, Room 200 500 Staples Drive One University Avenue Framingham, MA 01702 Lowell, MA 01854 508-253-0510 (978) 934-4855 [email protected] [email protected]

Product Stewardship Institute, Inc. - E2- FINAL June, 2005 Staples Pilot Project –Final Report to U.S. EPA Appendix F

Appendix F. Staples Retail Collection List

Staples Store Address Phone MA Brighton, MA 1660/1670 Soldiers Field Rd. 617-254-4822 Danvers, MA 301 Newbury Street, Danvers Plaza 978-777-9400 Danvers, MA 230 Independence Way, Liberty Tree Mall 978-762-0152 Natick, MA 881 Worcester Road 508-655-0811 Needham, MA 163 Highland Ave. 781-449-5766 Revere, MA 151 VFW Parkway 781-289-8950 Saugus, MA 444 Broadway (Rt 1), Martignetti Center 781-231-6860 Woburn, MA 335 Washington Street 781-932-4132 ME Bangor, ME 1131 Union St., Airport Mall 207-941-2182 Bangor, ME 180 Bangor Mall Blvd. 207-947-9225 Biddeford, ME 420 A Alfred Rd., 5 Point Shopping Center 207-284-7543 Brunswick, ME Route 24 - Bath Road 207-725-2741 Falmouth, ME 244B US Route 1 207-781-2255 N. Windham, ME 770 Roosevelt Trail 207-892-1740 Lewiston, ME 855 Lisbon Street 207-753-0742 Rockland, ME 235 Camden St. 207-596-5696 South Portland, ME 443 Western Avenue 207-871-9148 Waterville, ME 40 Waterville Commons Drive 207-873-4092 NH North Conway, NH 1739 White Mountain Highway 603-356-2666 Portsmouth, NH 1981 Woodbury Ave and Gosling Rd 603-431-3527 Rochester, NH 106 Milton Rd. 603-332-4421 Seabrook, NH 536 Lafayette Road 603-474-8511 Somersworth (Dover), NH 249 Indian Brook Drive 603-750-0078 CT New London, CT 292 US Rte. 1 860-439-1872 Norwich, CT 45 Salem Turnpike 860-886-8870 Old Saybrook, CT 1000 Boston Post Road 860-395-2980 RI Westerly, RI 16 Post Road 401-348-4900

Product Stewardship Institute, Inc. - F1 - FINAL June, 2005 Staples Pilot Project –Final Report to U.S. EPA Appendix G

Appendix G. Criteria for Selection of Retail Stores and Businesses for Pilot Project

Criteria for Selection of Retail Stores for Pilot Project Criteria Application Population density Select stores in areas of population concentration (urban) and population dispersion (suburban/rural) to simulate average population density. Population in pilot areas will be compared to collection participation to determine participation/capita. Electronics retailer density Select stores in areas where there are several other electronics retailers and areas where Staples is the only, or predominant, electronics retailer. This is intended to simulate areas of high and low computer usage. Availability of existing Select stores in areas where other electronics collections may have electronics collection already addressed a large percentage of historic (outdated, unusable) programs computers as well as areas where no collections have been offered. State CRT management Select stores in states where CRTs may be banned from disposal as solid regulations waste, and states where households and small businesses are allowed to dispose of CRTs as solid waste. Distance from store to Select stores at various distances from distribution centers to enable distribution center average costs for transportation to be calculated in the pilot.

Criteria for Selection of Businesses for Pilot Project Criteria Application

Variety of business sizes Select business operations relying on multiple computers and those with and sectors only a few computers. Regulatory status Select businesses considered “generators” of hazardous or universal waste and those that are not be regulated as generators. Availability of existing Select businesses in areas with electronics collection services and those electronics collection with no available collection. programs State CRT management Select stores in states where CRTs may be banned from disposal as solid regulations waste, and states where small businesses are allowed to dispose of CRTs as solid waste. Distance from store to Select businesses at various distances from the fulfillment center to fulfillment center enable average costs for transportation to be calculated in the pilot.

Product Stewardship Institute, Inc. - G1 - FINAL June, 2005 Staples Pilot Project –Final Report to U.S. EPA Appendix H

Appendix H. Staples Contract Collection List

Company Address City State Zip

Rogers Corp One Technology Drive Rogers CT 06263 Barnes 80 Scott Swamp Road Farmington CT 06032 Verispan 460 Totten Pond Road Waltham MA 02451 Riso, Inc. 380 Boston Street Topsfield MA 01983 Mykrolis 129 Concord Road Billerica MA 01821 206 Newbury Street 3rd Stride Associates Boston MA 02116 Floor Safety Insurance 20 Customhouse St Boston MA 02110 Todd Weld 28 State Street Boston MA 02109 Charles River Associates 200 Clarendon Street Boston MA 02116 DRS Power and Control 21 South Street Danbury MA 06810 Zoots 27 Needham Street Newton MA 02461 Texas Instruments 34 Forest Street Attleboro MA 02703 Delta Education 80 Northwest Blvd. Nashua NH 03063 Freudenerg NOK 450 Pleasant Street Bristol NH 03222

Product Stewardship Institute, Inc. - H2 - FINAL June, 2005 Staples Pilot Project –Final Report to U.S. EPA Appendix I

Appendix I. Retail and Commercial Electronics Drop-off Forms

Retail Store Electronics Drop-off Form

Date: / / 2005 Staples store location: Your information: Zip (required): ______Name (optional): ______Street(optional): City (optional): Telephone (optional): (_____) ______E-mail (optional): Electronics being dropped off for recycling (please list all items): Manufacturer (Apple, Brother, Canon, Dell, Epson, Hewlett Packard, Type of Electronics Intel, Lexmark, Panasonic, (Laptop, CPU Desktop, flat panel monitor, CRT monitor, Approximate Sharp, Sony, etc.) printer, scanner, mouse, keyboard, speakers, etc.) Age Quantity

Is this equipment from:  Your home  A business Was this equipment:  Being used on your desktop  Being stored for recycling or disposal Would you be willing to pay a nominal $10 fee to recycle your electronics in the future?  Yes  No How did you hear about this program?  Store flyer  Store display  Other: ______

For more information about this program, please contact Mark Buckley, VP for Environmental Affairs, Staples, Inc., (508) 253-0510 or [email protected]

For internal use only: Mail these forms weekly to Betty Pratt, Staples, Inc., 500 Staples Drive, Framingham, MA 01702

Product Stewardship Institute, Inc. - I1 - FINAL June, 2005 Staples Pilot Project –Final Report to U.S. EPA Appendix I

Commercial Electronics Drop-off Form

Date: / / 2005 Staples store location: Your information: Business Name: ______Contact Person: Street(optional): City: Zip: Telephone: (___) ______E-mail: Electronics being dropped off for recycling (please list all items): Manufacturer (Apple, Brother, Canon, Dell, Epson, Hewlett Packard, Type of Electronics Intel, Lexmark, Panasonic, (Laptop, CPU Desktop, flat panel monitor, CRT monitor, Approximate Sharp, Sony, etc.) printer, scanner, mouse, keyboard, speakers, etc.) Age Quantity

For more information about this program, please contact Mark Buckley, VP for Environmental Affairs, Staples, Inc., (508) 253-0510 or [email protected]

For internal use only: Mail these forms weekly to Betty Pratt, Staples, Inc., 500 Staples Drive, Framingham, MA 01702

Product Stewardship Institute, Inc. - I2 - FINAL June, 2005 Staples Pilot Project –Final Report to U.S. EPA Appendix J

Appendix J. Staples Store Communications Package

Store Communications Package

Project Overview A) Staples is sponsoring a (6) week recycling event in partnership with the US, EPA Plug into e-Cycling Program and the Product Stewardship Institute to encourage local customers to recycle their computers, monitors and business machines at their local Staples locations beginning Sunday, May 30 and ending Sunday, July 11th. Retail, SBD and select SBA customers will also participate in the event. The objectives of this pilot are to: . Help create a solution for our customers to address the mounting global issues surrounding proper disposal of electronic waste. . Highlight the Staples “makes it east to make a difference”. . Determine whether this model might become a viable part of our business in the future. Customers will bring back their equipment to the store, fill out a recycling form (see attachment #1) at the service deck and we will place the equipment into a cardboard Gaylord and collect the recycling form from the customer. When the Gaylord is full the material will be backhauled to Killingly, CT, consolidated and then shipped to the recycler (Envirocycle). B) Product/Limitations: Recyclable products for this event will be limited to the types of machines, which we sell i.e. CPUs, monitors, keyboards, mice, printers, scanners, faxes etc. No TVs, stereo systems etc. We will obviously encourage customers to utilize Staples every day recycling services for items such as inkjet and toner cartridges, cellular phones, PDAs, chargers and rechargeable batteries. We also will suggest that we limit recycling to (1) “system” per customer per store per day. Loosely defined a system would include a CPU, monitor, keyboard, mouse and printer and scanner. Obviously we will leave quantities up to your discretion. We are trying to avoid local recyclers and others from using the store as a “dump site” for large quantities of materials and over burden the store. For example, a customer bringing in (2) units is different than someone trying to bring a “truck load” of computers to the store. C) Alternative Recycling Options and Contacts: In the event that a recycler is interested in recycling more than the predetermined limit or more than your store can handle, please provide the person(s) with the following contact information Mike Tallon, Environcycle (570) 879-2862 xt 214 and he will assist them in recycling their items through a more appropriate channel. Please explain that stores are not equipped to receive large numbers of machines due to space and logistical constraints. Should your customer have any additional questions please do not hesitate to contact Mark Buckley at (508) 253-0510 or page him at (888) 405-8977. D) Recycle Process Retail: Step 1: Recycler enters the store and approaches the recycling area to drop off items. Step 2: Associate greets customer and provides them with Staples e-cycling form (attachment #1) to gather basic information. E) Store Layout and Material Handling: To collect materials for this event each store participating in the pilot will receive (6) Gaylord’s, that will be forced out of Killingly the week prior to May 30. These are the same 4x4x4 collapsible containers used to collect and recycle mixed paper at the store. These can be reordered as a store supply on the AS400 Sku# 492935. The gaylord’s will be positioned in the cart corral area in the store where carts are normally stored for the 6- week event. Please note that the location will vary based on store layout. Please refer to the attached front-end

Product Stewardship Institute, Inc. - J1 - FINAL June, 2005 Staples Pilot Project –Final Report to U.S. EPA Appendix J

drawings for Heartland Concept, Dover I and Dover II store locations. The collapsible Gaylord should be set up on a pallet in the designated area and a sign clipped onto the exterior per the sign kit instructions, which you will receive with the sign packages. For your particular store layout type please refer to attachments 2,3,4 and 5. When customer return equipment, place the equipment in the Gaylord carefully and place monitors with screens facing away from each other to avoid glass shattering during transit. Equipment can be co-mingled in the Gaylord. Please place a layer of old corrugated cardboard between each layer of equipment. Equipment can be stocked to the top of the Gaylord, but no higher for transit to Killingly and on to the recycler. Each store will also receive a vinyl banner for the exterior of the store (see attachment #6) and a sign for the gaylord container (see attachment #7). Stores’ will receive the copy of the bagstuffer (see attachment #8). F) Logistics: Stores can send less than two pallet quantities of materials back on their normal backhaul. More than two pallet quantities must be scheduled through the transportation department. All recycling forms must be mailed weekly to Betty Pratt, Staples, Inc., 500 Staples Dr., Framingham, MA 01702. G) Frequently asked questions: 1. What happens to this equipment? Staples is working with Envirocycle a certified recycler in Hallstead, PA. Envirocycle initially assesses equipment to determine if there is any value in refurbishing it or utilizing parts. The remaining components and equipment is then broken down into their base materials metals, glass and plastics. This material is then reused in the manufacturing of other products. 2. Why is recycling electronics so important? Due to the increased purchase and use of technology items there is a growing global problem associated with the safe disposal of these materials. 3. What are the environmental problems associated with improper electronic disposal? Electronic equipment and their components contain many heavy metals and toxins, which if disposed of improperly in landfills or incinerated contribute to contamination of water supplies and air. The effects of these materials can be cumulative in ecosystems. One computer monitor alone contains between 6-8 lbs of lead. 4. Where do the recycled materials go? Does any equipment get shipped overseas? No, Envirocycle maintains a strong chain or custody for these materials and all stay domestically. 5. Can we donate some equipment to local school or other organizations? No, for this project Staples needs to maintain very strict control of these materials and we cannot donate these at this time. 6. I’d like to recycle more items, how can I do that? The attractiveness and ease of the event make this a fantastic opportunity to recycle computers, monitors and other equipment. In order to meet the high demand of recycling products, Staples is asking that customers limit their recycling activity to one “system” per store per day. Customers are encouraged to visit multiple stores or return to the same store on different days. The event lasts for (6) weeks. 7. Where can I learn more about Staples and its commitment to the environment? Staples is committed to protecting our natural resources, through focus on environmental stewardship. Visit www.staples.com/recycle for more information about Staples recycled products, environmental commitment and mission, plus fun and interesting facts about recycling. 8. Who should I call if I have more questions? Mark Buckley (508) 253-0580 [email protected]

Product Stewardship Institute, Inc. - J2 - FINAL June, 2005 Staples Pilot Project –Final Report to U.S. EPA Appendix J

Figure 1. Banner

Figure 2. Flyer

Product Stewardship Institute, Inc. - J3 - FINAL June, 2005 Staples Pilot Project –Final Report to U.S. EPA Appendix K

Appendix K. Calendar Listing – Promotional Announcement

ATTN: Calendar Editors Calendar Listing June 8, 2004

Staples Launches Electronics Recycling Program at 27 New England Store Locations

What: Staples Electronics Recycling Program

When: June – July 11 during regular store hours

Where: 27 Staples store locations (see list attached)

Details:

Staples is kicking off an Electronics Recycling Program at 27 New England-area store locations to provide an easy way to recycle used desktop computers, monitors and business machines. The [town name] Staples store is participating. Staples is collaborating on the program with U.S. EPA’s Plug-In To eCycling program and the Product Stewardship Institute at UMass Lowell.

The recycling program encourages local Staples customers to bring in used equipment to participating Staples locations today through Sunday, July 11. Recyclable items are computer hardware and business machines--printers, copiers, scanners, faxes--sold by Staples (no TVs or radios). Companies supporting the program are: Apple, Brother International Corporation, Dell, Epson America, HP, Lexmark, Panasonic, Sharp and Sony.

Unused electronics, or e-waste, is among the fastest growing waste streams due to growing sales and rapid obsolescence of these products. Personal computers can pose significant environmental and human health threats if improperly disposed. These products often contain lead and mercury, among other potential health hazards.

Staples will send the collected items to Envirocycle, an electronics recycling company. With 15 years in electronics recycling, Envirocycle is one of the largest recyclers of electronic equipment and CRT glass. (www.enviroinc.com)

About EPA’s Plug-In To eCycling program:

www.epa.gov/epaoswer/osw/conserve/plugin/

About the Product Stewardship Institute:

http://www.productstewardship.us/

(more)

Product Stewardship Institute, Inc. - K1 - FINAL June, 2005 Staples Pilot Project –Final Report to U.S. EPA Appendix K

Staples – Electronics Recycling Program

Staples Store Address Phone MA Brighton, MA 1660/1670 Soldiers Field Rd. 617-254-4822 Burlington, MA 111 Middlesex Turnpike 781-221-4610 Danvers, MA 301 Newbury Street, Danvers Plaza 978-777-9400 Danvers, MA 230 Independence Way, Liberty Tree Mall 978-762-0152 Natick, MA 881 Worcester Road 508-655-0811 Needham, MA 163 Highland Ave. 781-449-5766 Saugus, MA 444 Broadway (Rt 1), Martignetti Center 781-231-6860 Woburn, MA 335 Washington Street 781-932-4132 ME Bangor, ME 1131 Union St., Airport Mall 207-941-2182 Bangor, ME 180 Bangor Mall Blvd. 207-947-9225 Biddeford, ME 420 A Alfred Rd., 5 Point Shopping Center 207-284-7543 Brunswick, ME Route 24 - Bath Road 207-725-2741 Falmouth, ME 244B US Route 1 207-781-2255 N. Windham, ME 770 Roosevelt Trail 207-892-1740 Lewiston, ME 855 Lisbon Street 207-753-0742 Rockland, ME 235 Camden St. 207-596-5696 South Portland, ME 443 Western Avenue 207-871-9148 Waterville, ME 40 Waterville Commons Drive 207-873-4092 NH North Conway, NH 1739 White Mountain Highway 603-356-2666 Portsmouth, NH 1981 Woodbury Ave and Gosling Rd 603-431-3527 Rochester, NH 106 Milton Rd. 603-332-4421 Seabrook, NH 536 Lafayette Road 603-474-8511 Somersworth (Dover), NH 249 Indian Brook Drive 603-750-0078 CT New London, CT 292 US Rte. 1 860-439-1872 Norwich, CT 45 Salem Turnpike 860-886-8870 Old Saybrook, CT 1000 Boston Post Road 860-395-2980 RI Westerly, RI 16 Post Road 401-348-4900

Staples Contact: Owen Davis 508-253-8468 [email protected]

Product Stewardship Institute, Inc. - K2 - FINAL June, 2005 Staples Pilot Project –Final Report to U.S. EPA Appendix L

Appendix L. Natick Bulletin & Tab Article on Pilot Project

July 2, 2004

NATICK BULLETIN & TAB Businesses need to play a recycling role. By Philip Maddocks

Since June, 27 Staples stores in the Northeast, including the store located on Rte. 9 in Natick, have allowed customers to discard used computers, computer “peripherals” (such as keyboards, mice, and speakers), printers, scanners, fax machines, and desktop copiers at the locations during store hours at no cost.

