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THE COLLECTION AND RECYCLING OF
USED COMPUTERS USING A REVERSE
DISTRIBUTION SYSTEM
A PILOT PROJECT
WITH STAPLES, INC.
FINAL REPORT
TO THE
U.S. ENVIRONMENTAL PROTECTION AGENCY
Developed by:
Product Stewardship Institute, Inc.
137 Newbury Street
Boston, MA 02116
(617) 236-4855
www.productstewardship.us
June 2005
Staples Pilot Project –Final Report to U.S. EPA
ACKNOWLEDGEMENTS
This report was written by Scott Cassel, Product Stewardship Institute Inc., with assistance from
Mark Buckley, Staples, and Christine Beling, U.S. Environmental Protection Agency/New
England.
The following people assisted in the development and implementation of this pilot project:
Mark Buckley
Vice President, Environmental Affairs
Staples, Inc.
(508) 253-0510
mark.buckley@staples.com
Scott Cassel
Executive Director, Product Stewardship Institute, Inc.
(617) 236-4855
scott@productstewardship.us
Christine Beling
U.S. Environmental Protection Agency/New England
(617) 918-1792
beling.christine@epa.gov
The following individuals provided technical information and assistance:







Katharine Kaplan Osdoba and Clare Lindsay, U.S. Environmental Protection Agency
Tom Metzner, Connecticut Department of Environmental Protection
Diana McKenzie, Carole Cifrino, and Scott Whittier, Maine Department of
Environmental Protection
Greg Cooper and James Paterson, Massachusetts Department of Environmental
Protection
Pierce Rigrod and Mike Guilfoy, New Hampshire Department of Environmental Services
Mark Dennen, Rhode Island Department of Environmental Management
Tina Haley and Mike Tallon, Envirocycle, Inc.
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TABLE OF CONTENTS
Problem Statement .................................................................................................................... 1
Goal Statement .......................................................................................................................... 1
Project Concept ......................................................................................................................... 1
Collaborative Project/Partners .................................................................................................. 2
Timeframe ................................................................................................................................. 2
Products Accepted .................................................................................................................... 2
General Operations ................................................................................................................... 3
Retail Operations .......................................................................................................... 3
Commercial Operations ................................................................................................ 3
Transportation to Recycler ............................................................................................ 3
Project Results .......................................................................................................................... 3
Data Collection ............................................................................................................. 3
Materials Collected: Units and Weights ....................................................................... 3
Retail Customer Surveys at Retail Locations ............................................................... 4
Contract Customer Surveys at Commercial Locations ................................................. 5
Customer Satisfaction ................................................................................................... 5
Promotion/Advertising and Customer Education ..................................................................... 6
project Costs.............................................................................................................................. 6
Retail Collection Costs ................................................................................................. 7
Commercial Collection Costs ....................................................................................... 8
Recycling Costs ............................................................................................................ 8
Other Costs.................................................................................................................... 9
Regulatory Issues ...................................................................................................................... 9
Federal Guidelines ........................................................................................................ 9
Pilot States Regulations ................................................................................................ 9
Pilot Project Benefits ................................................................................................................ 9
Key Lessons Learned .............................................................................................................. 10
Recommendations ................................................................................................................... 11
Program Logistics ....................................................................................................... 11
Training And Regulatory Requirements ................................................................................. 13
Data Collection, contracts, and budget ................................................................................... 13
Education And Outreach ......................................................................................................... 14
Program Evaluation ................................................................................................................ 14
CHAPTER I. BACKGROUND ......................................................................................................... 16
Problem Statement .................................................................................................................. 16
Solution: Shared Responsibility.............................................................................................. 16
Collaborative Project/Partners ................................................................................................ 17
Staples, Inc.: Responding to the Needs of Business Customers ................................. 17
Product Stewardship Institute, Inc. ............................................................................. 18
U.S. Environmental Protection Agency ...................................................................... 18
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Computer Manufacturers ............................................................................................ 18
Envirocycle, Inc.: Project Recycler ............................................................................ 19
State and Local Government Agencies ....................................................................... 20
Participant Funding/Contribution ........................................................................................... 20
Staples, Inc. ................................................................................................................. 21
Manufacturers ............................................................................................................. 21
Envirocycle ................................................................................................................. 22
State Agencies ............................................................................................................. 22
U.S. Environmental Protection Agency ...................................................................... 23
Product Stewardship Institute, Inc. ............................................................................. 23
CHAPTER II. PROJECT DESCRIPTION ........................................................................................... 24
Goal Statement ........................................................................................................................ 24
Retail Collection Locations..................................................................................................... 24
Commercial Collection Locations .......................................................................................... 24
Internet/Catalogue Customers ................................................................................................. 25
Timeframe ............................................................................................................................... 25
Products Accepted .................................................................................................................. 26
General Operations ................................................................................................................. 26
Retail Operations ........................................................................................................ 26
Commercial Operations .............................................................................................. 28
Transportation to Recycler .......................................................................................... 28
Staff Training and Education .................................................................................................. 28
Promotion/Advertising and Customer Education ................................................................... 29
CHAPTER III. SELECTING THE RECYCLING SERVICES ................................................................. 31
Logistical Concerns ................................................................................................................ 31
Regulatory Concerns ............................................................................................................... 31
Environmental Concerns ......................................................................................................... 31
Health and Safety Concerns .................................................................................................... 32
Security Concerns ................................................................................................................... 32
Reuse Opportunities ................................................................................................................ 32
Selection Process .................................................................................................................... 33
CHAPTER IV. PROGRAM RESULTS .............................................................................................. 35
Data Collection ....................................................................................................................... 35
Materials Collected: Units and Weights ................................................................................. 35
Total Equipment Collected (retail and commercial) ................................................... 35
Customer Equipment Surveys at Retail Locations ..................................................... 37
Contract Customer Surveys at Commercial Locations ............................................... 38
Perceptions of the Program ..................................................................................................... 39
Staples Staff ................................................................................................................ 39
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Customer Satisfaction ................................................................................................. 40
Effectiveness of Promotions/Advertising ............................................................................... 44
CHAPTER V. PILOT PROJECT COSTS ........................................................................................... 45
Total Costs .............................................................................................................................. 45
Project Design and Implementation ........................................................................................ 45
Recycling Costs ...................................................................................................................... 45
Staples’ Costs .......................................................................................................................... 46
Retail Collections ........................................................................................................ 46
Commercial Collections.............................................................................................. 47
Other Costs.................................................................................................................. 48
CHAPTER VI. PILOT PROJECT COST PROJECTIONS ...................................................................... 50
Estimated Costs to Staples ...................................................................................................... 50
CHAPTER VII. REGULATORY ISSUES .......................................................................................... 52
Federal Guidelines .................................................................................................................. 52
Pilot States Regulations .......................................................................................................... 52
Connecticut Regulations ......................................................................................................... 53
Maine Regulations .................................................................................................................. 54
Massachusetts Regulations ..................................................................................................... 55
New Hampshire Regulations .................................................................................................. 55
rhode island Regulations ......................................................................................................... 55
CHAPTER VIII. PILOT PROJECT BENEFITS .................................................................................. 57
CHAPTER IX. KEY LESSONS LEARNED ....................................................................................... 59
CHAPTER X. RECOMMENDATIONS .............................................................................................. 61
Program Logistics ................................................................................................................... 61
Training And Regulatory Requirements ................................................................................. 64
Data Collection, contracts, and budget ................................................................................... 65
Education And Outreach ......................................................................................................... 67
Program Evaluation ................................................................................................................ 68
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TABLES
Table 1.
Project Partners ............................................................................................................. 2
Table 2.
Staples/PSI Pilot Project – Collection Summary/All Equipment ................................. 4
Table 3.
Staples/PSI Pilot Project Retail Survey Data ................................................................ 5
Table 4.
Pilot Project Costs by Phase and Funding Source. ....................................................... 6
Table 5.
Pilot Project Retail Collection Cost: Handling, Shipping, and Transportation ............ 7
Table 6.
Average National Estimated Retail Collection Cost: Handling, Shipping, and
Transportation ............................................................................................................... 8
Table 7.
Pilot Project Contract Collection Cost: Handling, Shipping, and Transportation ........ 8
Table 8.
Staples/PSI Pilot Project Collection Summary Total Cost By
Brand And By Product ................................................................................................ 22
Table 9.
Recyclers Interviewed for Staples Pilot Project.......................................................... 34
Table 10. Staples/PSI Pilot Project – Collection Summary/All Equipment ............................... 36
Table 11. Percentage of Participating Manufacturers and Non-Participants by Equipment Type
36
Table 12. Total Equipment Collected By Brand And By Product – Retail Customer Surveys .. 37
Table 13. Total Equipment Units Collected by State – Retail Customer Surveys...................... 38
Table 14. Total Equipment Collected By Equipment Type and By Company – Contract
Customer Surveys ....................................................................................................... 39
Table 15. Staples/PSI Pilot Project Retail Survey Data .............................................................. 41
Table 16. Pilot Project Costs by Phase and Funding Source. ..................................................... 45
Table 17. Pilot Project Retail Collection Cost: Handling, Shipping, and Transportation .......... 46
Table 18. Average National Estimated Retail Collection Cost: Handling, Shipping, and
Transportation ............................................................................................................. 47
Table 19. Pilot Project Contract Collection Cost: Handling, Shipping, and Transportation ...... 48
Table 20. Factors Affecting Staples Costs .................................................................................. 51
Table 21. Quantity Data and Collection Method ........................................................................ 66
Table 22. Cost Data and Collection Method ............................................................................... 66
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APPENDICES
Appendix A. Letter to Computer Manufacturers
Appendix B. Contacts for Staples Pilot Project
Appendix C. Standard MOU and Summary of Manufacturer MOUs
Appendix D. Staples/PSI Pilot Project Cost Detail
Appendix E. Project Summary
Appendix F. Staples Retail Collection List
Appendix G. Criteria for Selection of Retail Stores and Businesses for Pilot Project
Appendix H. Staples Contract Collection List
Appendix I. Retail and Commercial Electronics Drop-off Forms
Appendix J. Staples Store Communications Package
Appendix K. Calendar Listing – Promotional Announcement
Appendix L. Natick Bulletin & Tab Article on Pilot Project
Appendix M. Reviewing Electronics Recyclers
Appendix N. Checklist For Electronics Recyclers
Appendix O. Reuse Organizations In The Northeast
Appendix P. Retail Equipment Collection Survey Data
Appendix Q. Contract Equipment Collection Survey Data
Appendix R. Retail and Contract Customer Satisfaction Surveys
Appendix S. Staples Data Needs for Pilot Project
Appendix T. Staples Internal Retail Collection Costs
Appendix U. U.S. EPA Regulatory Guidelines for Plug In Partners
Appendix V. Connecticut Department of Environmental Protection
Appendix W. Maine Department Of Environmental Protection
Appendix X. Massachusetts Department of Environmental Protection
Appendix Y. New Hampshire Department of Environmental Services
Appendix Z. Rhode Island Department Of Environmental Management
Appendix AA. Computer Manufacturers
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APPENDIX TABLES
Table D1. Brand-Sorted Data -- Monitors
Table D2. Brand-Sorted Data -- CPUs
Table D3. Brand-Sorted Data -- Printers/Mfds/Fax/Desktop Copiers/Scanners
Table D4. Brand-Sorted Data -- Laptops, Small Peripherals & Non Computer Equipment*
Table P1. Equipment Type Collected By Store And By Brand
Table P2. Total Equipment Type Collected By Store
Table P3. Equipment Type Collected By Major Brand
Table Q1. Staples Contract Customer Collection Data Total Number, Weight, And Cost By
Brand
Table T1. Staples Retail Pallet Costs
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Executive Summary
THE COLLECTION AND RECYCLING OF USED COMPUTERS USING REVERSE DISTRIBUTION
SYSTEMS: A PILOT PROJECT WITH STAPLES, INC.
EXECUTIVE SUMMARY1
PROBLEM STATEMENT
Used electronic products are one of the fastest growing waste problems in the world. A study by
the National Safety Council found that only 11-15 percent of computers were being reused or
recycled in 1998, and that electronics recycling is still unavailable or very expensive in many
United States cities and towns. Lead is found in the cathode ray tubes (CRTs) in televisions and
computer monitors. Electronic components contain other toxic substances, including cadmium
and phosphorous in CRTs, lead solder and copper on circuit boards, mercury in laptop displays,
lithium batteries, and brominated flame retardants in the plastic housing. These toxic materials
can be released to the environment from waste management or recycling practices, making it
imperative that discarded electronics are handled safely with regard to human health and the
environment. In addition, reusing and recycling electronics creates economic value, saves
resources and energy, and creates more jobs than disposal.
GOAL STATEMENT
The goal of the project was to collect and recycle unwanted electronics from Staples’ retail and
commercial customers using its existing product distribution network, and to evaluate whether
this approach represents a sustainable business model for Staples.
PROJECT CONCEPT
Since retailers are a direct connection to consumers of electronics, they are considered logical
points for consumer education, and potential take-back sites for used products. Many retailers
already manage used electronic products from returns, lease exchanges, and the replacement of
their own equipment at a cost that could be reduced or eliminated through a national electronics
management system. A few companies have even conducted voluntary take-back pilot projects
from retail customers. However, none of the financial models for calculating costs for a national
collection, transportation, and recycling infrastructure had considered the cost savings from
backhauling used electronics by reversing the existing distribution system.
This project tested this collection model in the northeast, using Staples’ product delivery
networks around the Killingly, Connecticut, distribution center (for retail products), the Putnam,
Connecticut, fulfillment center (for commercial products), and the North Reading and Sharon
transportation hubs in Massachusetts. Staples collected all brands of used computers at retail
stores located in Maine, Massachusetts, New Hampshire, Rhode Island, and Connecticut, and
from commercial customers in Massachusetts, New Hampshire, and Connecticut. The collected
equipment was backhauled by Staples’ carriers and consolidated at its distribution and
1
This report is available at http://www.productstewardship.us/pilot_takeback_staples.html and
www.plugintoecycling.org.
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fulfillment centers, then transported via Staples’ trucks to Envirocyle, an electronics recycler, in
Hallstead, Pennsylvania.
COLLABORATIVE PROJECT/PARTNERS
This project evolved from a joint meeting in April 2003 between representatives of Staples, Inc.
(headquartered in Framingham, MA), the Product Stewardship Institute, Inc. (Boston, MA), and
the U.S. Environmental Protection Agency/New England (Boston, MA). After PSI evaluated
Staples’ potential financial exposure and showed how costs could be contained, the company
contracted with PSI to design a pilot project for recovering computer equipment from its
customers. PSI and Staples enrolled in EPA’s “Plug-In To eCycling” pilots, which added
government financial and technical support, promoted cost-sharing incentives for manufacturers
and recyclers, and brought greater recognition for Staples.
Prompted by a January 2004 Plug-In To eCycling press event at the annual Computer Electronics
Show, the project gained the support of 10 manufacturer partners (see Table 1). Each partner
signed a memorandum of understanding (MOU) that committed these companies to pay for the
cost of recycling their brand of computer equipment and a share of the cost of recycling nonparticipant brands, including equipment manufactured by companies no longer in business, up to
a $10,000 cap. Additional partners included a recycler and five state agencies.
Table 1.
Project Partners

Staples, Inc.

Apple Computer, Inc.

Product Stewardship Institute, Inc.

Brother International Corp.

U.S. Environmental Protection Agency/New
England and Headquarters

Dell


Epson America, Inc.
Envirocycle, Inc.


HP
Connecticut Department of Environmental
Protection

Intel

Maine Department of Environmental Protection

Lexmark International, Inc.

Massachusetts Department of Environmental
Protection

Panasonic

Sharp Electronics Corporation

Sony Electronics, Inc.

New Hampshire Department of Environmental
Services

Rhode Island Department of Environmental
Management
TIMEFRAME
The pilot collections ran for six weeks, from May 29 through July 11, 2004.
PRODUCTS ACCEPTED
The pilot project accepted computer equipment, including computer processing units (CPUs),
computer monitors, laptops, large peripherals (e.g., printers, multi-fax devices, facsimile
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machines, desktop copiers, scanners), and small peripherals (e.g., keyboards, mice, speakers,
cables).
GENERAL OPERATIONS
Retail Operations
Computer equipment was collected at no charge at a cross-section of 27 Staples retail stores in
five states: Maine (10 stores), Massachusetts (8 stores), New Hampshire (5 stores), Connecticut
(3 stores), and Rhode Island (1 store). Equipment was shipped in the same manner as returns
(using reverse distribution) to the distribution center (DC) in Killingly, Connecticut.
Commercial Operations
Computer equipment was collected at no cost from 14 commercial customers in three states that
receive direct delivery of goods at their place of business by Staples’ trucks or common carrier.
Staples either picked up the equipment upon delivery of new products, as part of Staples’ typical
process for returning products that are defective, damaged, or otherwise unwanted, or scheduled
a separate pick up. Other equipment was “live loaded.” Gaylords were transported back (using
reverse distribution) to the fulfillment center (FC) in Putnam, Connecticut, or consolidated at
either the Sharon or North Reading, Massachusetts, transportation hubs for a line haul the next
day to the FC. Staples also took advantage of space on Envirocycle trucks from loads that were
being hauled from other electronics collection events in Massachusetts and Connecticut back
down to the Envirocycle facility.
Transportation to Recycler
When a tractor-trailer load of equipment accumulated at either the DC or FC, Staples’ trucks
transported the computers to Envirocycle in Hallstead, Pennsylvania. Typically, when Staples
had more than 22 pallets collectively at the DC and FC, it arranged for joint shipment of
commercial and retail mixed material to Envirocycle.
PROJECT RESULTS
Data Collection
The pilot project collected data that enabled Staples to understand the degree to which the
reverse distribution collection approach could be part of the company’s sustainable business
model, and how it could be implemented on a national scale. The retail and contract customer
satisfaction surveys helped PSI to evaluate the program from the users’ perspective. The data
collected will enable Staples to make adjustments and improvements to any future program
expansion that it plans to undertake, in which case there will be an ongoing need for data systems
to track equipment shipments, costs, and customer satisfaction.
Materials Collected: Units and Weights
PSI collected data in three ways for the retail and commercial collections:
(1) Data provided by Envirocycle, which combined retail and commercial loads;
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(2) Data tabulated from surveys filled out by customers at the retail locations; and
(3) Data tabulated from surveys filled out by commercial clients.
The total number of units of computer equipment collected was 4,522, weighing 107,360
pounds, and costing $7,983.10 to recycle (see Table 2). Although Staples advertised that it would
only accept computer equipment, an additional 735 units of audio/visual and other equipment
were collected, bringing the total number of units collected to 5,257. The non-computer related
units represented approximately 14 percent of the total number of units collected. The total
weight of all material collected was 115,028 pounds, costing $8,519.86 to recycle, for an average
cost per pound of 7.4 cents, and an average weight per unit of 21.88 pounds. Between 38% and
50% of monitors, CPUs, and large peripherals returned by customers was manufactured by
companies that were not partners in the pilot project.
Table 2.
Staples/PSI Pilot Project – Collection Summary/All Equipment
Product
Number Of Units
Pounds
Cost*
Computer Monitors
1,642
62,396
$6,568.00
CPUs
1,076
24,748
$0
649
10,386
$727.00
1,089
8,843
$619.01
66
987
$69.09
4,522
107,360
$7,983.10
645
4,516
$316.12
90
3,152
$220.64
5,257
115,028
$8,519.86
Small Peripherals
Printers/MFDs/Fax/Desktop
Copiers/Scanners
Laptops
SUBTOTAL — COMPUTER EQUIPMENT
Audio/Visual Equipment
Other
TOTAL – ALL EQUIPMENT
* $4.00/monitor; no charge for CPUs; $.07/pound for all other products
Retail Customer Surveys at Retail Locations
As part of the retail customer survey results that PSI tabulated (see Table 3), 1,351 retail
customers (81%) said they brought equipment from their home and 308 retail customers (19%)
said the equipment was from their business. Some of the customers operated a small business, or
were municipal officials and school employees, while the vast majority were residents. Table 3
also indicates that the vast majority of equipment came from storage, most people are willing to
pay a fee to recycle their computers, and a significant number of people heard about the program
through a store flyer or display.
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Table 3.
Executive Summary
Staples/PSI Pilot Project Retail Survey Data
Equipment From
Home
Office
1351
308
Equipment
Being
From
Used
Storage
529
Willing To Pay A Recycling
Fee In The Future
1095
Yes
No
1008
507
Heard About The
Program From
Store
Store
Flyer
Display
Other
260
483
845
Contract Customer Surveys at Commercial Locations
Data from the 14 contract customers that participated in the pilot project were parsed into the
following categories:

Equipment type collected by business and by brand.

