oversight

Electronic Waste: Actions Needed to Provide Assurance That Used Federal Electronics Are Disposed of in an Environmentally Responsible Manner

Published by the Government Accountability Office on 2012-02-17.

Below is a raw (and likely hideous) rendition of the original report. (PDF)

                United States Government Accountability Office

GAO             Report to the Ranking Member,
                Committee on Oversight and
                Government Reform, House of
                Representatives

February 2012
                ELECTRONIC WASTE

                Actions Needed to
                Provide Assurance
                That Used Federal
                Electronics Are
                Disposed of in an
                Environmentally
                Responsible Manner




GAO-12-74
                                               February 2012

                                               ELECTRONIC WASTE
                                               Actions Needed to Provide Assurance That Used
                                               Federal Electronics Are Disposed of in an
                                               Environmentally Responsible Manner
Highlights of GAO-12-74, a report to the
Ranking Member, Committee on Oversight
and Government Reform, House of
Representatives



Why GAO Did This Study                         What GAO Found
The Environmental Protection Agency            Over the past decade, the executive branch has taken steps to improve the
(EPA) estimates that across the federal        management of used federal electronics. Notably, in 2003, EPA helped to pilot
government 10,000 computers are                the Federal Electronics Challenge (FEC)—a voluntary partnership program that
discarded each week. Once these                encourages federal facilities and agencies to purchase environmentally friendly
used electronics reach the end of their        electronic products, reduce the impacts of these products during their use, and
original useful lives, federal agencies        manage used electronics in an environmentally safe way. EPA also led an effort
have several options for disposing of          and provided initial funding to develop third-party certification so that electronics
them. Agencies generally can donate            recyclers could show that they are voluntarily adhering to an adopted set of best
their reusable electronics to schools;
                                               practices for environmental protection, worker health and safety, and security
give them to a recycler; exchange
                                               practices. In 2006, GSA issued its Personal Property Disposal Guide to assist
them with other federal, state, or local
agencies; or sell them through selected
                                               agencies in understanding the hierarchy for disposing of excess personal
public auctions, including auctions            property, including used electronic products: reutilization, donation, sale, and
sponsored by the General Services              abandonment or destruction. In 2007 and 2009, executive orders were issued
Administration (GSA). As the world’s           that, among other things, established improvement goals and directed agencies
largest purchaser of information               to develop and implement improvement plans for the management of used
technology, the U.S. government,               electronics. The Office of Management and Budget, the Council on
through its disposition practices, has         Environmental Quality, and the Office of the Federal Environmental Executive
substantial leverage to influence              each play important roles in providing leadership, oversight, and guidance to
domestic recycling and disposal                assist federal agencies with implementing the requirements of these executive
practices. GAO was asked to examine            orders. To lay the groundwork for enhancing the federal government’s
(1) key initiatives aimed at improving         management of used electronic products, an interagency task force issued the
the management of used federal                 July 2011 National Strategy for Electronics Stewardship. The strategy, which
electronics and (2) improvements               describes goals, action items, and projects, assigns primary responsibility for
resulting from these initiatives and           overseeing or carrying out most of the projects to either EPA or GSA.
challenges that impede progress, if
any. To do this, GAO evaluated federal         Federal agencies have made some progress to improve their management of
guidance and policy, as well as                used electronic products, as measured by greater participation in the FEC and an
guidance and initiatives at five selected      increase in certified electronics recyclers, but opportunities exist to expand their
agencies. GAO selected agencies                efforts. For instance, agency participation in the FEC represents only about one-
based on, among other things, the              third of the federal workforce. GAO identified challenges with the tracking and
amount of electronics purchased.               reporting on the disposition of federal electronic equipment. For the five agencies
                                               GAO reviewed (Departments of Defense, Energy, Education, and Housing and
What GAO Recommends                            Urban Development and the National Aeronautics and Space Administration),
GAO recommends, among other                    data provided on the disposition of electronic products were inconsistent, which
things, that the White House Council           hampered GAO’s efforts to accurately assess the extent to which electronic
on Environmental Quality, the Office of        products procured by federal agencies are disposed of in an environmentally
Management and Budget, and GSA                 sound manner. Challenges associated with clarifying agencies’ responsibility for
take actions to require consistent             used electronics sold through auctions also remain. Currently, neither the agency
tracking and reporting of used                 nor the auction entities are required to determine whether purchasers follow
electronics and ensure appropriate             environmentally sound end-of-life practices. Not having controls over the ultimate
management of electronics sold at              disposition of electronics sold through these auctions creates opportunities for
auction. Each agency concurred with            buyers to purchase federal electronics and export them to countries with less
GAO’s recommendations but, in some             stringent environmental and health standards. Other challenges that may impede
instances, proposed alternatives for           progress toward improving federal agencies’ management of used electronics
executing the recommendations.
                                               include defining key terms such as “electronic product” and “environmentally
View GAO-12-74                                 sound practices,” as each agency uses its own definition of electronic products to
For more information, contact Frank Rusco at   report progress in implementing policies for electronics stewardship.
(202) 512-3841 or ruscof@gao.gov.

                                                                                         United States Government Accountability Office
Contents


Letter                                                                                               1
                       Background                                                                    4
                       Key Initiatives to Improve Federal Agencies’ Management of Used
                         Electronic Products Have Been Launched over the Past 10 Years               6
                       The Management of Used Federal Electronics Has Improved and
                         Opportunities Exist for Further Improvements, but Challenges
                         Remain                                                                    14
                       Conclusions                                                                 25
                       Recommendations for Executive Action                                        26
                       Agency Comments and Our Evaluation                                          27

Appendix I             Objectives, Scope, and Methodology                                          31



Appendix II            Comments from the Environmental Protection Agency                           35



Appendix III           GAO Contact and Staff Acknowledgments                                       37



Related GAO Products                                                                               38



Figure
                       Figure 1: Electronics Recycling Facilities Certified to the R2 or e-
                                Stewards Standard, as of September 30, 2011                        17




                       Page i                                                GAO-12-74 Electronic Waste
Abbreviations
CEQ             Council on Environmental Quality
DLA             Defense Logistics Agency
DOD             Department of Defense
DOE             Department of Energy
Education       Department of Education
EPA             Environmental Protection Agency
FEC             Federal Electronics Challenge
FMR             Federal Management Regulation
GSA             General Services Administration
HUD             Department of Housing and Urban Development
NASA            National Aeronautics and Space Administration
OFEE            Office of the Federal Environmental Executive
OMB             Office of Management and Budget
R2              Responsible Recycling


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Page ii                                                        GAO-12-74 Electronic Waste
United States Government Accountability Office
Washington, DC 20548




                                   February 17, 2012

                                   The Honorable Elijah E. Cummings
                                   Ranking Member
                                   Committee on Oversight
                                     and Government Reform
                                   House of Representatives

                                   Dear Mr. Cummings:

                                   Rapid advances in technology have led to increasing sales of new
                                   electronic products, such as computers, computer monitors, televisions,
                                   and cell phones. These electronic products have created new business
                                   opportunities, new ways to communicate, and a new way of conducting
                                   business in both the private and public sectors. These advances,
                                   however, have also created new environmental challenges. As we have
                                   previously reported, electronic products may contain toxic substances—
                                   such as cadmium, lead, and mercury—that can leach into soil or
                                   groundwater if improperly managed. 1 As the world’s largest purchaser of
                                   information technology—spending about $80 billion in fiscal year 2010—
                                   the U.S. government, through its disposition practices, has substantial
                                   leverage to influence domestic recycling, reuse, and disposal practices.
                                   However, if the federal government’s used electronics are not
                                   appropriately managed, they could be disposed of in landfills domestically
                                   or exported to countries that have less strict environmental and safety
                                   protections. 2 Studies have shown that used electronic products exported
                                   from the United States to some countries are often dismantled under
                                   unsafe health conditions, using methods like acid baths to extract
                                   precious metals or open-air incineration. For example, we reported in
                                   2008 that, while some exports of used electronic products can be handled
                                   responsibly in countries with effective regulatory regimes and by
                                   companies with advanced technologies, some used electronic products


                                   1
                                    GAO, Electronic Waste: EPA Needs to Better Control Harmful U.S. Exports through
                                   Stronger Enforcement and More Comprehensive Regulation, GAO-08-1044 (Washington,
                                   D.C.: Aug. 28, 2008).
                                   2
                                    For purposes of this report, we refer to all federal electronic products that may be reused,
                                   recycled, disposed of, or discarded as “used.” Federal agencies also use other terms,
                                   such as excess or surplus. See FMR, Subchapter B-Personal Property, 41 C.F.R. §102-
                                   35.20 (2011)




                                   Page 1                                                          GAO-12-74 Electronic Waste
owned by federal agencies have been sent to developing countries where
disposal practices are unsafe to workers and dangerous to the
environment. 3

Over the past decade, the executive branch has taken steps to improve
the management of used federal electronics. For example, in 2007 and
2009, executive orders were issued to strengthen federal agencies’
overall environmental management practices, including environmentally
sound management of federal electronic products, from procurement
through disposal—often referred to as electronics stewardship. 4 Recently,
we issued two reports that discussed elements of electronics stewardship
outlined in the executive orders related to the use of federal electronics,
including requirements to manage federal data centers in a more energy-
efficient manner and implement power management policies for
computers. 5

You requested that we review the status of federal initiatives to
appropriately manage the disposition of used electronic products—that is,
selling, donating, recycling, and disposing of federal electronics. Our
objectives were to examine (1) key initiatives aimed at improving the
management of used federal electronics and (2) improvements resulting
from these initiatives and challenges that impede progress, if any.