The used electronics are then transported by Staples to store distribution centers where they are shipped off to Envirocycle in Hallstead, Pa. The products are dismantled and the materials are sold for reuse in making new products.

The U.S. Environmental Protection Agency is hoping the Staples program, which runs through July 11, will help lead to a consolidated electronics disposal program involving the private sector and public agencies.

The Product Stewardship Institute, located at the University of Massachusetts, Lowell - which is collaborating on the Staples pilot program along with the EPA’s Plug-In to eCycling program and a number of electronics manufacturers - argues it is essential to involve manufacturers in the disposal process because state and local governments have neither the existing collection and recycling infrastructure, nor the necessary funds to properly manage electronics, which are generally manufactured with components that contain toxic substances, including lead, mercury, cadmium, lithium, brominated flame retardants, and phosphorous coatings.

“I think the area of [business] responsibility is emerging as the issue in solid waste management, at least in the coming decade,” said Scott Cassel, the director of the Product Stewardship Institute or PSI, which was formed in 1990 as a partnership between the state’s Executive Office of Environmental Affairs and the University of Massachusetts. “Right now the entire burden is on the state and local agencies to collect, recycle and dispose all the waste products. There needs to be a shared responsibility for these products. It only makes sense.”

“Ideally what the state and Product Institute are looking for from the manufacturers is some sort of financial assistance,” said Greg Cooper, the director for consumer programs at the Massachusetts Department of Environmental Protection. “I would at least hope in Massachusetts that assistance to municipalities would be a component of any system.”

Cassel said there are a number of companies within each product sector that have jumped out in front and recognized that because they are making the products, or because they have a roll in selling the products, they are playing a role in ultimately introducing the product into the waste stream.

Thus, they should also play a role in taking care that the product is properly disposed of.

Product Stewardship Institute, Inc. - L1 - FINAL June, 2005 Staples Pilot Project –Final Report to U.S. EPA Appendix L

Disposal of electronics is among the top waste concerns for communities and states, said Cassel.

“The toxicity, the proliferation of the products, their built-in obsolescence - there are a number of reasons why electronics is one of the top issues,” he said, adding that a particular concern is the mercury that is a component in computers.

While there is agreement that a comprehensive and safe program for collecting old electronics is needed, Cassel said the issue of who pays for it has been the topic of over two years of discussion through the National Electronics Product Stewardship Initiative.

At an “electronics dialogue meeting held in Portland, Ore. in February, and that included representatives from Dell, Epson, Hewlett-Packard, Panasonic, and Sharp, the participants drafted a resolution that commits electronics manufacturers to develop a sustainable financing system that would relieve the financial burden from state and local government agencies, though the group was still divided about which means to follow.

Some companies favor a system that is financed with a visible fee at the point of sale, much like the current bottle bill.

Other companies want a system that will allow them to incorporate the cost into the price they charge.

According to a PSI newsletter, the current system under consideration features a little of both ideas. The plan, which would be enacted through federal legislation, would start with an advanced recycling fee for the first seven years that would be paid into an industry-managed fund. At the end of the seven-year period, the manufacturers would internalize a significant share of collection, transportation, and recycling costs.

Some manufacturers, however, want to internalize costs at the start of the program and sell their products without a fee.

“Right now we’re waiting for the manufacturers to come back with an agreement they can all live with,” Cassel said. “They have been divided as an industry. The government, I believe, has been flexible.”

The government has also provided some of the motivation for businesses to police themselves. As the Electronic Industries Alliance, a partnership of electronic and high-tech associations and companies, states on its Web site, “a growing number of nations and states are considering legislation and regulations, which would severely impact the ability of the electronics industry to ship and sell its products globally. The industry’s overall goal is simple: to proactively develop programs to reduce the environmental impacts of the industry’s manufacturing processes and products throughout their entire life cycle - from design through use to end of life.”

Staples spokesman Owen Davis said the company’s pilot electronic recycling program is part of Staples’ environmental commitment and its ongoing effort to make product recycling easier for its customers.

Davis pointed out the company already accepts drop-offs of used printer ink cartridges, cell phones, pagers, and personal digital assistants (frequently referred to as PDAs).

Customers drop the items in a vertical tube located in the stores and Staples sends the devices to CollectiveGood in Tucker, Ga., where the phones are either refurbished for reuse throughout the Caribbean, Latin America, Eastern Europe and India or broken down to its parts for recycling.

Product Stewardship Institute, Inc. - L2 - FINAL June, 2005 Staples Pilot Project –Final Report to U.S. EPA Appendix L

Davis said the collection of larger consumer electronics such as computers, printers, and fax machines, because of the bulk of the equipment, poses more of a challenge for the stores.

“We’re looking for some lessons,” he said of the pilot program. “We’re trying to learn how to best offer this.”

“We certainly recognize there are a large number of these items that aren’t being used by people,” he added. “The question is, what do I do with this?

From our experience, people have this type of equipment lying around and are waiting for the day when it will be easy to recycle.”

Davis said it was still too early to sort out the number of computers and large business machines that had been turned into Staples stores in the Northeast since the pilot project began in June, he did add, “We are please so far with the participation.”

Dell Computer, one of the company’s participating in the pilot program run at Staples, also offers computer recycling through its own business.

Through Dell, consumers can donate their computers to the National Cristina Foundation to help disabled and economically disadvantaged children and adults in your own community. The foundation will pick up your computer at the customer’s residence.

The company will also pick up any brand of computer or computer peripheral.

The cost is $15 per 50 pounds. Since a personal computer generally weighs about 30 pounds, according to Dell, and a computer monitor weighs 42lb, the total cost of having a computer and monitor picked up by Dell for recycling would cost $30.

The town of Natick considers computers and computer monitors bulky waste.

The town will pickup bulky waste items two Saturdays a month for a minimum of $25 each. Payment in either cash or check for the appropriate quoted amount must be mailed or delivered to the Department of Public Works on or prior to the Thursday before the Saturday pickup. Pickup dates for each month are available by calling the Department of Public Works or the Sanitation Division.

Dell has also taken measures in the manufacture of its computers that it claims are environmentally beneficial.

In its Dell Sustainability Report 2004, the company states that the energy-saving component in its OptiPlex GX270 and SX270 systems alone “is estimated to reduce carbon dioxide emissions by over 700,000 tons per year.

The company also states in the report that the more expensive, space-saving flat-screen monitors that employ a cold cathode fluorescent lamp to illuminate the display panel, and which many customers are trading up to, are considerably more environmentally-friendly that the cathode ray tube monitors.

According to the report, the flat-screen monitors contain “only a few grams of lead in the solder” and use about 54 percent less energy than CRT monitors.

Product Stewardship Institute, Inc. - L3 - FINAL June, 2005 Staples Pilot Project –Final Report to U.S. EPA Appendix L

Dell’s plans for the future include shrinking the size of its desktop computers. Last year the company launched what it calls its “Ultra Small Form Factor” chassis, which, at approximately 10 x 10 x 31/2 inches, has about 20 percent of the volume of the typical mini-tower design.

It’s goal for the end of the year is to make desktop computer, portable computer, and server chassis plastic parts that are “free of halogenated flame retardants.”

Cassel said while the concept of product makers taking a role in the ultimate disposal or recycling of the goods they make is not that new, the term product stewardship has only taken hold in the last four years or so.

He thinks it signifies a change in attitude among business leaders.

“We need to do things differently, in a much clearer fashion,” he said.

“There is an understanding that manufacturers, state, and local agencies need to share the responsibility. Many are stepping up to the plate, like Staples.”

Cassel said it was Staples that initiated the idea for the current pilot program it is running at their Northeast stores and it should offer valuable lessons about what Cassel refers to as a reverse distribution system.

As for product stewardship, he says, “Many companies are catching on that this a new trend that will last.”

Product Stewardship Institute, Inc. - L4 - FINAL June, 2005 Staples Pilot Project –Final Report to U.S. EPA Appendix M

Appendix M. Reviewing Electronics Recyclers

--- DOCUMENT FOR STAPLES, INC. ---

Company: Company representative(s): Who interviewed: Date: ______

A. GENERAL COMPANY INFORMATION

1. What kind of company are they?  Broker - Brokers are companies that arrange for the electronics recycling Yes  No  services. If you use a broker, you must document all the downstream facilities that handle the equipment. Remember that a “Certificate of Recycling”provides no assurance that materials are being safely handled.  Reseller - Resellers triage to sort out saleable units from scrap, to erase hard Yes  No  drives, and to prepare equipment for resale. Many resellers are not interested in processing scrap for recycling and ship all non-saleable scrap to processors or brokers. The environmental audit process must continue downstream to determine how the scrap is being managed.  Demanufacturers – These facilities usually sort commodities and Yes  No  hazardous components using disassembly. Shredding systems might only reduce volume for transportation efficiencies or may include systems to separate different types of metallic and nonmetallic materials. Unless the recycler also processes batteries, mercury, leaded glass and all other hazardous materials, the audit process must still be continued downstream. 2. Can they give a general description of their business? Yes  No  This type of information may include:  Point of contact  Number of employees  Years in business and ownership history  Facility site information and history  Summary of operations and services offered A qualifications statement would be an adequate alternative to requesting individual types of information. 3. Do they process non-saleable equipment and components by breaking Yes  No  down or shredding? If not:  Are whole components outsourced or exported? If so, where are the markets for the electronic equipment?  What process does the downstream vendor employ?  Has the company done due diligence and can provide documentation on downstream facilities?  Are permits required?  How are residuals managed? ______

Product Stewardship Institute, Inc. - M1 - FINAL June, 2005 Staples Pilot Project –Final Report to U.S. EPA Appendix M

4. What type of products do they accept? (Later we need them to provide pricing for each type of equipment. We should specify if we want fees quoted on a per pound or per product basis.) Computers and peripherals Telephones, communications  Monitors  Conference phones  Desktop CPUs  Corded phones  LCD displays – laptops  Cordless phones  Notebook computers  Answering machines  CD drives  Pagers  Hard drives Miscellaneous  Zip drives  Pocket PCs  Cables (computers, etc.)  Data cartridges  DVD drives  Battery back-ups/UPS  Floppy drives  PC and digital cameras  Printers  Digital pens  Speakers  Joysticks Other office equipment  Game pads  Faxes  Remotes  Multifunction machines  PC cameras  Scanners  Copiers  Projectors/AV equipment 5. What services do they provide?  Brand sorting  Sort equipment for reuse to non-profit  Hard drive erasure/data destruction  Product tracking through final fate of materials  Other? ______

B. COMPLIANCE WITH FEDERAL, STATE, AND LOCAL ENVIRONMENTAL LAWS TO SAFEGUARD OCCUPATIONAL AND ENVIRONMENTAL HEALTH AND SAFETY. 1. Does the company have an EPA ID number? Yes  No  An EPA ID number only indicates that the company has registered with EPA as a waste generator. It is not a permit or a certification and EPA does not certify or approve electronics recyclers. 2. Can they provide information on the company’s compliance history? Yes  No  This type of information is available from the state regulatory agency or the federal EPA regional contact for RCRA compliance. Examples may include:  Summary of federal, state EPA, or other governmental agency inquiries and enforcement actions during the past three years.  Material reports to government agencies from the past three years

Product Stewardship Institute, Inc. - M2 - FINAL June, 2005 Staples Pilot Project –Final Report to U.S. EPA Appendix M

3. Can they offer evidence of proper permits? Yes  No  These permits may be environmental or business/operations oriented. Permit requirements vary state to state. The size and scope of the service provider will affect permit requirements as well. Permits might include:  Air permit  Storm water permit  Solid Waste permit  Business permit  Zoning permit  Transportation/licensure 4. Can they provide evidence of an environmental management system Yes  No  (EMS), an environmental risk management plan or electronic recycling certification? An EMS system or certification is not a guarantee of high environmental standards, but should be in place in all larger companies.  ISO 14000  EMAS (European Eco-Management and Audit Scheme)  IAER (International Association of Electronic Recyclers)  Recyclers Pledge of True Stewardship  Other?______5. Do they have a hazardous materials management plan? Yes  No  A service provider should have an operating plan in place that will ensure that all hazardous constituents are managed and ultimately recycled in a manner that prevents releases of hazardous constituents into the environment. 6. Do they meet OSHA requirements? Yes  No  OSHA requirements will vary between facilities. Check all for they provided evidence:  List of applicable OSHA mandates  Summary of OSHA inquiries for past 3 years including health hazard evaluations  Full OSHA citation history  Training records and written programs required by OSHA standards 7. Is there a trained Environment Heath and Safety supervisor on site? Yes  No  A trained EHS supervisor will often perform informal and formal inspections, procure needed safety equipment, and address EHS reporting requirements. A smaller company may not have a supervisor on site, but should have an employee assigned to this task.

Product Stewardship Institute, Inc. - M3 - FINAL June, 2005 Staples Pilot Project –Final Report to U.S. EPA Appendix M

C. DOCUMENTATION REGARDING END-USE MARKETS. 1. Can the company provide a detailed description of its processes? Yes  No   Demanufacturing  Reuse/Resale/Donations  Storage  Secure destruction  Send materials to a metals reclamation plant or smelter  Process the plastic, metal and glass and ship these to other companies for use in production of recycled products  Products manufactured 2. Does the company have a complete list of end-markets for materials? Yes  No  The company should be able to state where it sends commodity materials or product streams including:  CRTs  Plastics  Metals (steel, aluminum, copper)  Circuit Boards  Hazardous materials  Solid waste materials 3. Do they audit their end-markets? Yes  No  Smaller recyclers may not have the ability to perform an on-site audit of its end markets. However, all recyclers should be able to evidence some level of information regarding the capacity of its markets. In general, the facility should be maintaining records or documentation showing that materials are being properly managed. 4. How much of equipment received do they send for disposal in landfills or for incineration? Electronic products contain hazardous constituents. Television and computer CRTs have significant amounts of lead, chromium, nickel and zinc. Printed circuit boards contain small amounts of cadmium, nickel and other heavy metals. 5. If donated, can they supply you with documentation so that you can Yes  No  apply it towards your federal tax return?

6. Can they provide a complete inventory of equipment sent to be recycled, Yes  No  including property tags? Do they provide a certificate indicating when material was received and how it was processed? This information is important for tax records and for any potential liability claims.

Product Stewardship Institute, Inc. - M4 - FINAL June, 2005 Staples Pilot Project –Final Report to U.S. EPA Appendix M

7. Do they export or broker for export used equipment? If so, can they Yes  No  provide evidence that they are in compliance with notice and consent procedures specified under international laws and bilateral agreements? Countries that are part of the Organization for Economic Cooperation and Development (OECD, www.oecd.org) have agreed to control exports and to protect from the indiscriminate and uncontrolled traffic in hazardous wastes that are exported to developing countries. These controls dictate high standards for environmental management that involve costs that must be passed along to customers. Some U.S. companies export scrap material to less-developed countries, where lower labor costs contribute to lower processing costs. However, the receiving country may also have less protective environmental standards. Companies that export should at least export only to OECD countries or comply with OECD laws and agreements for the export of hazardous materials found in electronics.

D. OTHER STAPLES CONCERNS 1. Is the company willing to adapt its processes to accommodate Staples Yes  No  concerns? Examples of concerns include:  Greater emphasis on reuse – equipment sent to World Computer Exchange or other designated recipient (Staples should designate whether low cost or no cost)  No exporting – directly or indirectly through downstream markets - - to less-developed countries  No use of prison labor

E. RISK MANAGEMENT 1. Do they have environmental liability protection? Yes  No  They should be able to provide a schedule or copy of its insurance policy and indicate the amount of insurance coverage. 2. Do they have General Liability Insurance? How much coverage? Yes  No  They should be able to provide a schedule or copy of the insurance policy and indicate the amount of insurance coverage. 3. Do they have other types of insurance? Yes  No  They should be able to provide a schedule or copy of the insurance policy and indicate the amount of insurance coverage. 4. Do they have financial assurance e.g. bonding? Yes  No  Depending on the size and scope of the company, this question may not be applicable to all recovery facilities

Product Stewardship Institute, Inc. - M5 - FINAL June, 2005 Staples Pilot Project –Final Report to U.S. EPA Appendix M

F. DISCLOSURE VERIFICATION 1. Can they verify that their responses to your questions are Yes  No  accurate through an independent verification process or through documentation?

G. CONDUCTING THE SITE AUDIT Ask to see the shipping docks and containers. This may require a walk around the outside of the facility where shipping containers are stored. Check trash containers to see if any scrap electronic components are being sent to landfill.

Look for shipping containers designed for export. These look quite different from a typical road trailer in that they are entirely made of steel and sit on a flatbed trailer. Overseas shipping containers have doors that seal tightly with a rubber gasket, and it is apparent that the container is detachable from the trailer.

Within the facility look for indications of how outbound material is shipped. If you see only baled or unprocessed scrap, it is likely that it is being exported to developing countries. Recovery of material prepared this way would not be economical in most OECD countries.

Ask the recycler how many pounds of electronics are processed on a monthly basis. Then ask to see documentation showing resale activities and scrap shipments for the previous month, which should approximate that amount. If documentation falls short, you are not getting the whole picture. Moreover, outbound documentation helps to determine if more downstream research is required.