Equipment type collected by business.

Equipment type collected by major brand.
There were 636 units of equipment collected, totaling 13,226 pounds, at a recycling cost of $752.
Customer Satisfaction
PSI developed a Retail Customer Satisfaction Survey and a Contract Customer Satisfaction
Survey, which it administered by phone to a limited number of pilot project participants.
Retail Customers

Customer responses were overwhelmingly positive, and they wanted the program to
continue. From an operational perspective, the program was easy to implement.

Customers that brought in equipment did not want to dispose of it in the garbage but were
looking for an opportunity to recycle it. Staples provided that opportunity. Many cited
environmental reasons (e.g., toxics) for why they did not want to put it in the garbage. Others
stored the equipment in belief that there was still value to it.

Most customers were willing to pay a fee for the recycling service. (Even so, it must be kept
in mind that those who participated in the recycling program are a subset of all those who
have computers that need to be recycled. Those participating in recycling programs would
be more likely to pay to participate than those who are not motivated to recycle their
equipment.)
Contract Customers

Each company believed that Staples provided a valuable service and made it easy to collect
the equipment. All wanted to see the program continue; the average need for service per
company was estimated to be 1 or 2 times per year.
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
The program cleared out space where the computers used to be stored, so employees were
happy with the result. Employees were unaware of recycling options.

Most of the companies contacted said that they would be willing to pay to recycle their
equipment in the future, since most understood that they were actually required to safely
manage their products. However, almost all said that they would only use Staples for this
service if their price was competitive with alternative options. With that said, many thought
there was an added value to ordering supplies from the same company that took back the
used computer equipment.

Several companies wanted to receive a certificate of data destruction to ensure that
confidential information was wiped clear off the computers. Since this assurance was only
possible for recycled, and not reused, equipment, Staples did not offer reuse.
PROMOTION/ADVERTISING AND CUSTOMER EDUCATION
Staples took a cautious approach to promotion of the recycling program to keep from getting
inundated with equipment. This allowed the company to remain under budget, keep its focus on
the operations, develop buy-in from the whole Staples team, and develop a clear picture of what
will be required to successfully roll this program out nationally. By design, Staples promoted the
program slowly and ramped it up slowly. It never fully contacted all the media outlets, and kept
the program low-key throughout the six weeks. Much of this focus was on an in-store flyer, store
display, and banner. Six newspapers in Massachusetts, five papers in Maine, and one trade
publication ran stories about the program.
PROJECT COSTS
The cost of collecting, transporting, and recycling 115,028 pounds of retail and commercial
equipment collected in this pilot project was $93,432, or 19.9 cents per pound (see Table 4).
Table 4.
Pilot Project Costs by Phase and Funding Source.
Who Paid
U.S. EPA
Staples
Manufacturers
TOTAL COST
Project Phase
Project Implementation/Evaluation
Project Design
Handling/Collection – Retail (northeast region)
Transportation to DC and Envirocycle (northeast region)
Delivery of Pallets – Commercial (northeast region)
Pallet Pick Up/Delivery To FC and Envirocycle – Commercial
(northeast region)
Promotion, Staff training, Administrative Staff
Recycling
Cost
$46,541
$17,000
$1,870
$11,355
$72
$1,044
$7,030
$8,520*
$93,432
* Envirocycle’s recycling costs for this pilot project (7.4 cents per pound, on average) were approximately one-third the market rate (about 20 cents per
pound). Bolded items have been used to calculate the cost per pound.
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Retail Collection Costs
Staples internal cost for the 27 retail collections includes the cost of handling the computer
equipment in the store, transporting to the DC, and transporting to Envirocycle in Pennsylvania.
Staples treated retail returns of used electronics in the same manner as it treated other returns,
and shipped equipment in its own trucks to the DC. Staples hauled 377 pallet loads of computers
(equal to 17.14 trailer loads), at a handling cost of $4.96 per pallet and a cost to ship them to the
Killingly DC of $9.67 per pallet. Staples also incurred costs of $450 per trailer load to transport
to Envirocycle from the DC, equal to $20.45 per pallet. The total cost, therefore, to collect and
transport 377 retail pallet loads to Envirocycle through the DC was $13,225.16, or $35.08 per
pallet (see Table 5). The cost to collect and transport this retail equipment to Envirocycle prior to
recycling was 8.9 cents per pound. Adding to that the average price per pound to recycle the
equipment of 7.4 cents per pound, the total cost to collect, transport, and recycle retail equipment
in this pilot project was 16.3 cents per pound. If Staples had to pay the market recycling rate
(estimated at 20 cents per pound delivered at the facility gate), this total cost would equal about
28.9 cents per pound.
Table 5.
Pilot Project Retail Collection Cost: Handling, Shipping, and Transportation
Cost Type
Handling
Shipping to Distribution Center
Transport to Envirocycle
TOTAL COST
Per Pallet
Cost
$ 4.96
$ 9.67
$20.45
$35.08
Per Pound
Cost
1.26 cents
2.45 cents
5.19 cents
8.90 cents
Staples and PSI used the following
assumptions:
• 1 system = 3 units
• 6 systems = 1 pallet (Gaylord)
• 22 pallets = 1 trailer load

1 unit = 21.88 pounds (from Table 2)

1 pallet = 393.84 pounds
To calculate the following:
• $771.76/trailer load
• $ 35.08/pallet
• $ 5.85/system
• $ 1.95/unit
Costs in the New England corridor, however, are lower than the company’s nationwide average
given the northeast’s proximity to the DC and short transit times to stores. The national average
cost to ship a pallet of computer equipment from the store to the DC is estimated to be $28.53
per pallet (see Table 6). Therefore, if the pilot was expanded nationally, the cost to handle each
pallet and transport it to a qualified recycler through one of the company’s four DCs would be
$53.94, or 13.7 cents per pound. This cost assumes that the handling cost is $4.96 per pallet, and
that a qualified recycler will be within a 250-mile radius from a DC, which was the distance from
the Killingly DC to Envirocycle in this pilot project. Since Staples will seek to find a recycler at
a closer distance, this 13.7 cents per pound figure should be considered an upper amount.
Adding to that the average price per pound to recycle the equipment of 7.4 cents per pound, the
total cost to collect, transport, and recycle retail equipment nationally would be 21.1 cents per
pound. However, if Staples paid the market recycling rate (estimated at 20 cents per pound
delivered at the facility gate), this total cost would equal about 33.7 cents per pound.
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Table 6.
Executive Summary
Average National Estimated Retail Collection Cost: Handling, Shipping, and Transportation
Per Pallet
Cost
$ 4.96
$28.53
$20.45
$53.94
Cost Type
Handling
Shipping to Distribution Center
Transport to Qualified Recycler (<250 miles)
TOTAL COST
Per Pound Cost
1.26 cents
7.24 cents
5.19 cents
13.69 cents
As Table 6 indicates, in a national effort, there would be a marked difference in cost from the
northeast pilot project. The cost to recycle in other regions of the country would vary from the
national average depending on the distance to the DC from a retail location and the distance from
the DC to a qualified recycler. There are four Staples’ DCs in the country – in Connecticut,
Maryland, Indiana, and California.
Commercial Collection Costs
Staples also calculated its internal costs for collecting 636 units of equipment from 14 contract
customer locations. Based on the data in Table 7, the full cost to collect and transport 35.33
pallet loads to Envirocycle through the FC would be $1,116, or $31.59 per pallet. Using an
estimated weight of 21.88 pounds per unit (393.84 pounds per pallet) of equipment collected
(from Table 2), the cost to collect and transport this commercial equipment to Envirocycle prior
to recycling is 8.0 cents per pound. Adding to that the average price per pound to recycle the
equipment of 7.4 cents per pound, the total cost to collect, transport, and recycle commercial
equipment was 15.4 cents per pound. At an estimated market recycling rate of approximately 20
cents per pound, this total cost would equal about 28 cents per pound.
Table 7.
Pilot Project Contract Collection Cost: Handling, Shipping, and Transportation
Cost Type
Delivery of Pallets
Cost
$72
Per
Pallet
Cost
$2.04
Pallet Pick Up/Delivery To FC
$324
$9.17
Transport to Qualified Recycler
(<250 miles)
TOTAL COST
$720
$20.38
$1,116
$31.59
Per
Pound
Cost
0.52
cents
2.33
cents
5.17
cents
8.02
cents
Staples and PSI used the following
assumptions:
• 1 system = 3 units
• 6 systems = 1 pallet (Gaylord)
• 22 pallets = 1 trailer load

1 unit = 21.88 pounds (from Table 2)

1 pallet = 393.84 pounds
To calculate the following costs:
• $694.98/trailer load
• $ 31.59/pallet
• $ 5.27/system
• $ 1.76/unit
Recycling Costs
The 10 participating manufacturers contributed a total of $8,519.86. Envirocycle offered the
following discounted rates for equipment processing as project partner: $4.00 per monitor; no
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charge for CPUs; and $.07 per pound for large peripherals, small peripherals, laptops, and noncomputer equipment.
Other Costs
Promotion, staff training, and administrative staff costs were estimated to be approximately
$7,030. Staples did not believe that storage space for used electronics was a factor that added
cost to the project. Backhaul opportunities on Staples’ trucks are frequent, and the equipment
was treated as a "cross dock shipment" when it got to the DC, where it went immediately into a
trailer with equipment from the FC for shipment to Envirocycle. The time taken by Staples’
technical and managerial staff to plan and implement the pilot project was not estimated.
REGULATORY ISSUES
Federal Guidelines
Under federal regulations, any unwanted electronic equipment containing a cathode ray tube
(CRT), including computers and televisions, is currently considered a hazardous waste under
federal regulation (40 CFR Part 260). Hazardous waste regulations do not apply to household
sources of electronics, or to businesses that generate under 7-8 CRTs per year. States can have
more stringent regulations governing the handling of electronics, and there is no one set of
standards that applies to all states. Therefore, the result is a patchwork of regulations that must be
considered when setting up a program to accept used electronics. This situation might be
alleviated to some degree when the federal regulations for CRT electronics are finalized, as
expected in the fall of 2005, and adopted by the states. The proposed rule is available on the PSI
website, at http://productstewardship.us/pilot_takeback_staples.html. In the interim, the U.S.
EPA has provided guidelines for the safe management of materials (available at
http://www.epa.gov/epaoswer/osw/conserve/plugin/pdf/guide.pdf) for its “Plug In” partners who
collect electronic equipment for the purpose of recycling.
Pilot States Regulations
States have some ability to streamline regulations for electronics product stewardship efforts, and
PSI worked with Staples and state agency officials to identify and comply with the states’
regulatory interpretations. None of the state regulations added significantly to the cost and
complexity of this project. To standardize the handling procedures for all Staples facilities and
associates in the five pilot states, Staples adopted the general guidelines for universal waste
handling, transport, and storage.
PILOT PROJECT BENEFITS
There were numerous benefits to conducting this pilot project, many of which should be
considered when evaluating a national expansion. Each of the following benefits is discussed in
greater detail in the full document, as are the key lessons learned.

Solves a Pressing Environmental Need

Provides a Known Collection Location and Education Opportunity
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
Creates Good Will

Demonstrates Collaborative Problem Solving

Provides One Stop Shopping

Offers Staples a Promotional Opportunity

Offers Manufacturers a Promotional Opportunity

Establishes Staples as a Brand Leader

Provided an Impetus for Other Retailers to Engage

Enabled Data/Information Sharing
KEY LESSONS LEARNED

Program was Logistically Feasible: It is feasible for a retailer to take back unwanted
computer equipment at a retail store, or from businesses, using a reverse-logistics collection,
transportation, and recycling model.

Program was Successful. Staples staff, retail customers, and contract customers were
enthusiastic about the program and want it to continue. Over 57.5 tons of equipment was
collected in six weeks from both retail and commercial customers at a cost that was
competitive with other electronics collections.

Staples’ Customers are Environmentally Aware. Retail and commercial customers are
savvy about environmental concerns from electronic wastes. Few questioned the need for
collection.

Staples Customers are Willing to Pay for Computer Recycling (Note: This should not be
used as a reason to charge in the long-term, since there are still a significant number of
people who will not pay. But it can provide funds to start or supplement a program.)

There is a Backlog of Equipment. There is a significant backlog of equipment that needs to
be collected initially from customers, particularly among businesses, making a simple “back
haul” of equipment difficult for a “first time” recycling effort.

Computers Returned from Non-participating Companies were Significant. A significant
percentage of computer equipment returned to the collections came from those that did not
contribute financially to recycling costs.

Manufacturer MOUs Were Time Consuming to Negotiate. Most manufacturers wanted to
change some aspect of the standard MOU, and a few wanted individualized agreements that
were much different from the basic template.

Communication Miscues were Costly. Communication between the recycler and the
Project Team resulted in missed data gathering opportunities and extra time and cost to
extrapolate data (e.g., leaving one company out of the brand sort).

Commercial Collections were Unique. Whereas retail collections followed a noticeable
pattern, Staples needed to arrange contract customer collections individually owing to a
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variation in pick up locations and equipment quantities and types. Over time, models should
evolve within these collections, making contract customer service delivery easier.

A Little Promotion can go a Long Way. Taking a low-key promotional approach worked
well for Staples employees and management, even if additional customers could have
benefited by the initial pilot.

Expect Business Equipment. There was a small, but significant, segment of retail customers
who brought equipment used for business, including municipal offices.

Recyclers were Staples Shoppers. Most of those interviewed who returned equipment to
retail stores said that they typically shop at Staples. Few people came into the store only
because of the recycling program, largely owing to the focus on in-store promotion.

Data Quality was Not High. Allowing retail and contract customers to fill out their own
data sheets did not provide high quality data.

Beware of Municipal Regulations During Outreach. Some municipalities would not allow
Staples to advertise using a banner on the exterior of the store.
RECOMMENDATIONS
Whether to expand this computer recycling project nationwide is a decision for Staples
management. However, from the data developed from this project, there appears to be little
doubt that there is a clear need, and opportunity, to expand the collections both at retail outlets
and contract customer locations. The computer recycling service was well received; there are
numerous benefits to expansion; and Staples’ internal costs were reasonable. In addition, any
costs incurred by Staples could be offset by a fee charged to customers, many of whom are
willing to pay to recycle, and/or by manufacturers’ contributions. Adding computer recycling
service to Staples’ growing environmental products and services will solidify Staples’ position as
a company that not only provides quality office products and services, but one that cares about
the company’s impact on the environment and the community served by its retail stores.
Expanding this recycling service would further enhance Staples’ image as a sustainable business.
Those seeking electronics collection service, however, should not place an over-reliance on retail
take-backs, since these programs are undertaken at a company’s discretion. If Staples, for
example, decides to end the program, for whatever reason, this might pull the plug on recycling
if this were the only, or most significant option, available to consumers. Therefore, while the
Staples pilot project should be understood as a significant opportunity for Staples and other
retailers, these retail programs need to become part of a more comprehensive collection and
recycling infrastructure. Listed below are specific recommendations that Staples should consider
in expanding computer recycling services to other areas of the country, or making it permanent
in the five New England states that were part of the pilot project. Each is discussed in more detail
in the full document.
Program Logistics

Treat Used Computers Like A Return. Typical retail product returns are brought to a
customer service representative, who records vital information directly into a computer
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database and takes possession of the product. Used computers should follow a similar
procedure, which will ensure quality data, reduce the likelihood of equipment breakage, and
provide a greater level of service. Staples could handle computer returns from businesses at
the point at which orders are placed.

Charge a Recycling Fee. Until a state or national financing system comes into existence,
charge a fee to collect and recycle computer equipment from both retail and commercial
customers. The fee charged to customers will need to be competitive with other recycling
services, particularly among commercial customers, although there is an added value in
having one company – Staples – provide office supplies and recycling services (on the
backhaul) to these commercial customers. Providing a tangible community benefit, as it did
in a separate pilot project for retail customers in the Northwest, would add to the acceptance
of the retail fee.

Recover the Full Recycling Cost in the Recycling Fee. Do not rely on a cost share from
manufacturers in setting the recycling fee owing to the large percentage of computers
collected from non-participating manufacturers. There is a question as to whether
participating manufacturers will continue to cover the costs imposed by manufacturers that
are not taking responsibility for their fair share, and put themselves at a competitive
disadvantage.

Expand the Limit on Equipment Allowed per Retail Customer. Instead of restricting
residents to one computer system, consider expanding the limit on retail customers to 4 or 6
units per customer, as was successfully demonstrated in Staples’ Northwest pilot project.
Some limit will be needed if Staples will want to discourage business equipment.

Identify Business Equipment. Since some states may require that equipment from
businesses be identified and treated differently from equipment from households, ask a
question on the in-take survey as to the origin of the equipment of those entering retail stores.

Phase Collections — Cleanout and Maintenance. Before a maintenance program can be
put in place, anticipate that a large initial amount of material will be generated in areas
without past collections. Conducting equipment clean outs, phasing collections, or ramping
up service will ensure that the program is not inundated with equipment.

Implement a Commercial Equipment Pick-up System: Ensure a chain of custody to better
track equipment and report to customers by assigning a bar code or other identification to
shipments at the point at which the recycling service is ordered.

Develop a Standard MOU with Manufacturers with Few Variations. Dictate the terms
of an agreement and only allow variations in very special circumstances. If a business wants
to collect its own material, it should be required to pay for the cost of separating and
recycling its own equipment.

Assign a Dedicated Staples Daily Contact. Consider assigning an internal dedicated staff
person that could serve as the daily point contact to retrieve data, contact Core Team
personnel, and communicate preferences and decisions.

Promote Reuse. Ask potential recyclers being interviewed for future collections to provide
the cost of adding reuse to the services provided, and the method by which data will be
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destroyed. Use domestic reuse organizations until a credible system is put in place for the
return or proper management of electronics sent for reuse to other countries.

Enhance Data Security to Allow for Reuse: In the future, electronics from companies
should be tagged with a noticeable sticker or other identifier to signal to the recycler that
special handling is required (e.g., scrubbing the hard drive to allow for reuse). By instituting
a rigorous procedure that ensures data destruction, reuse might increase for companies that
have newer and, therefore, more marketable, equipment.