To address the first objective, we reviewed guidance and documents
regarding improvement initiatives led by the Environmental Protection
Agency (EPA); analyzed the electronics stewardship requirements
contained in the applicable executive orders and implementing
instructions; the Federal Acquisition Regulation, which governs the
process through which the federal government acquires goods and
services; the Federal Management Regulation (FMR), which, among


3
    GAO-08-1044.
4
 Executive Order 13423, “Strengthening Federal Environmental, Energy, and
Transportation Management.” 72 Fed. Reg. 3,919 (Jan. 26, 2007); and Executive Order
13514. “Federal Leadership in Environmental Energy, and Economic Performance,” 74
Fed Reg. 52,117 (Oct. 8, 2009).
5
 GAO, Data Center Consolidation: Agencies Need to Complete Inventories and Plans to
Achieve Expected Savings, GAO-11-565 (Washington, D.C.: July 19, 2011) and Green
Information Technology: Agencies Have Taken Steps to Implement Requirements, but
Additional Guidance on Measuring Performance Needed, GAO-11-638 (Washington D.C.:
July 28, 2011).




Page 2                                                     GAO-12-74 Electronic Waste
other things, regulates the disposal of federal personal property, including
electronics; 6 the General Services Administration’s (GSA) Personal
Property Disposal Guide, which serves as an index and quick-reference
guide to personal property management provisions in the FMR; and other
relevant electronics stewardship guidance.

To address the second objective, we selected a nonprobability sample of
five federal agencies—the Departments of Defense (DOD), Energy
(DOE), Education (Education), and Housing and Urban Development
(HUD); and the National Aeronautics and Space Administration (NASA)—
to examine how the federal policy framework is carried out in those
agencies. We selected DOD, DOE, and NASA because they each
participated to some extent in EPA’s Federal Electronics Challenge (FEC)
program and purchased large amounts of electronic products—ranking
first, eighth, and tenth, respectively, in terms of overall federal agency
information technology spending in fiscal year 2010. We selected
Education because, according to the FEC program manager, the agency
actively participates in the FEC and centrally manages its electronics
procurement and disposal functions. We selected HUD because the
agency was not participating in the FEC. Because we based the selection
of agencies on a nonprobability sample, the information we obtained is
not generalizable to all federal agencies. However, since the
nonprobability sample consists of a cross-section of agencies of different
sizes and levels of participation in the FEC, the evaluation of these five
agencies provides examples of different procurement and disposition
methods for electronics. We also obtained data on GSA’s federal excess
personal property utilization, donation, and sales programs for fiscal year
2010 to determine, for agencies using these programs, the extent to
which they utilized each disposition method for their used electronics. We
also designed and implemented a data collection instrument to collect
data from the five selected agencies on how they disposed of electronic
products for fiscal years 2009 and 2010. We attempted to resolve
inconsistencies in the data provided through these efforts, but we
determined that the data were not sufficiently reliable for the purpose of
reporting on amounts of electronics disposed of by the five agencies or
the extent to which agencies reutilize, donate, and sell used electronics


6
 The Federal Management Regulation requires that executive agencies to the maximum
extent practicable fill requirements for personal property by using existing agency property
or by obtaining excess property from other federal agencies in lieu of new procurements.
See FMR, Subchapter B-Personal Property, 41 C.F.R. Pt. 102-36, §102-36.65 (2011).




Page 3                                                          GAO-12-74 Electronic Waste
             through GSA’s federal excess personal property programs. We discuss
             these data problems in our report. We also met with officials responsible
             for procuring and disposing of electronic products for the five federal
             agencies, and we conducted site visits to the Kennedy Space Center in
             Cape Canaveral, Florida, and Defense Logistics Agency (DLA) Aviation in
             Richmond, Virginia, to discuss the procurement and disposition of
             electronic products. We also visited three recycling facilities that have a
             role in electronics recycling at federal agencies and interviewed facility
             officials about recycling procedures. We examined key provisions of the
             July 2011 National Strategy for Electronics Stewardship and compared
             them with existing policies for electronics stewardship. We also obtained
             information from the FEC program’s manager, officials within each of the
             five agencies, and seven champions for the FEC program regarding
             challenges that may affect agency participation in electronics stewardship
             initiatives. Details of our scope and methodology are in appendix I.

             We conducted this performance audit from October 2010 to January 2012
             in accordance with generally accepted government auditing standards.
             Those standards require that we plan and perform the audit to obtain
             sufficient, appropriate evidence to provide a reasonable basis for our
             findings and conclusions based on our audit objectives. We believe that
             the evidence obtained provides a reasonable basis for our findings and
             conclusions based on our audit objectives.


             As we have reported previously, EPA estimates that across the federal
Background   government 10,000 computers are disposed of each week. 7 Once these
             used electronics reach the end of their original useful lives, federal
             agencies have several options for disposing of them. Agencies generally
             are to donate their used electronics to schools or other nonprofit
             educational institutions; exchange them with other federal, state, or local
             agencies; sometimes trade them with vendors to offset the costs of new
             equipment; sell them—generally through the GSA’s surplus property
             program, which sells surplus federal government equipment, including
             used federal electronics, at public auctions; or give them to a recycler.




             7
              GAO, Federal Electronics Management: Federal Agencies Could Improve Participation in
             EPA’s Initiatives for Environmentally Preferable Electronic Products, GAO-10-196T
             (Washington, D.C.: Oct. 27, 2009).




             Page 4                                                     GAO-12-74 Electronic Waste
Federal agencies, however, are not required to track the ultimate
destination of their donated or recycled used electronic products. Instead,
agency officials generally consider this to be the recipient organization’s
responsibility. Consequently, federal agencies often have little assurance
that their used electronics are ultimately disposed of in an
environmentally responsible manner. In our prior work, we found that little
information exists, for example, on whether obsolete electronic products
are reused, stored, or disposed of in landfills. 8 If discarded domestically
with common trash, a number of adverse environmental impacts may
result, including the potential for harmful substances such as cadmium,
lead, and mercury to enter the environment. If donated or recycled, these
products may eventually be irresponsibly exported to countries without
modern landfills and with waste management systems that are less
protective of human health and the environment than those in the United
States. For example, in our prior work we found that some U.S.
electronics recyclers—including ones that publicly tout their exemplary
environmental practices—were apparently willing to circumvent U.S.
hazardous waste export laws and export certain regulated used electronic
products to developing countries. 9

The federal government’s approach to ensuring environmentally
responsible management of used electronics has relied heavily on EPA’s
FEC initiative, which, among other things, encourages federal facilities
and agencies to manage used electronics in an environmentally safe way.
In addition, executive orders were issued to strengthen federal agencies’
overall environmental management practices, including environmentally
sound management of federal electronic products. The Office of
Management and Budget (OMB), the White House Council on
Environmental Quality (CEQ), and the Office of the Federal
Environmental Executive (OFEE) each play important roles in providing
leadership, oversight, and guidance to assist federal agencies with
implementing the requirements of these executive orders. 10 More



8
 GAO, Electronic Waste: Strengthening the Role of the Federal Government in
Encouraging Recycling and Reuse, GAO-06-47 (Washington, D.C.: Nov. 10, 2005).
9
    GAO-08-1044.
10
  OFEE is responsible for promoting sustainability and environmental stewardship
throughout federal government operations. It was created by executive order in 1993, is
housed at the President’s Council on Environmental Quality, is administered by EPA, and
leads the interagency Steering Committee on Federal Sustainability.




Page 5                                                       GAO-12-74 Electronic Waste
                          recently, an interagency task force issued the July 2011 National Strategy
                          for Electronics Stewardship, 11 which is intended to lay the groundwork for
                          enhancing the federal government’s management of used electronics.


                          Over the past decade, the executive branch has undertaken several
Key Initiatives to        initiatives to improve federal agencies’ management of used electronics.
Improve Federal           Specifically, (1) EPA has led or coordinated several improvement
                          initiatives and issued guidance aimed at improving the management of
Agencies’                 used federal electronic products, (2) GSA has issued personal property
Management of Used        disposal guidance and instituted new requirements for electronics
Electronic Products       recyclers it has contracted with to dispose of federal electronic products,
                          (3) the President has issued executive orders that established goals for
Have Been Launched        improving the management of used federal electronics, and (4) an
over the Past 10 Years    interagency task force issued the July 2011 National Strategy for
                          Electronics Stewardship, which is intended to lay the groundwork for
                          enhancing the federal government’s management of used electronics.


EPA Has Led Initiatives   EPA has led or coordinated several key improvement initiatives to assist
Aimed at Improving the    agencies with the management of used federal electronics, including the
Management of Used        FEC, the Federal Electronics Stewardship Working Group, and the
                          establishment of electronics recycler standards for use in certification
Federal Electronics       programs.

                          Federal Electronics Challenge. In 2003, EPA, along with several other
                          agencies, piloted the FEC. 12 The FEC is a voluntary partnership program
                          that encourages federal facilities and agencies to purchase
                          environmentally friendly electronic products, reduce the impacts of these
                          products during their use, and manage used electronics in an
                          environmentally safe way. To participate, executive branch agencies or


                          11
                            White House Council on Environmental Quality, Environmental Protection Agency,
                          General Services Administration, National Strategy For Electronics Stewardship
                          (Washington, D.C.: July 20, 2011),
                          http://www.gsa.gov/graphics/admin/National_Strategy_Electronics_Stewardship_2011.pdf
                          12
                           A memorandum of understanding signed by the Executive Office of the President and 11
                          agencies in November 2004 formally committed the agencies to join the FEC as agency
                          partners and to actively sponsor participation of all facilities within each agency. The 11
                          agencies were the Departments of Agriculture, Defense, Energy, Health and Human
                          Services, Homeland Security, the Interior, Justice, Transportation, and Veterans Affairs;
                          and the Environmental Protection Agency and General Services Administration.