Watch out for recyclers that claim to be “EPA Permitted” or “EPA Certified.” The EPA has no permitting or certification process for electronics recyclers. Many times when these recyclers are asked for copies of their “EPA Permit” or “Certification” they offer a copy of an EPA ID number. This typically begins with three letters, including the state initials (PAD, for example, might be the beginning of an EPA ID number for a Pennsylvania company), followed by nine numbers. This is merely an EPA-issued number that is required for manifesting hazardous waste for shipment. Anyone who generates hazardous waste must have one to transport material for disposal. It is not a permit to recycle electronics.

Be wary of state permits. Some states do provide electronics recyclers with state operating permits but this does not necessarily mean the company is complying with any standards. In some states the regulatory agency provides permits to electronics recyclers, but the qualification process is limited.

Understand that a Certificate of Recycling is only the recycler’s own certification of, typically, the total weight of material received on a particular date and confirmation that it was processed “in accordance with all state and federal regulations.” For record-keeping purposes, it is good to have a Certificate of Recycling for each shipment that a generator sends to be recycled; but, remember, this is a highly unregulated industry, and you should conduct your own due diligence.

Product Stewardship Institute, Inc. - M6 - FINAL June, 2005 Staples Pilot Project –Final Report to U.S. EPA Appendix M

While the auditing process may appear to be complicated, doing some investigative work upfront when selecting your recycler can help to streamline the process and provide you with the assurance that you’ve selected the proper company.

The following are some guidelines to consider:

1. Do the background. Develop a short list of pre-qualified recyclers. State environmental agencies may be able to provide a list of e-recyclers serving your state but that does not mean they are endorsed by the state. 2. Ask questions and expect adequate answers. 3. Audit the facilities: It is impossible to conduct due diligence without physical and detailed facility audits. 4. Follow the materials trail and get all of the required downstream information. 5. Ask for references and follow up with contacting references to ensure that others have been satisfied with the company services.

RESOURCES: Computer TakeBack Campaign. “Recyclers Pledge of True Stewardship.” 2003 National Electronics Product Stewardship Initiative (NEPSI). “Due Diligence Guidance For Selection of Electronics Reuse and Recycling Services,” draft document. 2003 Roman, Lauren, S. “Environmental Challenge 2003: How to Audit an Electronics Recycler.” Roman is Vice President of Marketing for United Recycling Industries, Inc. [email protected] or 973-584-8859 Roman, Lauren, S. “Electronic Recycling Vendor Selection Process,” PowerPoint presentation. State of Wisconsin. “Wisconsin Electronic Recycling Disclosure Checklist”

Product Stewardship Institute, Inc. - M7 - FINAL June, 2005 Staples Pilot Project –Final Report to U.S. EPA Appendix N

Appendix N. Checklist For Electronics Recyclers

--- FOR STAPLES, INC. ---

Company: Address, Phone, Email, www: Contact Person and Position: Date: ______

A. GENERAL COMPANY INFORMATION 1. What kind of company is yours?  Broker  Reseller  Demanufacturer 2. Please provide a general description of the business, including:  Point of contact  Number of employees  Years in business and ownership history  Facility site information and history  Qualifications statement 3. Does your company process non-saleable equipment and components by Yes  No  breaking down or shredding? If not: Are whole components outsourced or exported? If so, where are the Yes  No  markets for the electronic equipment? What processes are employed by downstream vendors? Yes  No  Have you done due diligence and can you provide documentation on Yes  No  downstream facilities? Are downstream facilities permitted? Yes  No  How are residuals managed in downstream facilities? Yes  No 

Product Stewardship Institute, Inc. - N1 - FINAL June, 2005 Staples Pilot Project –Final Report to U.S. EPA Appendix N

4.What type of products do you accept? (Later we need pricing information. Do you provide quotes based on a per pound, per product, or other basis?) Computers and peripherals Telephones, communications  Monitors  Conference phones  Desktop CPUs  Corded phones  LCD displays – laptops  Cordless phones  Notebook computers  Answering machines  CD drives  Pagers  Hard drives Miscellaneous  Zip drives  Pocket PCs  Cables (computers, etc.)  Data cartridges  DVD drives  Battery back-ups/UPS  Floppy drives  PC and digital cameras  Printers  Digital pens  Speakers  Joysticks Other office equipment  Game pads  Faxes  Remotes  Multifunction machines  PC cameras  Scanners  Copiers  Projectors/AV equipment 5. What services does your company provide?  Brand sorting  Sort equipment for reuse to non-profit  Hard drive erasure/data destruction  Product tracking through final fate of materials  Other? ______6. Please provide references, including the most recent and related clients that you have provided services for. (List below or attach references.)

B. COMPLIANCE WITH FEDERAL, STATE, AND LOCAL ENVIRONMENTAL LAWS TO SAFEGUARD OCCUPATIONAL AND ENVIRONMENTAL HEALTH AND SAFETY. 1. Does your company have an EPA ID number? Yes  No  #______

2. Please provide information on the company’s compliance history: Yes  No  Examples may include:  Summary of federal, state EPA, or other governmental agency inquiries and enforcement actions during the past three years.  Material reports to government agencies from the past three years

Product Stewardship Institute, Inc. - N2 - FINAL June, 2005 Staples Pilot Project –Final Report to U.S. EPA Appendix N

3. Please provide evidence of necessary permits:

 Air permit  Storm water permit  Solid Waste permit  Business permit  Zoning permit  Transportation/licensure 4. Please provide evidence of an environmental management system (EMS) or an environmental risk management plan.

5. Is your company a certified recycler? If so, check all that apply: Yes  No   ISO 14000  EMAS (European Eco-Management and Audit Scheme)  IAER (International Association of Electronic Recyclers)  Recyclers Pledge of True Stewardship  Other?______6. Does your company have a hazardous materials management plan? Yes  No 

7. Please provide evidence that your company meets OSHA requirements, including:  List of applicable OSHA mandates  Summary of OSHA inquiries for past 3 years including health hazard evaluations  Full OSHA citation history  Training records and written programs required by OSHA standards Is there a trained Environment Heath and Safety supervisor on site? Yes  No 

C. DOCUMENTATION REGARDING END-USE MARKETS. 1. Please provide a detailed description of your company’s processes:  Demanufacturing  Reuse/Resale/Donations  Storage  Secure destruction  Send materials to a metals reclamation plant or smelter  Process the plastic, metal and glass and ship these to other companies for use in production of recycled   Products manufactured 2. Please provide a complete list of end-markets for materials.

3. Does your company audit the end-markets? Yes  No  If not, how do you ensure environmental and worker protection?

Product Stewardship Institute, Inc. - N3 - FINAL June, 2005 Staples Pilot Project –Final Report to U.S. EPA Appendix N

4. How much (and what type) of equipment or components received does your company send for disposal in landfills or for incineration? ______5. For equipment that is reused, is your company able to supply Yes  No  Staples with documentation to apply towards the federal tax return? 6. Can your company provide a complete inventory of equipment Yes  No  that is sent to be recycled, including property tags? Do you provide a certificate indicating when material was received and how it was processed? 7. Does your company export or (broker for export) used Yes  No  electronics equipment? If so, please provide evidence that your export policies are in compliance with notice and consent procedures specified under international laws and bilateral agreements.

D. OTHER STAPLES CONCERNS 1. Is your company willing to adapt your processes to accommodate Yes  No  Staples concerns? Examples of concerns include:  Equipment sent to World Computer Exchange or other designated recipient  No exporting of non-usable equipment or hazardous components -- either directly or indirectly through downstream markets -- to less- developed countries  No use of prison labor

E. RISK MANAGEMENT 1. Does your company have environmental liability protection? Yes  No  Please provide a schedule or copy of the insurance policy and indicate the amount of insurance coverage. 2. Do you have General Liability Insurance? Yes  No  Please provide a schedule or copy of the insurance policy and indicate the amount of insurance coverage. 3. Do you have other types of insurance? Yes  No  Please provide a schedule or copy of the insurance policy and indicate the amount of insurance coverage. 4. Does your company have financial assurance (e.g., bonding)? Yes  No 

F. DISCLOSURE VERIFICATION 1. Please verify that your responses are accurate through an independent Yes  No  verification process or through documentation?

Product Stewardship Institute, Inc. - N4 - FINAL June, 2005 Staples Pilot Project –Final Report to U.S. EPA Appendix O

Appendix O. Reuse Organizations In The Northeast

Several organizations in the U.S. direct working computers to schools and needy non-profit organizations. The following are a few of the reuse organizations in the northeast.

Share the Technology PO Box 548 Rancocas, NJ 08073 [email protected] http://www.sharetechnology.org/

Cambridge (MA) Computer Donation Program Kate Russell Walsh Cambridge Chamber of Commerce (617) 8764134 Email: Kate Russell Walsh

Mindshare Collaborative Charles Thompson P.O. BOX 35389 Brighton, MA 02135 (617) 787-7870 [email protected]

TecsChange-Technology For Social Change 1151 Massachusetts Avenue Cambridge, MA 02138 617-783-1668 [email protected]

Virtually Wired Educational Foundation Coralee Whitcomb 55 Temple Place Boston, MA 02111 (617)542.5555 [email protected]

National Cristina Foundation (203) 863-9100 http://www.cristina.org/

Product Stewardship Institute, Inc. - O1 - FINAL June, 2005 Staples Pilot Project –Final Report to U.S. EPA Appendix P

Appendix P. Retail Equipment Collection Survey Data

Retail Customer Equipment Collection Survey Data

Table P1. Equipment Type Collected By Store And By Brand

Store CPU Monitor Laptop Peripherals

#1-Brighton, MA APPLE 1 APPLE 3 APPLE 1 ATARI 1 COMPAQ 1 COMPAQ 1 EMC 2 MAC 5 GATEWAY 1 MAC 2 MICS 1 MISC 1 SAMSUNG 1

Totals Store #1 8 12 1 5

#2-Woburn, MA ACER 1 ACER 2 HP 1 ADVANCE 1 ADC 1 NEC 1 APPLE 9 AOC 1 MISC 1 AST 1 Apple 12 AT&T 1 AST 1 CLONE 1 COMP USA 1 COMP USA 1 COMPAQ 5 COMPAQ 11 COMPUADD 1 DEC 2 COMPUTINE 1 DELL 4 CORDATA 1 Digital 3 CTX 1 DYNAMICS 1 DEC 2 ELITE 1 DELL 5 EMACHINE 1 DIGIVIEW 1 GATEWAY 2 EVEREX 1 HP 5 GATEWAY 3 IBM 6 GOLDSTAR 1 INTEL 1 HP 9 MAC 1 IBM 4 MAC II 2 IMPRESSION 1 Micron 3 INTEL 1 MISC 5 LINK 3 NEC 2 MAC 1 NPC 2 MAG INOVISION 1 PACKARD BELL 2 MAGNAVOX 2 POWERSPEC 3 MISC 3 PROTEVA 1 NAP 1 SONY 3 NCR 1 NEC 4 NPC 1 Packard Bell 2 PCPC 1 PENTENIUM 1 PHILLIPS 1 PRINCETON 2 PROTEVA 1 PROVIEW 1 RIC 1 SAMPO 1 SAMSUNG 1 SONY 5 SUNSHINE 1 SUPER MAC 1 VIEW SONIC 4 WANG 1 WIT 1 ZENITH 1

Totals Store #2 76 98 3 44

Product Stewardship Institute, Inc. - P1 - FINAL June, 2005 Staples Pilot Project –Final Report to U.S. EPA Appendix P

Equipment Type Collected By Store And By Brand (continued)

Store CPU Monitor Laptop Peripherals

#8 - Natick, MA ACER 3 ACER 7 APPLE 4 AMIGA 1 AMIGA 1 ARCHE 1 APPLE 23 APPLE 24 COMPAQ 2 AST 2 AST 1 DELL 1 COMLINK 1 AT & T 1 IBM 4 COMMODORE 2 COMMODORE 2 LAPNOTE 1 COMPAQ 15 COMPAQ 11 MISC 1 CREATIVE 1 CRYSTAL SCAN 1 NEC 1 DELL 15 CTX 5 SHARP 1 DIGITAL 4 CYBERVISION 1 SONY 1 DTK 2 DELL 13 TOSHIBA 2 ELITE 1 DIGITAL 1 ZENITH 1 EMACHINES 1 DTK 1 ESCAPE SYS 1 EAGLE 1 EXIDY 1 EMERSON 1 GATEWAY 14 GATEWAY 8 HP 15 GOLDSTAR 1 IBM 12 HP 18 IDENTITY 1 IBM 9 IGENERIC 2 KFC 2 KLM 1 KLM 1 LEADING EDGE 1 MAC 4 MAC 3 MICRON 1 MIB 1 MISC 17 MICRON 1 MULTISCAN 1 MISC 16 NCR 1 NPC 1 NEC 3 NSTAR 1 NPC 1 PACKARD BELL 7 OKIDATA 1 PC BY MR. Z 2 ORCHISTRA 1 PC WAREHOUSE 1 Packard Bell 7 POWER SPEC 1 PGS 1 SMITH CORONA 1 PHILIPS 1 STAR 2 PRINCETON 1 SYQUEST 1 SAMPO 2 TANDY 3 SAMSUNG 4 TAVACIN 1 SCEPTRE 2 TC COMPUTER 2 SONY 1 TRI GEM 1 STAR 3 UNIRON 1 TANDY 3 WANG 1 TRI GEM 1 US LOGIC 1 VGA 1 VICTOR 1 VIEW SONIC 4 VISUAL SENSATION 1 Totals Store #8 166 174 20 354 #51- Saugus ACER 2 ACER 1 APPLE 2 APPLE 3 APPLE 14 COMPAQ 9 COMP U DYNE 2 DELL 4 COMPAQ 10 DIGITAL 2 CTX 1 HP 5 DELL 13 IBM 6 GATEWAY 13 KIER 2 HITACHI 2 MB CORP 1 HP 8 MICRO EXPRES 1 IBM 7 MISC 9 KDS 1 PACKARD BELL 2 MISC 1 PENTIUM 1 PANASONIC 1 SRB 2 PRINCETON 1 VIP CORP 1 SONY 2 Totals Store #51 50 77 2 57

Product Stewardship Institute, Inc. - P2 - FINAL June, 2005 Staples Pilot Project –Final Report to U.S. EPA Appendix P

Equipment Type Collected By Store And By Brand (continued)

Store CPU Monitor Laptop Peripherals

#108-South Portland, ME APPLE 14 ACTRONICS 1 APPLE 5 AST 1 ADDONICS 1 TOSHIBA 1 ASTI 1 APPLE 11 NEC 3 AT&T 2 AST 1 COMPAQ 1 CHERRYTOWN 1 AT&T 1 QUANTEX 1 COMPAQ 18 BROTHER 1 GATEWAY 1 COMPUADD 1 BSR 1 CSM 1 COMPAQ 16 DELL 2 CTX 1 DIGITAL 1 CTX 1 EMACHINES 2 CYBERVISION 1 EPSON 1 DEC 1 FAST DANA 1 DELL 2 GATEWAY 16 EMC 1 GORHAM MICRO 1 ENVISION 1 HP 13 EPSON 1 IBM 11 GATEWAY 13 INTEL 1 HPS 8 MICRON 3 HYUNDAI 1 MISC 15 IBM 4 NEC 3 KENSIKO 1 PACKARD BELL 6 MAG INOVISION 1 TANDY 1 MAGNAVOX 1 UNISYS 1 MEGA IMAGE 2 US TECH 1 MICRON 1 MISC 15 NEC 4 OPQUES 1 Packard Bell 5 PRINCETON 1 PROMOTHERS 1 PROVIEW 1 SONY 1 SUPERCOM 1 SVE 1 TANDY 1 UNISYS 1 VISION 1 YAMA 1 Totals Store #108 118 109 12 270

#167-Danvers, MA APPLE 16 ACER 1 COMPAQ 2 AST 1 AOG 1 ZENITH 1 COMPAQ 11 APEX 2 DELL 11 APPLE 17 EPSON 1 AST 1 GATEWAY 2 AST 1 HP 6 COMPAQ 10 MISC 9 Compudine 1 IBM 11 CPX 1 Micron 1 CTX 1 NCP 1 DELL 8 NCR 1 EVEREX 1 NPC 2 GATEWAY 4 PACKARD BELL 5 HEADSTART 1 ROYAL 1 HP 3 ZEOS 1 IBM 10 MAC 1 LEADING 1 ADM 3 MAG 21 1 PERFECT SYSTEM 1 MICRON 1 SONY 1 MISC 8 NORTGAR 1 NCP 1 NCR 1 NEC 2 PACKARD BELL 3 PRINCETON 1 ROYAL 1 SANYO 1

Product Stewardship Institute, Inc. - P3 - FINAL June, 2005 Staples Pilot Project –Final Report to U.S. EPA Appendix P

Equipment Type Collected By Store And By Brand (continued)

Store CPU Monitor Laptop Peripherals

Totals Store #167 87 97 3 101 #176-Portsmouth, NH ACER 1 ACER 2 APPLE 3 AMIGA 1 AMIGA 1 COMPAQ 2 APPLE 7 APPLE 7 DELL 1 ASSEMBLED 1 CTX 1 HP 1 CUSTOM 2 HONEYWELL 1 TOSHIBA 1 DELL 5 HP 4 ZENITH 1 DIGITAL 1 IBM 1 HONEYWELL 2 KDS 1 HP 2 MAC 1 MAC 1 Mag Inovision 1 MICRON 1 MGC 1 NA 1 MISC 2 PACKARD BELL 1 Occidental 1 XEROX 1 Packard Bell 4 PSI 1 Quantex 1 Signature 1 Sony 1 Totals Store #176 27 32 9 58