Incorporate Recycler Selection Criteria. If expanding computer collections across the
U.S., use the recycler selection criteria developed for the pilot project and determine the
relative importance of the proximity of a recycler to a consolidation point, among other
issues.

Collect Additional Items. Consider collecting and recycling other electronic items that
Staples sells but doesn’t now collect, such as computer discs and other electronic media.
These items should be phased in along an established timetable.
TRAINING AND REGULATORY REQUIREMENTS

Provide Training For Contract Customers. Many of Staples’ contract customers started
recycling their computer equipment during this pilot project. Consider developing training
specific for companies that will need to educate their own employees to start recycling
computers instead of throwing them away.

Handle All Materials Using General Guidelines For Universal Waste. Adopt general
guidelines to abide by the universal waste requirements if expanding the program nationwide
or making it permanent in the five New England states that were part of the pilot project.

Seek to Standardize Regulatory Requirements. Although complying with state regulatory
requirements was not overly burdensome, and PSI received excellent assistance from state
regulatory officials, the process was time-consuming. Standardized regulations will lower the
costs to collect, transport, and recycle electronics. However, if the regulatory requirements
prove to be too cumbersome in some states, consider limiting the initial program to states
with a more relaxed interpretation of how electronics can be safely managed.

Develop a Tracking System for Collected Computers. Staples’ automated return system
already tracks customer information, product type, brand name, and other data. Explore
adapting this return system to accommodate customers bringing used electronics.

Standardize Computer Handling Guidelines And Training For Staples Associates.
Refine and standardize training for the national rollout to ensure that it will meet the
regulatory requirements in all states.
DATA COLLECTION, CONTRACTS, AND BUDGET

Maximize Data Collection Capabilities Within Staples. Staples’ pallet-cost collection
system should be supported by more specific methods of per-unit accounting, including the
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assignment of bar codes to individual items using methods comparable to Staples’ current
return and exchange procedures.

Calculate Other Costs To Staples. Calculate and budget for total costs that will likely be
part of the national expansion of the collection system, including associate and management
time, storage, equipment and supplies, advertising, and promotion.

Budget for Non-computer Equipment. Expect, and budget for, a certain percentage of
related non-computer equipment, even if it is specifically not accepted as part of the program.

Develop Detailed Contract with Recycler. Develop a detailed contract with the recycler
regarding expectations about the companies for which brand sorts should take place, whether
retail and commercial loads will be tracked separately, the forms used for data collection,
how manufacturer cost shares are to be calculated, who invoices manufacturers for their cost
share, average weights used per equipment type, and which equipment types will be sorted
by brand.
EDUCATION AND OUTREACH

Phase Program Promotion. Continue the practice of phasing in the collection program
concurrent with ramped up advertising and promotion to ensure that staff do not become
overwhelmed by equipment and continue to support the program.

Provide Recycling Education to Staples Customers. When equipment is being collected,
Staples has a unique opportunity to educate retail and commercial customers about why
recycling computers makes sense, what happens to the equipment once it is picked up, what
would happen if the equipment was not collected, and what other products Staples recycles.

Enhance Communication with Partners. Regular communication updates with partners
will enhance project communication and reinforce the common goal toward which all
partners are working – the recycling of computer equipment.

Engage Pilot Partners in Outreach and Education. To increase project visibility, contact
pilot partners to assess the promotional and outreach resources available through these
organizations.

Obtain Local Approval to Exhibit Store Banners. Seek a waiver from the prohibition in
some municipalities to putting a banner on the exterior of the store.

Coordinate with America Recycles Day. Nearly every state has an America Recycles Day
coordinator who would be receptive to a partnership on computer recycling.
PROGRAM EVALUATION

Evaluate Customer Satisfaction. Staples should train its customer service staff to survey
retail and contractor customers to learn valuable lessons about the program.

Provide for Internal Feedback. Staples associates familiar with the recycling program
should provide important feedback on needed improvements.
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
Executive Summary
Communicate Project Results. Holding a briefing at critical junctures in the project
timetable will ensure that project results and implications are understood, and that the feeling
of participating in a joint project is enhanced.
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Background
CHAPTER I.
BACKGROUND
PROBLEM STATEMENT
Used electronic products are one of the fastest growing waste problems in the world. A 1997
study by Carnegie Mellon University estimated that by 2005, one computer would be disposed of
for every two that were purchased.2 A later study by the National Safety Council estimated that
more than 20 million personal computers became obsolete in the United States in 1998, and that
61.1 million computers could become outdated in 20043. This same study found that only 11-15
percent of computers were being reused or recycled in 1998, and that electronics recycling is still
unavailable or very expensive in many United States cities and towns. The study also reported
that many computers could be reused, refurbished, or harvested for parts if collected soon after
replacement, although too many are stored until the technology becomes obsolete.
In 1999, researchers at the University of Florida tested the leachability of lead from the cathode
ray tubes (CRTs) found in televisions and computer monitors. They found average
concentrations of 18.5 mg/L of lead were released from crushed CRTs, more than three times the
5.0 mg/L limit set by the U.S. Environmental Protection Agency.4 These findings determined
that many CRTs that were disposed of had to be managed as hazardous waste. In addition,
electronic components contain other toxic substances, including cadmium and phosphorous in
CRTs, lead solder and copper on circuit boards, mercury in laptop displays, lithium batteries, and
brominated flame retardants in the plastic housing. These toxic materials can be released to the
environment from waste management or recycling practices, making it imperative that discarded
electronics are handled safely with regard to human health and the environment. Reusing and
recycling electronics creates economic value, saves resources and energy, and creates more jobs
than disposal.
SOLUTION: SHARED RESPONSIBILITY
“Product Stewardship” is a principle that directs all those involved in the life cycle of a product
to take shared responsibility for reducing the health and environmental impacts that result from
the production, use, and end-of-life management of the product. Since April 2001, a multistakeholder group involved in the National Electronics Product Stewardship Initiative (NEPSI)
worked to develop a cooperative agreement that would share responsibility for the end-of-life
management of electronic products. Those involved in the dialogue included federal, state, and
local governments, manufacturers, recyclers, environmental organizations, and others. Retailers
were largely absent from the NEPSI discussions and, as a result, their capabilities have gone
largely unexplored – until now. Retailers, along with product manufacturers, have been viewed
2
Matthews, H.S., M.C. McMichael, C.T. Hendrickson, D.J. Hard. 1997. Disposition and End of Life Options for
Personal Computers, Green Design Initiative, Technical Report #97-10. Carnegie Mellon University, Pittsburgh.
3
National Safety Council’s Environmental Health Center. 2001. Electronic Product Recovery and Recycling
Baseline Report. Available from EHC, 1025 Connecticut Ave, NW, Suite 1200, Washington, DC 20036, 202-2932270
4
Townsend, Timothy G, Stephen Musson, Yon Chul Jang, Il-Hyun Chung. 1999. Characteristics of Lead
Leachability from Cathode Ray Tubes Using the Toxicity Characteristic Leaching Procedure, Report #99-5.
University of Florida, Center for Solid and Hazardous Waste Management, Gainesville FL.
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Background
as a critical component of the electronics recycling infrastructure. Since retailers are a direct
connection to consumers of electronics, they are considered logical points for consumer
education, and possible take-back sites for used products. Many retailers already manage used
electronic products from returns, lease exchanges, and the replacement of their own equipment at
a cost that could be reduced or eliminated through a national electronics management system.
COLLABORATIVE PROJECT/PARTNERS
This project evolved from a joint meeting in April 2003 between Mark Buckley (Vice President
of Environmental Affairs, Staples, Inc.), Scott Cassel (Executive Director, Product Stewardship
Institute, Inc.), and Christine Beling (U.S. Environmental Protection Agency/New England).
Staples had an interest in providing added service to its customers and wanted to take advantage
of its existing product distribution network. PSI was heavily involved in the national electronics
dialogue and believed that reducing collection and transportation costs would solve a key
problem for local government agencies collecting electronics. EPA was also committed to the
national dialogue, and had a great depth of experience in the logistics and cost of electronics
collections.
These three entities formed the Project Team, which reached out to other potential partners.
Through PSI and EPA contacts, computer manufacturers were encouraged to sign a
memorandum of understanding (MOU) with Staples as a commitment to share in the recycling
costs. Following PSI research and subsequent interviews, Staples chose Envirocycle, Inc. as the
project recycler. In addition, PSI asked the five state agencies in which the pilots were to be held
to join as pilot partners. These agencies, all of which are PSI members, became partners. The
roles and responsibilities of each of the project partners are described below.
Staples, Inc.: Responding to the Needs of Business Customers
Businesses disposing of even a few computers can be liable for mishandling hazardous waste.
Large businesses usually generate sufficient volumes of usable electronics to attract recycling
services, but small and medium-size businesses are left with few choices other than replacing
equipment and waiting for an affordable recycling opportunity. Even then, the burden is on the
business to ensure that the recycler operates in compliance with local, state, national, and
international requirements. Some businesses have unwittingly paid sham recyclers to handle their
old computers only to be informed later that the equipment was found in an illegal dump or in a
poor, developing nation.
Staples viewed this need by businesses as an opportunity to offer its customers a valuable service
that other office product retailers did not provide, and to help minimize the environmental impact
from electronics. Staples realized that, if its customers could return used computers through the
same ordering and delivery systems by which they purchase new products, small and mediumsize businesses could appreciate the same convenience and lower management prices now
available only to large businesses. Additionally, Staples could incorporate “best management
practices” to handle used electronics from its customers and facilities, thereby preventing future
environmental liability and unfavorable publicity. For the project, Staples committed its own
labor, transportation equipment, and storage capacity for consolidating the equipment and
shipping it to a recycler, and it also promoted the program.
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Background
Staples Core Team: To enhance communication within the company, Staples’ Mark Buckley
coordinated an internal Core Team, which included representatives from Industrial Engineering,
Marketing, Operations, Merchandising, Logistics, Small Business Advantage (commercial
customers, also called “contract customers”), and corporate offices. Other Staples departments
were included as needed. The team consisted of 10-15 people who were directly involved with
various phases and functions of the pilot project implementation. This group met once for
strategic planning purposes, and was authorized to devote the time and resources necessary for
the planning, implementation, and evaluation of the pilot project. Lines of communication were
defined so that representatives from different departments were able to work together during
program planning and delivery. Mark Buckley was responsible for coordinating the Staples Core
Team and communicating with the Team.
Product Stewardship Institute, Inc.
The Product Stewardship Institute, Inc. (PSI) held the country’s first Product Stewardship Forum
in December 2000 to address priority waste streams, including electronics. Following the
momentum created by this and other government-sponsored forums, the National Electronics
Product Stewardship Initiative, or “NEPSI,” was formed to focus a broader stakeholder dialogue
around electronics management. PSI coordinated the participation of over 25 state agencies and
numerous local agencies in this dialogue. Staples approached PSI in recognition of the Institute’s
national role in the electronics discussions, and expressed a willingness to share responsibility
for recovering electronics from its customers. PSI was aware that none of the NEPSI financial
models for calculating costs for a national collection, transportation, and recycling infrastructure
had considered the cost savings from backhauling used electronics by reversing the existing
distribution system. Staples and PSI agreed to partner on this project, and PSI was contracted by
Staples in the spring of 2003 to design a sustainable business model for recovering electronics
from its customers. PSI became the manager and coordinator of the pilot project to test the
design for national application.
U.S. Environmental Protection Agency
Staff working on the U.S. Environmental Protection Agency (EPA) Innovations Work Group, as
well as EPA Region 1/New England, are also partners in this pilot project. The partnership
between Staples and PSI drew more interest as EPA Headquarters launched a series of highly
visible, pilot electronic take-back projects under the banner of Plug-In to eCycling. After the
Staples pilot project was designed, PSI recommended that the Staples project become one of the
“Plug In” pilots, thereby enhancing government support, promoting cost-sharing incentives for
manufacturers and recyclers, and bringing greater recognition for Staples. (See
http://www.epa.gov/epaoswer/osw/conserve/plugin/pdf/staples.pdf for more on the Staples/PSI
eCycling Project.) In addition, PSI competed for, and secured, additional funding under EPA’s
Spring 2003 IWG grant competition.
Computer Manufacturers
Ten computer manufacturers agreed verbally to sign a memorandum of understanding (MOU)
with Staples that offered to pay for the cost of recycling their brand of computer equipment. In
addition, most of the companies agreed to pay for a share of the cost of recycling non-participant
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Background
brands. The following manufacturers announced their intent to participate in the Staples pilot
project at a January 2004 Plug-In To eCycling press event at the annual Computer Electronics
Show:

Apple Computer, Inc.

Intel

Brother International Corp.

Lexmark International, Inc.

Dell

Panasonic

Epson America, Inc.