                          Page 6                                                         GAO-12-74 Electronic Waste
their facilities must register and sign an agency pledge to become an
agency or facility FEC partner, or both. In general, agency partners are
responsible for supporting their facilities’ efforts but do not have specific
reporting requirements. Facility partners are required to submit a baseline
survey of their electronics stewardship activities when they join the
program. The survey is to include, among other things, a description of
(1) what the entity does with electronic products that are no longer used;
(2) which electronics recycling services it uses; and (3) what, if any,
measures the entity has taken to ensure that the electronic products were
recycled in an environmentally sound manner. 13 Facility partners are also
expected to report progress annually, and apply for recognition through
FEC awards.

FEC guidance directs participants to provide recipients of donated
electronics with instructions on how to have the electronics recycled
responsibly and how to verify that responsible recycling occurs—
procedures known as “downstream auditing.” When donating used
electronics, FEC instructs agencies and facilities to ensure that recipients
contact local or state environmental or solid waste agencies to obtain a
database of vendors who recycle used electronics once the equipment is
no longer useful to the recipient organization. FEC also recommends that
participating agencies and facilities instruct recipients to avoid
arrangements with recyclers that are unable or unwilling to share
references and cannot explain the final destination of the used electronics
they collect. When recycling electronics, participants are to determine
how much electronic equipment the recyclers actually recycle compared
with the amount they sell to other parties. In addition, FEC instructs
participants to physically inspect a potential recycler’s facilities. Used
electronics in trash containers, for example, may indicate that the facility
is not recycling it, and the presence of shipping containers may indicate
that the facility exports it.

To assist FEC partners, “FEC champions” are available to help regional
federal facilities with their electronics management programs. FEC



13
 The FEC Baseline Survey and Annual Reporting Form was developed to measure
partners’ progress against the FEC national program goals. The information collected may
be translated into the partner’s and program’s environmental benefits using the
Electronics Environmental Benefits Calculator, an EPA-developed online tool that
estimates the environmental benefits of improving the purchasing, use, and disposal of
computer products and electronic equipment.




Page 7                                                       GAO-12-74 Electronic Waste
champions are EPA representatives who are selected based on
geographic representation. Champions help federal facilities become FEC
facility partners; access resources for managing electronic products,
including FEC program information, fact sheets, and limited technical
assistance; and receive recognition for improving electronics
management programs.

The Federal Electronics Stewardship Working Group. This working group
coordinates interagency efforts to promote federal electronics
stewardship. It also acts as an advisory board for the FEC program.
During the working group’s monthly meetings, federal agencies have the
opportunity to discuss best practices for implementing the FEC and other
electronics stewardship initiatives within their respective agencies. The
FEC Program Manager told us the working group meetings serve as a
primary mechanism to facilitate communication with agency management
regarding the FEC program. Most executive agencies have at least one
representative serving with the working group.

Standards for certification of recyclers. EPA has worked with the recycling
industry and other entities to promote partnership programs that address
the environmentally sound management of used electronic products. As
we reported in July 2010, EPA convened electronics manufacturers,
recyclers, and other stakeholders and provided funding to develop
Responsible Recycling (R2) practices, so that electronics recyclers could
obtain certification to show that they are voluntarily adhering to the
adopted set of best practices for environmental protection, worker health
and safety, and security practices. 14 Certification for R2 practices became
available in late 2009. The R2 practices identify “focus materials” in used
electronic products, such as cathode-ray tubes or items containing
mercury, that warrant greater care owing to their toxicity and associated
risk if managed without the appropriate safeguards. Specifically, the
practices require that recyclers and each vendor in the recycling chain (1)
export products and components containing certain materials only to
countries that can legally accept them, (2) document the legality of such
exports, and (3) ensure that the material is being safely handled
throughout the recycling chain. R2 practices also establish a “reuse,
recover, dispose” hierarchy along the chain of custody for material



14
 GAO, Electronic Waste: Considerations for Promoting Environmentally Sound Reuse
and Recycling, GAO-10-626 (Washington, D.C.: July 12, 2010).




Page 8                                                    GAO-12-74 Electronic Waste
                           handling. These practices require recyclers to test electronics diverted for
                           reuse, and confirm that key functions of the unit are working before it may
                           be exported. Without such testing and confirmation, these used
                           electronics must be treated as though they are going to recycling and
                           may not be exported unless the R2 exporting provisions for recycling are
                           satisfied. Recognizing that some clients would not want their used
                           electronics remarketed or reused, R2 practices also require recyclers to
                           have systems in place to ensure that all such electronics processed can
                           be recycled, rather than recovered for reuse.

                           EPA encourages electronics recyclers to obtain certification to either R2
                           practices, or to e-Stewards, a separate voluntary certification program. e-
                           Stewards was initiated by the Basel Action Network in 2008, and the first
                           e-Stewards-certified facilities were announced in early 2010. 15 The length
                           and cost of the e-Stewards certification process depends on a facility’s
                           size and whether it has a documented environmental management
                           system in place. 16


GSA Has Issued Personal    In March 2006, to assist agencies in understanding the requirements
Property Disposal          associated with personal property disposal, GSA published the Personal
Guidance and Instituted    Property Disposal Guide. 17 Federal law requires that executive agencies,
                           as much as possible, obtain needed goods, including electronic products,
New Requirements for
                           by using existing agency property or by obtaining excess property from
Electronics Recyclers      other federal agencies in lieu of new purchases. 18 According to the GSA
Listed on GSA’s Contract   guide, agencies should follow a hierarchy for disposing of excess
Schedule                   personal property, including used electronic products: reutilization,
                           donation, sale, and abandonment or destruction.




                           15
                             The Basel Action Network was founded in 1997 and named after the Basel Convention,
                           the treaty under which parties have agreed to restrict trade in hazardous wastes and,
                           among other things, prohibit export of toxic waste to developing nations deemed unable to
                           manage the wastes in an environmentally sound manner.
                           16
                             EPA recognizes both the R2 and e-Stewards programs, but does not audit or certify
                           facilities for compliance with either of these certification programs.
                           17
                             This guide is available online at
                           http://www.gsa.gov/graphics/fas/5-06-00389_R2-yWC-w_0Z5RDZ-i34K-pR.pdf.
                           18
                             40 U.S.C. § 524(b); FMR Subchapter B-Personal Property, 41 C.F.R. § 102-36.65
                           (2011).




                           Page 9                                                        GAO-12-74 Electronic Waste
•    Reutilization. In general, all excess personal property, 19 including
     used electronic products, should be reported to GSA—preferably
     through the GSAXcess website. Personal property registered on the
     site is then available to other federal agencies and eligible state and
     nonprofit recipients who are seeking such property.

•    Donation. If computers and other electronic products cannot be
     reused internally or by another federal entity, an agency can also
     donate these products directly to a school or other eligible nonprofit
     organization through the Computers for Learning program. 20, 21 If a
     school declines the offer, the products must be reported to GSA for
     possible donation through the Federal Surplus Personal Property
     Donation Program. 22

•    Sales. If an agency’s property is not transferred or donated, it can be
     sold through public auctions. For example, the GSA Auctions®
     website offers the general public the opportunity to bid electronically
     on a wide array of federal assets, including used federal electronic
     products. Registered participants may bid on a single item or multiple
     items (lots) within specified time frames. In addition, in some cases
     federal agencies can sell their used electronic products on other
     internet auction sites.

•    Abandonment or destruction. An agency is allowed to abandon or
     destroy property, including used electronics, if an agency official
     determines that (1) the property has no commercial value, either as
     an item or as scrap; or (2) the cost of care, handling, and preparation



19
  Excess personal property is property under the control of any federal agency that is no
longer required for that agency’s needs, as determined by the agency head or designee.
20
   The authority for federal agencies to transfer research equipment, including computers,
to educational institutions and nonprofit organizations was established in law in 1992. See
15 U.S.C. § 3710(i) (2011).
21
  The Computers for Learning program facilitates the transfer of excess federal computer
equipment to schools and educational nonprofit organizations. The program implements
Executive Order 12999, Educational Technology: Ensuring Opportunity for All Children in
the Next Century, 61 Fed. Reg. 17,227 (Apr. 19, 1996).
22
  The Federal Surplus Personal Property Donation Program enables certain nonfederal
organizations, such as public agencies, nonprofit educational and public health activities,
public airports, and educational activities of special interest to the Armed Forces, to obtain
personal property that the federal government no longer needs.




Page 10                                                          GAO-12-74 Electronic Waste
                                  of the property for sale would be greater than the expected sales
                                  proceeds. 23

                             More recently, GSA has instituted new requirements for electronics
                             recyclers listed on the GSA Schedule. 24 In February 2011, GSA began
                             requiring proof of certification under either R2 or e-Stewards for new
                             vendors seeking to provide recycling or disposal services for used
                             electronic products under GSA’s environmental services schedule. 25
                             According to GSA officials, they also identified 5 vendors, out of the 58
                             vendors on the schedule at that time, that were performing recycling or
                             disposal services for used electronic products and provided these
                             vendors with modified contract terms—making R2 or e-Stewards
                             certification within 6 months a condition for performing these services
                             under the GSA schedule.