Product Stewardship Institute, Inc. - P4 - FINAL June, 2005 Staples Pilot Project –Final Report to U.S. EPA Appendix P

Equipment Type Collected By Store And By Brand (continued)

Store CPU Monitor Laptop Peripherals

#194-Bangor, ME ACER 1 ACER 2 ZENITH 1 AMPTEC 1 ADI 1 APPLE 23 AOL SPECTRUM 2 ATA 1 APPLE 24 BTO 2 ARCUS 1 COMPAQ 6 AS 1 COMPUADD 1 AT & T 1 COMTRADE 1 BTC 1 DATASHIELD 2 COMPAQ 7 DELL 5 COMPUADD 2 DOS 1 CTX 1 EVEREX 15 DAYTEK 1 GATEWAY 9 DELL 1 HP 4 DELL 7 IBM 1 DESKTOP DISPLAY 1 IBM 6 DIGITAL 2 KDS 1 EVEREX 1 KLH 1 GATEWAYS 14 KOMODO 1 GOLDSTAR 1 LASER 1 GRID 800 1 LEADING EDGE 2 HANSON 1 MCINTOSH 2 HITACHI 1 MICRON 1 HP 3 MIDWEST MICRO 2 IBM 11 MISC 9 ICM 1 NAMCO 1 KDS 1 NEC 1 KFC 1 PACKARD BELL 7 KLH 2 PANASONIC 4 LEADING EDGE 1 PREMIO 1 MACINTOSH 3 PROFESSIONAL PC 1 MAG VISION 1 QUANTEX 1 MICRON 1 RADIO SHACK 1 MIDWEST MICRO 1 SWAN 1 MIRROR 1 TANDY 1 MISC 4 TELEVIDEO 1 MITAC 1 TIGER 1 NEC 3 TOSHIBA 1 ORCHESTRA 1 ULTRA 1 PACKARD BELL 8 WANG 1 PANASONIC 2 ZEOS 2 PIXIE 1 PRINCETON 2 QUANTEX 1 RADIO SHACK 1 RELYSIS 1 ROYAL 1 SAMSUNG 2 SMITH CORONA 1 SONY 3 STANDARD TECH 1 SWAN 1 TANDY 2 TELEX 1 TRADEMARK 1 ULTRA SONIC 1 VIEWSONIC 2 YAMA 1 Totals Store #194 125 143 1 185

Product Stewardship Institute, Inc. - P5 - FINAL June, 2005 Staples Pilot Project –Final Report to U.S. EPA Appendix P

Equipment Type Collected By Store And By Brand (continued)

Store CPU Monitor Laptop Peripherals

#200-Needham, MA APPLE 8 AOC 1 COMPAQ 1 COMPAQ 3 APPLE 10 DELL 1 DELL 4 AT&T 1 APPLE 2 GATEWAY 2 COMPAQ 2 EVEREX 1 HP 4 COMTERM 1 WINBOOK 1 MISC 13 DELL 3 MOTOROLA 1 GATEWAY 3 NA 1 HP 3 NPC 2 IBM 2 PCCLONE 1 MISC 11 ZENITH 1 NEC 3 PACKARD BELL 1 PRINCETON 1 PRO COMPUTING 1 SAMSUNG 1 TATUNG 1 VISION GRAPHICS 1 ZENITH 1 Totals Store #200 40 47 6 73 #297-Brunswick, ME ACER 1 ACER 17 APPLE 3 ACROS 1 ACROS 1 CANON 1 APPLE 32 AMDEK 1 DELL 1 CLONE 1 APPLE 25 ZENITH 1 COMMODOR 1 BROTHER 1 ZEOS 1 COMPAQ 4 CHAMPION 1 CRYSDALIEN 1 COMPAQ 4 DELL 6 CSX 1 DIGITAL 1 CTX 1 ELITE 1 DATA GENERAL 1 GATEWAY 15 DELL 13 HP 19 DIGITAL 2 IBM 3 ELITE 1 KEYPRO 1 GATEWAY 8 LASER 1 HITACHI 1 LEADING EDGE 3 HP 7 MAC 5 IBM 2 MAGITRONIC 1 IMTEC 1 MARKET TEK 1 KEYPRO 1 MICRON 1 KOREA DATA SYS 1 MIDWEST MICRO 1 LASER 2 MISC 26 LEADING EDGE 2 NORTHGATE 2 LIKOM 2 PACKARD BELL 1 LINK 1 PC CLONE 1 MAC 3 PERFORMA 1 MAGNITRONIC 2 PIOPNEX 1 MAGNOVOX 4 PREMIO 1 MEMOREX 1 SEAGATE 1 MIAC 1 SYSTEM RESOURCES 4 MICRON 1 TANDY 4 MISC 11 TIGER 4 MITSUBISHI 3 ULTRA 2 NEC 4 VALUE LINE 7 OPTIQUEST 1 ORCHESTRA 1 PACKARD BELL 2 PACOM 1 PANASONIC 2 PHILLIPS 1 PIONEX 1 PRINCETON 1 QUANTEX 1 SAMSUNG 1 SCAN PRO 1 SONY 1 TANDY 6 TARDON 1 TAXAN 1 TEXAS INSTR 3 VIEW SONIC 2 ZENITH 1 Totals Store #297 155 155 7 267

Product Stewardship Institute, Inc. - P6 - FINAL June, 2005 Staples Pilot Project –Final Report to U.S. EPA Appendix P

Equipment Type Collected By Store And By Brand (continued)

Store CPU Monitor Laptop Peripherals

#307-Lewiston, ME APPLE 1 ADP 1 GATEWAY 1 CREATIVE 2 APPLE 1 TOSHIBA 1 DATAWORLD 1 AST 1 DELL 3 COMODORE 1 DIGITAL 1 CTX 1 GATEWAY 5 DELL 3 HP 1 DIGITAL 1 IBM 1 GATEWAY 4 KAYPRO 1 HP 1 MISC 2 IBM 1 PACKARD BELL 1 IBM 1 PROTEVA 1 KDS 1 TANDY 1 LINK 4 TIGER 1 MISC 1 TOSHIBA 1 PACKARD BELL 3 PRINCETON 1 PRO VIEW 1 SONY 3 TELEVIDEO 1 TOUCH 1

Totals Store #307 23 32 2 51

#373-Rochester, NH ABS 1 APPLE 1 APPLE 1 ACER 3 COMPAQ 1 APPLE 1 GATEWAY 1 BEC 1 IBM 2 COMPAQ 1 PACKARD BELL 2 GATEWAY 1 PACKARD BELL 2 SAMSUNG 1 Totals Store #373 11 7 1 21

Product Stewardship Institute, Inc. - P7 - FINAL June, 2005 Staples Pilot Project –Final Report to U.S. EPA Appendix P

Equipment Type Collected By Store And By Brand (continued)

Store CPU Monitor Laptop Peripherals

#495-Danvers, MA APPLE 47 ACER 2 COMPAQ 1 ARALZE 1 APPLE 48 HUNDAI 1 ASPEN 1 COMPAQ 12 IBM 1 COMPAQ 16 CTX 1 TOSHIBA 1 COMSTAR 1 DELL 12 WINBROOK 1 DELL 4 DIGIVIEW 1 ZENITH 2 EPSON 1 ELZO 1 GATEWAY 5 EMC 1 HP 5 EPSON 3 MAC 4 GATEWAY 3 MICRON 1 GOLDSTAR 2 MISC 9 GVC 1 PACKARD BELL 1 HP 3 WHITE BOX 1 IBM 2 ZEOS 1 KDS 2 MAC 5 MAG 1 MAXTEC 1 MICRON 1 MISC 11 MITSUBISHI 1 MTX 1 NEC 1 PACKARD BELL 3 PANASONIC 2 PHILIPS 1 PRESIDENT TECH 1 PRINCETON 2 SAMSUNG 1 SANPO ALPHA 1 SCEPTINE 1 SMITH CORONA 1 SONIC VIEW 1 SONY 1 VGA 1 VIEW SONIC 1 VIVITRON 1 WANG 1

Totals Store #495 98 135 7 89

Product Stewardship Institute, Inc. - P8 - FINAL June, 2005 Staples Pilot Project –Final Report to U.S. EPA Appendix P

Equipment Type Collected By Store And By Brand (continued)

Store CPU Monitor Laptop Peripherals

Totals Store #495 98 135 7 89

Product Stewardship Institute, Inc. - P9 - FINAL June, 2005 Staples Pilot Project –Final Report to U.S. EPA Appendix P

Equipment Type Collected By Store And By Brand (continued)

Store CPU Monitor Laptop Peripherals

#648-Bangor, ME ACER 2 ACER 9 LUBREX 1 ACS 1 ACERVIEW 1 AMI 1 ADC 1 AMTELCO 2 APPLE 11 APPLE 12 ATT 1 AST 1 COMMODORE 1 COMPAQ 4 COMPAQ 7 COMPU ADD 1 CTX 1 DELL 4 DAEWOO 1 DIGIVIEW 1 DELL 3 DSR 2 DIGITAL 2 EMACHINES 1 DIGIVIEW 1 EVEREX 2 DTK 1 GATEWAY 10 EMACHINE 2 GENISYS 1 EMC 1 HP 5 EVEREX 1 IBM 1 EVERVISION 1 MAC 2 GATEWAY 13 MICRON 1 GOLDSTAR 1 MISC 7 HP 4 NEC 2 IBM 2 PACKARD BELL 3 MAC 1 TANDY 2 MAGNAVOX 1 ULTRA 1 MAGNAVOX 1 ZENITH 2 MICRO 1 MISC 3 NEC 4 NUMBUE 1 PACKARD BELL 3 RIC 1 SAMSUNG 1 SMITH CORONA 1 SONY 1 TANDY 1 TANTUNG 2 ULTRA 1 Totals Store #648 71 88 1 114

#806 Old Saybrook, CT APPLE 6 ACER 1 COMPAQ 3 APPLE 6 DBI 1 COMPAQ 2 DELL 5 DELL 1 IBM 3 EMACHINE 2 PACKARD BELL 9 GATEWAY 2 SAMSUNG 1 IBM 2 KOS 2 MAC 1 MISC 1 NEC 1 NORTHGATE 1 PACKARD BELL 9 PHILLIPS 1 SAMSUNG 1 SONY 2

Totals Store #806 28 35 41

Product Stewardship Institute, Inc. - P10 - FINAL June, 2005 Staples Pilot Project –Final Report to U.S. EPA Appendix P

Equipment Type Collected By Store And By Brand (continued)

Store CPU Monitor Laptop Peripherals

#836-Westerly, RI ACER 1 ACER 1 APPLE 1 APPLE 1 CANON 1 MAC 1 AUSTIN 1 CYBERVISION 1 BSR 1 DELL 42 CANON 2 DTK 1 COMPAQ 1 EPSON 3 GATEWAY 2 GATEWAY 2 IBM 1 GOLDSTAR 1 MISC 5 IBM 1 OSC 1 KDS 1 PACKARD BELL 2 MISC 4 PREMIA 20 MITSUBISHI 1 PACKARD BELL 2 SAMSUNG 4 Totals Store #836 38 65 2 77

#871-Biddeford, ME AOC 1 AMDEK 2 IBM 1 APPLE 3 AOC 1 COCCI COMP 1 APPLE 1 COMPAQ 1 COCCI COMP 1 EMACHINE 1 COMPAQ 2 HP 2 CTI 1 IBM 4 CTX 2 LEADING EDGE 1 DELL 1 MICRON 5 EMACHINE 1 MISC 2 ENVISION 1 NEC POWERMATE 1 HP 2 PACKARD BELL 5 IBM 3 TEXAS INSTRUMENT 1 LEADING EDGE 1 MAGNAVOX 2 MICRON 1 MISC 10 NEC 1 NEC 1 NEC POWERMATE 1 PACKARD BELL 7 PRINCETON 1 VOX 1 Totals Store #871 28 44 1 61

#947-Norwich, CT APPLE 3 APPLE 3 COMPAQ 6 COMPAQ 1 GATEWAY 1 DELL 1 HP 1 GATEWAY 1 IBM 1 HP 2 MACINTOSH 1 NEC 1 MISC 2 PACKARD BELL 1 NEC 1 PRINCETON 1 PACKARD BELL 1 PSI 1 ZEROX 1 TRINITRON 1 Totals Store #947 18 13 0 45

Product Stewardship Institute, Inc. - P11 - FINAL June, 2005 Staples Pilot Project –Final Report to U.S. EPA Appendix P

Equipment Type Collected By Store And By Brand (continued)

Store CPU Monitor Laptop Peripherals

#1095-Falmouth, ME APPLE 13 ACER VIEW 2 AST 1 COMP USA 1 APPLE 16 DIGITAL 1 COMPAQ 5 COMP USA 1 GATEWAY 1 CREATIVE 1 COMPAQ 5 DELL 5 DELL 6 DIGITAL 1 DTX 1 DOWNTIME 2 EVEREX 1 DTX 1 GATEWAY 6 EVEREX 1 HP 2 GATEWAY 4 IBM 5 IBM 8 ICD 1 INTEL 2 INTEL 1 LEXMARK 1 KDS 2 MAC 1 LEXMARK 1 MISC 3 MAC 1 NCR 2 MEMOREX 1 PACKARD BELL 1 MISC 5 PATRIOT 1 MITSUBISHI 1 ZENITH 1 NCR 3 ZEOS PANTERA 1 NEC 2 OPTIQUEST 1 PACKARD BELL 2 PHILLIPS 1 PROVIEW 1 SEPTER 1 ULTRA 1 V TECH 1 VIEWSONIC 2 Totals Store #1095 55 73 3 120

#1100-Somersworth, NH APPLE 3 APPLE 1 DELL 1 DELL 1 DELL 1 TOSHIBA 1 IBM 1 GATEWAY 2 MAC 1 IBM 1 MICRO EXPRESS 1 MAC 1 SAMSUNG 1 MAGNAVOX 2 SPECTRA 1 MITSUBUSHI 1 ULTRA 1 NAP ELECTORNICS 1 ZENITH 1 NEC 1 PRINCETON 1 SAMSUNG 1 TATUNG 1 ULTRA 1

Totals Store #1100 11 15 2 17

Product Stewardship Institute, Inc. - P12 - FINAL June, 2005 Staples Pilot Project –Final Report to U.S. EPA Appendix P

Equipment Type Collected By Store And By Brand (continued)

Store CPU Monitor Laptop Peripherals

#1124-Seabrook, NH APPLE 6 ACER 1 SHARP 3 COMMODORE 1 APPLE 9 TOSHIBA 1 COMPAQ 2 AT&T 2 COMPUDYNE 1 COMPAQ 2 CPS 1 COMPUDYNE 1 GATEWAY 3 CYBERVISION 1 GENERIC 1 DELL 1 HP 4 DIGITAL 3 IBM 7 EMACHINE 1 MISC 8 EMC 1 NA 2 EMERSON 1 PACKARD BELL 5 Gateway 2 SHARP 2 HP 6 SONY 1 INTEL 1 TANDY 3 KDS 1 MAGVIEW 1 MISC 15 NA 4 NA 4 NEC 2 PACKARD BELL 3 PHILIPS 1 SAMSUNG 1 SANYO 1 Totals Store #1124 47 65 4 74 #1132-Waterville, ME APPLE 1 HP 2 NEC 1 FIRST VIEW 1 PHILLIPS 1 SHARP 1 GATEWAY 1 RADIO SHACK 1 HP 2 SAMSUNG 1 MICRON 1 SUPERVIEW 1 QUANTEX 1 RADIO SHACK 1 Totals Store #1132 8 6 2 7

#1228-North Conway, NH APEX 1 APPLE 6 APPLE 3 APPLE 6 AST 1 COMPAQ 1 AST 1 COMPAQ 2 NEC 1 COMPAQ 4 CYBERVISION 1 DELL 4 DELL 2 DFI 1 DIGITAL 17 EMERSON 1 EMACHINE 1 EPIC 1 EMC 1 E-TOWER 1 EMERSON 1 GATEWAY 2 E-TOWER 1 IBM 2 GATEWAY 1 MAGITRONIC 1 IBM 3 METRA 1 MIC 1 MICRON 2 MICRON 2 MICROX 1 MISC 3 MISC 7 NEC 2 NCR 1 PACKARD BELL 5 NEC 1 PRINCETON 1 OKIDATA 1 RADIUS 1 PACKARD BELL 7 SMITH CORONA 1 PAI 1 SONY 1 TANDY 1 TANDY 2 TECH MEDIA 1 Totals Store #1228 48 57 5 137

Product Stewardship Institute, Inc. - P13 - FINAL June, 2005 Staples Pilot Project –Final Report to U.S. EPA Appendix P

Equipment Type Collected By Store And By Brand (continued)