Sharp Electronics Corporation

HP

Sony Electronics, Inc.
PSI and Staples only approached manufacturers of computers and computer peripherals, since
the pilot collections focused on those materials. PSI and Staples drafted a letter that was sent by
Peter Scala, Staples Merchandising Department, and Mark Buckley to the managers of the
Staples account for each computer supplier – Brother, Canon, Epson, Hewlett-Packard, Lexmark,
Minolta, Panasonic, and Sharp (see Appendix A: Letter to Computer Manufacturers). While
Staples contacted the manufacturers’ account representatives, PSI phoned the policy and legal
advisors for the same companies to seek their partnership. This dual approach emphasized the
importance of the Staples pilot project in the context of other national electronics management
efforts. PSI also contacted computer manufacturers that are not currently suppliers for Staples,
recognizing that the pilot collections would recover all brands of computer equipment, including
those from companies no longer in business. PSI’s intent was to engage as many partners as
possible to reduce each participant’s cost burden.
While PSI and Staples were contacting manufacturers, EPA held several meetings with
manufacturers of electronics equipment, including computers and televisions, to develop formal
commitments for sharing costs for Plug-In To eCycling projects, including the Staples project.
EPA offered participating manufacturers incentives such as favorable publicity and recognition.
To formalize agreements with the 10 manufacturers, PSI drafted a model agreement and sent it to
each manufacturer. PSI asked each manufacturer to pay for processing its own equipment plus a
portion of the equipment manufactured by companies no longer in business, and by
manufacturers not participating in the pilot. Based on the projected amount of equipment to be
collected, PSI was able to calculate a reasonable projected cost for the pilot project collections.
Based on this estimate, Staples agreed to cap each manufacturer’s total cost at $10,000. This
cost ceiling helped to gain the commitment to participate from the 10 manufacturers.
Envirocycle, Inc.: Project Recycler
National Context: Staples, as well as participating manufacturers, were concerned about their
potential liability in the pilot project. Prior to the time that the pilot was being implemented, the
Basel Action Network released a compelling video showing improper computer recycling
overseas. Staples and PSI wanted to make sure that the recycler chosen for the project would
handle the equipment in an environmentally and socially responsible manner. Staples decided
that the recycler chosen would not transport materials overseas, but would only use domestic
markets. In addition, environmental groups and some government agencies expressed concern
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Background
over the use of prison labor to process electronics, which they claim results in a competitive
disadvantage for private electronics recyclers. Since this issue was unresolved at the time of
project implementation, Staples chose not to use prison labor. These decisions were taken so
that the project would not be delayed, and were not definitive policy positions taken by Staples
or the Project Team.
Summary of Selection Process. To select a recycler, PSI compiled databases of active recyclers
from officials in the five pilot project states, as well as from WasteCap of Massachusetts, the
Northeast Recycling Council, and EPA. PSI then worked in conjunction with a graduate student
intern at the Massachusetts Institute of Technology’s Materials Systems Lab, who reviewed
company websites to narrow the list to full-service recyclers that provided disassembly, data
removal, reuse, and recycling. To further screen recyclers, PSI developed criteria, in conjunction
with Staples, and assisted Staples in interviewing three recyclers that met the criteria.
PSI asked electronics manufacturers and state officials if they had worked with any of the three
recyclers being interviewed. Several of the computer manufacturers responded that they would
only participate as pilot project sponsors if Envirocycle, located in Hallstead, Pennsylvania, was
the chosen recycler. These companies had established a partnership with Envirocycle, had toured
the recycling plant, and performed audits of the company’s environmental performance. After
Envirocycle presented a proposal to become a full partner in the eCycling pilot project by
providing services at a vastly reduced recycling rate, Staples and PSI determined that
Envirocycle offered the best choice at this time. (For more information about the recycler
selection process, see Chapter III.)
State and Local Government Agencies
PSI obtained support for the pilot project from environmental officials in the five northeast states
in which the pilot was being implemented – Connecticut, Maine, Massachusetts, New
Hampshire, and Rhode Island. PSI and EPA also compiled a list of municipal recycling contacts
in the towns where pilot stores were located, as well as key state and federal agencies and
organizations in the pilot regions (see Appendix B: Contacts for Staples Pilot Project).
PARTICIPANT FUNDING/CONTRIBUTION
PSI reduced Staples’ costs for the pilot project by developing cost-sharing arrangements with
manufacturers and the recycler, and by drawing on the resources of state and local government
agencies. PSI also obtained EPA funding for a significant portion of its own involvement in the
pilot project development, monitoring, and evaluation.
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Background
Staples, Inc.
Staples costs for the pilot project included initial pilot design; equipment handling at the 27 retail
locations and 14 commercial locations; shipment to the Distribution Center and Fulfillment
Center in Connecticut; and transportation to the Envirocycle facility in Hallstead, Pennsylvania.
Staples also incurred minimal costs to promote and plan the project. These costs, which are
detailed in Chapter V, were calculated to be $38,371, including $17,000 for the pilot design,
$14,341 for the collection and transportation of retail and commercial equipment, and $7,030 for
program promotion, staff training, and administrative staff.
Manufacturers
MOUs. PSI attempted to obtain signed memorandums of understanding (MOUs) from each of
the 10 manufacturer partners. The standard agreement developed by PSI and Staples required
partners to pay for the cost of recycling their own computer equipment, and a share of computer
equipment from non-participating manufacturers, up to a cap of $10,000. The percentage share
of non-participants was based on the percentage of the participating manufacturers’ equipment
collected in the pilot. (See Appendix C for a standard MOU.)
After several months of discussions with representatives from each of the manufacturers, PSI
obtained signed agreements with Apple, Epson, Panasonic, and Sharp. Draft MOUs were
developed with Brother, Dell, Lexmark, and Sony. HP made a verbal commitment to join the
project, but requested that Envirocycle separate out HP products and ship them to HP. Dell
originally agreed to pay only for its brand products and a percentage of non-participating brands
for commercial collections only, and not for retail collections. Later, Dell also requested that its
products be sorted and transported to one of its approved recyclers.
Sharp’s MOU capped its payment at $5,000 and did not allow payment for a percentage of nonparticipating brands, expressing concern over the fairness of certain large companies not
participating in the program. After the pilot, however, Sharp did agree to pay for a percentage of
equipment from non-participants owing to the low cost of the pilot. Panasonic also expressed
similar concerns, but agreed after the pilot to pay for its share of non-participant equipment,
again owing to the low pilot cost. (For a summary of manufacturer MOUs, see Appendix C.)
Cost Share. The 10 participating manufacturers contributed a total of $8,519.86. A summary of
these costs appears by brand and by product in Table 1 below, with brand-sorted cost details
appearing in Appendix D. Envirocycle sorted the brands of two non-participating manufacturers
(Gateway and IBM), which were also included in the data analysis. PSI used standard equipment
weights provided by Envirocycle and discounted rates for equipment processing. PSI also
calculated each brand’s share of the cost for recycling the products of non-participants.
Envirocycle conducted brand sorts only on monitors, CPUs, and large peripherals. For those
equipment types, each brand’s cost share for non-participants was calculated directly. However,
for laptops, small peripherals, and non-computer equipment, PSI averaged the brand shares for
monitors and large peripherals and applied that average percentage to the three other categories
in which no brand sort occurred.
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Table 8.
Background
Staples/PSI Pilot Project Collection Summary Total Cost By Brand And By Product
Brand
Apple
HP/Compaq
Gateway (NP)
IBM (NP)
Dell
Sony
Epson
Panasonic
Brother
Sharp
Lexmark **
Other
TOTAL
Monitors
$3,794.00
$1,599.00
$742.00
$269.00
$33.00
$82.00
$33.00
$16.00
$6,568.00
Large
Peripherals
CPUs
$0
$0
$0
$0
$0
$0
$0
$0
$0.0
$127.11
$310.86
$0.00
$0.00
$118.89
$52.13
$8.22
$1.80
$619.01
Other
Equipment*
$521.74
$496.95
$75.31
$27.32
$131.35
$64.38
$12.20
$3.60
$1,332.85
Total Cost
$4,442.85
$2,406.81
$817.31
$296.32
$283.24
$198.51
$53.42
$21.40
$8,519.86
(NP) Non-Participant
* Includes Laptops, Small Peripherals and Non-Computer Equipment
** Lexmark’s share was extrapolated based on data provided by Envirocycle to Matt Russell, Lexmark, about a collection involving
Best Buy eCycle events and other east coast gov’t collections. The total pounds collected of all electronics were 2 million pounds.
Envirocycle estimated that events typically are 25% computers and 75% TV’s. Further, Lexmark’s share of this event was 274
pounds of equipment. Therefore Lexmark’s estimated share of that event for computer equipment only was .055% (274 lbs divided
by 500,000 lbs.) PSI used the same percentage for Lexmark’s percentage in the Staples pilot, resulting in a cost share of $6.66
(.00055x$12,103.28). PSI also used brand-sorted data provided by the FL Department of Environmental Protection. For its
electronics collection, computers represented 42% of the total by weight. PSI used this percentage to derive Lexmark’s percentage
in comparison to all computer equipment collected, which was 1.45%. PSI used this percentage to derive a second data point for
Lexmark’s cost share in the Staples pilot: $175.50. PSI averaged the two cost figures to derive the $91.08 cost share. This share
was not added to the total, since it was calculated outside of the total costs.
Envirocycle also did not conduct a sort of Lexmark products, a project partner. To develop a cost
share for Lexmark, PSI used the average percentage share that Lexmark products represented in
two electronics collection pilot projects – one conducted by Envirocycle and the other conducted
by the Florida Department of Environmental Protection. The analysis for this calculation appears
at the bottom of Table 8.
Envirocycle
One of the factors in choosing Envirocycle as the pilot project recycler was its offer to provide a
discounted recycling rate. Envirocycle offered the following discounted rates for equipment
processing: $4.00 per monitor; no charge for CPUs; and $.07 per pound for large peripherals,
small peripherals, laptops, and non-computer equipment. These rates provided greater certainty
for Staples and manufacturers that costs would be contained.
State Agencies
All five state agencies pledged staff resources to ensure a successful pilot, and offered planning
and promotional support, technical assistance, and regulatory guidance regarding the handling of
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Background
collected materials. The greatest amount of assistance came from Connecticut and Maine owing
to those states’ regulatory requirements.
U.S. Environmental Protection Agency
EPA recognized that the data collected in this pilot project would be of significant value in the
development of a national electronics management system. In recognition of the importance of
the pilot project, EPA awarded PSI with an “Innovations Work Group (IWG) Grant” of $46,541
to support the development, implementation, and evaluation of the project. EPA Headquarters
staff lent technical assistance to ensure that the project provided relevant data and visibility for
its partners. They provided the template for data collection that was used by Envirocycle and PSI
to report on the pilot collection. In addition, staff from EPA New England provided project
technical support, and assisted in program outreach.
Product Stewardship Institute, Inc.
As a full project partner, PSI coordinated project partners, collected and analyzed data, and
completed tasks needed to provide the best information possible for this pilot project. Many of
these tasks were beyond the scope of EPA or Staples funding, and became PSI’s financial
contribution to the project.
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Program Description
CHAPTER II.
PROJECT DESCRIPTION
As part of the Plug-In To eCycling project, PSI developed a Project Summary that described the
initial design of the pilot project (see Appendix E). Early in the design phase, Staples and PSI
decided that the collection model would be tested in the northeast, using Staples’ product
delivery networks around the Killingly distribution center (DC) and the Putnam fulfillment
center (FC) in Connecticut, and the North Reading and Sharon transportation hubs in
Massachusetts. These routes cover retail stores and commercial customers in northeastern states,
and were in close proximity to Staples’ main office in Framingham, Massachusetts, the Product
Stewardship Institute’s office in Boston, Massachusetts, and EPA/New England’s office in
Boston.
GOAL STATEMENT
The goal of the project was to collect and recycle unwanted electronics from Staples’ retail and
commercial customers using its existing product distribution network, and to evaluate whether
this approach represents a sustainable business model for Staples.
RETAIL COLLECTION LOCATIONS
Computer equipment was collected at no charge at a cross-section of 27 Staples retail stores in
five states: Maine (10 stores), Massachusetts (8 stores), New Hampshire (5 stores), Connecticut
(3 stores), and Rhode Island (1 store). Appendix F lists the retail stores selected for the pilot
project. For the pilot, PSI developed criteria to select a representative sample of retail stores that
could provide adequate data for a potential nationwide expansion. Appendix G outlines the
criteria developed by PSI and Staples for retail store selection, which includes population
density, electronics retailer density, availability of existing electronics collection programs, state
regulations for managing cathode ray tubes, and distance from the store to the distribution center.
In selecting the pilot stores, Staples and PSI also considered ways to prevent possible problems
in the implementation phase. Consideration was given to the size of the stores, the amount of
storage space, and accessibility for customers dropping off electronics. By limiting the pilot to
two Staples distribution regions, program promotion was localized, and the number of incidents
of customers bringing electronics to non-participating stores was minimized. Staples’ Mark
Buckley made the final selection of participating stores, after a meeting with regional store
managers.
COMMERCIAL COLLECTION LOCATIONS
Computer equipment was collected at no cost from 14 commercial customers in three states (see
Appendix H). Contract customers, particularly small businesses, comprise the largest percentage
of Staples customers. The 14 business customers for the pilot project were selected from the
Staples Business Advantage (SBA) program. SBA customers order merchandise from Staples
on-line or by phone/catalogue, and receive direct delivery of goods at their place of business by
Staples trucks or common carrier.
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Program Description
To ensure that the pilot collection provided a representative sample of project volumes and costs
for a nationwide program, PSI and Staples identified several selection criteria, listed in Appendix
G. Staples ultimately selected a cross section of contract customers – large and small, hitechnology users and those not technology driven, and those that were likely to be receptive to
the pilot program.
INTERNET/CATALOGUE CUSTOMERS
Staples and PSI originally planned to collect from Internet and catalogue customers for this pilot
project. However, owing to the complexity involved in developing the retail and commercial
collections, and the added complexity of an Internet segment, Staples decided not to proceed
with this aspect of the pilot project at this time. However, it may be instructive to consider the
approach that PSI and Staples had discussed.
A growing number of Staples customers are small business owners and individuals who order
on-line and receive merchandise through common carriers, such as United Parcel Service (UPS).
PSI and Staples originally planned to include a sample of 24 customers from this category in the
pilot study. These customers were to have had the option of returning used computers to a
participating retail store, or to return equipment by common carrier (at their own expense) either
to Staples’ Distribution/Fulfillment Centers or directly to the recycler.
To acquire a sample of on-line customers, Staples considered developing a customer interface on
its website that would have allowed customers to self-select from specific zip codes or
geographic regions when they searched the Staples on-line catalogue and queried or purchased
certain computer products. The communication, either by email, a pop-up window, or other
method, was to include the following:

A description of the Staples Electronics Collection Pilot Project;

An offer for the Internet customer to participate in the limited pilot program (free recycling
of the customer’s electronics equipment); and

A description of the methods by which the customer would bring or ship their electronic
equipment to Staples (via participating Staples retail stores or UPS shipping).
Customers choosing to ship their computer equipment by common carrier would have been
assigned a bar code or other form of identification that identified them as a pilot project
participant. As an alternative, Internet customers could have been directed to a Staples toll-free
number, and the service order and data collected by telephone. In that case, the recycler would
have tracked the quantities of equipment that arrived by common carrier from Internet
customers.
TIMEFRAME
The pilot collections ran for six weeks, from May 29 through July 11, 2004.
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Program Description
PRODUCTS ACCEPTED
The pilot project accepted computer equipment, including computer processing units (CPUs),
computer monitors, laptops, large peripherals (e.g., printers, multi-fax devices, facsimile
machines, desktop copiers, scanners), and small peripherals (e.g., keyboards, mice, speakers,
cables). Non-computer equipment and other electronics were not advertised as being accepted,
although Staples’ staff did not turn away customers bringing these other types of electronic
equipment. In fact, 14% of the units collected were non-computer equipment. Officially, Staples
advertised that it would accept the following: Recyclable items [such as] computer hardware and
business machines--printers, copiers, scanners, faxes--sold by Staples (no TVs or radios).
Customers were limited to one computer system per person per store per day.
In the initial phase of the pilot project design, Staples and PSI considered the entire list of
electronic items and supplies sold by Staples as candidates for the collection program. Since the
focus of the national electronics dialogue was on computer systems and televisions, it was
determined that computers and related equipment would definitely be included in the collection.
Staples, however, does not sell televisions, so these were eliminated from the list. PSI and
Staples, therefore, decided that the pilot project would collect only computers and computer
peripherals because these constitute larger office equipment with recycling potential. Of the
material collected, only CRTs are regulated as a hazardous waste in some states. PSI advises
further research into the markets for the other electronic products.
GENERAL OPERATIONS
Retail Operations
Customers entering Staples retail stores were instructed to place computer equipment in a bulk
cargo container called a “Gaylord box” (4 feet wide by 4 feet long by 4 feet high) that was
positioned in the front of the store, and to fill out a short survey (see Appendix I). Staples staff
assisted those needing help to bring equipment from their cars and to place it into the Gaylord.
When a Gaylord became full, Staples staff would move it to the back room for shipping in the
same manner that returns are shipped. Gaylords were labeled as to the store they originated from,
and shipped (using reverse distribution) to the DC in Killingly, Connecticut.
Staples was interested in an electronics collection model that could be sustained as part of its
ongoing business operation. There are three basic types of electronics collections that were
considered for this pilot: (1) ongoing collections, (2) one-time collection “events,” and (3) a
hybrid system that combined ongoing collections and events. Staples decided to proceed with
Option 1: Ongoing Collections.
Ongoing Collection: In this model, which PSI recommended and Staples ultimately chose,
customers were encouraged to bring computers to participating retail stores during normal
business hours any day during the six-week period. This approach spread out the program over a
longer period of time, provided greater convenience to customers, and eliminated the need to
coordinate activities outside the store. In addition, it was most compatible with ongoing business
operations at retail stores, and did not require additional staffing to manage the used computers
entering the stores. In-store signage directed customers where to take the equipment within the
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Program Description
store, and promotional materials outlined program restrictions (e.g., acceptable material types
and quantity limitations).
The disadvantage to this model was that it required Staples associates on all shifts to be aware of
the program and informed in how to manage computers that were received. There was also a
possibility that assistance to customers bringing used computers into the store could divert retail
associates away from shoppers or from other regular duties, although there were no reports of
this taking place.
One-Time Collection Events: These events typically last one or two days, during which
participants can drive through the collection site (usually a parking lot), with their materials
being off-loaded from vehicles into trailers or containers. The advantage of collection events is
their short duration, for which store associates can be temporarily reassigned. The disadvantages
include the need to coordinate the collection activities outside the store. These events require a
parking lot or other outdoor area capable of handling an ongoing stream of traffic and potential
lines of vehicles waiting to be served. The event cannot interrupt business operations or obstruct
emergency vehicles, school busses, or access to area homes.
An event requires an adequate workforce to handle the volume, and additional staffing may be
needed. Events also require coordinated publicity, a plan for inclement weather, and often a plan
for moving collected materials off the site immediately after the event. Depending on local
population and other factors, events have drawn up to 1,000 vehicles. To employ this type of
collection for the Staples pilot, Staples would have had to coordinate with property management
(if store properties were leased or shared), local traffic enforcement, local recycling groups, and
other volunteers to staff the events. PSI also advised Staples that it would have had to address
liability concerns should damage to person or property occur as a result of the collection event.
A collection event, however, could be simplified by contracting with a recycler to set up and
staff the event. Many recyclers now offer this service and are experienced in how to move traffic
and materials in an efficient manner. This option was not recommended, and was ultimately not
chosen.
Hybrid Collection Option: A third collection option is a hybrid of the collection event and
ongoing collection. Staples could have collected computers in the store on specific days (e.g.,
Saturdays and Sundays) throughout the pilot project. A more visible collection area (e.g., at the
front of the store), promotional materials, and the concentration of customers bringing computers
on those days would lend to the atmosphere of an “event.” An advantage of this model is that
store associates would only have to be concerned with the collections on specific days, and
additional staffing could be assigned during those days, if needed. The disadvantages are that any
required additional staffing would present an additional program cost to Staples. A collection
limited to one or two days a week, or month, is not as convenient to customers and would
increase the possibility that customers would bring materials on non-collection days.
PSI recommended that Staples explore a hybrid model (in-store collections restricted to certain
days) in a few retail stores to determine if this type of collection would have less impact on
staffing needs, and whether it would impact customer participation and shopping patterns. To
simplify the pilot, however, this option was ultimately not chosen.
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Program Description
Commercial Operations
Staples’ contract customers scheduled an appointment to have their computer equipment picked
up by Staples trucks. Staples provided survey forms to each customer, which provided
information on the type of equipment to be collected and the number of items. Staples used this
information to determine how to collect the equipment. Prior to pick up at most locations,
Staples dropped off Gaylord boxes, labels, pallets, and packing materials, and asked that
equipment be packaged, labeled, and brought to the loading dock. For some of the contract
customers, Staples picked up the equipment upon delivery of new products. For other contract
customers, Staples had to schedule a separate pick up. To accommodate pallet-sized pickups,
Staples used its own furniture trucks with drop-gate equipment. Some customers required that
Staples “live load” them either at their dock or on the street owing to space and/or time
constraints. Others were picked up as part of Staples typical process for returning products that
are defective, damaged, or otherwise unwanted.
Gaylords were transported back (using reverse distribution) to the FC in Putnam, Connecticut.
In some cases, Staples trucks went straight from the business to the FC, although in other cases,
Staples consolidated the loads at either the Sharon or North Reading, Massachusetts,
transportation hubs for a line haul the next day to the FC. Most of the Connecticut customers
went directly to the FC. Staples also took advantage of space on Envirocycle trucks from loads
that were being hauled from other electronics collection events in Massachusetts and Connecticut
back down to the Envirocycle facility.
Transportation to Recycler
When a tractor-trailer load of equipment accumulated at either the DC or FC, Staples’ trucks
transported the computers to Envirocycle in Hallstead, Pennsylvania. Typically, when Staples
had more than 22 pallets collectively at the DC and FC, it arranged for joint shipment of
commercial and retail mixed material to Envirocycle.
STAFF TRAINING AND EDUCATION
PSI, in conjunction with Staples, coordinated an internal Core Team meeting with Staples
employees who manage its retail and commercial operations. Those in attendance were Staples
district managers with jurisdiction over the 27 stores selected for the pilot, as well those
managing SBA customers. This meeting was held in January 2004, during which Staples and PSI
presented the program, answered questions, established a kick-off date, and assigned staff
responsibilities. Once key Staples employees were informed about the program and participated
in its design, they were able to communicate program goals and implementation procedures to
their employees.
Staples district managers, who oversee the retail stores, trained their employees about customer
relations, equipment handling, and in-store promotion. Staples associates at participating retail
stores (as well as those in non-participating stores in the surrounding area) were made aware of
the pilot project, although not every associate was involved in the collection effort. During each
staff shift, associates helped to receive and stack computer equipment, distribute the equipment
collection survey, and ensure the collection of data. Staples associates involved in the handling
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Program Description
of used computers received training to minimize the potential for problems of injury, breakage,
and customer dissatisfaction. SBA delivery associates also received similar training prior to the
collection period.
Staples developed a Store Communications Package that consisted of a two-page information
sheet, an in-store flyer, and two sizes of labels to affix to Gaylords that were to hold the
equipment. The information sheet explained the project, products accepted/limitations,
alternative recycling options, what to do when customers entered the store with equipment, store
layout and materials, logistics, and frequently asked questions. (See Appendix J for the
information sheet, flyer, and banner.)
PSI determined the training required by regulatory officials in the pilot project states, and
outlined the recommended content for a Staples associate training session. Staples had to abide
by training regulations in one of the pilot states. Regulations from the Maine Department of
Environmental Protection (ME DEP) require that “…each person handling Universal Waste
should be trained for the particular job that they are doing and be aware of the clean up
procedures in the event of breakage.” The ME DEP offered to hold training sessions for Staples’
employees involved in the take-back program, although this was deemed unnecessary.
Staples trained a coordinator at each store who was responsible for training store associates,
reporting on the pilot program, answering procedural questions, and communicating with the
Core Team. Staples internal information delivery systems (e.g., “General Manager Review” and
“Staples at Work”) were effective at distributing information about the pilot project, its goals,
progress made, and problems encountered. Staff was trained regarding:

Regulations – to ensure that all associates were thoroughly familiar with the proper
electronics handling procedures.

Ergonomics – pertaining to how to lift and carry heavy computer equipment.

Customer Relations – to avoid potential problems and deal with actual problems (e.g.,
customers bringing in unacceptable materials, too many units, etc.).

Non-participating Stores – the procedures to follow when equipment turned up at nonparticipating stores.