Executive Orders Issued in   In January 2007, Executive Order 13423 established goals for federal
2007 and 2009 Established    agencies to improve the management of their used electronic products.
Goals for Improving the      Among other things, the executive order required that agency heads (1)
                             establish and implement policies to extend the useful life of agencies’
Management of Used           electronic equipment and (2) ensure the agency uses environmentally
Federal Electronics          sound practices with respect to the disposition of the agency’s electronic
                             equipment that has reached the end of its useful life. Furthermore, the
                             instructions for implementing the executive order, issued on March 28,
                             2007, called for each agency to develop and submit to OFEE by May 1,
                             2007, an electronics stewardship plan to implement electronics
                             stewardship practices for all eligible owned or leased electronic products.
                             Among other things, the plans were to address how agencies will ensure


                             23
                                According to the GSA guidance, agencies are not to abandon or destroy property in a
                             manner that is detrimental or dangerous to public health or safety. Specific requirements
                             for the utilization and disposal of hazardous material are found in 41 C.F.R. Pt. 101-42
                             (2011). Hazardous material may include property that possesses special characteristics,
                             which in the opinion of the holding agency could be hazardous to health, safety, or the
                             environment if improperly handled, stored, transported, disposed of, or otherwise
                             improperly used.
                             24
                               Under the GSA Schedules program, GSA establishes long-term governmentwide
                             contracts with commercial firms to provide access to millions of commercial supplies
                             (products) and services at volume discount pricing.
                             25
                               The purpose of GSA’s Environmental Services Schedule for Materials and Waste
                             Recycling and Disposal Services (899-5) is to assist federal agencies in choosing
                             recyclers that GSA has determined meet certain requirements for various services.




                             Page 11                                                        GAO-12-74 Electronic Waste
that all electronic products no longer needed by an agency are reused,
donated, sold, or recycled using environmentally sound management
practices at end of life. The implementing instructions called for agencies’
plans to

•   comply with GSA procedures for the transfer, donation, sale, and
    recycling of electronic products (discussed above), as well as any
    applicable federal, state, and local laws and regulations; and

•   use national standards, best management practices, or a national
    certification program for electronics recyclers.

The implementing instructions for Executive Order 13423 also directed
each agency and its facilities to participate in the FEC or to implement an
equivalent electronics stewardship program that addresses the purchase,
operation and maintenance, and end-of-life management strategies for
electronic products consistent with the FEC’s recommended practices
and guidelines.

In October 2009, Executive Order 13514 built on the previous executive
order but included slightly different goals for electronics stewardship.
Executive Order 13514 calls for agencies to develop, implement, and
annually update strategic sustainability performance plans to specify how
they intend to achieve the goals of the order. Agencies were required to
submit fiscal year 2010 plans to CEQ and OMB by June 2010. Executive
Order 13514, however, did not supersede or revoke the earlier executive
order, and that order’s goals and requirements remain in effect. 26




26
   See Omnibus Appropriations Act, 2009, Pub. L. No. 111–8 § 748, 123 Stat. 693
(providing that Executive Order 13423 shall remain in effect hereafter except as otherwise
provided by law).




Page 12                                                       GAO-12-74 Electronic Waste
The National Strategy for   In July 2011, an interagency task force, 27 co-chaired by CEQ, EPA, and
Electronics Stewardship     GSA, issued the National Strategy for Electronics Stewardship, which
Aims to Improve the         describes goals, action items, and projects that are intended to lay the
                            groundwork for enhancing the federal government’s management of used
Federal Government’s
                            electronic products, among other things. The strategy assigns primary
Management of Used          responsibility for overseeing or carrying out most of the projects to either
Electronics                 EPA or GSA. Most of the projects are scheduled for completion from
                            summer 2011 through spring 2013. Among other things, the strategy
                            directs GSA to issue

                            •   through interagency collaboration and with public input, a
                                comprehensive and governmentwide policy on used federal electronic
                                products that maximizes reuse, clears data and information stored on
                                used equipment, and ensures that all federal electronic products are
                                processed by certified recyclers; and

                            •   revised reporting guidance to improve federal agencies’ tracking of
                                used federal electronic products throughout their life cycle and to post
                                comprehensive data on Data.gov and other publicly accessible
                                websites. 28

                            The strategy also recommends that the federal government

                            •   require and enable recipients of used federal equipment that has been
                                sold, transferred, or donated for reuse to use certified recyclers and
                                follow other environmentally sound practices to the greatest extent
                                possible; and

                            •   encourage electronics manufacturers to expand their product take-
                                back programs, and use certified recyclers as a minimum standard in
                                those programs by expanding the use of manufacturer take-back




                            27
                               The interagency task force is separate from the Federal Electronics Stewardship
                            Working Group referenced earlier in the report.
                            28
                               Data.gov was launched in 2009 and its purpose is to increase public access to high-
                            value, machine-readable datasets generated by the executive branch of the federal
                            government.




                            Page 13                                                        GAO-12-74 Electronic Waste
                                  agreements in federal electronics purchase, rental, and service
                                  contracts. 29


                           According to our review of agency documents and discussions with
The Management of          agency officials, federal agencies have made some progress to improve
Used Federal               their management of used electronic products, as measured by greater
                           participation in the FEC and an increase in certified electronics recyclers,
Electronics Has            but opportunities exist to expand their efforts. In addition, challenges
Improved and               remain that may impede agencies’ progress toward further improving their
                           management of used federal electronics, including in the tracking and
Opportunities Exist        reporting of data on the disposition of used federal electronics, in
for Further                clarifying agencies’ responsibility for used electronics sold through
Improvements, but          auctions, and in clarifying definitions for key terms and reconciling
                           differences between the executive orders.
Challenges Remain

FEC Participation Has      Since we first reported on the FEC in November 2005, 30 participation has
Grown, and Opportunities   grown from 12 agencies and 61 individual facilities to 19 agencies and
Exist to Increase          253 individual facilities, as of September 2011. However, participation still
                           represents only about one-third of the federal workforce and, in some
Participation
                           cases, participation means that an agency has identified its current
                           practices for managing electronic products and set goals to improve them
                           but has not reported on progress toward achieving these goals as
                           required. Specifically, only a little more than half of the agencies and
                           facilities that were registered as FEC partners submitted an annual
                           accomplishment report in 2010 to demonstrate the agency or facility’s
                           progress in electronics stewardship; these reports are a key component
                           of actively participating as a partner. Because FEC participation is
                           voluntary, EPA officials said EPA has no authority to require agencies to
                           report on their progress. As a result, the extent to which agencies that do
                           not report progress are reaching their goals is unknown. However, the
                           FEC program manager told us that with a recent change in policy, FEC


                           29
                             Some electronics manufacturers have created product take-back programs; in these
                           programs, consumers return used equipment to the manufacturers, and the manufacturers
                           manage the equipment’s reuse, recycling, or disposal. Take-back programs are common
                           among large electronic products manufacturers, such as Apple, Dell, and Hewlett-
                           Packard.
                           30
                                GAO-06-47.




                           Page 14                                                    GAO-12-74 Electronic Waste
facility partners that do not submit their fiscal year 2011 annual reporting
form by January 31, 2012, will be considered inactive. An FEC official
stated that despite increased efforts to market the program, some
agencies find the FEC’s reporting requirements to be time-consuming.

For the five agencies we reviewed, participation in FEC varied.
Specifically:

•   DOD participates in the FEC as an agency partner, but the majority of
    its installations or facilities do not participate. According to EPA data,
    16 of DOD’s approximately 5,000 installations participate in the FEC.
    DOD officials told us that they are conducting outreach to encourage
    installations to participate but that some installations may not
    participate because officials believe that the registration process is too
    rigorous and burdensome.

•   NASA centers are allowed to participate in the FEC, but they are not
    required to do so because other agency initiatives accomplish the
    same goals, according to agency officials. Three of NASA’s 10
    centers participate in the FEC.

•   HUD does not participate in the FEC. We found that agency officials
    did not understand the FEC participation requirements. HUD’s
    electronics stewardship plan states that HUD participates in the FEC,
    but an EPA official, who is responsible for the FEC program, told us
    that HUD never registered to become a partner—which involves
    submitting a baseline survey of the agency’s electronics stewardship
    activities. In our discussions with HUD officials, we found that they
    were not aware of the FEC registration or reporting requirements and
    continued to believe that the agency was participating.

•   DOE officials promote FEC participation, submit annual
    accomplishment reports, and actively participate in the FEC awards
    program. According to agency officials, over a 6-year period, 23 DOE
    facilities have won FEC awards, with many winning multiple times. All
    but two DOE facilities participate.

•   Education participates in the FEC as an agency and facility partner.
    However, because it centrally manages the purchasing and
    disposition of electronics, Education submits annual accomplishment
    reports for the agency as a whole.




Page 15                                               GAO-12-74 Electronic Waste
                          For those agencies or facilities that actively participate in the FEC,
                          participation can provide federal officials with the information and
                          resources 31 needed to provide greater assurance that their used
                          electronics are disposed of in an environmentally responsible manner,
                          according to EPA documents. For the five agencies we reviewed, officials
                          at agencies or facilities that actively participated in the FEC said that the
                          FEC provided invaluable support. For example, according to DOD
                          officials at one installation, the information sharing that is facilitated
                          through the FEC is one of the biggest benefits of participation—when
                          faced with a problem, the FEC can provide information from other
                          agencies that have faced comparable problems. Similarly, Education
                          officials told us that membership in Federal Electronics Stewardship
                          Working Group was very helpful. In addition, DOE officials said that they
                          have had much success with the FEC program and that the FEC awards
                          program has motivated many DOE facilities to participate in electronics
                          recycling.



