Looking into legality of electronics recycling

Originally Posted by hills

Thought it best to take another run at this.

The rules are very hard to get rid of once they are in place. Much easier said than done. (Have some experience in this area not related to ewaste.)

Now ... the question arises .... and this is a very important question: Do the regulators even have the authority to propagate rules that carry the weight of law ?

There are three branches of government. The judicial is the system of courts. The legislative branch propagates law. The executive branch puts the law into practice.

The regulators come under the executive branch. They can enforce the law but they cannot make law. That power is reserved to the legislature alone.

All that legal and constitutional stuff aside :

Here in Maine they have different classifications -or- permits for different jobs. For example ... you might be an ewaste consolidator. You might be a dismantler. You might be a processor that actually works with chemicals and refines ewaste. As you can imagine ... the regulations for a processor would be much more involved than the regulations for a consolidator.

I'm just wondering if there may be something similar in your state. Maybe you wouldn't need all of the special certifications for the ewaste activities you're engaged in ?

Maybe all of the things mentioned in your first post pertain only to an ewaste operation doing millions of dollars of business in a year ?

That might be worth looking into.

I was/am hoping that is the case, but from reading the law/permit (http://www.depgreenport.state.pa.us/...me=WMGR081.pdf)

ANYONE recycling electronics (and by their definitions of recycling, which is outlined in the document/link above) I am a recycler and required to have this permit to legally operate.

This document defines recycling as:

For the purpose of this permit:a. “Recycling” includes the salvaging of clean and uncontaminated metals,plastics and glass for use as raw materials for an industrial process;salvaging of precious metals via separation and shipment to a preciousmetals recycler; salvaging of uncontaminated electronic or mechanicalcomponents for re-use in their original function; and the salvaging of anypotentially leachable materials/components (including CRTs that are sent tospecialty recycling facilities for additional recycling or other beneficial use perseparate Department approval).


So even if I was just taking ram out of computers I get from people, and putting in other computers, TECHNICALLY I am an electronics recycler and would need this permit..... according to what is in this document.

In a few places in the document, they do make a distinction and different requirements for recyclers who have >= 5 tons on-site at any one time, and those that do not. However it does not say that anyone, with any amount can be exempt from requiring this permit.



I may just go down the the office and ask them what the deal is




after some googleing, I did find this, which seems to reference a 5 ton exemption.... on page 19

https://www.philadelphiastreets.com/...-2-26-2015.pdf

But cant find any more info on that being the case