Data Collection and Management – procedures for administering and managing
questionnaires, and other data collection and management procedures.
PROMOTION/ADVERTISING AND CUSTOMER EDUCATION
To prepare for the launch of the pilot project, PSI contacted state officials in each of the five
states in which the collections were to occur. In addition, EPA/New England called the local
recycling coordinators for the municipalities in which the 27 stores were located. (See Appendix
B for a list of local contacts in the communities targeted for pilot collections.)
Staples’ marketing department developed and distributed promotional and educational materials
prior to the pilot collections. To minimize customer confusion in non-participating areas,
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Program Description
promotion was highly targeted to Staples customers in the pilot areas, rather than broadcast in
regional newspapers or other media. Staples did not want residents in adjacent communities
whose stores were not serving as pilot locations to think that they, too, could bring back their
equipment to the stores in their communities.
To advertise the retail program, Staples developed an in-store flyer, store display, and banner.
Many customers who recycled equipment heard about the program when they were shopping for
products, prompting them to come back at another time with their computer equipment. Staples
also developed and distributed a two-page “Calendar Listing” to local newspapers throughout the
New England states announcing the retail pilot (see Appendix K). Staples’ Owen Davis
conducted phone interviews with press who called for more information. The following
publications developed an article on the pilot program:

Massachusetts

 Natick Bulletin & Tab, June 11, 2004 (weekly circ 3,369)
 Natick Bulletin & Tab, July 2, 2004 (weekly circ 3,369)
 Daily Times Chronicle Reading, June 9, 2004 (daily circ 14,797)
 Daily Times Chronicle Winchester, June 9, 2004
 Daily Times Chronicle Wakefield, June 9, 2004
 Daily Times Chronicle Woburn, June 9, 2004
Maine

 Cape Courier, July 3, 2004 (semi-monthly circ 4,000)
 Biddeford-Saco Courier, July 2, 2004 (weekly circ 23,000)
 Southern Forecaster, July 2, 2004 (weekly circ 10,000)
 Gorham Times, July 2, 2004 (bi-weekly circ 4,000)
 Current, July 8, 2004 (weekly)
Greenbiz.com, June 14, 2004
(See Appendix L for a comprehensive article about the pilot program and the larger issue of
electronics recycling written by Philip Maddocks of the Natick Bulletin & Tab, July 2, 2004.)
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Selecting the Recycling Services
CHAPTER III.
SELECTING THE RECYCLING SERVICES
Selecting an electronics recycler required PSI and Staples to consider several important
logistical, regulatory, environmental, health and safety, and security issues.
LOGISTICAL CONCERNS
Staples used its own carriers, or contracted carriers, to transport collected computers to the
recycler from consolidation points at Staples DC and FC in Connecticut. Since a sustainable
business model minimizes fuel consumption, Staples requested that PSI narrow the selection of
recycling companies to those within close proximity to the DC and FC. Staples intended to
match the delivery of used computers to the recycler with the pick up of new product from
nearby suppliers so that otherwise empty trucks could be used on the back haul. For the pilot
project, PSI considered recyclers within a 200-mile radius of the Staples DC and FC.
REGULATORY CONCERNS
Chapter VII of this report addresses state requirements for managing used electronics as either a
hazardous waste or universal waste. Staples had a responsibility to ensure that the company it
selected was in compliance with all local, state, and federal regulations pertaining to materials
recovery, waste management, transport of hazardous materials, and worker protection. Staples
wanted to select a company with a good compliance record.
The best way to select a recycler is by conducting a “due diligence” review or by conducting a
paper and physical audit of the facility. With limited resources, Staples and PSI were unable to
conduct on-site facility audits for the pilot project. To protect itself from potential liability,
Staples considered only those recyclers for which a thorough investigation into the processes, byproducts, and end markets was conducted by pilot state regulators or the electronics
manufacturers involved in the pilot. PSI also developed guidelines for screening recyclers that
were reviewed by regulatory agencies in the pilot states. Appendix M contains the document that
was used by Staples and PSI to evaluate recyclers during and after each interview, while
Appendix N is the document that was provided in advance to recyclers to help them prepare for
the interview.
ENVIRONMENTAL CONCERNS
Environmental concerns related to electronics management go beyond guarantees of regulatory
compliance. Compliance, for the most part, means that companies have the appropriate state
permits, environmental controls, and insurance coverage for the activities that are conducted by
the company. However, Staples’ corporate goals include minimizing waste, maximizing reuse
and recycling, and conserving energy. Because of these goals, Staples and PSI developed
additional criteria that were also incorporated into the screening process. Companies were asked
about their own waste minimization practices (e.g., ISO 14000 certification, internal and thirdparty audits) and how they assure that downstream vendors are reducing waste. Company
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Selecting the Recycling Services
processes were compared to determine which methods would enhance reuse and recycling of the
materials (e.g., front end sorting, demanufacturing, resale and reuse programs).
HEALTH AND SAFETY CONCERNS
One contentious issue discussed in the NPSI dialogue is the practice of using prison labor or
exporting whole electronics or electronic components to cheap labor markets in poor developing
nations. The prison labor issue is as much about creating unfair market advantages using
taxpayer-supported labor at prisons as it is about concern over prison workers’ health and safety.
Since this issue had not been resolved by NEPSI at the time of this pilot project, Staples did not
want to use prison labor to process any materials collected as part of the project.
The export of materials to developing countries was another unresolved issue. While a closed
loop recycling process advocates for returning materials for reuse in the manufacture of new
materials, many electronics are manufactured in countries that may not enforce health and
environmental protection standards. Some U.S. companies export scrap material to these
countries, where lower labor costs contribute to lower processing costs. Countries that are part of
the Organization for Economic Cooperation and Development (OECD, www.oecd.org) have
agreed to control exports to protect developing countries. These controls dictate high standards
for environmental management.
For the pilot project, Staples and PSI determined that there should be no export of the collected
electronics or their hazardous components (e.g., CRTs, circuit boards) to non-OECD countries in
order to eliminate the potential negative impact on the environment and human health in
developing nations. Companies screened for the pilot project were asked to describe how they
would ensure that no hazardous materials would be sent to developing nations by downstream
vendors, and Envirocycle, the selected recycler, provided documentation of end markets for the
project.
SECURITY CONCERNS
Staples and PSI ensured that Envirocycle offered secure data removal as an option for businesses
participating in the pilot project. Envirocycle destroyed hard drives as part of the recycling
process.
REUSE OPPORTUNITIES
Staples wanted to maximize the reuse of working computers that were of recent technology.
These computers usually originate from businesses, rather than households, as businesses tend to
upgrade equipment more frequently and to replace all equipment at once. In considering sending
computers for reuse, however, concerns arose about confidential information that still might be
contained on the hard drive, even after business personnel remove files. In worst cases,
confidential information in the wrong hands could cause significant harm to the business and its
clients, or even threaten homeland security. Since several businesses were not comfortable with
the data security options available to them through the pilot, the project did not reuse any
equipment. Customers, therefore, could be assured that there was complete control over the final
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Selecting the Recycling Services
destination of the material. In the future, if reuse becomes part of the services offered, Staples
expects that the hard drives of reusable computer components will be “scrubbed” in accordance
with U.S. Department of Defense requirements for those requesting a Certificate of Destruction.
(For additional information on reuse, see Appendix O.)
Prior to project implementation, Staples was approached by World Computer Exchange, Inc.
(WCE), a non-profit organization with offices in Massachusetts, and whose purpose is to provide
working computers to schools and other organizations in developing countries. WCE claimed to
have put thousands of Pentium and Power Mac computers into use by people who would
otherwise not have had access to the technology. Many of the computers being shipped abroad
are outdated and not desirable in U.S. reuse markets. The WCE is concerned about the proper
disposal of computers in the recipient countries and, at the time of this pilot, was developing a
task force of representatives from several international organizations to investigate possible
solutions. However, when this pilot was ready for implementation, its practice was to harvest
usable parts and dispose of the rest by whatever means were locally available. The need to
ensure the proper management of reused computers, especially abroad, was another factor in
Staples not including reuse in this initial pilot project.
SELECTION PROCESS
Three recyclers were interviewed after PSI determined that they met the selection criteria
developed with Staples, even though one was outside of the preferred transportation radius from
the Connecticut DC and FC. These recyclers appear in Table 9 below, along with how they
address logistical, regulatory, health/safety, and security issues. Following the interviews,
Envirocycle was selected owing to the familiarity that many of the manufacturers had with the
company, and because of its proposal to become a full partner in the pilot project by providing
services at a vastly reduced recycling rate.
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Table 9.
Selecting the Recycling Services
Recyclers Interviewed for Staples Pilot Project
Company
Logistical
Regulatory
Compliance/
Environmental
Health and
Safety
Security
Electronicycle, Inc.
Dick Peloquin (877-829-6209)
461-471 West Broadway
Gardner, MA 01440
Phone: 800-829-5082
Local: 978-632-7666
Fax:
978-632-1651
dick@electronicycle.com
http://www.electronicycle.com
45.8 miles from the
Distribution Center in
Putnam, CT;
approximately 55 miles
from the Fulfillment Center
in Killingly, CT
Permitted by MA;
audit by New
Jersey; used for
the Northeast
Recycling
Council’s pilot
collections
Can guarantee no
prison labor or
export to nonOECD countries
through detailed
tracking
Can provide
assurances for data
removal and
documentation for all
reused computers
Envirocycle
Greg Voorhees (570-879-2862)
Rt. 81 Exit 230PO Box 899
Hallstead, PA 18822-0899
Phone: 800-711-6010
Local: 570-879-2862
Fax: 570-879-2008
gvoorhees@enviroinc.com
http://www.enviroinc.com/
Metech, International
Chris Ryan (978-772-4897)
120 Mapleville Main Street
Mapleville, RI 02839
401-568-0711
cryan@metech-arm.com
Approximately 198 miles
from the Distribution
Center in Putnam, CT and
the Fulfillment Center in
Killingly, CT
Compliance
assurances;
audits completed
by several
electronics
manufacturers
Can guarantee no
prison labor or
export to nonOECD countries
through detailed
tracking
Can provide
assurances for data
removal and
documentation for all
reused computers
Approximately 12 miles
from the Distribution
Center in Putnam, CT;
approximately 15 miles
from the Fulfillment Center
in Killingly Center
Compliance
assurances and
permits from the
State of
Massachusetts;
ISO 9001 and
14001
Can guarantee no
prison labor or
export to nonOECD countries
through detailed
tracking
Can provide
assurances for data
removal and
documentation for all
reused computers
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Staples Pilot Project –Final Report to U.S. EPA
Program Results
CHAPTER IV.
PROGRAM RESULTS
DATA COLLECTION
The pilot project collected data that enabled Staples to understand the degree to which the
reverse distribution collection approach could be part of the company’s sustainable business
model, and how it could be implemented on a national scale. It also assisted PSI, EPA, and pilot
partners in learning how reverse distribution systems can affect costs of a national electronics
collection infrastructure. Finally, the retail and contract customer satisfaction surveys helped PSI
to evaluate the program from the users’ perspective. The data collected will enable Staples to
make adjustments and improvements to any future program expansion that the company plans to
undertake. If Staples decides to expand this program, there will be an ongoing need for data
systems to track equipment shipments, costs, and customer satisfaction.
The responsibility for collecting and analyzing the various types of data was divided among pilot
project partners to maximize the use of existing capabilities, minimize program costs, and ensure
that the data were useful and accurate. The following entities were involved in the data collection
effort: PSI, Envirocycle, Staples’ retail management and associate level support, and Staples’
logistics managers for pallet placement and transport.
MATERIALS COLLECTED: UNITS AND WEIGHTS
PSI collected data in three ways for the retail and commercial collections – (1) Data provided by
Envirocycle, which combined retail and commercial loads; (2) Data tabulated from surveys filled
out by customers at the retail locations; and (3) Data tabulated from surveys filled out by
commercial clients.
Total Equipment Collected (retail and commercial)
Envirocycle collected data on the following equipment: computer monitors, CPUs, laptops, large
peripherals (e.g., printers, multi-fax devices, facsimile machines, desktop copiers, scanners), and
small peripherals (e.g., keyboards, mice, speakers, cables). The number of units collected, their
associated weights, and the cost of recycling by component are listed in Table 10 below. The
total number of units of computer equipment collected was 4,522, weighing 107,360 pounds, and
costing $7,983.10 to recycle. Although Staples advertised that it would only accept computer
equipment, an additional 735 units of audio/visual and other equipment was collected, bringing
the total number of units collected to 5,257. The non-computer related units represented
approximately 14 percent of the total number of units collected. The total weight of all material
collected was 115,028 pounds, costing $8,519.86 to recycle. (See Table 16 in Chapter V for a
complete breakdown of collection, transportation, and recycling costs.)
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Table 10.
Program Results
Staples/PSI Pilot Project – Collection Summary/All Equipment
Product
Number Of Units
Pounds
Cost*
Computer Monitors
1,642
62,396
$6,568.00
CPUs
1,076
24,748
$0
649
10,386
$727.00
1,089
8,843
$619.01
66
987
$69.09
4,522
107,360
$7,983.10
645
4,516
$316.12
Small Peripherals
Printers/MFDs/Fax/Desktop
Copiers/Scanners
Laptops
SUBTOTAL — COMPUTER EQUIPMENT
Audio/Visual Equipment
Other
TOTAL – ALL EQUIPMENT
90
3,152
$220.64
5,257
115,028
$8,519.86
* $4.00/monitor; no charge for CPUs; $.07/pound for all other products
Envirocycle also tracked the number of units collected by major brand for monitors, CPUs, and
large peripherals (see Appendix D). For monitors, Apple is by far the brand that was returned
most often and, for large peripherals, HP is the brand most often returned if Compaq products are
also included. For CPUs collected, HP and Apple were the brands most often returned.
Envirocycle did not brand sort for laptops, small peripherals, and non-computer equipment. To
estimate the percentage share for each of these product categories, PSI averaged the percentage
shares for each brand for monitors and large peripherals (the two equipment types for which
there is a cost to recycle) and used this as the percentage share for a combination of the three
other categories. These extrapolated shares appear in Appendix D. Envirocycle tracked 8 of the
10 eCycling partners, but did not track products from the Lexmark brand. The cost share for
Lexmark was derived as shown in Table 8. Intel, another partner, sells its computer memory
chips to computer manufacturers and, therefore, does not have its own brand computer. (For
further discussion of manufacturer costs, see Chapter I.)
PSI calculated the percentage of equipment that was derived from participants compared to the
percentage derived from non-participants. Only actual, and not extrapolated data, are used. These
data are summarized in Table 11 below. As shown in the table, between 38% and 50% of
monitors, CPUs, and large peripherals returned from customers has come from companies that
did not participate in the pilot project.
Table 11.
Percentage of Participating Manufacturers and Non-Participants by Equipment Type
Monitors
CPUs
Large Peripherals
Participating Manufacturers
50%
50%
62%
Non-Participants
50%
50%
38%
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Staples Pilot Project –Final Report to U.S. EPA
Program Results
Customer Equipment Surveys at Retail Locations
Approximately 1,800 customers who returned equipment to Staples’ 27 retail locations filled out
a survey (see Appendix I) providing information about the manufacturer of the computer
equipment being returned, the type of equipment (e.g., laptop, CPU, monitor, etc.), the number
of units returned, and their age. These forms were collected by Staples and entered into a master
spreadsheet that was provided to PSI, which parsed the data to determine the following:
1. Equipment type collected by store and by brand.
2. Total equipment type collected by store.
3. Equipment type collected by major brand.
These data appear in Appendix P, and are summarized below in Table 12.
Table 12.
Total Equipment Collected By Brand And By Product – Retail Customer Surveys
Brand
HP/Compaq
Apple
Dell
Gateway (NP)
IBM (NP)
Epson
Panasonic
Sony
Lexmark
Brother
Sharp
Other
TOTAL
Monitors
CPUs
Laptop
Printer
Scanner
Fax
Copier
187
251
137
112
74
7
8
30
1
2
0
219
238
86
105
82
3
4
5
1
0
2
14
24
5
3
9
0
0
1
0
0
5
262
75
2
8
13
81
27
0
27
10
0
25
3
0
1
0
1
0
0
1
0
0
4
0
0
0
0
0
5
0
0
6
4
2
0
0
0
1
0
0
0
0
0
2
1,600
1,363
99
727
85
32
18
Other
Peripherals
1,497
Total
713
591
230
229
179
92
44
36
30
18
13
0
5,421
* Other Peripherals: Keyboards, Mice, Speakers, etc.
(NP) Non-Participant
A few interesting observations from Table 12 are that:
1. The total amount of equipment collected as recorded on the retail surveys is 5,421 units,
slightly higher than the 5,257 units reported by Envirocycle. This discrepancy is
significant since the retail surveys were for retail collection only, whereas Envirocycle
data represented both retail and commercial equipment. The retail surveys also covered
25 of 27 retail stores. The reason for the discrepancy may be due to the poor quality of
the data from retail customers and/or communication and reporting issues among partners
as to which data were required to be tracked.
2. Data collected by brand were very similar, but not identical, to the brand-sorted data
reported by Envirocycle.
Table 13 below provides a summary of the data collected by the five state partners:
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Staples Pilot Project –Final Report to U.S. EPA
Table 13.
Program Results
Total Equipment Units Collected by State – Retail Customer Surveys
State
Connecticut
Massachusetts
Maine
New Hampshire
Rhode Island
TOTAL
No. Of Stores
Collecting*
Units Collected
2
7
10
5
1
25*
Average Units
Collected Per Store
180
1,928
2,428
649
182
5,367
90
275
242
130
182
215
* PSI received data from 25 of the 27 stores. Data were not available for New London, CT and Revere, MA.
These data show that Massachusetts and Maine lead the pilot states in the average units collected
per store, which might correspond to electronics legislation in those states and a heightened
public awareness about the hazards of electronics disposal. Comments from Staples store
managers in Maine confirmed that customers were seeking electronics recycling options owing
to their knowledge of state legislation. In addition, Massachusetts and Maine were the only two
states in which local press articles appeared notifying residents about the opportunity to recycle
their computers. These articles, presumably, could have contributed to additional computers
being brought into the stores. One factor, however, must also be considered – store size. It is
possible that those stores collecting fewer computers were smaller in size than those collecting a
larger number of computers.
Contract Customer Surveys at Commercial Locations
Data from the 14 contract customers that participated in the pilot project were parsed into the
following categories:

Equipment type collected by business and by brand.

Equipment type collected by business.

Equipment type collected by major brand.
These data appear in Table 14 below and in Appendix Q.
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Table 14.
Program Results
Total Equipment Collected By Equipment Type and By Company – Contract Customer Surveys
Large
Monitors (1)
Company
#
Verispan
DRS Techn
8
16
5
0
2
14
13
6
0
6
4
27
4
26
131
Stride & Assoc
Rogers Corp
Safety Ins
Mykrolis
Freudenerg NOK
Todd & Weld
Delta Education
Barnes Group
Riso, Inc
Texas Instruments
Charles River
Zoots
TOTAL
Wgt (lbs)
304
608
190
0
76
532
494
228
0
228
152
1026
152
988
4,978
CPU's (2)
#
Wgt (lbs)
0
10
33
22
7
20
27
0
0
41
7
32
4
14
217
0
230
759
506
161
460
621
0
0
943
161
736
92
322
4,991
Laptops (3)
Wgt
#
(lbs)
0
3
18
9
0
0
0
2
0
51
0
0
0
0
83
0
45
270
135
0
0
0
30
0
765
0
0
0
0
1245
Small
Peripherals * (4)
#
Wgt (lbs)
3
10
5
0
9
7
4
0
8
39
1
7
1
21
115
Other
Peripherals ** (5)
#
24.36
81.2
40.6
0
73.08
56.84
32.48
0
64.96
316.68
8.12
56.84
8.12
170.52
933.8
Wgt (lbs)
1
2
0
0
0
1
0
0
0
0
5
22
0
0
31
15
30
0
0
0
15
0
0
0
0
75
330
0
0
465
Equipment (6)
Wgt
#
(lbs)
5
0
0
2
0
1
0
0
2
23
0
2
0
35
52
0
0
20.8
0
10.4
0
0
20.8
239.2
0
20.8
0
0
364
Total
#
Wgt (lbs)
17
41
61
33
18
43
44
8
10
160
17
90
9
61
612
395.36
994.20
1,259.60
661.80
310.08
1,074.24
1,147.48
258.00
85.76
2,491.88
396.12
2,169.64
252.12
1,480.52
12,976.80
*Large Peripherals Include: Printers/Dot Matrix/Laser/Fax/Other
** Small Peripherals Include: Keyboard/Mice/Speakers/etc.
(1)
(2)
(3)
(4)
(5)
(6)
Average weight for pilot project collection calculation at 38 pounds/unit.
Average weight for pilot project collection calculated at 23 pounds/unit.
Average weight for pilot project colletion calculated at 15 pounds/unit.
Average weight for pilot project collection calculated at 8.12 pounds/unit.
Average weight for pilot project collection calculated at 15 pounds/unit.
Average weight for pilot project collection calculated at 10.4 pounds/unit (based on an estimated percentage
using full collection figures for non-computer equipment in this pilot).
A few interesting observations regarding Table 14 are that:

612 units of equipment were collected, totaling 12,977 pounds.