The Number of Certified   Since the R2 and e-Stewards certification processes were made available
Recyclers Has Grown and   in 2009 and 2010, respectively, the number of certified recyclers in the
Opportunities Exist for   United States has grown greatly. From September 2010 to September
                          2011, the number of electronics recycling facilities certified to the R2
Agencies to Increase      standard increased from 15 to 122 and the number of facilities certified to
Their Use                 the e-Stewards standard grew from 6 to 40. Figure 1 shows the locations
                          of the electronics recycling facilities in the United States that have
                          obtained third-party certification as of September 30, 2011.




                          31
                           Resources include instruction sheets, tips, and checklists, among other things, which
                          participants can choose to use.




                          Page 16                                                       GAO-12-74 Electronic Waste
Figure 1: Electronics Recycling Facilities Certified to the R2 or e-Stewards Standard, as of September 30, 2011




                                          The increased number of certified recyclers should make it easier for
                                          agencies to locate recyclers that will, among other things, ensure that any
                                          harmful materials are being safely handled throughout the recycling
                                          chain. For the five agencies we reviewed, almost no certified recyclers
                                          were used, and in most cases agency officials either misidentified a
                                          recycler’s certification status or indicated that they did not know the
                                          recycler’s certification status. According to our analysis of the disposition
                                          information these agencies provided, of the 25 electronics recycling
                                          companies that the five agencies reported using in fiscal year 2010, only
                                          one was certified by either R2 or e-Stewards for all locations where the
                                          agency used it as of September 30, 2010, and agencies were correct in



                                          Page 17                                                    GAO-12-74 Electronic Waste
identifying whether or not their recyclers were certified in only four
cases. 32

The confusion regarding electronics recyclers’ certification status could
stem in part from the absence of clear guidance. The implementing
instructions for Executive Order 13423 direct agencies to use national
standards, best management practices, or a national certification program
for recyclers. To date, however, none of the oversight agencies—OMB,
CEQ, and OFEE—have provided agencies with clear guidance specifying
whether R2 or e-Stewards, the two existing certification programs, qualify
as “national certification programs for recyclers” under the implementing
instructions. 33

In an effort to address this issue, according to the National Strategy for
Electronics Stewardship, EPA and GSA are to take steps to address the
need for well-defined requirements for those certification programs that
federal agencies will rely upon. Specifically, EPA, in consultation with
GSA and other relevant agencies, is to develop a baseline set of
electronics recycling criteria to ensure, among other things, that all
downstream handlers of used electronics manage these materials in a
way that protects the environment, public health, and worker safety. EPA
is also to initiate a study of the current electronics certification programs
to evaluate the strength of their audits of downstream facilities. According
to the national strategy, as part of its effort to establish a comprehensive
and governmentwide policy on used federal electronic products, GSA will
consider the baseline set of criteria, the results of the study of current
certification programs, and other requirements and considerations in
determining which certification programs satisfy the governmentwide
requirement to use certified recyclers. Although the strategy calls for GSA
to, with public input, issue a revised policy and propose changes to the
FMR, it is unclear if GSA is on track to do this by February 2012, given
that it has not issued a public draft, nor conducted a public comment or
other public input process. Similarly it is unclear when, if, or how GSA’s
revised policy component regarding certified recyclers will be
incorporated into the FMR. Moreover, it is unclear what mechanism GSA



32
 Of the 25 electronics recyclers used by the five agencies in fiscal year 2010, four had
obtained either R2 or e-Stewards certification as of September 30, 2011 for all locations
used by the agencies.
33
     EPA has formally recognized these programs on its website.




Page 18                                                           GAO-12-74 Electronic Waste
                           will use to issue the revised policy prior to its inclusion in the FMR, as the
                           policy may not be in conformance with the current FMR. In addition, the
                           national strategy does not specify if or how EPA and GSA will routinely
                           update other federal agencies on the status of their efforts to implement
                           the national strategy’s recommendations. 34


The Tracking and           Currently, due to challenges associated with the tracking and reporting of
Reporting of Data on the   used federal electronics, the ultimate disposition of these electronics is
Disposition of Used        unknown—making it difficult to measure the effectiveness of Executive
                           Orders 13423 and 13514, which were aimed at improving the
Electronics Presents       management of used federal electronics and ensuring the proper disposal
Challenges                 of electronics that have reached the end of their useful life. The National
                           Strategy for Electronics Stewardship acknowledges the challenges
                           associated with tracking and reporting the disposition of used federal
                           electronics and proposes some solutions for improving the data that
                           agencies report to GSA. Under the national strategy, GSA is to streamline
                           and standardize reporting through the annual Report of Non-Federal
                           Recipients 35 to gather data on the type, quantity, and intended use of
                           electronic products leaving federal ownership, and the recipients of these
                           products. It is unclear, however, what electronics the new reporting
                           requirements will cover. The national strategy suggests that the annual
                           Report of Non-Federal Recipients will be expanded to include the
                           reporting of the disposition of electronic products to all recipients.
                           Currently, the report includes only property donated to such nonfederal
                           recipients as schools and state and local governments, and therefore
                           does not include the disposition of significant quantities of electronics.

                           If GSA intends to use this report to capture agencies’ data, it is unclear
                           how the report will improve the quality of the limited data GSA currently
                           receives. GSA officials told us that while the agency currently collects
                           disposition data from agencies through its GSAXcess database,
                           GSAXcess is not an accountable property system; 36 therefore, data


                           34
                              The benchmark document issued along with the national strategy states “As the National
                           Strategy is implemented, the project benchmarks will be updated.”
                           35
                              Under 40 U.S.C. § 529, executive agencies must submit to GSA, following the close of
                           each fiscal year, an annual report of personal property furnished to any nonfederal
                           recipient during the previous fiscal year, known as the Report of Non-Federal Recipients.
                           36
                            Accountable property systems are “systems of record” or systems that contain an
                           agency’s official property records, according to GSA officials.




                           Page 19                                                       GAO-12-74 Electronic Waste
                           validation is limited. 37 According to a GSA bulletin, a number of executive
                           agencies have not submitted reports to GSA on exchange/sale
                           transactions and property furnished to nonfederal recipients, as currently
                           required, or have not included all of the required information—thus
                           presenting data challenges as GSA seeks to carry out its oversight and
                           management responsibilities.

                           The data challenges are further complicated by the fact that individual
                           agency procedures for tracking electronics are not consistent. Agencies
                           typically record the acquisition of electronics as individual units, such as
                           desktop or laptop computers, and continue to track these electronics as
                           individual units while in use at the agency. However, when agencies
                           dispose of these same electronics, they may use a different method for
                           tracking them. For example, rather than tracking the disposition of used
                           electronic products as individual units, agencies may aggregate a number
                           of similar items into a single line item or they may report them by weight.
                           In addition, a single agency may use different metrics for different types of
                           disposition. For example, DLA, a DOD acquisition and disposition agency,
                           tracks electronic products sent to recyclers in pounds and electronic
                           products disposed of through other means—such as donated to schools
                           or transferred to other agencies—by individual unit. Because some
                           electronics are tracked and reported as line items and some are recorded
                           in pounds, it is not possible to compare the extent to which the agency
                           relies on one disposition method over another. For the five agencies we
                           reviewed, data provided to us on the disposition of electronic products
                           were similarly inconsistent, which hampered our efforts to accurately
                           assess the extent to which electronic products procured by these federal
                           agencies were disposed of in an environmentally sound manner.


Challenges Remain in       GSA’s personal property disposition procedures do not clarify agency
Clarifying Agencies’       responsibilities for tracking or placing contract conditions on the ultimate
Responsibility for Used    disposition of used electronics if they are sold through auctions. As we
                           reported in August 2008, some electronics recyclers in the United
Electronics Sold through   States—including those that have purchased government electronics sold
Auctions



                           37
                             GSA has built edit checks into the system requiring agencies to confirm amounts that
                           are over certain dollar amounts.




                           Page 20                                                       GAO-12-74 Electronic Waste
through auction—appeared willing to export regulated electronics
illegally. 38

We identified two auction disposal methods—those used by GSA and by
DOD—that could result in used federal electronics being handled in an
environmentally risky manner. Specifically, under the GSA auction process,
registered participants can bid electronically on items within specific time
frames. To participate, potential buyers register with GSA by providing
information about themselves, such as name, address, and payment
information, before they can bid on items, according to GSA officials.
However, GSA officials told us that they do not evaluate the information
obtained from buyers to determine whether they are brokers or resellers
who might potentially export these used products to other countries where
they may not be handled in an environmentally sound or safe manner.
Moreover, GSA officials stated that the agency does not have enforcement
authority after these items are sold to the general public. They told us that if
GSA is made aware of any inappropriate activity or violations of the terms
of the sale, it will refer the information to the GSA Inspector General for
further investigation. According to agency documentation, GSA’s online
auction procedures include standard sales terms and conditions, special
security notifications, and export control clauses. However, none of the
terms, conditions, or clauses included in GSA’s auction procedures are
aimed at ensuring that (1) electronics containing certain materials 39 are
exported only to countries that can legally accept them, 40 (2) recyclers
document the legality of such exports, and (3) the material is being safely
handled throughout the recycling chain.