Store CPU Monitor Laptop Peripherals

#1259-North Windham, ME APPLE 1 AST VISION 1 IBM 1 ARCHE LEGACY 1 AT&T 1 AT&T 1 COMPAQ 1 DMI 1 DIGITAL 1 GENERIC 1 IBM 1 HP 2 LEADING EDGE 1 HYUNDAI 1 MAG 1 MISC 4 MITSUBISHI 1 NEC 1 NEC 1 QUANTUM 2 PACKARD BELL 1 TANDY 1 RGB 1 THINKPAD 1 SEPTRE 3 VIEWSONIC 1 Totals Store #1259 17 15 1 25

#1291-Rockland, ME COMPAQ 1 GATEWAY 1 IBM 2 DEC 1 HP 1 TBM 1 GATEWAY 3 MISC 1 HP 2 PANASONIC 1 MAC 3 RADIUS 1 Totals Store #1291 10 5 3 14 COMBINED TOTALS 1363 1599 98 2307

Product Stewardship Institute, Inc. - P14 - FINAL June, 2005 Staples Pilot Project –Final Report to U.S. EPA Appendix P

Table P2. Total Equipment Type Collected By Store

STATE CPU MONITOR LAPTOP PERIPHERALS TOTAL

0806 CT 28 35 0 41 0947 CT 18 13 0 45 TOTAL CT 46 48 0 86 180 0001 MA 8 12 1 5 0002 MA 74 98 3 44 0008 MA 166 174 20 354 0051 MA 50 77 2 57 0167 MA 87 97 3 101 0200 MA 40 47 7 73 0495 MA 98 135 6 89 TOTAL MA 523 640 42 723 1928 0108 ME 118 109 12 270 0194 ME 125 143 1 185 0297 ME 155 155 7 267 0307 ME 23 32 2 51 0648 ME 71 88 1 114 0871 ME 28 44 1 61 1095 ME 55 73 3 120 1132 ME 8 6 2 7 1259 ME 17 15 1 25 1291 ME 11 5 3 14 TOTAL ME 611 670 33 1114 2428 0176 NH 27 32 9 58 0373 NH 11 7 1 21 1100 NH 12 15 2 17 1124 NH 47 65 4 74 1228 NH 48 57 5 137 TOTAL NH 145 176 21 307 649 0836 RI 38 65 2 77 182

TOTALS 1363 1599 98 2307 5367

Table P3. Equipment Type Collected By Major Brand

MONITOR LAPTOP PRINTER SCANNER FAX COPIER

APPLE 251 APPLE 24 COMPAQ/HP 262 COMPAQ/HP 25 BROTHER 6 CANON 5 COMPAQ/HP 187 COMPAQ/HP 14 EPSON 81 MICROTECH 12 PANASONIC 5 XEROX 4 DELL 137 IBM 9 APPLE 75 UMAX 8 HP 4 HP 2 GATEWAY/EMACHINES 112 NEC 7 CANON 45 MUSTEK 4 SHARP 4 SHARP 2 IBM 74 TOSHIBA 8 LEXMARK 27 CANON 3 CANON 3 PACKARD BELL 73 ZENITH 6 PANASONIC 27 APPLE 3 PANAFAX 2

834 68 517 55 24 13 52.1% 68.7% 71.1% 64.7% 75.0% 72.2%

Product Stewardship Institute, Inc. - P15 - FINAL June, 2005 Staples Pilot Project –Final Report to U.S. EPA Appendix P

Equipment Type Collected By Major Brand (continued)

MONITOR LAPTOP PRINTER SCANNER FAX COPIER

ACER 49 ARCHE 1 ACER 1 ACER 3 AUTLOGIC 1 IBM 1 ACROS 1 AST 1 ADOBE 1 AGFA 1 BELL 1 LANIER 1 ACTRONICS 1 CANON 1 ALPS 2 ASTA 1 LUMAK 1 MISC 2 ADC 2 DELL 5 AMEGA 1 DIGITAL 1 MICROTEC 1 STAR 1 ADDONICS 2 DIGITAL 1 AMT 1 EASY PHOTO 1 MINOLTA 1 ADI 1 EVEREX 1 APEX 1 EPSON 1 MISC 1 ADP 1 GATEWAY 3 APPOLLO 1 FUJITSU 1 MURATA 1 AMDEK 2 HUNDAI 1 ATARI 1 GATEWAY 1 XEROX 1 AMIGA 2 LAPNOTE 1 BROTHER 10 LEXMARK 1 AOC 4 LUBREX 1 CITIZEN 2 LUMINA 2 AOL SPECTRUM 2 MAC 1 COMMODORE 3 MEMOREX 2 APEX 2 MISC 2 DEC 1 MICROSOFT 1 ARCUS 2 QUANTEX 1 DELL 2 MISC 3 AST 9 SHARP 5 DESKJET 2 NIKON 1 AT&T 8 SONY 1 DIGITAL 22 PRIMA SCAN 1 BROTHER 2 TBM 1 DOT MATRIX 1 RELISYS 1 BSR 1 WINBOOK 2 FARGO 2 SCAN MAKER 1 BTC 1 ZEOS 1 FUJITSU 3 SCANTAK 1 CANON 1 GATEWAY 8 SCAPORT 1 CHAMPION 1 GEMINI 15 1 VANTAS 1 COCCI COMP 1 IBM 13 VISIONEER 3 COMMODORE 4 IMAGE MAKER 7 XEROX 1 COMP U DYNE 2 INTEL 1 COMP USA 5 LASER PRINTER1 COMPUADD 3 MAC 5 COMPUTINE 4 MANNESMEN 1 COMTERM 1 MINOLTA 1 CORDATA 1 MISC 47 CPX 1 MPI 1 CRYSTAL SCAN 1 NCR 1 CSX 1 NEC 6 CTI 1 OKIDATA 16 CTX 18 OLYMPIA 2 CYBERVISION 5 PACKARD BELL 5 DAEWOO 1 PRINTER WORKS1 DATA GEN 1 RADIO SHACK 3 DAYTEK 1 REYNOLDS 1 DEC 3 SILVER REED 1 Desktop Displays 1 SMITH CORONA4 DIGITAL 32 STAR 4 DTK 4 STORM 1 EAGLE 1 STYLE WRITER 2 ELITE 1 STYLUS 2 ELZO 1 TANDY 8 EMC 7 TEXAS INST 5 EMERSON 3 TIGER 1 ENVISION 2 XEROX 4

Product Stewardship Institute, Inc. - P16 - FINAL June, 2005 Staples Pilot Project –Final Report to U.S. EPA Appendix P

Equipment Type Collected By Major Brand (continued)

MONITOR LAPTOP PRINTER SCANNER FAX COPIER

EPSON 7 E-TOWER 1 EVEREX 5 EVERVISION 1 GOLDSTAR 7 GRID 800 1 GVC 1 HANSON 1 HEADSTART 1 HITACHI 4 HYANDAI 1 HONEYWELL 1 ICD 1 ICM 1 IMPRESSION 2 IMTEC 1 INTEL 3 KDS 10 KENSIKO 1 KEYPRO 1 KFC 3 KLM 3 KOREA DATA SYS 1 KOS 2 LASER 2 LEADING EDGE 6 LEXMARK 1 LIKOM 2 LINK 8 MAC 23 MAG 7 MAGNOVOX 13 MAXTEC 1 MEGA IMAGE 1 MEMOREX 2 MGC 1 MIAC 1 MICRO 1 MICRON 10 MICS 1 MIDWEST MICRO 1 MIRROR 1 MISC 128 MITAC 1 MITSUBUSHI 8 MTX 1 MULTISCAN 1 NAP 6 NCR 4 NEC 40 NEC POWERMATE 1 NORTHGATE 1 NPC 3 NUMBUE 1 Occidental 1 OKIDATA 1 OPTIQUEST 3 ORCHESTRA 3 PACOM 1 PANASONIC 8 PCPC 1 PENTENIUM 1 PGS 1 PHILLIPS 8 PIONEX 1 ProductPIXIE Stewardship1 Institute, Inc. - P17 - FINAL June, 2005 President Tech 1 PRINCETON 17 PRO COMPUTING 1 PRO VIEW 4 Staples Pilot Project –Final Report to U.S. EPA Appendix P

Equipment Type Collected By Major Brand (continued)

MONITOR LAPTOP PRINTER SCANNER FAX COPIER

PENTENIUM 1 PGS 1 PHILLIPS 8 PIONEX 1 PIXIE 1 President Tech 1 PRINCETON 17 PRO COMPUTING 1 PRO VIEW 4 PROMOTHERS 1 PROTEVA 1 PSI 2 QUANTEX 3 RADIO SHACK 2 RADUIS 2 RELYSIS 1 RGB 1 RIC 2 ROYAL 2 SAMPO 3 SAMSUNG 20 SANPO ALPHA 1 Sanyo 2 SCANPRO 1 SCEPTINE 1 SCEPTRE 4 SIGNATURE 2 SMITH CORONA 4 SONY 30 SPECTRA 1 STANDARD TECH 1 STAR 3 SUNSHINE 1 SUPER MAC 1 SUPERCOM 1 SUPERVGA 1 SUPERVIEW 1 SVE 1 SWAN 1 TANDY 17 TARDON 1 TATUNG 4 TAXAN 1 TECHMEDIA 2 TELEVIDEO 1 TELEX 1 TEXAS INSTR 3 TOUCH 1 TRADEMARK 1 TRI GEM 1 TRINITRON 1 ULTRA 4 UNISYS 1 US LOGIC 2 V TECH 1 VGA 2 VICTOR 1 VIEWSONIC 20 VISION 3 VISUAL SENTATION 1 VIVITRON 1 VOX 1 WANG 2 WIT 1 YAMA 2 ZENITH 3

Product Stewardship766 Institute, Inc.30 210 - P18 - 30 8 5 FINAL June, 2005 Staples Pilot Project –Final Report to U.S. EPA Appendix P

Equipment Type Collected By Major Brand (continued)

MONITOR LAPTOP PRINTER SCANNER FAX COPIER

WIT 1 YAMA 2 ZENITH 3

766 30 210 30 8 5

47.9% 30.6% 28.9% 35.3% 25.0% 27.8%

1600 98 727 85 32 18

Product Stewardship Institute, Inc. - P19 - FINAL June, 2005 Staples Pilot Project –Final Report to U.S. EPA Appendix Q

Appendix Q. Contract Equipment Collection Survey Data

Table Q1. Staples Contract Customer Collection Data Total Number, Weight, And Cost By Brand

Large Small Non-Computer Monitors (1) CPU's (2) Laptops (3) Peripherals (4) (A) Peripherals (5) (B) Equipment (6) Totals Brand # Wgt Cost # Wgt Cost # Wgt Cost # Wgt Cost # Wgt. Cost # Wgt. Cost # Wgt. Cost

3COM 2 20.8 $ 1.46 2 20.8 $1.46 ACER 1 38 $4.00 1 15 $1.05 2 53 $5.05 ACW 2 76 $8.00 2 76 $8.00 ADI 2 76 $8.00 2 76 $8.00 AMPTRON 1 38 $4.00 1 38 $4.00 APC 1 10.4 $ 0.73 1 10.4 $0.73 APPLE 4 152 $16.00 18 414 22 566 $16.00 ARBOR 7 266 $28.00 7 266 $28.00 AST 3 69 3 69 $0.00 AXIS 10 81.2 $5.68 10 81.2 $5.68 BAYNETWORKS 3 24.36 $1.71 3 24.36 $1.71 BROTHER 1 15 $1.05 1 8.12 $0.57 2 23.12 $1.62 CABLESCAN 1 38 $4.00 1 15 $1.05 2 53 $5.05 CANON 1 8.12 $0.57 1 8.12 $0.57 CARON 4 32.48 $2.27 4 32.48 $2.27 COMPUTCITY 1 23 1 23 $0.00 CTS 10 380 $40.00 10 380 $40.00 CTX 1 38 $4.00 1 38 $4.00 CYBEX 1 10.4 $ 0.73 1 10.4 $0.73 DATA MAX 2 16.24 $1.14 2 16.24 $1.14 DECISION DATA 1 38 $4.00 1 38 $4.00 DELL 9 342 $36.00 21 483 3 45 $3.15 5 75 $5.25 1 10.4 $ 0.73 39 955.4 $45.13 ELO 7 266 $28.00 7 266 $28.00 ELTRON 5 40.6 $2.84 5 40.6 $2.84 EPSOM 3 24.36 $1.71 3 24.36 $1.71 GATEWAY 6 228 $24.00 7 161 3 45 $3.15 16 434 $27.15 HP/COMPAQ 7 266 $28.00 49 1127 38 570 $39.90 58 470.96 $32.97 1 15 $1.05 9 93.6 $ 6.55 162 2,542.56 $108.47 IBM 2 76 $8.00 2 46 12 180 $12.60 1 8.12 $0.57 1 15 $1.05 1 10.4 $ 0.73 19 335.52 $22.95 ICON 5 190 $20.00 1 23 6 213 $20.00 IMPRESSION 1 38 $4.00 1 38 $4.00 K25 SYSTEM 1 23 1 23 $0.00 KDS 1 38 $4.00 1 15 $1.05 2 53 $5.05 LEXMARK 14 113.68 $7.96 2 20.8 $ 1.46 16 134.48 $9.41 LYNX 1 38 $4.00 1 38 $4.00 MACINTOSH 19 437 19 437 $0.00 MAG 1 38 $4.00 1 38 $4.00 MANITOO 1 10.4 $ 0.73 1 10.4 $0.73 MGC 1 38 $4.00 1 38 $4.00 MICRON 1 38 $4.00 19 437 20 475 $4.00 MICROTEK 1 8.12 $0.57 1 8.12 $0.57 MISC/GENERIC 39 1482 $156.00 68 1564 22 330 $23.10 4 41.6 $ 2.91 133 3417.6 $182.01 NEC 4 92 4 60 $4.20 8 152 $4.20 OKIDATA 5 40.6 $2.84 1 10.4 $ 0.73 6 51 $3.57 OPXIQUEST 1 38 $4.00 1 38 $4.00 PANASONIC 1 38 $4.00 18 270 $18.90 3 24.36 $1.71 22 332.36 $24.61 PHILIPS 1 38 $4.00 1 23 2 61 $4.00 SAFE 1 8.12 $0.57 1 8.12 $0.57 SAMSUNG 6 228 $24.00 6 228 $24.00 SMILE 1 38 $4.00 1 38 $4.00 SONY 1 38 $4.00 1 38 $4.00 STARR 1 8.12 $0.57 1 8.12 $0.57 SUN 1 38 $4.00 1 10.4 $ 0.73 2 48.4 $4.73 SUN SPARK 1 10.4 $ 0.73 1 10.4 $0.73 TATUNG 5 190 $20.00 5 190 $20.00 TI 2 30 $2.10 2 30 $2.10 TOSHIBA 1 15 $1.05 1 15 $1.05 TRINITRON 1 38 $4.00 1 38 $4.00 TRISTAR 1 23 1 23 $0.00 TRONIX 1 23 1 23 $0.00 VIEWSONIC 1 38 $4.00 1 38 $4.00 WELLFLEET 2 16.24 $1.14 10 104 $ 7.28 12 120.24 $8.42 WYSE 1 38 $4.00 1 23 2 61 $4.00

TOTALS 131 4,978 $524.00 217 4,991 83 1,245 $87.15 115 933.8 $65.37 31 465 $32.55 35 364 $25.48 612 12976.8 $734.55

(1) Average weight for pilot project collection calculation at 38 pounds/unit. At project discounted rate of $4.00/monitor. (2) Average weight for pilot project collection calculated at 23 pounds/unit. No charge for CPU recycling. (3) Average weight for pilot project collection calculated at 15 pounds/unit. At project discounted rate of $0.07/pound. (4) Average weight for pilot project collection calculated at 8.12 pounds/unit. At project discounted rate of $0.07/pound. (5) Average weight for pilot project collection calculated at 15 pounds/unit. At project discounted rate of $0.07/pound. (6) Average weight for pilot project collection calculated at 10.4 pounds/unit (based on an estimated percentage using full collection figures for non-computer equipment in this pilot). At project discounted rate of $0.07/pound. (A) Large Peripherals Include: Printers/Dot Matrix/Laser/Fax/Other (B) Small Peripherals Include: Keyboard/Mice/Speakers/etc.

Product Stewardship Institute, Inc. - Q1 - FINAL June, 2005 Staples Pilot Project –Final Report to U.S. EPA Appendix R

Appendix R. Retail and Contract Customer Satisfaction Surveys

STAPLES/PSI RETAIL CUSTOMER SURVEY

(1) What motivated you to bring in your equipment? (2) Did you buy anything at the store when you returned your item? Yes ____ No _____ If yes, was the purchase: under $50 _____ $51-$100 _____ $101-$250 _____ over $250 _____

(3) What about the program worked well?

(4) What problems, if any, did you have with the program?

(5) What suggestions would you have for future improvement?

(6) In the future, would you be willing to pay to recycle your computer equipment? If yes, how much per computer system? under $5 _____ $6-10 _____ $11-15 _____ $16-20 _____

(7) Are there other items that you would like Staples to collect? Would you be willing to pay to recycle those? *************************** STAPLES/PSI COMMERCIAL CUSTOMER SURVEY

(1) What about the program worked well?

(2) What problems, if any, did you have with the program?

(3) What suggestions would you have for future improvement?

(4) In the future, would you be willing to pay to recycle your computer equipment? If yes, how much per computer system? under $5 _____ $6-10 _____ $11-15 _____ $16-20 _____

(5) Are there other items that you would like Staples to collect? Would you be willing to pay to recycle those?