The total cost to recycle this equipment was $735.

From Appendix Q, we see that the highest cost share belongs to HP/Compaq, by more than
double that of the brand with the next highest cost.
PERCEPTIONS OF THE PROGRAM
Staples Staff
Mark Buckley received informal feedback from store managers and the four district managers
responsible for the 27 stores in the five pilot project states. General comments were as follows:

Customer responses were overwhelmingly positive.

Most customers were willing to pay a fee for the recycling service.

From an operational perspective, the program was easy to implement.
Following the pilot project, PSI interviewed Bruce Christian, Staples District Manager for 11
stores (10 in Maine, 1 in New Hampshire). Mr. Christian believed that the recycling program
was “absolutely successful.” He estimated that he personally talked to approximately 30
customers and received “a phenomenal response.” Customers were pleased that Staples provided
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Staples Pilot Project –Final Report to U.S. EPA
Program Results
the service and have asked him to hold collections again. It provided good will with the
customers. Even if they didn’t purchase supplies when they brought in equipment, Mr. Christian
believed that they would likely do so at another time.
While the response was decidedly positive, there were some issues to work out. Mr. Christian
and his staff were slightly overwhelmed by the amount of equipment brought back, and some
people took advantage and brought more equipment than allowed. He believes, however, that
once the first glut of material is taken out of people’s homes, the program will be more
manageable. He believes that people want convenience and they are willing to pay for it. There is
labor involved in collecting, transporting, and recycling, and he believes that Staples should
charge a fee for collection.
Other issues experienced were that smaller stores, which lacked space, could not put the Gaylord
collection box out front, making logistics more difficult. Also, at the end of the program, some
staff at the stores complained that material was stored for 3-4 days without being collected.
These problems, though, were minor in comparison to the positive results.
Mr. Christian suggested that Staples collect computer equipment on a year round basis. He
believes that this arrangement would be more reliable in that people would know that they could
bring their equipment anytime. He felt that he would be inundated if the collection happened
only sporadically. Minimally, he suggested collection once per quarter.
Mr. Christian also suggested handling the equipment like a return so that there is an initial
interaction with a Staples Associate when a customer enters the store. This procedure would be
easier and smoother for Staples and the customer. This process would also reduce any possibility
of breakage when placing the equipment in the Gaylord container, and customer data could be
more accurately recorded. He also felt a need to control the drop off of equipment so that
businesses did not unload too many units. He suggested that this could be accomplished by
asking for identification. He also thought that Staples could possibly give a coupon toward new
product sales to provide an incentive for customers to come back. Mr. Christian believed that
there is a need to collect other electronics at Staples, so that there is one place that people can
bring their equipment. Customers asked that Staples take back DVDs, fluorescent lamps, and
other products. Staples sells some, but not all, of these products. In considering this request,
Staples will have to evaluate the feasibility of accepting each product. Lamps, for example,
could present some difficulties because they are fragile.
Customer Satisfaction
PSI developed a Retail Customer Satisfaction Survey and a Contract Customer Satisfaction
Survey (see Appendix R), which it administered by phone to a limited number of pilot project
participants. PSI collected the data and evaluated the responses. The surveys sought responses
related to:

Customer satisfaction with the collection program (what worked well, suggestions for future
improvements).

Customer motivation to participate (environmental, cost, other).
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Staples Pilot Project –Final Report to U.S. EPA
Program Results

Purchasing at time of collection services – did they make a purchase at Staples.

Willingness to pay for special computer management services in the future.

Other electronics they would like to recycle through Staples.
Retail Customers. PSI attempted to survey one customer for each of the 27 stores in the pilot.
Staples provided PSI with several hundred retail equipment collection surveys from those
customers who provided at least some contact information. The surveys were grouped by store.
From those surveys, PSI selected customers at random, but sought to reach those who provided
at least their name, phone number, and minimum equipment collection information. Some of the
customers operated a small business, or were municipal officials and school employees, while
the vast majority were residents. As part of the retail customer survey results that PSI tabulated
(see Table 15) 1,351 retail customers (81%) said they brought equipment from their home and
308 retail customers (19%) said the equipment was from their business. Phone calls were
attempted during December 2004 and January 2005. PSI placed, on average, four calls per
customer to reach a person who was available to answer the survey. PSI was able to reach 20
customers that returned equipment to 16 different locations in four states.
Table 15. Staples/PSI Pilot Project Retail Survey Data
Equipment From
Home
Office
1351
308
Equipment
Being
From
Used
Storage
529
1095
Willing To Pay A Recycling
Fee In The Future
Yes
No
1008
507
Heard About The
Program From
Store
Store
Flyer
Display
Other
260
483
845
The following analysis is derived from the Retail Customer Satisfaction Survey:

Retail customers were overwhelmingly pleased with the recycling program, and wanted the
program to continue on an ongoing basis, or at least several times each year. They found it
simple and convenient. Placing the equipment in the box and filling out the survey was quick
and easy.

Customers that brought in equipment did not want to dispose of it in the garbage but were
looking for an opportunity to recycle it. Staples provided that opportunity. Many cited
environmental reasons (e.g., toxics) for why they did not want to put it in the garbage. Others
stored the equipment in belief that there was still value to it.

Some people were motivated to bring in their equipment owing to the Massachusetts state
ban on CRTs or to avoid a town disposal fee.

Most people who found out about the program did so while they were in the store purchasing
office supplies. Of those who filled out a survey in the store, 483 said that they heard about
the program through a store display, the largest single source of information. Another 260
heard about the program from a store flyer, and 845 people heard about the program from
“other means” (e.g., word of mouth, newspaper, website). (See Table 15 above.)
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Staples Pilot Project –Final Report to U.S. EPA
Program Results

Most of those interviewed said that they often buy their supplies at Staples, whether or not
they purchased something when they dropped off their computer equipment. Some made a
special trip to come back with their equipment on another day.

The vast majority of customers interviewed said that they would be willing to pay at least $5
per computer system to recycle, although many were willing to spend $10 or even $20. These
data corroborate in-store survey data (e.g., forms filled out by retail customers) that showed
that those willing to pay a fee to recycle outnumbered those who wouldn’t by a two to one
margin (see Table 15). (Even so, it must be kept in mind that those who participated in the
recycling program are a subset of all those who have computers that need to be recycled.
Those participating in recycling programs would be more likely to pay to participate than
those who are not motivated to recycle their equipment.)

Most people were satisfied by the number of items Staples collects, although some wanted
Staples to also collect other electronic equipment (e.g., DVDs, PDAs, etc.); others were
interested in Staples collecting fluorescent lamps. Most people did not know that Staples
provided customers with recycling opportunities on an ongoing basis for hand-held
electronics (including digital cameras, PDA's, Palm Pilots, and pagers), rechargeable
batteries, toner cartridges, and cell phones. A small percentage of those surveyed did know
of the toner cartridge recycling program offered by Staples.

The assistance provided by Staples staff was, for the most part, deemed informed and
helpful. A few people reported that they were seeking more assistance or that the staff person
they spoke with was not informed about the program.

Most of the equipment came from storage. From the in-store retail surveys (Table 15), 1,095
respondents (67%) said that the equipment came from storage, while 529 respondents (33%)
said that the equipment was being used prior to bringing in for collection. This statistic
supports the need for a one-time cleanout before a maintenance program is initiated.
Retail customers provided PSI with the following recommendations as to how to improve the
program:

Greater advertising and promotion of the program, particularly through the town (e.g.,
website, newspaper, recycling coordinators, etc.).

Communicate better with municipal officials so they know about the program and can
promote it.

Provide information on what happens to the equipment once it is collected (e.g., where
recycled; what products are made from plastics, metals, glass, etc.).

Provide a reuse opportunity for the usable equipment.

Provide information on Staples’ other recycling opportunities, such as rechargeable batteries,
cell phones, toner cartridges, and hand-held electronics.

Have Staples staff handle the incoming material like a return at the service desk so the
customer does not have to handle material or fill out a form.
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Program Results

Provide assistance, if needed, to take equipment out of cars and into the store, particularly for
elderly customers.

Provide step-by-step instruction for the customer on what to do with the equipment when
they come into the store.

Don’t put a limit on the number of items collected, since some residents had to make several
trips.
Contract Customers. Of the 14 contract customers that contributed computer equipment in the
pilot project, PSI attempted to interview 12 companies (seeking a mix of small, medium, and
large-size companies) and succeeded in reaching 9 of them. PSI placed, on average, three calls
per company before reaching an individual who was able to answer the survey questions.
The following summary and analysis is derived from the Contract Customer Satisfaction Survey:

There was unanimous interest and enthusiasm for this program from all those interviewed.
Each of them believed that Staples provided a valuable service and made it easy to collect the
equipment. The company provided a list of equipment, packaged it, put it in a staging area,
and Staples came and took it away. Some said that this ease was due to Staples knowing
about their company account, and Staples’ familiarity with the company’s customers,
requirements, needs, and demands. This helped with scheduling, delivering products, turn
around time, and paperwork. However, it should be noted that at least some of the
enthusiasm for the recycling program came from the fact that is was free, saving the
company money. Even so, one company employee commented that he felt that this was a fair
arrangement since the company was taking part in a pilot program that was working out
issues.

The program was also successful because it cleared out space where the computers used to be
stored, so employees were happy with the result. Once again, Staples provided a solution for
those looking to recycle their equipment and get it out of storage. No one really wanted to
dispose of the equipment, but they didn’t perceive that they had another option.

Most of the companies contacted said that they would be willing to pay to recycle their
equipment in the future, since most understood that they were actually required to safely
manage their products. However, almost all said that they would only use Staples for this
service if their price was competitive with alternative options. With that said, many thought
there was an added value to ordering supplies from the same company that took back the
used computer equipment.

All wanted to see the program continue; the average need for service per company was
estimated to be 1 or 2 times per year.

Several companies wanted Staples to offer a certificate of data destruction to ensure that
confidential information is wiped clear off the computers.

Three of the companies had a hard time scheduling a pickup, especially for larger items. One
company cited a great deal of uncertainty as to whether or not the collection would even
occur.
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Program Results

One of the larger companies cited the difficulty in training their own employees to start
recycling the computers instead of throwing them away. Once this education took place, the
program went more smoothly. They offered that, if they were to do it over, they would have
conducted a small pilot project first, and then scaled it up. Staples, however, was
accommodating and wonderful to work with.

Some of the items suggested for Staples to recycle are: analog telephones, fluorescent light
bulbs; paper; batteries; mixed plastics and Teflon; wood pallets.

One person interviewed wanted to know more about how the recycling was part of the
reverse distribution system.
EFFECTIVENESS OF PROMOTIONS/ADVERTISING
Staples took a cautious approach to promotion of the recycling program. Staples was concerned
that employees would be inundated with equipment and that costs might exceed their program
budget. Staples’ goal was to determine whether the costs of the program could be sustainable
and fit within the company’s business model. Staples’ advertising and promotional program is
summarized in Chapter II. Much of this focus was on in-store signage and flyers. By design,
Staples promoted the program slowly and ramped it up slowly. It never fully contacted all the
media outlets, and kept the program low-key throughout the six weeks.
This strategy, though, was a major reason for the internal success of the program. By keeping the
focus on the systems and costs, Staples was able to develop a clear picture of what will be
required to successfully roll this program out nationally. This information was obtained in a
manner that gained the support of Staples staff. Staples associates were very supportive of the
recycling program, as were retail and commercial customers. For the most part, the program did
not overwhelm Staples staff, so that they could feel good about the recycling service they were
providing and build on its success, rather than be concerned about making major mistakes, or
taking a great deal of time away from their basic jobs. By reducing its promotion, Staples was
able to meet one of its goals of developing a willing and eager staff that is ready to fully
implement the program. Store employees interviewed by PSI after the program spoke favorably
about the simplicity of the program, their ability to manage it properly, and customers’
overwhelmingly positive response.
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Pilot Project Costs
CHAPTER V.
PILOT PROJECT COSTS
To determine the economic sustainability of the collection model, PSI attempted to measure true
costs of the system. Some of the costs identified for the pilot are related only to planning, while
others are ongoing. However, as the data indicate, even the pilot data can only be applied to the
northeast region of the country.
TOTAL COSTS
The total costs for this pilot project were $93,432, as detailed in the following table.
Table 16.
Pilot Project Costs by Phase and Funding Source.
Who Paid
U.S. EPA
Staples
Manufacturers
TOTAL COST
Project Phase
Project Implementation/Evaluation
Project Design
Handling/Collection – Retail (northeast region)
Transportation to DC and Envirocycle (northeast region)
Delivery of Pallets – Commercial (northeast region)
Pallet Pick Up/Delivery To FC and Envirocycle – Commercial
(northeast region)
Promotion, Staff training, Administrative Staff
Recycling
Cost
$46,541
$17,000
$1,870
$11,355
$72
$1,044
$7,030
$8,520*
$93,432
* Envirocycle’s recycling costs for this pilot project (7.4 cents per pound, on average) were approximately one-third the market rate (about 20 cents per
pound). Bolded items have been used to calculate the cost per pound.
From the table above, the cost of collecting, transporting, and recycling 115,028 pounds of retail
and commercial equipment collected in this northeastern pilot project was 19.9 cents per pound.
Items from the table that are bolded have been used to calculate the cost per pound. These costs
do not include project implementation/evaluation, design, and promotion/staff
training/administrative staff. In addition, Staples did not quantify the cost of technical and
managerial staff time to conceive of and implement the project.
PROJECT DESIGN AND IMPLEMENTATION
Staples contributed almost $17,000 for the design of the pilot, while EPA contributed $46,541
for project planning, implementation, data collection, and analysis.
RECYCLING COSTS
The cost to recycle 107,360 pounds of computer equipment collected was $7,983.10, while the
total cost of collecting all equipment (115,028 pounds, including non-computer equipment) was
$8,519.86. This recycling cost was based on Envirocycle’s special offer of $4.00/monitor; no
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Pilot Project Costs
charge for CPUs; and $.07/pound for all other products. PSI estimates that this cost is about onethird the market rate. The average price, including all units collected, was 7.4 cents per pound.
STAPLES’ COSTS
Retail Collections
Staples internal cost for the 27 retail collections includes the cost of handling the computer
equipment in the store, transporting to the DC, and transporting to Envirocycle in Pennsylvania.
Staples treated retail returns of used electronics in the same manner as it treated other returns,
and shipped equipment in its own trucks to the DC. The company has prearranged positions
allotted to its stores for pallets, totes, corrugated bales, Gaylords, and product returns. Appendix
T lists the internalized shipping and handling costs associated with the retail pilot, including the
number of pallets collected per store.
As Appendix T indicates, Staples hauled 377 pallet loads of computers (equal to 17.14 trailer
loads), at a handling cost of $4.96 per pallet and a cost to ship them to the Killingly DC of $9.67
per pallet. The average "return" cost per pallet was, therefore, $14.63. In addition to these costs,
Staples incurred costs of $450 per trailer load to transport to Envirocycle from the DC, equal to
$20.45 per pallet. The total cost, therefore, to collect and transport 377 retail pallet loads to
Envirocycle through the DC would be $13,225.16, or $35.08 per pallet (see Table 17 below).
Using an estimated weight of 21.88 pounds per unit (393.84 pounds per pallet) of equipment
collected (see Table 2; 5,257 units collected weighing 115,028 pounds), the cost to collect and
transport this retail equipment to Envirocycle prior to recycling was 8.9 cents per pound. Adding
to that the average price per pound to recycle the equipment of 7.4 cents per pound, the total cost
to collect, transport, and recycle retail equipment in this pilot project was 16.3 cents per pound. If
Staples had to pay the market recycling rate (estimated at 20 cents per pound delivered at the
facility gate), this total cost would equal about 28.9 cents per pound.
Table 17.
Pilot Project Retail Collection Cost: Handling, Shipping, and Transportation
Cost Type
Handling
Shipping to Distribution Center
Transport to Envirocycle
TOTAL COST
Per Pallet
Cost
$ 4.96
$ 9.67
$20.45
$35.08
Per Pound
Cost
1.26 cents
2.45 cents
5.19 cents
8.90 cents
Staples and PSI used the following
assumptions:
• 1 system = 3 units
• 6 systems = 1 pallet (Gaylord)
• 22 pallets = 1 trailer load

1 unit = 21.88 pounds (from Table 2)

1 pallet = 393.84 pounds
To calculate the following:
• $771.76/trailer load
• $ 35.08/pallet
• $ 5.85/system
• $ 1.95/unit
Costs in the New England corridor, however, are lower than the company’s nationwide average
given the northeast’s proximity to the DC and short transit times to stores. As indicated in
Appendix T, the national average cost to ship a pallet of computer equipment from the store to
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Pilot Project Costs
the DC is estimated to be $28.53 per pallet. Therefore, if the pilot was expanded nationally, the
cost to handle each pallet and transport it to a qualified recycler through one of the company’s
four DCs would be $ 53.94, or 13.7 cents per pound. This cost assumes that the handling cost is
$4.96 per pallet, and that a qualified recycler will be within a 250-mile radius from a DC, which
was the distance from the Killingly DC to Envirocycle in this pilot project. Since Staples will
seek to find a recycler at a closer distance, this 13.7 cents per pound figure should be considered
an upper amount. Adding to that the average price per pound to recycle the equipment of 7.4
cents per pound, the total cost to collect, transport, and recycle retail equipment nationally would
be 21.1 cents per pound. However, if Staples paid the market recycling rate (estimated at 20
cents per pound delivered at the facility gate), this total cost would equal about 33.7 cents per
pound.
Table 18.
Average National Estimated Retail Collection Cost: Handling, Shipping, and Transportation
Cost Type
Handling
Shipping to Distribution Center
Transport to Qualified Recycler (<250 miles)
TOTAL COST
Per Pallet
Cost
$ 4.96
$28.53
$20.45
$53.94
Per Pound Cost
1.26 cents
7.24 cents
5.19 cents
13.69 cents
As Table 18 indicates, in a national effort, there would be a marked difference in cost from the
northeast pilot project. The cost to recycle in other regions of the country would vary from the
national average depending on the distance to the DC from a retail location and the distance from
the DC to a qualified recycler. There are four Staples’ DCs in the country – in Connecticut,
Maryland, Indiana, and California.
Commercial Collections
Staples also calculated its internal costs for collecting equipment from contract customers, which
were as follows:
(1)
DELIVERY OF PALLETS: $9.00 for each delivery of pallets/Gaylords to the customer
to prepare for the pickup. Eight of the 14 contract customers required the delivery of
pallets/Gaylords since this was only done for those customers with greater than 10
systems (30 units).
a.
(2)
$9/pallet X 8 deliveries = $72
PALLET PICK UP/DELIVERY TO FC (includes the cost to pick up the pallets and
transport them back to the Fulfillment Center in Connecticut):
a.
$27.00 per pickup (4 pallet average/2 workers) OR
b.
$18.00 per pickup (less than 4 pallet average)
•
•
•
$27/pickup X 8 pickups = $216 (full pallet loads)
$18/pickup X 6 pickups = $108 (partial pallet loads)
TOTAL: $324
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Pilot Project Costs
For the eight businesses at which pallets were dropped off in advance, Staples truck
pickup costs were at the higher end -- $27 per pickup. For the six pickups where
Gaylords were not used, Staples either live loaded the equipment (owing to space
constraints) and packaged the equipment on pallets right on the trucks, or had the
business box the equipment prior to a Staples pickup. Based on this experience, Staples
found that it would be best, in the future, to continue using Gaylords for full pallet loads,
but to live load all other pickups so as to reduce packaging cost and time needed for
pickups for less-than-full pallet loads.
(3)
TRANSPORT TO ENVIROCYCLE: $450 per trailer load X 1.6 loads = $720.
From Table 14 in Chapter IV, we see that 636 units of equipment were collected at the 14
contract customer locations. Based on the above data, therefore, the full cost to collect
and transport 35.33 pallet loads to Envirocycle through the FC would be $1,116, or
$31.59 per pallet (see Table 19 below):
Using an estimated weight of 21.88 pounds per unit (393.84 pounds per pallet) of equipment
collected, the cost to collect and transport this commercial equipment to Envirocycle prior to
recycling is 8.0 cents per pound. Adding to that the average price per pound to recycle the
equipment of 7.4 cents per pound, the total cost to collect, transport, and recycle commercial
equipment was 15.4 cents per pound. At an estimated market recycling rate of approximately 20
cents per pound, this total cost would equal about 28 cents per pound.
Table 19.
Pilot Project Contract Collection Cost: Handling, Shipping, and Transportation
Cost Type
Delivery of Pallets
Pallet Pick Up/Delivery To FC
Transport to Qualified Recycler (<250
miles)
TOTAL COST
Cost
$72
$324
$720
Per Pallet
Cost
$2.04
$9.17
$20.38
$1,116
$31.59
Staples and PSI used the following
assumptions:
• 1 system = 3 units
• 6 systems = 1 pallet (Gaylord)
• 22 pallets = 1 trailer load
To calculate the following costs:
• $694.98/trailer load
• $ 31.59/pallet
• $ 5.27/system
• $ 1.76/unit
Other Costs

Storage space for used electronics – Staples did not believe that this was a factor that added
cost to the project. Backhaul opportunities on Staples’ trucks are frequent, and the equipment
was treated as a "cross dock shipment" when it got to the DC, where it went immediately into
a trailer with equipment from the FC for shipment to Envirocycle.