38
 GAO-08-1044. EPA has issued regulations specifically addressing management of
cathode ray tubes, and imposing requirements on their handling and export.
39
   For example, the R2 practices identify “focus materials,” which include items such as
cathode-ray tubes or items containing mercury that warrant greater care owing to their
toxicity and associated risk if managed without the appropriate safeguards.
40
  GSA’s general sales terms and conditions contain general conditions requiring, among
other things, that bidders comply with all applicable federal, state, local, and multi-
jurisdictional laws, ordinances, and regulations, in the transportation, transfer, export, use,
or disposal of the property, and that purchasers represent, warrant, and certify that they
will use and ultimately dispose of any hazardous property purchased under
GSAAuctions.gov site as stipulated under applicable federal, state, local, and international
laws and regulations. As previously noted, however, most electronics are not considered
“hazardous” under U.S. law.




Page 21                                                           GAO-12-74 Electronic Waste
Unlike GSA, DOD is not directly involved in the auction process but
instead sells its used electronics to a private company, which then resells
the used electronics through its web-based auction process. According to
DOD officials, DOD’s responsibility for tracking its used electronics ends
once it passes to the contractor—Government Liquidation. DOD officials
said that Government Liquidation has its own terms and conditions that
bidders must adhere to once they purchase the used electronics. As with
GSA auctions, the terms and conditions included in the Government
Liquidation auctions are not aimed at ensuring that used federal
electronics are exported only to countries that that can legally accept
them. 41 In our review of these auction websites, we found that the
overwhelming majority of used electronic products are sold in bulk, which
would indicate that they are being sold to brokers or resellers, not
individual consumers. 42

The National Strategy for Electronics Stewardship seeks to address the
problems associated with used federal electronics sold through auction.
According to the strategy, the electronics stewardship policy that GSA is to
establish will prohibit the sale of nonfunctional electronics through public
auction except to third-party certified recyclers and refurbishers. Functional
electronics are to be directed through the existing hierarchy of transfer,
donation, and sale. It is unclear, however, how this policy will work in
practice. Currently, agencies sell electronics in mixed lots of potentially
functional and nonfunctional equipment. For example, officials at one
agency said that it was not cost effective to test items to ensure that they



41
   Government Liquidation’s terms and conditions contain the general requirement that the
buyer agrees to comply with all applicable export laws and regulations. However, most
electronics are not considered “hazardous” under U.S. law, thus are not subject to EPA’s
export rules for hazardous wastes. The terms also note that “[a]ny device which is
damaged in transit or is found to be cracked, shattered or broken may subject the Buyer to
regulations pertaining to the handling, storage, transportation, re-sale or disposal of
electronic waste,” and generally cautions—but does not require—buyers “to use and
ultimately dispose of any hazardous components or constituents according to all
applicable local, national or international laws and regulations in a manner safe for the
public and the environment.”
42
   Moreover, information on the potential for reuse of such equipment is unclear. These
auctions are typically labeled as “scrap,” defined by Government Liquidation as “property
sold for its material content value, and for which it is not intended that the property or any
of its parts or components be used for its originally intended purpose.” Government
Liquidation’s terms and conditions, however, state that it sells only useable electronic
devices, including reparable devices, but that the company makes no warranties or
representations regarding the electronic devices it sells.




Page 22                                                           GAO-12-74 Electronic Waste
are functional; therefore, items are sold through GSA “as is” with no implied
warranty. These agency officials said that they combine items in sales lots
that will bring the most return to the federal government. In addition, we
found that electronics listed on the Government Liquidation and GSA
auction websites are frequently marketed as “tested to power-up only,” or
with disclaimers such as “condition of the property is not warranted.” Under
the national strategy, it is unclear whether electronics characterized in this
way would qualify as “functional.” In addition, the national strategy does not
provide clear and detailed criteria to assist federal agencies in bundling
functional and nonfunctional electronics for sale exclusively to certified
recyclers or refurbishers, distinguishing between functional and
nonfunctional electronics by conducting specific tests, and labeling
electronic products. Moreover, if federal agencies sell used functional
electronic products through auctions, neither the agency nor the auction
entities are required to impose conditions or to perform due diligence by
conducting auditing to determine whether all downstream reusers of such
products follow environmentally sound end-of-life practices.

In contrast, the European Union has detailed guidance for determining
the functionality of electrical and electronic equipment, as part of
distinguishing whether the equipment is considered waste in the context
of import-export rules. The guidance states that the tests required to
determine functionality depend on the type of electronics, but generally,
completion of a visual inspection without testing functionality is unlikely to
be sufficient for most types of electronics; it also states that a functionality
test of the key functions is sufficient. The guidance also identifies defects
that materially affect functionality and would therefore cause an item to be
considered “waste” if, for example, the equipment did not turn on, perform
internal set-up routines, or conduct self-checks. 43 As discussed
previously, R2 practices establish a similar “reuse, recover, dispose”
hierarchy along the chain of custody for material handling and require
recyclers to test electronics diverted for reuse, and confirm that key
functions of the unit are working before it may be exported. 44




43
   Regulation (EC) No 1013/2006 Revised Correspondents’ Guidelines No. 1, Shipments of
Waste Electrical and Electronic Equipment (WEEE) (June 2007).
44
   Similarly, WRAP, a government-backed private nonprofit organization in the United
Kingdom, recently issued a protocol establishing minimum recommended tests that
computers and related equipment must pass to be considered functional and fit for reuse.




Page 23                                                      GAO-12-74 Electronic Waste
Challenges Remain in        We found that key terms concerning electronics have not been defined
Defining Key Terms and in   and that differences between the executive orders have not been
Clarifying Differences      clarified. In particular:
between the Executive       •   Key terms not defined. Key terms such as “electronic product” and
Orders                          “environmentally sound practices” are not explicitly defined in the
                                executive orders, the guidance provided to agencies for implementing
                                the executive orders, or the National Strategy for Electronics
                                Stewardship. Consequently, each of the agencies we reviewed used
                                its own definition of electronic products to report progress in
                                implementing policies for electronics stewardship. For example, DOE
                                defines electronic products as printers, desktop computers, notebook
                                computers, and monitors; DOD, Education, HUD, and NASA use
                                broader definitions that include servers, routers, and switches; cell
                                phones and musical instruments; and refrigerators. Moreover, without
                                a clear definition of what constitutes an environmentally sound
                                practice, agencies are free to dispose of their used electronics
                                through online auctions or other means that provide little assurance
                                that (1) these electronics are exported only to countries that can
                                legally accept them, 45 (2) recyclers document the legality of such
                                exports, and (3) the material is being safely handled throughout the
                                recycling chain.

                            •   Differences between the executive orders have not been clarified.
                                CEQ has not issued implementing instructions regarding electronics
                                stewardship for Executive Order 13514, which was signed in 2009,
                                and CEQ, OMB, and OFEE have not harmonized the electronics
                                stewardship requirements contained in executive orders 13423 and
                                13514. For example, under Executive Order 13423, the requirement
                                to use environmentally sound practices applies to electronic
                                equipment that has “reached the end of its useful life,” whereas
                                Executive Order 13514 includes “all agency excess or surplus
                                electronic products,” and the difference between these terms has not
                                been clarified. In addition, the implementing instructions for Executive



                            45
                               Under EPA regulations, used cathode-ray tubes are the only electronic device
                            specifically regulated as hazardous waste and whose export is subject to controls.
                            According to EPA statements, used electronic devices other than cathode-ray tubes do
                            not generally qualify as hazardous waste under the Resource Conservation and Recovery
                            Act of 1976 as amended, which is the statute governing hazardous waste handling and
                            disposal. However, foreign countries may restrict the import of a wider range of used
                            electronics.




                            Page 24                                                    GAO-12-74 Electronic Waste
                  Order 13423 direct agencies to ensure that contracts for leased
                  electronic equipment incorporate language that requires that at the
                  end of the lease period, the equipment is reused, donated, sold, or
                  recycled using environmentally sound management practices. This
                  directive is not included in Executive Order 13514 nor in the guidance
                  provided to agencies for preparing their strategic sustainability
                  performance plan that is to be used under Executive Order 13514.
                  Officials from these oversight agencies told us that they have
                  informed federal agencies that electronics stewardship plans under
                  Executive Order 13423 can be incorporated by reference into their
                  strategic sustainability performance plans to satisfy certain
                  requirements for Executive Order 13514. Or alternatively, strategic
                  sustainability performance plans may be used in lieu of separate
                  electronics stewardship plans. However, CEQ, OMB, and OFEE have
                  not addressed differences or updated the implementing instructions
                  for Executive Order 13423.


              Federal initiatives to improve the management of agencies’ used
Conclusions   electronics—including the FEC, certification for recyclers, personal
              property disposal guidance, the executive orders, and the National
              Strategy for Electronics Stewardship—have sought to assist federal
              agencies in the handling of used electronic products. And progress has
              been made. More agencies and facilities are participating in the FEC, and
              a growing number of recyclers have received third-party certification.
              However, opportunities exist to increase the breadth and depth of
              agencies’ participation in the FEC and to expand the use of certified
              electronics recyclers.

              Federal agencies also face challenges that may impede their progress
              toward improving their management of used federal electronics.
              Specifically, 2 years have elapsed since Executive Order 13514 required
              CEQ to issue implementing instructions. In the absence of such
              instructions, agencies do not have definitions for key terms such as
              “electronic products” and “environmentally sound practices,” and the
              guidance for implementing the executive orders provides inconsistent
              information on what procedures an agency should follow when
              implementing environmentally sound practices. In addition,
              inconsistencies between Executive Orders 13514 and 13423 have yet to
              be addressed; without doing so, CEQ lacks assurance that agencies are
              meeting electronics stewardship requirements of both orders, given that
              CEQ and OMB permit agencies to comply using either an electronics
              stewardship plan under Executive Order 13423 or a strategic



              Page 25                                            GAO-12-74 Electronic Waste
                      sustainability performance plan under Executive Order 13514.
                      Furthermore, without consistent tracking and reporting of the disposition
                      of used federal electronics, there is no mechanism to measure the
                      effectiveness of federal policies aimed at ensuring the proper disposal of
                      electronics that have reached the end of their useful life.