Product Stewardship Institute, Inc. - R1 - FINAL June, 2005 Staples Pilot Project –Final Report to U.S. EPA Appendix S

Appendix S. Staples Data Needs for Pilot Project

1) To identify the sample of stores and contract customers

Commercial customers  Businesses of different size (number of employees within the facility)  Businesses from various sectors (healthcare, manufacturing, etc.)  Businesses with hazardous materials management already in place vs. those without  Businesses served by Staples’ trucks vs. those served by commercial carrier  Businesses at various distances from the fulfillment center  Businesses at various distances from the transportation hubs  Businesses that do large volume Staples’ purchasing vs. lower volume  Businesses in MA (with CRT ban enforced) vs. those in other states  Businesses that participate in (or plan to participate in) other Staples collection/recycling programs vs. those that do not participate  Businesses that purchase equipment from several OEMs versus purchasing equipment from a single OEM

Retail customers  Stores serving concentrated (urban) vs. dispersed (suburban, rural) populations  Stores in a cluster of large retail electronics stores vs. one large retail electronics store for several miles  Communities with active electronics recycling programs vs. those without  Communities in MA (with CRT ban) vs. those in other states  Stores in one region so that advertising or publicity doesn’t result in customers coming with equipment to a non-participating store  Stores in locations that would be suitable for a collection “event” such as big, open lot, good access and egress from highway, ability to hold a line of traffic without obstructing through traffic  Stores at various distances from the distribution center  Stores with adequate retail space to accommodate an ongoing collections area

Internet customers  Customers within certain geographic regions (rural, urban, and/or suburban)  Customers that purchase high and/or low volumes of Staples products

Product Stewardship Institute, Inc. - S1 - FINAL June, 2005 Staples Pilot Project –Final Report to U.S. EPA Appendix S

 Customers at various distances from the recycler (if they need to ship directly to the recycler)  Customers at various distances to Staples stores (if they have the option of returning electronics to stores) 2) To Determine Operational Costs/Values

Advertising and promotion (initial and ongoing) will there be separate promotion of the collection services or will it be included in broader collection? Will it be possible to determine a value for the promotion if it is part of a larger advertising effort?

Staples staff training – Will there be training of Staples staff about the electronics recycling program, safe lifting and handling of heavy materials, handling of bare CRTs that are removed from their housing, etc? If so, can a cost or value be determined for the training?

Cost of electronics handling (value of time, etc.) – Is there a way for Staples to estimate the amount of time employees are spending on moving equipment, dealing with customer returns of equipment, stacking and loading, etc.? This should include retail store employees for managing the drop-offs from customers, delivery employees for pick-up of materials, delivery employees for material drop-off at the FCs, DCs, and transportation hubs, and logistics employees to coordinate pickups by recyclers.

Value of storage space – Does Staples have a formula for determining value of storage space at retail store and at DCs, FCs, and transportation hubs (assuming that space would not be used otherwise. If space was used before and now contains electronics for any period of time, we should calculate this as a real cost)

Value of transporting the equipment to DCs or FCs – Has Staples already determined the cost per mile (or cost per trip) for empty trucks returning to warehouses? Will it be possible to measure any additional costs for those trucks running full or partially full on the backhaul (e.g., added fuel costs, less stores/businesses on a delivery run because of additional time required to pick-up the waste electronics, etc.).

Cost of serving Internet customers – How does Staples collect information on the Internet customers (e.g. shipping charges)?

Costs of additional shipping supplies/equipment – Will Staples be able to determine costs for equipment specific to electronics collection (Gaylord containers, pallets, pallet jacks, etc.)?

Cost of processing and recycling – We will need to determine costs broken down for contractor set up at collection events, contractor transport from consolidation points to recycling facility, sorting costs (if we decide to sort by brand for vendor recycling), and recycling costs. If vendors pay for part of recycling, we will calculate the value of that service based on the cost to recycle the rest).

Product Stewardship Institute, Inc. - S2 - FINAL June, 2005 Staples Pilot Project –Final Report to U.S. EPA Appendix S

Note: For business collections, we need to determine if: 1) The transportation hub is the electronics consolidation point for the recycler or 2) The fulfillment center is the electronics consolidation point for the recycler. If this is the case then it appears there is a two-step process where Staples must collect the electronics from the business and deliver/store the electronics at the transportation hub. Staples must then pick-up the electronics at the transportation hub and transport the electronics to the fulfillment center.

3) To Evaluate Results of Pilot Project

 Quantities of electronics collected by pound (perhaps also by unit, product type, OEM, etc.)  Number of participants in the program  Satisfaction of participants, willingness to pay attitudes based on surveys  Satisfaction of employees with the pilot – suggestions for improvements  Total program costs to Staples  Total value of Staples’ (and OEMs and other key stakeholders’) services

Product Stewardship Institute, Inc. - S3 - FINAL June, 2005

Project Pilot Staples

Institute, Stewardship Inc. Product

Appendix T. Staples Internal Retail Collection Costs

Table T1. Staples Retail Pallet Costs

– Shipping/ Final Report to U.S. EPA Shipping/ National Total Handling/ Killingly $28.53/ Total Pilot National Store City/State Address State Zip Phone # Pallets $4.96 Pallet $9.67 Pallet Pallet S&H Cost S&H Cost 0187 New London, CT 292 US Rte. 1 CT 06320 860-439-1872 7 $34.72 $67.69 $102.41 0806 Old Saybrook, CT 1000 Boston Post Road CT 06475 860-395-2980 17 $84.32 $164.39 $248.71 0836 Westerly, RI 16 Post Road RI 02891 401-348-4900 6 $29.76 $58.02 $87.78 0947 Norwich, CT 45 Salem Turnpike CT 06360 860-886-8870 6 $29.76 $58.02 $87.78

0108 South Portland, ME 443 Western Avenue ME 04106 207-871-9148 32 $158.72 $309.44 $336.49

0194 Bangor, ME 1131 Union St. ME 04401 207-941-2182 20 $99.20 $193.40 $292.60 0297 Brunswick, ME Route 24 - Bath Road ME 04011 207-725-2741 23 $114.08 $222.41 $336.49 0307 Lewiston, ME 855 Lisbon Street ME 04240 207-753-0742 14 $69.44 $135.38 $204.82 0648 Bangor, ME 180 Bangor Mall Blvd. ME 04401 207-947-9225 17 $84.32 $164.39 $248.71 0871 Biddeford, ME 420 A Alfred Rd. ME 04005 207-284-7543 10 $49.60 $96.70 $146.30 1095 Falmouth, ME 244B US Route 1 ME 04105 207-781-2255 12 $59.52 $116.04 $175.56

1132 Waterville, ME 40 Waterville Commons DriveME 04901 207-873-4092 10 $49.60 $96.70 $146.30 U

1 1228 North Conway, NH 1739 White Mountain HighwayNH 03860 603-356-2666 11 $54.56 $106.37 $160.93

- 1259 N. Windham, ME 770 Roosevelt Trail ME 04062 207-892-1740 8 $39.68 $77.36 $117.04 1291 Rockland, ME 235 Camden St. ME 04841 207-596-5696 10 $49.60 $96.70 $146.30 0002 Woburn, MA 335 Washington Street MA 01801 781-932-4132 17 $84.32 $164.39 $248.71 0008 Natick, MA 881 Worcester Road MA 01760 508-655-0811 26 $128.96 $251.42 $380.38 0051 Saugus, MA 444 Broadway (Route 1) MA 01906 781-231-6860 6 $29.76 $58.02 $87.78 0167 Danvers, MA 301 Newbury Street MA 01923 978-777-9400 29 $143.84 $280.43 $424.27 0176 Portsmouth, NH 1981 Woodbury Ave and GoslingNH Rd 03801 603-431-3527 11 $54.56 $106.37 $160.93 1 Brighton,MA 1660 Soldiers Field Rd. MA 2135 617-254-3351 6 $29.76 $58.02 $87.78 0200 Needham, MA 163 Highland Ave. MA 02494 781-449-5766 16 $79.36 $154.72 $234.80 0373 Rochester, NH 106 Milton Rd. NH 03868 603-332-4421 7 $34.72 $67.69 $102.41 0394 Revere, MA 151 VFW Parkway MA 02151 781-289-8950 12 $59.52 $116.04 $175.56 0495 Danvers, MA 230 Independence way MA 01923 978-762-0152 22 $109.12 $212.74 $321.86 1100 Somersworth (Dover), NH 249 Indian Brook Drive NH 03878 603-750-0078 8 $39.68 $77.36 $117.04

FINAL 2005 June, 1124 Seabrook, NH 536 Lafayette Road NH 3874 14 $69.44 $135.38 $204.82

377 $1,869.92 $3,645.59 $10,755.81 $5,515.51 $12,625.73

Appendix T Appendix

Staples Pilot Project –Final Report to U.S. EPA Appendix U

Appendix U. U.S. EPA Regulatory Guidelines for Plug In Partners

Plug-In to eCycling Guidelines for Materials Management Purpose

As part of an effort by EPA to develop national guidance for the management of “end-of-life” electronics, the Agency has drafted the following guidelines for use in the Plug-In To eCycling Campaign. The Campaign and its pilots will be used by the Agency to “test” these guidelines and allow the Agency to have real world information about what practices will most effectively protect human health and the environment, while at the same time enabling practicable programs for management of end-of-life electronics.

These guidelines are intended to be used as a framework for considering the acceptance of partners to the Plug-In Campaign. The Agency developed these guidelines based on what we believe, on a general basis, to be the most important elements for protection of human health and the environment in managing end-of-life electronics. However, the Agency is open to the possibility that not all aspects of these guidelines are critical in all cases of end-of-life management. That is, the Agency recognizes that, on a facility-specific basis, there may be practices that do not conform with every element of these guidelines, yet these practices may also ensure the protection of human health and the environment.

Vital to the success of the Campaign, as well as any program for improved management of end- of-life electronics, is the availability of adequate markets for reuse and recycling. Thus, these guidelines are not intended to be a barrier to delivering reusable equipment or industrial feedstock materials to legitimate markets and environmentally sound facilities, wherever they exist.

Applicability of Guidelines

These guidelines are applicable to all Plug-In partners who, through contracts or other arrangements, utilize reuse, refurbishment, recycling or disposal services. Plug-In partners take appropriate due diligence measures to ensure that downstream facilities and operations use practices that are consistent with these guidelines. The guidelines are applicable to all activities

Product Stewardship Institute, Inc. - U1 - FINAL June, 2005 Staples Pilot Project –Final Report to U.S. EPA Appendix U

undertaken by a Plug-In partner, not just those that are undertaken as part of a Plug-In To eCycling pilot.

The guidelines are not written to directly address collection activities. Rather, the guidelines address activities that ensue following collection: reuse, refurbishment, recycling and disposal, as well as the responsibilities of the Plug-In partner to ensure that such activities are conducted consistent with these guidelines.

Companies or other entities that perform recycling or related processing activities (other than collection) are not eligible to become Plug-In partners at this time. In order for the Agency to form Plug-In partnerships directly with processors and recyclers, the Agency would specifically request certain data and other information from these entities and/or request that such information be kept at the facility that would document the consistency of their operations with these guidelines. In order to minimize the burden on the public for information gathering pursuant to federal activities, the Paperwork Reduction Act of 1995 requires that the Agency obtain approval from the Office of Management and Budget (OMB) for such information gathering activities. Unfortunately, development of such an information gathering request by EPA, as well as the OMB approval process, would require 6 months to a year to complete. Thus, the Agency is not now in a position to request, receive and review information from processors and recyclers regarding the consistency of their operations with these guidelines. As an alternative, it is the intent of the Agency to work towards the establishment of a third-party organization to function as an entity for review and recognition of processors and recyclers of end-of-life electronics. The Agency also will not accept as Plug-In partners entities who are primarily engaged in the landfill or incineration of end-of-life electronics, as these disposal operations are not the primary focus of the Plug-In To eCycling program.

Due Diligence

The guidelines call for due diligence efforts on the part of Plug-In partners regarding the handling and disposition of end-of-life electronics. However, the guidelines do not incorporate the same level of due diligence under all circumstances. Rather, the level of due diligence recommended is commensurate with the risk of the activities involved, as well as being aimed at fulfillment of certain waste and material management goals under Plug-In. For example, the guidelines call for due diligence to provide assurance that incineration and landfill of any form of e-waste is minimized and, if utilized, is safe; whereas, the due diligence steps for reuse, refurbishment and recycling focus on only those used electronics that contain or consist of materials that, if mismanaged, are most likely to present hazards to human health or the environment. Thus, reuse is the most favored management option, followed by recycling and, least desirable, landfilling or incineration.

Guidelines 1-4 below pertain to all end-of-life electronics for which Plug-In partners have responsibility. Among other things, guidelines 1-4 call for due diligence regarding any electronic products or components that are sent to incineration or land disposal. However, guideline 5, regarding reuse and refurbishment, and guideline 6, regarding recycling, only

Product Stewardship Institute, Inc. - U2 - FINAL June, 2005 Staples Pilot Project –Final Report to U.S. EPA Appendix U

pertain to certain “designated materials,” as defined in the relevant footnote. Designated materials are those that are of concern because they contain or consist of materials that, when mismanaged, may present hazards to human health or the environment.

Thus, no guidelines beyond those of 1-4 apply to the reuse, refurbishment or recycling of end-of- life electronics that, either in processed or unprocessed form, do not contain or consist of designated materials. The Agency encourages the processing (including sorting) of used electronics to enhance the value of output streams, often resulting in the generation of multiple commodity streams that do not contain or consist of designated materials.

Because equipment for reuse often contains designated materials, guideline 5 will be applicable to many reuse markets. However, to maximize reuse, the elements of guideline 5 are relatively simple--the Plug-In partner ensures that equipment meets legitimate reuse specifications, is packaged to protect its value, and that proper business records are kept of the transaction. The only other guideline having relevance to reuse is guideline 4(a)—the Plug-in partner ensures that export of reusable equipment is in conformance with the laws of importing and transit countries. Guidelines 1-5 are applicable to equipment for refurbishment.

GUIDELINES for MATERIALS MANAGEMENT

All electronics

1 1. The Plug-In partner ensures that reuse, refurbishment and recycling techniques are used to the full extent practicable, i.e., recognizing technical and economic feasibility, in an effort to minimize incineration and land disposal of electronic equipment and components. The Plug-In partner ensures that proper business records are kept demonstrating that incineration and land disposal are minimized.

2. Where incineration or land disposal is unavoidable, the Plug-In partner ensures that:

(a) Consideration is first given to whether the waste has value for energy recovery. For certain wastes, such as plastics, incineration with energy recovery is preferable over incineration without energy recovery or landfill. For wastes that have value for energy recovery, but for which energy recovery is technically or economically infeasible, the Plug-In partner ensures that a reasonable case of infeasibility has been made.

(b) The wastes (including those generated at refurbishment and recycling operations, smelters, etc.) are managed safely at facilities that are fully licensed for treatment and disposal purposes by all appropriate governing authorities. The Plug-In partner ensures that there is written evidence substantiating this.

(c) Landfills and incinerators have an environmental management system in place, as is described in guideline 6(b) below for certain recycling facilities.

Product Stewardship Institute, Inc. - U3 - FINAL June, 2005 Staples Pilot Project –Final Report to U.S. EPA Appendix U

3. The Plug-In partner ensures that all applicable federal and state requirements pertaining to the transport, processing and management of electronic products and components are complied with.

4. In the case of export of any electronic products and components, the Plug-In partner ensures that:

(a) Any applicable requirements of the U.S., as well as applicable requirements of importing and transit countries, are complied with, and proper business records are kept documenting such compliance.

(b) Prior to export, the materials listed below are removed and handled separately, unless:

(i) The export is for purposes of reuse or refurbishment, or

(ii) The Plug-In partner has documented and regularly monitored controls in place to assure that the materials will be removed in member countries of the OECD:

(1) Batteries. (2) Mercury- and PCB-containing lamps and devices. (3) Circuit boards, unless they are contained in hand-held electronic equipment, such as cellular phones, PDAs, etc. (Note: Under U.S. rules, minimal quantities of mercury and batteries that are protectively packaged to minimize dispersion of metal constituents do not need to be removed from whole circuit boards). (4) CRTs and CRT glass, both of which are adequately processed for use as an industrial feedstock material prior to export.

Note: The U.S. is not currently a party to the Basel Convention, although the U.S. is a member of the OECD. International trade in hazardous wastes is governed by existing agreements under both OECD and Basel, as well as by the laws of exporting, importing and transit countries. Trade in end-of-life electronics that are considered hazardous wastes intended for recovery between the U.S. and any OECD country are governed by the OECD control system, as implemented through the laws and regulations of the member countries. Because the U.S. is not a party to the Basel Convention, federal law does not yet include obligations for U.S. exporters of end-of-life electronics that are considered hazardous wastes under the Basel Convention. However, U.S. exporters should be cognizant that Basel Convention requirements could affect them, as implemented by the laws of importing and transit countries. In addition, the importing and transit countries may have other laws and regulations that could affect U.S. exporters and their transactions. Until such time as the U.S. becomes a party to the Basel Convention, no country that is a party to Basel but not a member of OECD can legally accept hazardous waste exported from the U.S. absent a bilateral agreement between the governments under Article 11 of the Basel Convention. At this time, the U.S. has no bilateral agreements with any countries

Product Stewardship Institute, Inc. - U4 - FINAL June, 2005 Staples Pilot Project –Final Report to U.S. EPA Appendix U

outside of the OECD that provide for the export of hazardous waste. Current U.S. rules regarding the export of hazardous wastes can be found at 40 CFR Part 262, Subparts E and H.