Promotion and marketing – the cost of the banner and in-store signage was estimated to be
$150 per store, or $4,050 for the 27 stores.
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
Pilot Project Costs
Staff training was estimated to cost approximately $ 1,180. This cost was divided into retail
training costs of $ 1,072 (for staff at the 27 stores) and other training costs of $ 108 (for staff
at the 3 main consolidation facilities – the DC, FC, and the transportation hub in
Massachusetts). Staff training was not necessary at the 14 commercial businesses, since
equipment was either packed by the business or included as part of Staples’ pallet delivery or
pickup cost.
Staples derived the retail training costs by accounting for associate training and educational
materials (estimated at $100 for all 27 stores) and associate training labor (estimated at $972;
$12/hour x 1 hour total training/staff person x 3 staff/store x 27 stores). There was minimal
training needed to service the 3 main consolidation facilities; this was estimated to be $108
($12/hour x 1 hour total training/staff person x 3 staff/facility x 3 facilities).

Administrative staff time was estimated to be about $1,800 to collect the data forms and
input data. The time taken by Staples’ technical and managerial staff to plan and implement
the pilot project was not estimated.
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Pilot Project Cost Projections
CHAPTER VI.
PILOT PROJECT COST PROJECTIONS
ESTIMATED COSTS TO STAPLES
Before agreeing to proceed with the design phase of this project, Staples requested that PSI
estimate the costs associated with a pilot electronics collection program. They did not want to
start this pilot without knowing that the costs would be reasonable and that the pilot would have
a chance to become an ongoing national program. PSI was familiar with this need to limit
financial obligations from its work with companies on the NEPSI dialogue. It was critical that
concerns over “a blank checkbook” be alleviated, and that a degree of fiscal control be
implemented so that Staples, and ultimately the project partners, could feel comfortable in their
participation. Therefore, in the spring of 2003, PSI developed an extensive analysis of projected
costs. Based on this estimate and calculations, and justifications provided by PSI, Staples was
willing to proceed with the pilot project.
To conduct this assessment, PSI used data from electronics collections around the United States
to make quantity and cost projections. PSI presented a high estimate of 154,600 pounds at a
maximum cost of $0.25/lb. for a total of $38,960. These estimates were later refined based on
new cost information from Envirocycle and an initial selection of retail locations for the pilot
project. When Staples and PSI agreed to partner with Envirocycle, the recycler offered a
reduced price for the processing of electronics collected during the pilot project. Envirocycle also
provided PSI with a weight breakdown of electronics typically received at its collections, and
shared a spreadsheet it developed for estimating participation at its collection events. The
spreadsheet, which has proven to be a useful and accurate tool, is based on the population for the
area served by the collection, a per capita recovery rate, and calculations based on participation
rates ranging from .25% to .75% of the population.
To better estimate the quantities and costs for the Staples project, PSI multiplied these numbers
by the population of the communities in which the participating retail stores are located. From
U.S. Census and Atlas data, the total population of the original 26 communities considered for
the pilot was 713,386. (The number of retail locations changed slightly prior to implementation.)
A low, .25% participation rate, yielded an estimated 77,046 pounds of electronics, while a high
participation rate of .75% yielded an expected 231,137 pounds of equipment for the original 26store region. For the retail stores alone, these estimates translated into the following costs (based
on pricing data provided by Envirocycle):
Low Range: 77,046 lbs @ $0.0834/lb* = $6,426
High Range: 231,137 lbs @ $0.0834/lb* = $19,277
Since this projection only covered costs from retail collections, PSI also wanted to consider the
cost of processing used electronics returned from businesses that are part of the Staples Business
The $0.0834/lb. figure was based on Envirocycle’s new cost figures, and an average breakdown by weight of what
typically comes to a collection.
*
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Pilot Project Cost Projections
Advantage program. However, Staples had not yet selected the participating businesses, so there
was no way to estimate the quantity of used electronics that these customers might contribute to
the pilot program. Even with these unknowns, PSI deduced that it was highly unlikely that the
recycling costs for the pilot program would exceed the original projection of $38,960. In fact,
the total cost of the retail and contract customer collections totaled $8,519.86 (based on
Envirocycle’s special processing rate).
PSI made every attempt to offset Staples’ costs by securing funding toward PSI’s role in the pilot
project, by engaging manufacturers and recyclers in cost-sharing, by tapping the resources of
local and state agencies whose regions will benefit from the pilot, and by writing and receiving a
grant from the U.S. EPA to conduct the project. Even so, there were many unknown variables
that required conservative planning and a willingness to make decisions in the face of data and
cost uncertainties. PSI attempted to put in place measures to control the extent of unforeseen
costs. The following factors in Table 20 were seen to contribute to the cost of the project:
Table 20.
Factors Affecting Staples Costs
Factor
Potential Impact On Cost Estimates
How It Was Addressed
• There is no way to predict what SBA
customers will contribute.
• If customers bring greater than average
quantities into retail stores, the costs will
rise. Quantities and participation are
directly correlated to program promotion.
• SBA customers were surveyed to
determine how much used equipment
they have.
Processing
Costs
The 0.0834/lb. was based on an average
breakdown by weight of what typically
comes to a collection. If more equipment
comes into the pilot than projected, the
overall cost will increase.
The amount of materials accepted were
kept low by limiting program promotion.
Cost sharing
The number of partners will impact the
costs that Staples will have to bear.
Obtaining the partnership of 10
manufacturers decreased an already low
program cost.
In-house
Capabilities
The more capabilities (e.g., data
management, training) Staples can develop
internally, the less the cost.
PSI picked up several data management
tasks that will be assumed by Staples
and/or the recycler in the future.
Quantities
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• Staples imposed a limit of 1 system per
retail customer. In addition, program
promotion was limited.
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Staples Pilot Project –Final Report to U.S. EPA
Regulatory Issues
CHAPTER VII.
REGULATORY ISSUES
FEDERAL GUIDELINES
Under federal regulations, any unwanted electronic equipment containing a cathode ray tube
(CRT), including computers and televisions, is currently considered a hazardous waste under
federal regulation (40 CFR Part 260). Hazardous waste regulations do not apply to household
sources of electronics, or to businesses that generate under 7-8 CRTs a year. New proposed EPA
regulations for CRT electronics were posted in the Federal Register of June 12, 2002, and EPA is
expected to finalize them in the fall of 2005. The proposed rule is available on the PSI website, at
http://productstewardship.us/pilot_takeback_staples.html. Proposed changes would designate as
a “commodity” all CRT electronics that are destined for recycling at a permitted or approved
facility. In the interim, the U.S. EPA has provided guidelines for the safe management of
materials (available at http://www.epa.gov/epaoswer/osw/conserve/plugin/pdf/guide.pdf) for its
“Plug In” partners who collect electronic equipment for the purpose of recycling (see Appendix
U).
PILOT STATES REGULATIONS
States can have more stringent regulations governing the handling of electronics, and many states
place some responsibility on the collector. Unfortunately, there is no one set of standards that
applies to all states, so the result is a patchwork of regulations that must be considered when
setting up a program to accept used electronics or any other material that might be considered
“waste,” including some solid wastes (e.g., paper, cardboard) or those considered universal
wastes, such as rechargeable batteries and fluorescent lamps.
As designed, the Staples pilot project collected all brands of used computers at retail stores
located in Maine, Massachusetts, New Hampshire, Rhode Island, and Connecticut, and from
commercial customers in Massachusetts, New Hampshire, and Connecticut. The collected
equipment was backhauled by Staples’ carriers and consolidated at Staples’ distribution and
fulfillment centers in Connecticut. Staples trucks then transported the materials to Envirocyle, an
electronics recycler, in Hallstead, Pennsylvania. State agency officials in the pilot area identified
several applicable regulations (below) that pertained to the Staples project. States have some
ability to streamline regulations for electronics product stewardship efforts, and PSI worked with
Staples and state agencies to identify and comply with the states’ regulatory interpretations.
None of the state regulations added significantly to the cost and complexity of this project.
Under state interpretations of the regulations, Staples had to meet the following requirements:

Obtain EPA ID numbers for participating stores in Maine;

Obtain EPA ID numbers for participating distribution and fulfillment centers in Connecticut;

Provide employee training (which states offered to provide) in universal waste handling in
Maine and Connecticut, and transportation hubs;
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Regulatory Issues

Obtain EPA ID number for shipping electronics across Maine;

Track materials through a state-approved shipping log (Staples standard log met approval);
and

Document collection program participants (e.g., name, address, indicate if they are a
business) through a sign-in log or other information tracking system.
On behalf of Staples, PSI sent a formal letter to the key regulatory official in each of the five
pilot states requesting a return letter stating the specific requirements for the pilot project. The
letter to the agencies included a description of the project. These letters, along with the
responses from the state officials, appear in Appendix V through Appendix Z, along with state
regulatory materials. In summary, Massachusetts and New Hampshire did not consider
computers collected for recycling in the pilot to be waste, so universal waste regulations did not
apply there. However, Connecticut, Maine, and Rhode Island did conclude that universal waste
regulations applied to the Staples collected materials.
To standardize the handling procedures for all Staples facilities and associates in the five pilot
states, Staples adopted the general guidelines for universal waste handling, transport and storage.
These general guidelines include:

Storing used electronics in buildings with a roof and four walls or in a cargo-carrying portion
of a truck.

Labeling containers or pallets containing the electronics as “Used Electronics.”

Storing electronics for no more than a year before shipping to a recycler.

Documenting the pilot project participation through a modification of Staples current
information systems (e.g., as a dummy “return”) or use a sign-in log to document that they
managed their computers through the Staples program.

Getting approval for the current or slightly modified tracking systems (e.g., bill of lading) to
document that collected materials reach the recycler.
States that have designated electronics as a universal waste also have storage and handling
requirements. To standardize the Staples collection program for all states, electronics collected at
retail stores were stacked in Gaylord boxes and labeled.
CONNECTICUT REGULATIONS
The Connecticut Department of Environmental Protection determined that Staples had to apply
to its agency for an EPA identification number as a large quantity universal waste handler for the
distribution center and fulfillment center that consolidated the collected computers, since these
sites were expected to consolidate more than 5,000 kg (approximately 11,000 pounds) of
equipment at any given time. Retail stores collecting equipment from consumers were designated
as small quantity handlers of universal waste, since they were expected not to store more than
5,000 kg at any one time. The key difference between the requirements is that no disassembly is
allowed for those designated as a large quantity universal waste generator without a state permit.
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Regulatory Issues
According to Connecticut regulations as they apply to the stores, the distribution center, and the
fulfillment center, collected equipment can be stored for no longer than one year from the date it
is received. Storage requirements state that each container, package, or pallet of used electronics
must be labeled clearly with any of the following: “Universal Waste - used electronics,” or
“Waste Used Electronics,” or “Used Electronics.” Used electronics must be stored in a building
with a roof and four walls or in a cargo-carrying portion of a truck, in a manner to prevent used
electronics from being exposed to the environment. The used electronics must be handled,
stored, and transported in a manner that maintains the reuse or recyclability of the used
electronic. A handler must immediately clean up and contain any broken cathode ray tube and
place it in a container that is closed, structurally sound, and compatible with the CRT. It should
prevent leakage, spillage, or releases of broken CRTs, glass particles, or other hazardous
constituents from such broken tubes to the environment.
Since Staples used its own carriers to transport materials to the recycler, Staples needed to
comply with regulations for universal waste transporters. The Connecticut guidelines are further
detailed in Appendix V, along with correspondence between PSI and state officials. CT DEP
assisted greatly with the application process. PSI assisted Staples in filling out the paperwork to
apply to the CT DEP for an EPA identification number for the DC and FC. Contact Tom
Metzner, Connecticut Department of Environmental Protection, (860) 424-3242,
tom.metzner@po.state.ct.us.
MAINE REGULATIONS
Maine considered computers collected in the pilot to be hazardous (universal) waste. However,
on a case-by-case basis, there is flexibility for the state to streamline these regulations for
“manufacturer sponsored, product stewardship” collection efforts. Under the Maine Universal
Waste Rule for CRTs, each store participating in the pilot collection was required to apply to the
Maine Department of Environmental Protection (ME DEP) for a State identification number
identifying the store as a universal waste handler. PSI assisted Staples in this application process,
and was allowed to apply once for all stores involved. In the future, if Staples decides to conduct
this program permanently, a federal EPA identification number will need to be obtained for each
participating store location. Also, additional requirements would apply if Staples were to accept
computers from businesses.
Trucks that transported the collected materials were required either to be licensed hazardous
(universal) waste transporters, common carriers that are equipped to ship universal waste, or selftransporters that track materials using the state’s approved bill of lading. Staples’ carriers and
shipping forms met the state requirements, but had to be reviewed and approved by the ME DEP
before transporting materials in Maine. Since Staples transported the computers (as universal
waste) out of state, it needed to use a Universal Bill of Lading (UBOL) for shipping. PSI assisted
Staples in receiving UBOLs from the DEP.
The retail collections were not expecting to take equipment from businesses, although Staples
staff did not prohibit those who used the computers in small businesses from participating. As
reported in Chapter IV, approximately 19% of the retail-collected equipment came from small
businesses. It is important to note that Maine requires businesses that bring computers to a
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collection to sign a log in order to document that they properly managed their equipment. Maine
officials also recommend that households sign a log. Staples must keep the log on file for 3
years, in the event of a state audit. In any case, all participants were asked to fill out a survey that
included their contact information and equipment returned. The survey that PSI developed for
Staples was considered acceptable by Maine DEP officials.
Maine officials also required store employees handling the computer equipment to receive
training, and offered to provide it to Staples staff. The state also had labeling and storage
requirements. Storage limitations required that equipment be shipped within one year of
collection, which it was. Maine’s Universal Waste Guidelines can be found at:
http://www.maine.gov/dep/rwm/hazardouswaste/uwhandbook2004.doc. Correspondence between PSI
and state officials appears in Appendix W. Contact Maine Department of Environmental
Protection, Division of Oil & Hazardous Waste Facilities Regulation. Diana McKenzie (207)
287-7880, Diana.M.McKenzie@maine.gov.
MASSACHUSETTS REGULATIONS
The Massachusetts Department of Environmental Protection (MA DEP) regulations mirror the
proposed federal rule on CRTs. Since Staples only collected the materials, and did not make a
determination whether the equipment was working (therefore suitable for reuse), then it was not
considered a waste. The MA DEP also did not regulate the equipment at the two in-state
transportation hubs that were used as cross-dock facilities for the collection of commercial
equipment en route to the FC in Putnam, Connecticut. Material stayed at the hubs for less than
24 hours and, in many cases, just a few hours, before being backhauled to the FC. The MA DEP
provided guidance for the management of computer monitors regarding the care that should be
taken in handling, storing, and shipping the collected materials to prevent breakage or release to
the environment. Appendix X contains frequently asked questions and answers on
Massachusetts’ regulation of CRTs, along with correspondence between PSI and state officials.
Contact James Paterson, Massachusetts Department of Environmental Protection, (617) 5561096, James.Paterson@state.ma.us.
NEW HAMPSHIRE REGULATIONS
New Hampshire identifies used CRTs as universal waste. However, since Staples was not the
entity making a determination of reusability, it did not have to comply with universal waste
handler requirements. Regarding storage, Staples could not store collected materials for more
than a year. Appendix Y contains guidance from the state on the Universal Waste Rule and
CRTs, along with correspondence between PSI and state officials. Contact Pierce Rigrod, New
Hampshire Department of Environmental Services, (693) 271-3713, prigrod@des.state.nh.us.
RHODE ISLAND REGULATIONS
Rhode Island regulated Staples as a small quantity handler of universal waste for the computer
equipment collected at the one participating retail location in Rhode Island. These regulations
are found under Section 13 of the Rules and Regulations for Hazardous Waste Management.
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Correspondence between PSI and state officials appears in Appendix Z. Contact Mark Dennen,
Rhode Island Department of Environmental Management, (401) 222-2797.
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Pilot Project Benefits
CHAPTER VIII.
PILOT PROJECT BENEFITS
There were numerous benefits to conducting this pilot project, many of which have already been
discussed in the preceding text. However, it is useful to highlight those that should be considered
when evaluating a national expansion.

Solves a Pressing Environmental Need: At its basic root, the pilot showed that Staples, as
a company, was perceived as offering a viable solution to residents and businesses that had
equipment that they knew should not be disposed. The system set up worked for both retail
and commercial customers. Over 115,000 pounds of unwanted computer equipment was
recycled.

Provides a Known Collection Location and Education Opportunity: Millions of people
already shop at Staples stores worldwide. They know where the stores closest to their home
or business are located, and have worked those locations into their transportation patterns, as
well as office supply purchasing habits. By collecting computers at these locations, people do
not need to change these pre-existing patterns of behavior. These locations also offer an
ideal opportunity to notify people about the collections and to educate them about why
collection is important, where products are taken once collected, and other Staples
environmental services.