                      The recently issued National Strategy for Electronics Stewardship seeks
                      to advance federal agencies’ efforts to manage used electronics.
                      However, it is unclear whether it will fully address challenges that impede
                      environmentally sound management of used federal electronics.
                      Furthermore, it is doubtful whether the strategy will be effective without a
                      mechanism for routinely keeping agencies and the public apprised of its
                      progress toward establishing a governmentwide policy on used federal
                      electronics—particularly with respect to use of third-party national
                      certification for electronics recyclers—so that agencies have a clear
                      understanding of their responsibilities and other interested parties are
                      apprised of agencies’ progress toward completing actions identified in the
                      strategy. Currently, the strategy does not state how agencies will be kept
                      informed of implementation efforts. In addition, the strategy lays out an
                      approach for ensuring that federal agencies dispose of nonfunctional
                      electronics in a sound manner, but it does not provide clear and detailed
                      criteria to assist federal agencies in bundling functional and nonfunctional
                      equipment for sale exclusively to certified recyclers and refurbishers and
                      distinguishing between functional and nonfunctional electronics by
                      conducting specific tests and labeling electronic products. Finally, if
                      federal agencies sell used functional electronic products through
                      auctions, neither the agency nor the auction entities are required to
                      perform due diligence by conducting auditing to determine whether all
                      downstream reusers of such products follow environmentally sound end-
                      of-life practices.


                      To improve federal electronics stewardship, we are making the following
Recommendations for   four recommendations.
Executive Action
                      To support federal agencies’ efforts to improve electronics stewardship,
                      we recommend that the Director of the White House Council on
                      Environmental Quality, in collaboration with the Director of the Office of
                      Management and Budget, and the Administrator of the General Services
                      Administration collaborate on developing and issuing implementing
                      instructions for Executive Order 13514 that




                      Page 26                                              GAO-12-74 Electronic Waste
                     •   define key terms such as “electronic products” and “environmentally
                         sound practices;” address inconsistencies between this executive
                         order and Executive Order 13423; and as appropriate, provide clear
                         direction on required agency actions under the national strategy; and

                     •   require consistent information tracking and reporting on the
                         disposition of used electronics among agencies.

                     To provide transparency on progress toward completing the actions
                     identified in the National Strategy for Electronics Stewardship, we
                     recommend that the Director of the White House Council on
                     Environmental Quality, the Administrator of EPA, and the Administrator of
                     GSA provide quarterly status updates on a publicly accessible website.

                     To ensure that electronic products procured by federal agencies are
                     appropriately managed, we recommend that GSA include measures in its
                     policy to ensure that all electronics sold through auction are appropriately
                     managed once they reach the end of their useful lives. Such measures
                     could include

                     •   bundling functional and nonfunctional equipment for sale exclusively
                         to certified recyclers, who would be responsible for determining the
                         best use of the equipment under the “reuse, recover, dispose”
                         hierarchy of management; or

                     •   if agencies or GSA are to be responsible for screening electronics for
                         auction and distinguishing between functional and nonfunctional
                         equipment,

                         •     providing clear and detailed criteria for doing so, such as specific
                               testing and labeling; and

                         •     ensuring that purchasers or recipients of functional electronic
                               products sold through government auctions use certified recyclers
                               or perform due diligence and conduct downstream auditing.


                     We provided a draft of this report to OMB, CEQ, GSA, and EPA for
Agency Comments      review and comment. In addition, we provided DOD, DOE, Education,
and Our Evaluation   HUD, and NASA with excerpts of the draft report that pertained to each
                     agency and incorporated technical comments received as appropriate. In
                     written comments, which are reproduced in appendix II, EPA generally
                     concurred with our recommendations. OMB, CEQ, and GSA did not



                     Page 27                                                 GAO-12-74 Electronic Waste
provide written comments to include in our report. Instead, in e-mails
received on February 1, January 19, and January 17, 2012, from the
agencies’ respective liaisons, OMB, CEQ, and GSA generally concurred
with our recommendations. Even with their general concurrences, in
some instances, the agencies proposed alternative approaches for
executing the recommendations. In the e-mail from its liaison, OMB
concurred with the comments in the e-mail from CEQ’s liaison but did not
provide additional comments of its own.

In response to our recommendation that CEQ, in collaboration with OMB
and GSA, issue implementing instructions for Executive Order 13514 that
define key terms; require consistent information tracking and reporting;
and provide clear direction on required agency actions under the national
strategy, CEQ stated that it would reserve its decision regarding our
recommendation until after GSA issues its comprehensive
governmentwide policy on electronic stewardship. Specifically, CEQ
stated that GSA’s policy would address the issues we identified with
regard to unclear definitions and inconsistent tracking and reporting of
electronics but was silent on how it would provide clear direction on
required agency actions under the national strategy. GAO believes it is
imperative for CEQ to issue implementing instructions along with GSA’s
issuance of its policy. Without such instructions, agencies will lack clarity
on required agency actions under the national strategy and whether
adhering to the GSA policy is necessary and/or sufficient for
implementing the executive order. Moreover, it remains unclear what
mechanism GSA will use to issue its revised policy prior to its inclusion in
the FMR, to the extent the current FMR does not conform with the new
policy. Concerning this issue, GSA stated that it will publish guidance
documents concurrent with proposing changes to the FMR. However, as
GSA intends to issue guidance documents, which are not legally binding
on agencies, as well as regulations, which are, it will be important for
CEQ to issue implementing instructions that indicate which actions in the
guidance documents, as well as any other actions beyond those in the
FMR, are necessary to comply with the executive order.

In addition, as we recommended, CEQ, EPA, and GSA agreed that they
would update a publicly accessible website on the status of progress
toward completing the actions identified in the National Strategy for
Electronics Stewardship. CEQ stated that progress reporting would be
accomplished by GSA and GSA agreed to provide status updates at least
quarterly. However, in its written comments, EPA requested that, instead
of quarterly status updates, we revise our recommendation to require
status updates as significant progress is made or key milestones are met.


Page 28                                              GAO-12-74 Electronic Waste
EPA stated that due to the nature of some of the work the agencies have
committed to as part of the national strategy, it may not be appropriate to
report to the general public on a routine basis. We did not revise the
recommendation and are not recommending such disclosure. Instead, we
are recommending that the agencies provide a quarterly status update
that characterizes the progress made toward achieving each action item
or project. For example, one action item in the national strategy directed
the Federal Electronics Stewardship Working Group to recommend to
CEQ by November 18, 2011, metrics and other reporting tools to
measure agencies’ progress in implementing the revised Federal
Electronics Stewardship Policy. It would be helpful to have updated
information on whether the working group has made its recommendation
to CEQ and when CEQ will announce the new metrics and reporting
tools. Currently, such information is not publicly available. In fact, as of
February 8, 2012, more than 6 months after the policy and benchmarks
were issued, no updates have been provided on publicly accessible
websites.

With regard to our recommendation that GSA include measures in its
electronic stewardship policy to ensure that all electronics sold through
auction are appropriately managed once they reach the end of their
useful lives, in the e-mail received from its liaison, GSA noted that the
agency is working toward this goal. Specifically, GSA stated that it is
working toward including measures to (1) bundle all equipment for sale to
certified recyclers, who then determine proper reuse or recycling, or (2)
provide agencies with clear, detailed criteria to distinguish between
functional and nonfunctional electronics and ensure that purchasers or
recipients of federal electronics use certified recyclers or perform
downstream auditing, while also noting that GSA has limited authority to
require recipients of used federal electronics to recycle them once
ownership has transferred to those recipients.




Page 29                                              GAO-12-74 Electronic Waste
As agreed with your office, unless you publicly announce the contents of
this report earlier, we plan no further distribution for 30 days from the
report date. At that time, we will send copies to the Secretaries of
Defense, Education, Energy, and Housing and Urban Development; the
Administrators of EPA, GSA, and NASA; the Director of OMB; the Chair
of the White House CEQ; the Federal Environmental Executive;
appropriate congressional committees; and other interested parties. The
report also will be available at no charge on the GAO website at
http://www.gao.gov.

If you or your staff have any questions concerning this report, please
contact me at (202) 512-3841 or ruscof@gao.gov. Contact points for our
Offices of Congressional Relations and Public Affairs may be found on
the last page of the report. GAO staff who made major contributions to
this report are listed in appendix III.

Sincerely yours,




Frank Rusco
Director, Natural Resources
  and Environment




Page 30                                            GAO-12-74 Electronic Waste
Appendix I: Objectives, Scope, and
              Appendix I: Objectives, Scope, and
              Methodology



Methodology

              The objectives for this report were to examine (1) key initiatives aimed
              at improving the management of used federal electronics and
              (2) improvements resulting from these initiatives and challenges that
              impede progress toward improving the management of used federal
              electronics, if any.