“Designated materials” for reuse or refurbishment

2 5. This guideline applies to designated materials that are directed to reuse or 3 refurbishment. However, it is only intended to apply to those shipments of designated materials (such as the following intact equipment: monitors, televisions, CRT bulbs, CPUs, laptops, printers and cell phones) that have been prescreened to meet legitimate reuse or refurbishment specifications. Unscreened shipments for evaluation of reuse/refurbishment potential and shipments containing some reusable (or refurbishable) and some non-reusable (or non-refurbishable) equipment are considered shipments for recycling and are addressed in guideline 6. In the case of refurbishment, guidelines 1-4 and 6 apply to any components that are subsequently determined to be unusable.

For designated materials that are directed to reuse or refurbishment, the Plug-In partner ensures that:

(a) All items in the shipment meet legitimate reuse or refurbishment specifications.

(b) All items in the shipment meet the specifications of the consignee.

(c) All items in the shipment are packaged in a manner that is consistent with preservation of the used equipment for reuse or refurbishment. That is, the packaging protects the used equipment in storage and transport, such that the value of the used equipment for reuse or refurbishment is not diminished.

(d) Proper business records are kept that document the transfer of the used equipment to the consignee for reuse or refurbishment purposes, including:

(i) Name and address of consignee.

(ii) Description of shipment content and conformance with consignee product specifications.

(iii) Product specifications of consignee.

(iv) If for-profit transaction, amount paid for the consigned material.

“Designated materials” for recycling

4 6. The Plug-In partner ensures that all designated materials that are directed to recycling are processed by facilities that meet the guidelines herein. The Plug-In partner ensures that

Product Stewardship Institute, Inc. - U5 - FINAL June, 2005 Staples Pilot Project –Final Report to U.S. EPA Appendix U

proper business records are kept that demonstrate that all downstream processing and recycling operations, including smelters, that receive designated materials, use practices that are consistent with these guidelines. For any processing and recycling facilities that receive designated materials, the Plug-In partner ensures that:

(a) Facilities are fully licensed by all appropriate governing authorities. The degree of licensing necessary will vary depending upon the particular jurisdiction, as well as the size and nature of the facility. In some cases, extensive environmental permitting may be required by the governmental authorities, whereas in other cases perhaps only a business license is needed.

(b) Facilities have an environmental management system (EMS) in place. EPA recognizes that flexibility for small businesses is necessary and that, in some cases, a fully developed and certified EMS may be unnecessary. In lieu of a fully developed and certified EMS (e.g., using ISO, EMAS or industry standards, such as those of the IAER), a facility has a written plan describing the facility’s risk management objectives for environmental performance and compliance and its plans for attaining these objectives based on a “plan-do-check-act” continual improvement model. Regular re-evaluation of environment, health and safety (EH&S) objectives and monitoring of progress toward achievement of these objectives is conducted and documented at all facilities. EPA also recognizes that a fully developed EMS may not yet be in place for many facilities. In any case, a written plan describing risk management objectives and plans for attainment based on a “plan-do-check-act” model is in place.

(c) Facilities take sufficient measures to safeguard occupational and environmental health and safety. Such measures may be indicated by local, state, national and international regulations, agreements, principles and standards, as well as by industry standards and guidelines. Except as noted below, such measures for all facilities include:

i. EH&S training of personnel.

ii. An up-to-date, written hazardous materials identification and management plan that specifically addresses at least the following: lead, mercury, beryllium, cadmium, batteries, toner, phosphor compounds, PCBs, and brominated flame retardants and other halogenated materials, with particular focus on possible generation of by-product dioxins and furans.

iii. Where materials are shredded or heated, appropriate measures to protect workers, the general public and the environment from hazardous dusts and emissions. Such measures include adaptations in equipment design or operational practices, air flow controls, personal protective devices for workers, pollution control equipment or a combination of these measures.

Product Stewardship Institute, Inc. - U6 - FINAL June, 2005 Staples Pilot Project –Final Report to U.S. EPA Appendix U

iv. An up-to-date, written plan for reporting and responding to exceptional pollutant releases, including emergencies such as accidents, spills, fires, and explosions.

v. Liability insurance for pollutant releases, accidents and other emergencies.

vi. Completion of an EH&S audit, preferably by a recognized independent auditor, on an annual basis. However, for small businesses, greater flexibility may be needed, and an audit every three years may be appropriate.

(d) Facilities have a regularly-implemented and documented monitoring and recordkeeping program that tracks key process parameters, compliance with relevant safety procedures, effluents and emissions, and incoming, stored and outgoing materials and wastes.

(e) Facilities have an adequate plan for closure. The need for closure plans and financial guarantees is determined by applicable laws and regulations, taking into consideration the level of risk. Closure plans should be updated periodically, and financial guarantees should ensure that the necessary measures are undertaken upon definite cessation of activities to prevent any environmental damage and return the site of operation to a satisfactory state, as required by the applicable laws and regulations.

1 “Plug-In partner” means a manufacturer, retailer, government agency, non-profit, or other entity who (1) is not a recycler nor performs recycling activities (other than collection), (2) through contracts or other arrangements, utilizes reuse, refurbishment, recycling or disposal services, and (3) has a Plug-In To eCycling partnership agreement with EPA.

2 “Designated materials” means any electronic products and components containing or consisting of circuit boards, shredded circuit boards, CRTs, batteries, and mercury- and PCB-containing lamps and devices. However, this definition does not include circuit boards that have been processed to the point where they no longer are readily identifiable as circuit boards or shredded circuit boards (such as after burning/melting), as well as CRT glass that has been adequately processed for use as an industrial feedstock material. In these cases, the economic value of the material has been enhanced significantly through processing; thus, commodities of value have been created and concern for the subsequent environmental mismanagement of this material is greatly decreased.

3 “Refurbishment” means the repair, reconditioning or upgrading of an end-of-life product or component for the purpose of equipment reuse. Refurbishment of end-of-life electronics includes replacement of components or parts that are part of a larger piece of electronic equipment, aesthetic improvements, such as polishing and removal of scratches, and upgrading of the equipment by installation of new operating systems, memory, or software.

4 “Recycling” facilities include any non-disposal facilities that receive designated materials under

Product Stewardship Institute, Inc. - U7 - FINAL June, 2005 Staples Pilot Project –Final Report to U.S. EPA Appendix U

conditions that do not conform with guideline 5 above for legitimate reuse or refurbishment.

Product Stewardship Institute, Inc. - U8 - FINAL June, 2005 Staples Pilot Project –Final Report to U.S. EPA Appendix V

Appendix V.

Connecticut Department of Environmental Protection

Product Stewardship Institute, Inc. - V1 - FINAL June, 2005 Staples Pilot Project –Final Report to U.S. EPA Appendix V

Product Stewardship Institute, Inc. - V2 - FINAL June, 2005 Staples Pilot Project –Final Report to U.S. EPA Appendix V

Universal Waste Rule Connecticut Department of Environmental Protection Fact Sheet (Excerpts) Purpose This fact sheet is designed to answer general questions and provide basic information on management of universal wastes in Connecticut, and is not intended to supersede the applicable regulations. The information provided below addresses the requirements applicable only to large quantity handlers (LQH) and small quantity handlers (SQH) of universal wastes. The universal waste rule requirements are found in Section 22a-449(c)-113 of the Regulations of Connecticut State Agencies (RCSA), effective as of June 27, 2002. It incorporates 40 CFR (Code of Federal Regulations) 273 in its entirety except for following provision that is not incorporated: 40 CFR 273.32(a)(3) (regarding an exemption from notification requirements for large quantity handlers of recalled universal waste pesticides). It is your responsibility to comply with all applicable laws and regulations. The state has modified certain federal requirements making the program more stringent in certain sections. For the specific modifications, refer to the above noted web site.

What is the Universal Waste Rule? The Universal Waste Rule provides a set of streamlined regulations to reduce the regulatory burden by allowing longer time for the storage of the wastes, reduced record-keeping requirements and consolidation off-site without a permit. Universal wastes are:

1. Generated in a wide variety of settings other than the industrial settings usually associated with hazardous wastes; 2. Generated by a vast community (typically greater than 1,000 sources); 3. May be present in significant volumes in non-hazardous waste management systems. Why did EPA develop the Universal Waste Rule and DEP adopt the rule?

1. There are three general goals that EPA had when it developed the streamlined universal waste regulations: 2. To encourage resource conservation while ensuring adequate protection of human health and the environment; 3. To improve implementation of the current Subtitle C hazardous waste regulatory program; 4. To provide incentives for individuals and organizations to collect the unregulated portions of these universal waste streams and manage them using the same systems developed for the regulated portion, thus removing them from the municipal waste stream. Although EPA’s primary goal for the universal waste program is to encourage recycling, batteries, thermostats, pesticides, lamps and used electronics being sent for disposal may also be managed under the universal waste regulations.

What wastes are subject to the Universal Waste Rule? 40 CFR 273.1 and Sections 22a-449(c)- 113(a)(2)(B) of the RCSA

Product Stewardship Institute, Inc. - V3 - FINAL June, 2005 Staples Pilot Project –Final Report to U.S. EPA Appendix V

There are five waste streams that can be managed as a universal waste in Connecticut. These universal wastes are:

 Batteries,  Mercury-containing thermostats,  Certain pesticides,  Lamps (including but not limited to fluorescent, neon and mercury vapor lamps), and  Used electronics. How long can I store Universal Wastes on-site? 40 CFR 273.15 and 40 CFR 273.35 In general, a handler can store a universal waste on-site for no longer than one year from the date the universal waste is generated, or received from another handler.

How much can I store on-site? 40 CFR 273.6 A small quantity handler can accumulate not more than 5000 kilograms total of universal waste (batteries, pesticides, thermostats, lamps and used electronics collectively) at any time.

A large quantity handler can accumulate 5000 kilograms or more of universal waste (batteries, pesticides, thermostats, lamps and used electronics collectively) at any time.

When does the time limit begin? 40 CFR 262.34(a)(2) In general, the time limit begins when the generator first determines that the universal waste is a waste. It must be marked, labeled and dated at that time.

What are the universal waste labeling and marking requirements? 40 CFR 273.14 and 273.34 with modifications under Section 22a-449(c)-113(a)(2)(I) &(T) of the RCSA and Sections 22a-449(c)-113(c) and (d) of the RCSA. A generator must follow the labeling and marking requirements as outlined below:

Universal waste batteries (each battery) or a container in which the batteries are contained must be labeled or marked clearly with any of the following: “Universal Waste - Battery(ies)” or “Waste Battery(ies), or “Used Battery(ies)”.

Universal waste lamps (each lamp) or a container or package in which such lamps are contained must be labeled or marked clearly with any of the following: “Universal Waste - Lamp(s)” or “Waste Lamp(s), or “Used Lamp(s)”.

Universal waste used electronics (each piece of equipment) or a container, package or pallet in which the used electronics are contained must be labeled or marked clearly with any of the following: “Universal Waste - used electronics” or “Waste Used Electronics, or “Used Electronics”.

What are the requirements for areas where universal wastes are stored? 40 CFR 273.13 and 273.33 with modifications in Section 22a-449(c)-113(F), (G), (H), (Q), (R) and (S) of the RCSA and Section 22a-449(c)-113(c) and (d) of the RCSA.

A handler must manage universal wastes in a way that prevents releases of any universal waste or component, or constituent of a universal waste to the environment. Universal waste pesticides, lamps and thermostats must be stored in a container. A handler must contain any universal waste battery that shows evidence of leakage, spillage or damage that could cause leakage in a container. A handler must place and

Product Stewardship Institute, Inc. - V4 - FINAL June, 2005 Staples Pilot Project –Final Report to U.S. EPA Appendix V

keep any universal waste thermostats in a container. All containers for universal waste must be closed, structurally sound, compatible with the contents of the universal waste, and must be capable of preventing leakage, spillage or damage that could cause leakage.

Used electronics must be stored in a building with a roof and four walls or in a cargo carrying portion of a truck, in a manner to prevent used electronics from being exposed to the environment. The used electronics must be handled, stored and transported in a manner that maintains the reuse or recyclability of the used electronic. A handler must immediately clean up and contain any broken cathode ray tube and place in a container that is closed, structurally sound and compatible with the CRT. It should prevent leakage, spillage or releases of broken CRTs, glass particles or other hazardous constituents from such broken tubes to the environment. A handler must not shred, crush, heat or otherwise treat used electronics. A small quantity handler may disassemble used electronics for the sole purpose of marketing, reselling, reusing or recycling components. A large quantity handler must first obtain a permit issued by the commissioner before disassembling used electronics.

Adequate aisle space must be maintained around the containers to allow unobstructed movement of personnel and emergency response equipment. A minimum of 30-inch aisle space is recommended.

Handlers of universal waste must immediately contain all releases of universal wastes and other residues from universal wastes. A handler must determine whether any material resulting from the release (e.g., spilled material, residue, absorbent) is hazardous wastes, and if so, must manage that material as a hazardous waste. The handler is considered the generator of the material resulting from the release and is treated as a hazardous waste generator.

What are the requirements when shipping universal waste off-site? RCSA Section 22a-449(c)- 113(a)(1) incorporating 40 CFR 273.18 and 40 CFR 273.38 with modifications under 22a-449(c)- 113(a)(2)(L),(M),(W) and (X).

You are prohibited from sending or taking universal waste to a place other than another universal waste handler, a destination facility (including a RCRA treatment, storage, disposal facility), or a foreign destination.

If you self-transport universal waste off-site, you become a universal waste transporter and must comply with all universal waste transporter regulations under Subpart D and F of 40 CFR 273.

If your universal waste meets the definition of hazardous materials under 49 CFR 171 through 180, you must package, label, mark and placard the shipment, and prepare the proper shipping papers in accordance with DOT regulations under 49 CFR parts 172 through 180.

Before sending universal waste to another universal waste handler, you must ensure that the receiving handler will receive the shipment.

If you send a shipment of universal waste to another handler or to a destination facility and the shipment is rejected, you must either receive the waste back or agree on a destination facility to which the shipment will be sent.

You may reject a shipment of universal waste to your site. If you do so, you must inform the original handler. You must send the shipment back to the original handler or send the shipment to a destination facility agreed to by both the originating and receiving handler.

Product Stewardship Institute, Inc. - V5 - FINAL June, 2005 Staples Pilot Project –Final Report to U.S. EPA Appendix V

If you receive a shipment of hazardous waste that cannot be managed as a universal waste, you must notify EPA of the illegal shipment and provide the necessary information to EPA. If you receive a shipment of non-hazardous, non-universal waste, the handler may manage the waste in compliance with federal, state or local solid waste regulations.

How do I track my universal waste shipments? RCSA Section 22a-449(c)-113(a)(2)(Y) and (Z) incorporating 40 CFR 273.19; 273.39.

Universal waste does not count toward generator status. Universal wastes do not need to be shipped on a manifest.

A small quantity handler of universal waste is not required to keep records of shipments of universal wastes unless the waste is being exported to a foreign destination.

A large quantity handler of universal waste must keep a record of each universal waste shipment received at the facility. In addition, a large quantity handler of universal waste must keep a record of each universal waste shipment sent from the handler to other facilities. Each record may be in the form of a log, invoice, manifest, bill of lading or other shipping document. The records must include the following information: name and address of the original handler, quantity of each type of universal waste shipped or received, date of shipment or receipt. You must retain all of these records for at least three years from the date of receipt of shipment or the date a shipment of universal waste left the facility.

What are the employee training requirements? A small quantity handler of universal waste must inform all employees who handle or have responsibility for managing universal waste. The information must describe proper handling and emergency procedures appropriate to the type(s) of universal waste handled at the facility.

A large quantity handler of universal waste must ensure that all employees are thoroughly familiar with the proper waste handling and emergency procedures, relative to their responsibilities during normal facility operations and emergencies.

Where can I obtain additional information? For further information on this program, visit our web site www.dep.state.ct.us/wst/hw/hwregs.htm or by contacting DEP’s Waste Engineering and Enforcement Division through COMPASS (Compliance Assistance) at (888) 424-4193 or mail to:

Connecticut Department of Environmental Protection Bureau of Waste Management Engineering and Enforcement Division 79 Elm Street Hartford, CT 06106-5127

September 2002

Product Stewardship Institute, Inc. - V6 - FINAL June, 2005 Staples Pilot Project –Final Report to U.S. EPA Appendix W

Appendix W. Maine Department Of Environmental Protection

Product Stewardship Institute, Inc. - W1 - FINAL June, 2005 Staples Pilot Project –Final Report to U.S. EPA Appendix W

Product Stewardship Institute, Inc. - W2 - FINAL June, 2005 Staples Pilot Project –Final Report to U.S. EPA Appendix W

Product Stewardship Institute, Inc. - W3 - FINAL June, 2005 Staples Pilot Project –Final Report to U.S. EPA Appendix W

Product Stewardship Institute, Inc. - W4 - FINAL June, 2005 Staples Pilot Project –Final Report to U.S. EPA Appendix X

Appendix X. Massachusetts Department of Environmental Protection

Product Stewardship Institute, Inc. - X1 - FINAL June, 2005 Staples Pilot Project –Final Report to U.S. EPA Appendix X

Product Stewardship Institute, Inc. - X2 - FINAL June, 2005 Staples Pilot Project –Final Report to U.S. EPA Appendix X

Product Stewardship Institute, Inc. - X3 - FINAL June, 2005 Staples Pilot Project –Final Report to U.S. EPA Appendix X

COMMONWEALTH OF MASSACHUSETTS EXECUTIVE OFFICE OF ENVIRONMENTAL AFFAIRS DEPARTMENT OF ENVIRONMENTAL PROTECTION ONE WINTER STREET, BOSTON, MA 02108, 617-292-5500

Questions and Answers Regarding Massachusetts DEP’s Cathode Tube Regulations

The following is regulatory guidance for the handling of discarded CRT in accordance with Department’s regulations for this waste stream, which appear at 310 CMR 16.02, 16.05, 19.043(5)(k), 30.010 and 30.104.

