Draft:  April 16, 2003

Environmentally Preferable Procurement Guidelines for Electronic Products

(Prepared by Computer TakeBack Campaign
in collaboration with Health Care Without Harm)

It is well recognized that over the past few decades, high tech manufacturers have produced millions of electronic products that have provided greater efficiency, convenience and productivity to human endeavors.  Unfortunately, what is less known is that the manufacture, use and disposal of electronic products has a broad range of adverse environmental and health impacts.  The procurement guidelines listed below provide the first steps that need to be taken to minimize the environmental and public health threats of electronic products as well as stimulate market demand for environmentally safe electronic products. 

Experience shows it is instructive to use life-cycle costing practices that incorporate end-of-life disposal costs into the full cost of electronic products to an institutional buyer. This allows the purchasing manager to compare the costs of end-of-life disposal of an electronic product (which must be done as hazardous waste in most states) to the benefits of requiring the vendor to take back the equipment at end of useful life. 

These guidelines are organized into three categories:

1.     End of Life Management

   Due to the higher sales and shorter life spans of electronic products, electronic waste has become the world’s fastest growing waste stream.  The National Safety Council predicts that in the U.S. between 315 million and 680 million computers will become obsolete within the next few years[1]. In California alone, 6,000 computers become obsolete everyday[2].   Less than ten percent of discarded computers are currently recycled, with the remainder stockpiled or improperly disposed of in landfills or incinerators.  Fifty to eighty percent of the e-waste collected for recycling is being exported to Asian countries with no infrastructure to accommodate the hazardous properties of e-waste[3].  Domestically some manufacturers are using taxpayer-subsidized prison labor to recycle electronic products. Prisons unfairly compete with private sector recycling and thus deter the vitally needed development of a private-sector infrastructure for domestic waste recycling.  Clearly, we need to do much more to promote effective collection and responsible recycling/reuse of obsolete electronic equipment. (Note: Prior to July 2003, Dell was using prison labor. On July 3rd Dell stated publicly that they would end their relationship with UNICOR. As of their mid-July shareholder meeting, Dell switched operations to RCI and Image Microsystems.)

2.     Design for the Environment and Public Health

   Today, the average electronic product contains hundreds of hazardous materials, many of which pose a threat to human health and the environment if improperly disposed of at the end of their useful life. These materials can also pose a threat to worker health in the manufacturing and recycling processes.  Of particular concern are chlorinated plastics (PVC used in cable wiring), brominated flame retardants (used in plastic computer housings, and circuit boards), heavy metals such as lead (used in CRT monitors and lead solder), mercury (used LCD displays), and cadmium (used in batteries, resistors, CRTs and plastic components).   As of 2006, the European Union has mandated that most electronic products be free of mercury, cadmium, and lead as well as certain brominated flame retardants, but the United States has no similar rules. 

   Since only about ten percent of computers are currently recycled each year, designing for reduced toxicity (while increasing recyclability/reusability) is critical to reducing the massive amounts of toxic materials that are included in electronic products annually. By reducing these harmful chemicals at the source, we will also reduce the long-term risks to public health and the environment.

3.     Energy Efficiency

   Computers and office equipment use 74 billion kWh of electricity per year.  This is equivalent to the total electricity used by 7 million households.  Most of the energy used to power electronic products comes from fossil fuel-based energy sources, i.e. coal, gas and oil—all of which contribute to global warming, ozone depletion, and air pollution – and subsequent degradation of human health and the environment.   Encouraging the development of electronic products that conserve energy can slow this degradation.

Recommended Procurement Guidelines

Although electronic manufacturers are beginning to develop cleaner, greener electronic products, there are very few products on the market today in the U.S. that will meet all of the necessary environmental health requirements.  In recognition of these current limitations, these guidelines are separated into two sections.  The first section – Tier 1 -- contains recommended bid specifications for products that can be purchased on the market between 2003-2006. These guidelines give preference to manufacturers who have demonstrated product improvement on key environmental health attributes including, but not limited to:

• Manufacturer takeback of equipment
• Reduction of toxic components
• Increased recycled content
• Reduced packaging
• Upgradability
• Longevity
• Electronic waste bans on export and prison labor
• Clean manufacturing practices
• Design for reuse and recycling.

The second section – Tier 2 -- is a list of questions that will help prepare manufacturers for bid requirements that may be included in purchasing contracts in the future – perhaps within the next three to five years.  The inclusion of these questions as part of the bid specifications will be critical to helping electronics manufacturers prioritize their research and development investments to meet more stringent environmental health guidelines in the future.

Tier 1

Recommended Bid Specifications for current purchasing cycles (2003-2006)

End of Life Management:

• Bid specifications should require vendors and manufacturers to provide take back and management services for end of life electronic products.  This can be accomplished either through a lease or through a contractual provision whereby the seller agrees to be responsible for taking back the products and providing for appropriate re-use or recycling when the buyer no longer needs the product.
• Require manufacturers to provide information on how electronic products are recycled and reused at the end of life.
• Provide preference to manufacturers who have take back programs that comply with the requirements established in the Electronic Recyclers Pledge (see attachments), which includes:
  • Hazardous electronic waste will not be sent to landfills or incinerators for disposal or energy recovery;
  • Hazardous electronic waste will not be exported to developing countries;
  • Electronic waste will not be sent to prisons for recycling; and
  • Recycling will be handled by a responsible recycling operation with an environmental management system in place.