              To identify initiatives aimed at improving the management of used federal
              electronics, we reviewed guidance and other documents describing the
              Environmental Protection Agency (EPA) initiatives related to the Federal
              Electronics Challenge (FEC), the Federal Electronics Stewardship
              Working Group, and Responsible Recycling (R2) practices. We analyzed
              the requirements for electronic products contained in the applicable
              executive orders and implementing instructions that make up the federal
              policy framework; the Federal Acquisition Regulation, which governs the
              process through which the federal government acquires goods and
              services; the Federal Management Regulation (FMR), which, among
              other things, regulates the disposal of federal personal property, including
              electronics; 1 and the General Services Administration’s (GSA) Personal
              Property Disposal Guide, which serves as an index and quick-reference
              guide as it relates to personal property management provisions in the
              FMR; and other relevant electronics stewardship guidance. We also
              reviewed the July 2011 National Strategy for Electronics Stewardship.

              To identify improvements resulting from federal initiatives to improve
              management of used federal electronics and challenges that impede
              progress, we selected a nonprobability sample of five federal agencies—
              the departments of Defense (DOD), Energy (DOE), Education
              (Education), and Housing and Urban Development (HUD); and the
              National Aeronautics and Space Administration (NASA)—to examine how
              the federal policy framework is carried out in those agencies. We selected
              DOD, DOE, and NASA because they each participated to some extent in
              the FEC program and purchased large amounts of electronic products—
              ranking first, eighth, and tenth, respectively, in terms of overall federal
              agency information technology spending in fiscal year 2010. We selected
              Education because, according to the FEC program manager, the agency
              actively participates in the FEC and centrally manages its electronics


              1
               The FMR, Subchapter B-Personal Property. 41 C.F.R. Pt. 102-36, requires that executive
              agencies, to the maximum extent practicable, fill requirements for personal property by
              using existing agency property or by obtaining excess property from other federal
              agencies in lieu of new procurements.




              Page 31                                                     GAO-12-74 Electronic Waste
Appendix I: Objectives, Scope, and
Methodology




procurement and disposal functions. We selected HUD because the
agency was not participating in the FEC. We used FEC participation as a
selection criterion because we hoped to include agencies with a range of
experience with managing used electronics in an environmentally safe
way. Because the selection of agencies was based on a nonprobability
sample, the information we obtained is not generalizable to all federal
agencies. However, because the nonprobability sample consists of a
cross-section of agencies of different sizes and levels of participation in
the FEC, the evaluation of these agencies provides relevant examples of
different procurement and disposition methods for electronics. For these
five agencies we also collected and reviewed fiscal year 2010 strategic
sustainability performance plans. We also conducted semistructured
interviews with officials from the Office of Management and Budget
(OMB), the White House Council on Environmental Quality (CEQ), the
Office of the Federal Environmental Executive (OFEE), and EPA to
discuss their respective roles in assessing agency performance and
managing the FEC and other federal initiatives for electronics
stewardship. In some cases, we followed up the interviews with additional
questions, and on two occasions, CEQ provided us with written
responses to some of our questions on the roles of OMB, CEQ, and
OFEE and other issues on federal electronics stewardship, such as how
OMB and CEQ decide on whether an agency’s program is equivalent to
the FEC. In addition, at GSA, we conducted semistructured interviews
with officials on the agency’s policies and procedures for the transfer,
donation, sale, and recycling of electronic products.

To determine the extent to which agencies used various disposition
methods (i.e., reuse, donation, and sale) we analyzed governmentwide
GSA data from GSAXCess, Exchange Sale, and Non-Federal Recipients
reports for fiscal year 2010. We designed and implemented a data
collection instrument to collect agency-specific disposition data for fiscal
years 2009 and 2010 from the five agencies selected for our
nonprobability sample. We encountered a number of limitations in
obtaining reliable data. For example, GSA officials acknowledged that
GSA does not verify the data that it collects from other agencies. The five
selected agencies that we collected data from also did not have
consistent definitions of electronics and sometimes reported inconsistent
information or used inconsistent methods of tracking the disposition of
used electronics. For example, DOD tracks some items by weight and
other items by line item. We attempted to resolve inconsistencies in the
data provided through this effort through follow-up efforts with the five
agencies in which we discussed how they attempted to collect the data
we requested and related challenges and limitations. Based on these


Page 32                                              GAO-12-74 Electronic Waste
Appendix I: Objectives, Scope, and
Methodology




conversations, we determined that the data were not sufficiently reliable
for the purposes of reporting on amounts of electronics disposed of by the
five agencies and we did not use information collected in the data
collection instrument on the extent to which agencies used various
disposition methods.

We also visited the Kennedy Space Center, in Cape Canaveral, Florida,
and Defense Logistics Agency (DLA) Aviation in Richmond, Virginia, to
discuss the procurement and disposition of electronic products. We
selected Kennedy Space Center because it is designated as NASA’s
Principal Center for Recycling and Sustainable Acquisition. We selected
DLA Aviation in Richmond, Virginia, because of its role in disposing of
excess property received from the military services through DLA
Disposition. We also visited a UNICOR recycling facility located in
Lewisburg, Pennsylvania, as well as two private electronics recycling
facilities located in Tampa, Florida. 2 We selected these facilities because
of their role in electronics recycling at federal agencies. At these facilities,
we interviewed officials about the procedures involved in recycling used
federal electronic products and observed the electronics recycling
process to learn how electronics are safely disassembled and, in some
cases, processed for reuse.

To assess the extent to which the July 2011 National Strategy for
Electronics Stewardship addresses any challenges that may impede
participation in electronics stewardship initiatives, we examined key
provisions of the strategy, such as dividing functional and nonfunctional
electronics, and compared these provisions with existing policies for
electronics stewardship. In response to our request for information on
electronics stewardship, FEC program’s manager, officials within each of
the five agencies, and seven champions for the FEC program provided
information on the challenges that may affect agency participation in
electronics stewardship initiatives. 3 In addition, we interviewed officials




2
 UNICOR, Federal Prison Industries is a self-sustaining, self-funded corporation
established in 1934 by executive order to create a voluntary real-world work program to
train federal inmates.
3
 We obtained written information on the responsibilities, training, and challenges facing
seven FEC champions. The FEC program manager currently serves as the champion for
two of the EPA regions, and the FEC champion for one region did not respond to our
request for information.




Page 33                                                       GAO-12-74 Electronic Waste
Appendix I: Objectives, Scope, and
Methodology




with the R2 and e-Stewards recycler certification programs, 4, 5 the
Electronics TakeBack Coalition, and an electronics recycler to determine
the extent to which recyclers in the United States have obtained
certification and to discuss their views about the capacity of certified
electronics recyclers located in the United States.

We conducted this performance audit from October 2010 to January 2012
in accordance with generally accepted government auditing standards.
Those standards require that we plan and perform the audit to obtain
sufficient, appropriate evidence to provide a reasonable basis for our
findings and conclusions based on our audit objectives. We believe that
the evidence obtained provides a reasonable basis for our findings and
conclusions based on our audit objectives.




4
 The Responsible Recycling (R2) Practices is a set of guidelines for accredited
certification programs to assess electronics recyclers’ environmental, worker health and
safety, and security practices.
5
 The e-Stewards Standard for Responsible Recycling and Reuse of Electronic Equipment
was developed by the Basel Action Network and is the basis for electronics recycling
companies to become certified e-Stewards recyclers.




Page 34                                                        GAO-12-74 Electronic Waste
Appendix II: Comments from the
             Appendix II: Comments from the
             Environmental Protection Agency



Environmental Protection Agency




             Page 35                           GAO-12-74 Electronic Waste
Appendix II: Comments from the
Environmental Protection Agency




Page 36                           GAO-12-74 Electronic Waste
Appendix III: GAO Contact and Staff
                  Appendix III: GAO Contact and Staff
                  Acknowledgments



Acknowledgments

                  Frank Rusco, (202) 512-3841 or ruscof@gao.gov
GAO Contact
                  In addition to the contact named above, Diane LoFaro, Assistant Director;
Staff             Elizabeth Beardsley; Pamela Davidson; Stephanie Gaines; Deborah
Acknowledgments   Ortega; Ilga Semeiks; Carol Herrnstadt Shulman; and Vasiliki
                  Theodoropoulos contributed to this report.




                  Page 37                                           GAO-12-74 Electronic Waste
Related GAO Products
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             Green Information Technology: Agencies Have Taken Steps to
             Implement Requirements, but Additional Guidance on Measuring
             Performance Needed. GAO-11-638. Washington, D.C.: July 28, 2011.

             Data Center Consolidation: Agencies Need to Complete Inventories and
             Plans to Achieve Expected Savings. GAO-11-565. Washington, D.C.:
             July 19, 2011.

             Electronic Waste: Considerations for Promoting Environmentally Sound
             Reuse and Recycling. GAO-10-626. Washington, D.C.: July 12, 2010.

             Federal Electronics Management: Federal Agencies Could Improve
             Participation in EPA’s Initiatives for Environmentally Preferable Electronic
             Products. GAO-10-196T. Washington, D.C.: October 27, 2009.

             Electronic Waste: EPA Needs to Better Control Harmful U.S. Exports
             through Stronger Enforcement and More Comprehensive Regulation.
             GAO-08-1044. Washington, D.C.: August 28, 2008.

             Electronic Waste: Strengthening the Role of the Federal Government in
             Encouraging Recycling and Reuse. GAO-06-47. Washington, D.C.:
             November 10, 2005.

             Electronic Waste: Observations on the Role of the Federal Government in
             Encouraging Recycling and Reuse. GAO-05-937T. Washington, D.C.:
             July 26, 2005.




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             Page 38                                              GAO-12-74 Electronic Waste
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