What is a CRT? A CRT is the picture tube made of glass, lead and other materials found inside televisions, computer monitors and some video game units.

What should a resident do with a used or obsolete TV or computer monitor? First, consider giving your TV or computer monitor to some person or organization, either a local school system or non-profit organization that can use it. If the unit is very old, broken, or simply obsolete it needs to be properly recycled or disposed of.

Second, residents should call their municipal Department of Public Works or Board of Health to determine how TV sets and computer monitors are being handled in their community. In many cases, communities with curbside trash and recycling collection will schedule specific collection dates during the year for TVs and computer monitors just as they do for refrigerators, stoves, and other household appliances. Communities with drop-off collection of trash and recyclables will often designate a collection site for TVs and monitors at the drop-off facility. The DEP provides grant funding to many municipalities for the proper handling of CRTs. However, municipal programs set their own collection schedules, hours of operation, and collection procedures. Residents are advised to call their municipal program first to obtain updated information.

Residents who live in a city or town without municipal trash or recycling collection need to make their own arrangements for the proper recycling or disposal of TVs and computer monitors. The DEP provides information to assist residents in locating a recycling company or non-profit organization.

Consult the DEP’s “Recycling Services Directory and Markets Guide for Massachusetts” for a list of companies that handle TVs, computer monitors and other kinds of used electronic equipment. (www.state.ma.us/dep/recycle/rsd/rsd.htm) Locate the listing for “Computers and Electronic Equipment”.

When a company upgrades its computer system, are the old CRTs regulated by DEP? As long as the company sends the CRTs to someone who will determine whether to reuse, resell or repair them for return to service as operable CRTs, or pass them on to someone else who will make this determination, the old CRTs are a “commodity” and are not regulated by DEP.

Product Stewardship Institute, Inc. - X4 - FINAL June, 2005 Staples Pilot Project –Final Report to U.S. EPA Appendix X

When are CRTs regulated by DEP as a solid or hazardous waste? A CRT is regulated as a hazardous waste once it has been crushed or when it is disposed intact. Note: hazardous waste rules do not apply to households. Additional rules apply to companies that accumulate “non-commodity CRTs,” which are CRTs that have been determined will not be returned to service as operable CRTs. Companies that accumulate non-commodity CRTs are regulated under the solid waste regulations as “CRT Operations,” the requirements for which are described below.

How are monochrome CRTs regulated under DEP’s new CRT regulations? DEP’s position that monochrome CRTs are non-hazardous has not changed. Monochrome CRTs are, however, subject to the solid waste disposal ban that took effect April 1, 2000.

What’s the difference between a “commodity CRT” and a “non-commodity CRT”? A commodity CRT is a CRT that is in use or a CRT for which a determination regarding its future use has not yet been made by another party, such as a CRT repair expert. A commodity CRT may include working CRTs as well as non-working CRTs which are repairable by a CRT professional. Non-commodity CRTs are CRTs that have been determined will definitely not be returned to service.

Some of the CRTs my company wants to get rid of are not working and may not be returned to service. Is my company a “CRT Operation” because it may be accumulating “non-commodity CRTs”? No, your company would not be subject to the rules for CRT Operations unless it makes a decision that a CRT will definitely not be returned to service.

How can a company or municipal collection program avoid becoming a CRT Operation inadvertently by accumulating a non-commodity CRT(s)? DEP does not expect most CRT users to be experts in determining whether an inoperable CRT can be repaired and returned to service. This determination should be deferred to a CRT repair expert. As long as this determination is deferred to a CRT operation or CRT repair expert, a company or municipal collection program is not subject to regulation as a CRT Operation.

What if a company, municipal collection program or charity elects to make the determination that its CRTs are “non-commodity CRTs”? In the event that a determination is made that a CRT will not be returned to service, it must be managed in accordance with the solid waste requirements for “CRT Operations” which appear at 310 CMR 16.05(3)(f): Conditionally Exempt Recycling Operations.

A CRT Operation that accumulates up to 40 tons of non-commodity CRTs must:  Minimize breakage,  Segregate its non-commodity CRTs from solid waste,  Comply with RCRA export rules for shipments to foreign countries,  Transfer its CRTs only to another CRT operation, recycler or hazardous waste facility (TSDF),  Hold CRTs no longer than 1 year, and

Product Stewardship Institute, Inc. - X5 - FINAL June, 2005 Staples Pilot Project –Final Report to U.S. EPA Appendix X

 Label its CRTs. A CRT Operation that holds 40 tons of non-commodity CRTs for more than 21 days must also:  Notify DEP  Maintain shipping records and accumulation duration records for 3 years I own/operate a CRT Operation and may occasionally need to store my non-commodity CRTs for more than a year. Is this allowable, and if so, how would I demonstrate to DEP the need to exceed the 1-year limit? A CRT Operation may store CRTs for more than one year when it is necessary to facilitate proper shipment (e.g. economically viable loads), recovery, treatment or disposal. Since you are required to demonstrate the need for more than one year of storage, DEP recommends that companies maintain records for non-commodity CRT accumulation in accordance with good business practices. These could include records ordinarily kept by businesses such as a log, written communications (including signed contracts) or copies of shipping documents such as bills of lading or receipts.

My company handles commodity CRTs exclusively (e.g. CRTs that are no longer needed by their original users) but is concerned that a DEP inspector might ask us to prove they are not “non-commodity CRTs.” What should we do? DEP recommends, but does not require, that companies maintain records for commodity CRTs in accordance with good business practices. These could include records ordinarily kept by businesses such as a log, inventory, written communications (including signed contracts) or copies of shipping documents such as bills of lading or receipts.

DEP’s CRT regulations state that a CRT Operation that accumulates more than 40 tons of non- commodity CRTs (for more than 21 days) must notify DEP of its activity and comply with other additional requirements. What volume of CRTs does 40 tons translate to? 40 tons translates to approximately two full tractor trailer loads of CRTs. For the purposes of determining whether the 40- ton limit has been exceeded, the DEP does not make a distinction between CRT monitors that are intact and those CRTs whose glass is intact but have been stripped of the plastic housing.

If I choose not to send my company’s CRTs to a facility for reuse, repair or to a CRT Operation for potential recycling, and instead decide to dispose of the CRTs, what shipping and other requirements apply? Since there is a disposal ban on sending CRTs to a solid waste facility, you would have to send the CRTs to a hazardous waste treatment, storage or disposal facility (TSDF). CRT shipments to a TSDF must be made in accordance with applicable hazardous waste regulations found at 310 CMR 30.000. CRTs shipped into other States become subject to those other States’ requirements.

What do I do with a CRT that has broken accidentally? Incidental numbers of CRTs that are visibly broken and substantially intact (i.e. cracked and slightly damaged) may be managed as commodity CRTs. Greater than incidental numbers of such CRTs must be managed as either non-commodity CRTs or as a hazardous waste. Incidental numbers of broken CRTs that are significantly damaged (i.e. broken into pieces) resulting from

Product Stewardship Institute, Inc. - X6 - FINAL June, 2005 Staples Pilot Project –Final Report to U.S. EPA Appendix X

unintentional breakage during routine handling and transportation may be shipped off-site as non-commodity CRTs provided that the broken CRTs are handled in a manner that is protective of worker health and safety. Greater than incidental numbers of such CRTs must be managed as hazardous waste.

Product Stewardship Institute, Inc. - X7 - FINAL June, 2005 Staples Pilot Project –Final Report to U.S. EPA Appendix Y

Appendix Y. New Hampshire Department of Environmental Services

Product Stewardship Institute, Inc. - Y1 - FINAL June, 2005 Staples Pilot Project –Final Report to U.S. EPA Appendix Z

Product Stewardship Institute, Inc. - Y2 - FINAL June, 2005 Staples Pilot Project –Final Report to U.S. EPA Appendix Z

Product Stewardship Institute, Inc. - Y3 - FINAL June, 2005 Staples Pilot Project –Final Report to U.S. EPA Appendix Z

WMD-HW-25 2002

Proper Management of Cathode Ray Tubes from Computer Monitors and Televisions

What is a Cathode Ray Tube? A cathode ray tube (CRT) is the video display unit found in televisions and computer monitors. A picture is created when a stream of electrons travels through a tube and lights up a phosphor coating on the glass face. There are two waste management issues associated with CRTs: the impact on the environment/health issues attributed to high amounts of lead and glass under pressure, and society’s ability to deal with a growing number of discarded items. For these reasons, it is important to properly manage CRTs and then send them to appropriate locations for recycling, reuse, or disposal.

How are CRTs regulated? A household CRT is considered solid waste and is subject to the New Hampshire Solid Waste Rules, up to the point it is separated from other household wastes. A CRT generated by a business, or separated from the disposal waste stream falls within the State’s Universal Waste Rule, which became effective on October 13, 2001 (Env-Wm 1101-1114 of the New Hampshire Hazardous Waste Rules). The Universal Waste Rule sets management standards for commonly generated items based upon their relative risk and includes common consumer items such as fluorescent lamps, thermometers, thermostats and antifreeze. The Universal Waste Rule streamlines the more stringent hazardous waste regulations that would otherwise apply to a waste CRT.

The Growing Waste Stream According to the U.S. Environmental Protection Agency (EPA), monitors make up 11percent of the electronics waste stream. In a 1995 study, it is also estimated that CRTs contribute 28 percent of the lead found in the entire municipal waste stream, a figure that is expected to jump to 30 percent when numbers for 2000 become available. In the next ten years, it is estimated that 315 million computers will inundate the national waste infrastructure, with about 1.5 million units impacting New Hampshire.

Approximately 95 percent of discarded computers end up in the solid waste stream, headed for disposal or treatment in landfills and incinerators. Additionally, the television industry is bracing for a change to digital broadcasts, scheduled to happen after 2006, which means existing televisions will need to be replaced or upgraded.

Product Stewardship Institute, Inc. - Y4 - FINAL June, 2005 Staples Pilot Project –Final Report to U.S. EPA Appendix Z

Health and Environmental Concerns Computer monitors and televisions are heavy and extremely bulky, and a typical monitor can weigh as much as 35-70 pounds, occupying significant storage space. In fact, the very bulk of these items has created problems for handlers in terms of back strain and injuries due to dropping. Also, the CRTs in monitors and televisions contain lead in the tube, neck and the enclosed glass seal (“frit”). According to a recent study, the funnel alone can contain as much as 75 ppm of leachable lead as determined through a toxicity characteristic leaching procedure. A typical 27” television can have up to 8 pounds of lead.

Requirements for Households Households are not required to recycle their CRTs, although it is certainly recommended. The local transfer station/recycling center is often the recipient of these household computers and televisions, which usually end up in the disposal container or the metal recycling bin. If the municipality separates the materials from the disposable trash, they must treat the computers as universal waste, store the computers, and arrange for their transportation to alternate locations. If the community has a “swap shop,” there is the greater likelihood of reuse of the entire unit or parts by local repair shops and other consumers. Consumers should check with their local facility for specific acceptance requirements.

Finally, there are several “takeback” programs, where manufacturers or retail establishments will accept monitors and televisions, either free of charge or for a fee ranging from $7-$30.00 (e.g., IBM and Hewlett Packard). Contact the New Hampshire Department of Environmental Services (DES) at 271- 6847 for specific vendors and programs, or visit the DES website at www.des.state.nh.us/pcas.

Product Stewardship Institute, Inc. - Y5 - FINAL June, 2005 Staples Pilot Project –Final Report to U.S. EPA Appendix Z

Requirements for Businesses (Universal Waste The Informed Consumer Handlers) CRTs from a business are considered a universal waste once they When upgrading your are no longer usable or repairable. Thus, the CRT will either need to computer, consider keeping be recycled or donated (working), or sent to a hazardous waste your old monitor. Since most disposal facility. For vendor information and specific rules for monitors made within the last universal waste (Env-Wm 1101-1114), contact the DES at 271-6847 five years are compatible with or visit the website at www.des.state.nh.us/pcas. today’s computers, you can

save a significant amount of CRTs should be stored in a manner that does not pose a hazard to money by using your current health or the environment. Unless the universal waste handler meets unit. the requirements of Env-Wm 1113.03 of the Hazardous Waste Rules, CRTs must not be broken. Those CRTs that are broken should be stored in non-leaking containers. Each CRT must be labeled with the words “Waste Cathode Ray Tube,” “Used Cathode Ray Tube(s),” or

“Universal Waste - Cathode Ray Tube(s).”

Requirements for Facilities that Process Electronic Wastes If electronic equipment wastes (including CRTs) are collected from households or businesses, a solid waste permit may be needed. If the activity is simply repairing and reselling or donating electronic equipment, then no permit is necessary. If there is actual dismantling of the electronic equipment for recycling or disposal, a solid waste facility permit is required. Contact the DES Solid Waste Bureau at 271-2925 for permit information.

Product Stewardship Institute, Inc. - Y6 - FINAL June, 2005 Staples Pilot Project –Final Report to U.S. EPA Appendix Z

Appendix Z. Rhode Island Department Of Environmental Management

Product Stewardship Institute, Inc. - Z1 - FINAL June, 2005 Staples Pilot Project –Final Report to U.S. EPA Appendix Z

Product Stewardship Institute, Inc. - Z2 - FINAL June, 2005 Staples Pilot Project –Final Report to U.S. EPA Appendix Z

Product Stewardship Institute, Inc. - Z3 - FINAL June, 2005 Staples Pilot Project –Final Report to U.S. EPA Appendix AA

Appendix AA. Computer Manufacturers

Apple Computer Inc. Brother International Corp. Brian Miller, Corporate Manager Bill Epperson Environmental Health & Safety Director of Sales Apple p: 603 964-1530 1 Infinite Loop, MS: 35-EHS [email protected] Cupertino, CA 95104 p: 408 974-7629 c: 408 640-9014 Henry Sacco [email protected] Chief Legal Officer (908) 252-3029 (ph) [email protected]

Canon Dell Mario J. Rufino, Senior Chemical Safety Engineer Pat Nathan Environmental Management and Product Safety Vice President, Corporate Social Responsibility Department (EMPS) Dell Canon U.S.A., Inc. One Dell Way One Canon Plaza Round Rock, TX 78682 Lake Success, NY 11042 p: 512 728-1479 p: 516 328-5610 [email protected] f: 516 328-5169 [email protected] Shari Carle Sustainable Business Analyst [email protected] 512-728-4980 (ph) 512-907-5700 (pager)

Mike Watson Program Manager, Dell Asset Recovery Services [email protected]

Epson America, Inc. Gateway Shelby Houston Donald McClellan Manager, Customer Programs Vice President [email protected] Gateway, Inc. 562-290-5445 (ph) 707 D Street NW Washington, DC 20004 George Lundberg [email protected] Environmental and Safety Engineer Epson Portland Inc. 3950 NW Aloclek Place Hillsboro, OR 97124 p: 503 617-5607 f: 503 617-6746 [email protected]

Product Stewardship Institute, Inc. - AA1 - FINAL June, 2005 Staples Pilot Project –Final Report to U.S. EPA Appendix AA

Hewlett-Packard IBM Renee St. Denis Tim Mann [email protected] Program Manager, Product Environmental Policy 916-785-8034 IBM Corporation 8660 Maidstone Court David Isaacs Largo, FL 33777 Manager, Environmental Policy p: 877 247-8964 Hewlett-Packard Company [email protected] 900 17th Street, NW -- Suite 1100 Washington, DC 20006 p: 202 884-7033 [email protected]

Kevin Farnam f: 281-514-8254

Intel Lexmark International, Inc. Allen Wilson Patrick Brewer Manager, EH&S Manager Government Affairs [email protected] 740 West New Circle Road 480-715-2390 (ph) Lexington, KY 40550 [email protected]

Tonya Jackson Manager, Environmental, Health & Safety Lexmark 740 West New Circle Road Lexington, KY 40550 p: 859 232-7925 [email protected]

NEC Panasonic Toshio Nakajima David A. Thompson President and CEO Corporate Headquarters General Manager NEC Electronics America Inc. Corporate Environmental Department, 3G-4 2880 Scott Boulevard Matsushita Electric Corporation of America Santa Clara, CA 95050-2554 One Panasonic Way Secaucus, NJ 07094 p: 201 271-3486 f: 201 348-7686 [email protected]

Sharp Electronics Corporation Sony Frank Marella Mark Small Manager, Corporate Environmental Affairs Sony Corporation Sharp Electronics Corporation 16450 W. Berardo Drive/MZ7160 One Sharp Plaza San Diego, CA 92127 Mahwah, NJ 07430 858-942-2729 p: 201 529-9408 [email protected] f: 201 529-8425 [email protected]

Product Stewardship Institute, Inc. - AA2 - FINAL June, 2005