Design for the Environment and Public Health:

• Purchasing preferenceshould be given to electronic products that minimize the use of toxic and hazardous constituents.
• At a minimum, electronics manufacturers should demonstrate that they are complying globally with European Union’s Directive -- Restriction of Hazardous Substances -- which requires the phase out of lead, mercury, hexavalent chromium, cadmium and certain brominated flame retardants (PBBs and PBDEs) by 2006 (with certain exceptions).
• In addition, preference should be given to manufacturers who go beyond the EU requirements by phasing out chlorinated plastics (PVC) and all brominated flame retardants.  
• Purchasing preference should be given to electronic products that use recycled content and produce products that can easily be recycled.
  • At a minimum, electronics manufacturers should demonstrate that they   are complying globally with the European Union’s WEEE Directive, which requires manufacturers to recycle or reuse more than half of their old equipment on the market by 2006.
• Purchasing preference should be given to electronic products that have been certified by independent third party eco-labeling programs, such as TCO, Blue Angel, etc.
• Purchasing preference should be given to electronic products with labels containing consumer information on the hazardous materials contained in the electronic equipment.
• Purchasing preference should be given to companies that use   recyclable, nontoxic packaging as follows:
  • Vendor shall use reduced and/or recycled packaging for shipping, such as boxes that contain a minimum of 35% post-consumer fiber for all corrugated cardboard.
  • Vendor shall minimize quantity and weight of any non-recyclable packaging and shipping material; e.g., use molded paper or cardboard substitutes for polystyrene and Styrofoam.
  • Vendor’s product user manuals shall be easily recyclable (no difficult binding) and printed on recycled content paper (with at least 30% post-consumer fiber content).
  • Purchasing preference should be given to companies whose products are shipped in packaging that is taken back by the seller.
  • Purchasing preferenceshould be given to companies that provide product upgradeability options.

Energy Efficiency

• Include the requirement that all electronic equipment meet Energy Star™ specifications.   In addition, please provide the following detailed setup specifications:
  • Equipment shall be configured so it automatically enters a low-power mode after a period of inactivity.
  • When a computer in a low-power mode is used again, it automatically returns to active mode.
  • Computer shall be shipped with power management feature enabled.
  • For computers that will be used in networked environments, provide CPU’s and monitors that are set up to sleep on networks and respond to wake events.
  • Provide integrated computer systems, where the CPU and monitor will together enter a low-power mode of no more than 45 watts after a specified period of inactivity.
  • Deliver all machines configured properly for automatic energy-saving features, as per current energy starJ specifications.
  • Provide customer support on the power management features so that these features remain properly activated.

Tier 2

Key Questions to submit to electronics manufacturing and sales companies  for Environmentally Preferable Electronic Products in anticipation of future procurement

Design for the Environment and Public Health

What policies are in place to reduce the use of toxic materials throughout the product’s life cycle (manufacture, use, end of life)?

Does the product contain materials with inherently harmful properties such as teratogens, persistent bioaccumulative substances, carcinogens, reproductive toxins, endocrine disruptors, and mutagens?

Does the product contain halogenated flame retardants?  If so, explain which ones and where they are included.

Does the product contain chlorinated plastics? If so, explain which ones and where they are included.

What percentage of the plastics in the product is currently being recycled at the end of life?

Does the product contain heavy metals?  If so, specify which ones.

How does the company evaluate safer material alternatives for use in product design and manufacture?

What is the percentage of recycled content in the electronic product?

Is the product designed for upgradeability and or reusability?  If so, how?

Is the product designed for easy disassembly and recyclability?

Does the manufacturer use nontoxic, biodegradable packaging that is taken back by the manufacturer for reuse?

Has the manufacturer established supplier guidelines outlining material restrictions?  Please include a copy of these guidelines and details on implementation policies and practices.

Manufacturing

What standards are in place to protect occupational health and safety?

Does the manufacturer perform routine industrial hygiene monitoring and quarterly reporting for all facilities that use hazardous materials of concern, including but not limited to monitoring for airborne lead and bromine, chlorine, and mercury compounds and other chemicals of concern on the California Proposition 65 list of carcinogens and reproductive toxins. [4]   Please also include a copy of your latest OSHA Log 300 report.

Does the manufacturer perform routine human health monitoring and quarterly reporting (in accordance with all applicable privacy protections) for all workers and contractors, including but not limited to blood testing for exposure to lead and bromine, chlorine, and mercury compounds?

What percentage of renewable energy sources are used to power your manufacturing facilities as well as the manufacturing and distribution facilities of those in your supply chain?

Use

What tests have been performed to determine what materials are off-gassed during the use of the product?

Does the product go beyond Energy Star™ requirements?  If so, how?

What features have been designed into the product to save ink and toner in printers and copiers?

Are your toner cartridges refillable by third-party vendors?

Are the environmental attributes labeled on the product, including but not limited to the hazardous materials contained in the product?

Are products designed to improve ergonomics for users, thus reducing Workers Compensation claims and improving worker productivity?  If so, please explain.

End of Life Management

Does the manufacturer have a takeback system in place for all of its electronic products that is free of charge to all of its classes of customers?

Has the manufacturer instituted bans on exporting electronic waste to developing countries and on using prison labor to recycle electronic products?

Is the manufacturer using recycling facilities with environmental management systems in place and which are in compliance with all applicable local, state, and federal environmental, land use, and occupational health laws?

What percentage of the manufacturer’s products are recovered for reuse and recycling at its facilities?

If the product is not reused or recycled, what is done with the electronic waste?

Other

What research and development plans does the company have in place to create cleaner products?  When will these products be on the market?