There are some pretty big things to consider before calling IBM.
First things first. I'm not sure what consumer waste means. If the author means consumer waste is stufff like office products or equipment, then yeah, in the office or business situation, consumer waste is not exempt.
But if the author means household waste, (waste generated in private households and the like), then the waste is specifically exempted from being a hazardous waste in most states (reg. cite 40 CFR 261.4(b)).
That means if the waste was generated at home, it ain't hazardous, but the same material generated in a business could be hazardous. This is pretty complex stuff, so ask a regulator or a consultant like me.
As for the actual IBM service: On the surface, this looks pretty appealing. Most businesses, unless they are considered "conditional exempt" need to think things through very carefully before using a service like this. It turns out that if IBM screws up, then you, not IBM bears a big chunk of the liability.
Additionally, if your business is governed by RCRA, then you may be getting yourself into the scrap metal and recycling rules of 40 CFR. These things are pretty scary. In short, talk to you regualtory agency before using this kind of service. Even the way you internally manage the old computers can change what is okay and not okay to send off site for recycling. Just ask AT&T -- They were recently popped 190K for not providing the right answers to EPA region 2.
What does this all mean? 1) This could be a good way to get rid of your old computers and parts, but (to be safe) look to charities that won't be scrapping or reclaiming materials from your old equipment. This will keep you away from the gray areas. 2) If you aren't sure your okay. Look in the regs. Ignorance does not reduce liability, and scrap and recycling are tough to work with under RCRA. 3)Computers, batteries, and parts are one of the uberheadaches of RCRA (second only to chemical weapons disposal -- this I know) so be careful, and talk to your regulator.
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There are some pretty big things to consider before calling IBM.
First things first. I'm not sure what consumer waste means. If the author means consumer waste is stufff like office products or equipment, then yeah, in the office or business situation, consumer waste is not exempt.
But if the author means household waste, (waste generated in private households and the like), then the waste is specifically exempted from being a hazardous waste in most states (reg. cite 40 CFR 261.4(b)).
That means if the waste was generated at home, it ain't hazardous, but the same material generated in a business could be hazardous. This is pretty complex stuff, so ask a regulator or a consultant like me.
As for the actual IBM service: On the surface, this looks pretty appealing. Most businesses, unless they are considered "conditional exempt" need to think things through very carefully before using a service like this. It turns out that if IBM screws up, then you, not IBM bears a big chunk of the liability.
Additionally, if your business is governed by RCRA, then you may be getting yourself into the scrap metal and recycling rules of 40 CFR. These things are pretty scary. In short, talk to you regualtory agency before using this kind of service. Even the way you internally manage the old computers can change what is okay and not okay to send off site for recycling. Just ask AT&T -- They were recently popped 190K for not providing the right answers to EPA region 2.
What does this all mean? 1) This could be a good way to get rid of your old computers and parts, but (to be safe) look to charities that won't be scrapping or reclaiming materials from your old equipment. This will keep you away from the gray areas. 2) If you aren't sure your okay. Look in the regs. Ignorance does not reduce liability, and scrap and recycling are tough to work with under RCRA. 3)Computers, batteries, and parts are one of the uberheadaches of RCRA (second only to chemical weapons disposal -- this I know) so be careful, and talk to your regulator.
Later,
Fred b.
compliance thug.