Creates Good Will: These collections create good will with residents in the neighborhood
who come to see Staples as not only a business that provides office supply services but one
that cares about their environmental well being. The collections also assist state and local
government officials by providing another outlet for the collection of computer equipment,
which places a heavy burden on public works departments nationwide. The service provided
also creates a connection to Staples employees, who are now perceived not only as someone
who can help choose the right printer for one’s home office needs, but also as someone
providing a socially positive service to customers. Employees were thanked for the service,
and this can only develop loyalty to the employer.

Demonstrates Collaborative Problem Solving: This pilot project brought together a retailer
(Staples), a non-profit (PSI), a federal agency (EPA), a recycler (Envirocycle), computer
manufacturers, state agencies, and local agencies to provide a joint solution to a problem in
which they all share a responsibility. It enabled all participants to understand their unique
roles in helping to solve a pressing environmental problem. Success on this project will
allow for the opportunity for success on other similar projects with these same participants,
or a different configuration of partners.

Provides One Stop Shopping: By providing residents and businesses with one company
that sells office supplies and recycles them when no longer usable, it simplifies an already
complicated daily existence. Contract customers particularly will seek one company to
provide both services, which will save on accounting transaction costs.
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Pilot Project Benefits

Offers Staples a Promotional Opportunity: Combining a recycling service with sales of
new products allows for a joint promotional opportunity when re-launching stores or
promoting other store specials.

Offers Manufacturers a Promotional Opportunity: By Staples using their infrastructure to
collect equipment made by another company, Staples actually provides that manufacturer
with an opportunity to share in the promotional benefits and good will created by the
collection. There is tremendous pressure on manufacturers to provide a solution to the
environmental problems created by computer equipment waste. It also creates a marketing
opportunity for those companies to sell new products.

Established Staples as a Brand Leader. Through this project and other environmental
programs, Staples has established itself as a retail leader regarding the provision of
environmental solutions for its customers. This project set a benchmark against which other
retailers will measure their performance.

Provided an Impetus for Other Retailers to Engage: After Staples announced that it
would conduct a retail reverse-distribution pilot, Good Guys and Office Depot followed with
similar electronics collection programs. These were the first retail efforts to collect and
recycle electronics. By showing that such a collection could take place, and that it was
willing to act, Staples created momentum among retailers so that others are considering how
to make their businesses into sustainable companies. Ultimately, this is one of the biggest
benefits to the current pilot effort. As Staples expands its environmental services, other
companies will likely follow or risk losing a competitive advantage based on added social
value.

Enabled Data/Information Sharing: The project provided an opportunity to contribute data
so that others working on solutions to electronics management, particularly regarding the
retailers’ role, can benefit.
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Key Lessons Learned
CHAPTER IX.
KEY LESSONS LEARNED

Program was Logistically Feasible: It is feasible for a retailer to take back unwanted
computer equipment at a retail store, or from businesses, using a reverse-logistics collection,
transportation, and recycling model.

Program was Successful. Staples staff, retail customers, and contract customers were
enthusiastic about the program and want it to continue. Over 57.5 tons of equipment was
collected in six weeks from both retail and commercial customers at a cost that was
competitive with other electronics collections.

Staples’ Customers are Environmentally Aware. Retail and commercial customers are
savvy about environmental concerns from electronic wastes. Few questioned the need for
collection.

Staples Customers are Willing to Pay for Computer Recycling (Note: This should not be
used as a reason to charge in the long-term, since there are still a significant number of
people who will not pay. But it can provide funds to start or supplement a program.)

There is a Backlog of Equipment. There is a significant glut of material needed to be
collected initially from customers, since much had been in storage previously. For many of
the contract customers, this was their first computer recycling effort. This initial backlog of
equipment was especially significant for the business collection program, which made a
simple “back haul” of equipment difficult for a “first time” recycling event. It is assumed
that subsequent and/or periodic events would be more efficient.

Computers Returned from Non-participating Companies were Significant. A significant
percentage of computer equipment returned to the collections came from those that did not
contribute financially to recycling costs.

Manufacturer MOUs Were Time Consuming to Negotiate. The agreement process with
potential manufacturer partners was time consuming, whether or not the company was a
Staples vendor. Most manufacturers wanted to change some aspect of the standard MOU,
and a few wanted individualized agreements that were much different from the basic
template.

Communication Miscues were Costly. Communication between the recycler and the
Project Team resulted in missed data gathering opportunities and extra time and cost to
extrapolate data (e.g., leaving one company out of the brand sort).

Commercial Collections were Unique. Whereas retail collections followed a noticeable
pattern, Staples needed to arrange contract customer collections individually owing to a
variation in pick up locations and equipment quantities and types. Over time, models should
evolve within these collections, making contract customer service delivery easier.

A Little Promotion can go a Long Way. Taking a low-key promotional approach worked
well for Staples employees and management, even if additional customers could have
benefited by the initial pilot. Staff were prepared for the program, were often cited as helpful
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Key Lessons Learned
in the follow up surveys, and were enthusiastic about continuing the program. With little
advertising and promotion, Staples can provide an added service to existing clientele,
endearing them further to the company, since they are already Staples customers. It is
possible, however, that Staples could have allowed more units to be collected per customer
and collected more computer equipment over the pilot period, knowing now the number of
units that were collected and the low cost of the project.

Expect Business Equipment. There was a small, but significant, segment of retail customers
who brought equipment used for business purposes. Some equipment also came from
municipal offices.

Recyclers were Staples Shoppers. Most of those who returned equipment to a retail store
and were interviewed said that they typically shop at Staples. Few people came into the store
only because of the recycling program. This was largely due to the focus on in-store
promotion.

Data Quality was Not High. Allowing retail and contract customers to fill out their own
data sheets did not work as well as had hoped. Many people dropped off equipment,
scribbled some information, and left the store, or went shopping in the store. Only 282 of the
approximately 1800 retail customer survey forms had contact information that was usable.
Commercial data were better, but still incomplete and inconsistent.

Beware of Municipal Regulations During Outreach. Some municipalities would not allow
Staples to advertise using a banner on the exterior of the store.
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Recommendations
CHAPTER X.
RECOMMENDATIONS
Whether to expand this computer recycling project nationwide is a decision for Staples
management. However, from the data developed from this project, there appears to be little
doubt that there is a clear need, and opportunity, to expand the collections both at retail outlets
and contract customer locations. The computer recycling service was well received; there are
numerous benefits to expansion; and Staples’ internal costs were reasonable. In addition, any
costs incurred by Staples could be offset by a fee charged to customers, many of whom are
willing to pay to recycle, and/or by manufacturers’ contributions. Adding computer recycling
service to Staples’ growing environmental products and services will solidify Staples’ position as
a company that not only provides quality office products and services, but one that cares about
the company’s impact on the environment and the community served by its retail stores.
Expanding this recycling service would further enhance Staples’ image as a sustainable business.
Those seeking electronics collection service, however, should not place an over-reliance on retail
take-backs, since these programs are undertaken at a company’s discretion. If Staples, for
example, decides to end the program, for whatever reason, this might pull the plug on recycling
if this were the only, or most significant option, available to consumers. Therefore, while the
Staples pilot project should be understood as a significant opportunity for Staples and other
retailers, these retail programs need to become part of a more comprehensive collection and
recycling infrastructure. Listed below are specific recommendations that Staples should consider
in expanding computer recycling services to other areas of the country, or making it permanent
in the five New England states that were part of the pilot project.
PROGRAM LOGISTICS

Treat Used Computers Like A Return. Typical retail product returns are brought to a
customer service representative, who records vital information directly into a computer
database and takes possession of the product. Used computers should follow a similar
procedure, which will ensure quality data, reduce the likelihood of equipment breakage, and
provide a greater level of service. Staples could handle computer returns from businesses at
the point at which orders are placed. If used electronics are handled as a special “return” in
Staples’ electronic information system, the data could then be harvested for important
information. It will be important to determine if Staples’ computer system can be adapted to
collect the necessary data.

Charge a Recycling Fee. Until a state or national financing system comes into existence,
charge a fee to collect and recycle computer equipment from both retail and commercial
customers. The fee charged to customers will need to be competitive with other recycling
services, particularly among commercial customers, although there is an added value in
having one company – Staples – provide office supplies and recycling services (on the
backhaul) to these commercial customers. Providing a tangible community benefit, as it did
in a separate pilot project for retail customers in the Northwest, would add to the acceptance
of the retail fee. In the Staples pilot project in Washington and Oregon, a portion of the fee
charged to customers for computer recycling was donated to a local school chosen by the
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customer to receive the donation. Staples will still need to determine how much to charge to
cover costs and provide a return to the community. The initial fee should include the cost of
recycling non-participants’ equipment, since participating manufacturers should not be
expected to continue to cover the costs for non-participants, particularly as volumes collected
increase.

Recover the Full Recycling Cost in the Recycling Fee. Do not rely on a cost share from
manufacturers in setting the recycling fee owing to the large percentage of computers
collected from non-participating manufacturers. There is a question as to whether
participating manufacturers will continue to cover the costs imposed by manufacturers that
are not taking responsibility for their fair share, and put themselves at a competitive
disadvantage. As the cost for participating gets too great, these companies may cease to
voluntarily participate in the program. If this potential impact is not factored into the
program’s cost at the outset, it may require Staples to raise the fee later, which is not
desirable. Instead, that fee should assume that the full recycling costs will be recovered
through the fee, unless specific long-term arrangements are made in advance with
participating manufacturers.

Expand the Limit on Equipment Allowed per Retail Customer. Instead of restricting
residents to one computer system, consider expanding the limit on retail customers to 4 or 6
units per customer, as was successfully demonstrated in Staples’ Northwest pilot project.
there should be no need for Staples staff to enforce an unpopular condition and overly limit
the amount of computer equipment returned for recycling. During the pilot project, some
residents complained that they had to make several trips, or left equipment in storage owing
to the limitation allowing only one computer system. However, some limit will be needed if
Staples wants to discourage business equipment.

Identify Business Equipment. Since some states may require that equipment from
businesses be identified and treated differently from equipment from households, ask a
question on the in-take survey as to the origin of the equipment of those entering retail stores.

Phase Collections — Cleanout and Maintenance. Before a maintenance program can be
put in place, anticipate that a large initial amount of material will be generated in areas
without past collections. This will particularly be the case in a business. Conducting
equipment clean outs, phasing collections, or ramping up service will ensure that the program
is not inundated with equipment. Consider promoting a clean out of equipment through
dedicated retail collection events prior to implementing ongoing in-store collections. For
contract customers, a similar phased collection schedule can be adapted so that the first
pickup is expected to be a cleanout of stored computers prior to an ongoing maintenance
schedule. Such a practice will reduce pressure on retail employees to learn new procedures
and ensure that they are not inundated with equipment. It will also likely save Staples funds
by consolidating services to a few days for each retail location. Another option is to more
slowly ramp up in-store, ongoing collections.
While phased collections should definitely be considered for contract customers, additional
consideration will be needed before phased collections can result in a real benefit for retail
customers. In areas with few computer collection options, a Staples retail collection will not
alleviate the backlog of material from storage. However, if the Staples program is part of
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other collections, and these collections have taken place over several years, it is possible that
Staples will see a shift to a maintenance mode. In the Northwest, however, this shift has not
yet occurred even with the existence of ongoing, convenient computer recycling programs.
Additional retail collections, therefore, will need to take place before an established pattern is
detected.

Implement a Commercial Equipment Pick-up System: Ensure a chain of custody to better
track equipment and report to customers by assigning a bar code or other identification to
shipments at the point at which the recycling service is ordered. Consider setting up
commercial collections so that businesses have the opportunity to pre-select used computer
pick up from a menu of services and submit an “order form” describing the shipment (e.g.,
number of computer units, type of equipment). At that specific point, Staples could assign a
bar code or other identification to shipments to track the materials from the source to the
recycler.

Develop a Standard MOU with Manufacturers with Few Variations. Although PSI and
Staples developed a standard MOU, manufacturers spent countless hours trying to
manipulate it for their own particular circumstances. While a certain degree of flexibility is
advisable, the time spent in negotiating individually was not worthwhile, particularly with
companies that have their own special circumstances. Consider having one agreement that a
manufacturer either signs or doesn’t sign. Also, dictate the terms of an agreement and only
allow variations in very special circumstances. If a business wants to collect its own material,
it should be required to pay for the cost of separating and recycling its own equipment. It is
advisable to include in the MOU the name of the recycler and other important details to
clarify expectations.

Assign a Dedicated Staples Daily Contact. Consider assigning an internal dedicated staff
person that could serve as the daily point contact to retrieve data, contact Core Team
personnel, and communicate preferences and decisions. This person could coordinate staff
activities, take direction from senior staff, and be available to keep the project going. The
person should take direction from a senior manager who has authority with senior staff across
the company. Staples will need to include this staff time in its costs and, ultimately, the fee
charged to the public at retail, or contract customers. If Staples expands nationwide, this
would be a full-time position. However, if the expansion were to proceed in phases, this
position would be a part-time position.

Promote Reuse. Reuse is a more environmentally sustainable practice than recycling.
However, it takes more planning, and is more complicated regarding regulations and data
destruction. Ask potential recyclers being interviewed for future collections to provide the
cost of adding reuse to the services provided, and the method by which data will be
destroyed. Sending working computers for reuse to developing nations poses no liability for
Staples and is a worthy cause, but it may be interpreted by some environmental groups as
another form of third world dumping. For any expansion of this pilot program, use domestic
reuse organizations until a credible system is put in place for the return or proper
management of electronics sent for reuse to other countries.

Enhance Data Security to Allow for Reuse: In the future, electronics from companies
should be tagged with a noticeable sticker or other identifier to signal to the recycler that
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special handling is required (e.g., scrubbing the hard drive to allow for reuse). This procedure
would allow for a greater level of certainty regarding data destruction. Staples could
implement a system for scanning and numbering items, and translating them into SKUs, as
part of a data security and unit tracking system. By instituting a rigorous procedure that
ensures data destruction, reuse might increase for companies that have newer and, therefore,
more marketable, equipment.

Incorporate Recycler Selection Criteria. If expanding computer collections across the
U.S., use the recycler selection criteria developed for the pilot project and determine the
relative importance of the proximity of a recycler to a consolidation point, among other
issues.

Collect Additional Items. Consider collecting and recycling other electronic items that
Staples sells but doesn’t now collect, such as computer discs and other electronic media.
These items should be phased in along an established timetable.
TRAINING AND REGULATORY REQUIREMENTS

Provide Training For Contract Customers. Many of Staples’ contract customers started
recycling their computer equipment during this pilot project. Some stored the computers,
while others disposed of them in the garbage. For some companies, computer recycling is a
major shift in practice. Consider developing training specific for companies that will need to
educate their own employees to start recycling computers instead of throwing them away.
Such a training would be a perfect opportunity for state regulatory officials to work in
conjunction with Staples and its customers. Conduct a small pilot project first, and then scale
it up if successful.

Handle All Materials Using General Guidelines For Universal Waste. Adopt general
guidelines to abide by the universal waste requirements if expanding the program nationwide
or making it permanent in the five New England states that were part of the pilot project.

Seek to Standardize Regulatory Requirements. Although complying with state regulatory
requirements was not overly burdensome, and PSI received excellent assistance from state
regulatory officials, the process was time-consuming. Standardized regulations will lower the
costs to collect, transport, and recycle electronics. States, however, may want to regulate
used electronics themselves, as many states do not agree with the current interpretations on
electronic waste from EPA. Problems will only arise, though, if state regulations are
functionally incompatible. However, if the regulatory requirements prove to be too
cumbersome in some states, consider limiting the initial program to states with a more
relaxed interpretation of how electronics can be safely managed. If states find they are
missing out on a good pilot program because of their regulations, they may be inclined to
change their regulations. Seek the support of EPA regional offices and headquarters to
determine the most efficient regulatory approach depending on the future program.

Develop a Tracking System for Collected Computers. Staples’ automated return system
already tracks customer information, product type, brand name, and other data. Explore
adapting this return system to accommodate customers bringing used electronics. Universal
waste transporter requirements include the keeping of a shipping log (bill of lading) to track
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materials. The Maine Department of Environmental Protection approved the shipping log
developed by PSI for compliance in that state. In addition, Maine requires documentation of
the source for the collected computers so that businesses can demonstrate that they managed
their used computers in compliance with state laws.
The automated system would satisfy regulatory tracking requirements, and customers could
be provided with a receipt that would demonstrate that their equipment was handled in an
appropriate manner. Additionally, the data gathered in an automated system could also
provide important information on the equipment coming into the system and on the customer.
If the automated tracking system cannot be employed, Staples can use the same type of forms
used for the pilot project, which provided customer name and contact information, and
indicated if the computers were from a business. Staples must keep these logs on file for a
period of 3 years after the collection program. To standardize storage and handling
requirements, follow the same procedures as was followed for the pilot project (see Chapter
VII). Staples will have to verify that these proposed labeling and tracking systems meet the
regulatory requirements of the states in which the program will take place.

Standardize Computer Handling Guidelines And Training For Staples Associates. For
the pilot, Staples provided its personnel that handled computers with brief training and
printed guidelines for how to handle equipment to prevent worker injury and breakage, and
what to do during accidental breakage. The Connecticut DEP and Maine DEP offered to
meet with Staples, provide training (or training materials) to Staples associates, and further
define training recommendations and requirements. In an expansion effort, seek to identify
and evaluate other training efforts developed for workers staffing electronics collections.
Refine and standardize training for the national rollout to ensure that it will meet the
regulatory requirements in all states.
DATA COLLECTION, CONTRACTS, AND BUDGET

Maximize Data Collection Capabilities Within Staples. Staples’ pallet-cost collection
system should be supported by more specific methods of per-item accounting. Assigning bar
codes to individual units (containers or pallets), using methods comparable to Staples’
current return and exchange procedures, will facilitate accounting of expenses as items move
through the Staples small business delivery system (e.g., from business to delivery truck,
transportation hub, fulfillment center, recycler) or the retail system (e.g., from household or
small business to retail store/pallet to distribution center, to recycler). Coordinate bar code
information with the recycler, so that all parties involved in materials handling will be able to
calculate more precise costs for each stage of handling.

Calculate Other Costs To Staples. Calculate and budget for total costs that will likely be
part of the national expansion of the collection system, including associate and management
time, storage, equipment and supplies, advertising, and promotion.

Budget for Non-computer Equipment. Expect, and budget for, a certain percentage of
related non-computer equipment, even if it is specifically not accepted as part of the program.

Develop Detailed Contract with Recycler. Develop a detailed contract with the recycler
regarding expectations about the companies for which brand sorts should take place, whether
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retail and commercial loads will be tracked separately, the forms used for data collection,
how manufacturer cost shares are to be calculated, who invoices manufacturers for their cost
share, average weights used per equipment type, and which equipment types will be sorted
by brand. This project involved many details at numerous stages of project development.
Small details that were not resolved in advance caused significant time delays, uncertainty,
and cost. For example, a brand sort was not conducted for one of the participating companies,
requiring the development of a complex cost share calculation. Listed below are two charts
that suggest the types of data that Staples could collect itself, and what it could require the
recycler to provide.
Table 21.
Quantity Data and Collection Method
Quantity Data
Data Collection Method
Pounds and units of collected materials from retail
stores
Recycler provides data
Pounds and units of collected materials from SBA
businesses
Recycler provides data
Pounds and units of collected materials from
Internet/catalog customers
Recycler provides data
Quantities by brand
Recycler provides data (either sample or true count)
Number of business participants
Staples calculates from SBA participants and from
sign in logs at retail store collections
Number of household participants
Staples calculates from sign in logs at retail store
collections
Average pounds/units per participant
Staples calculates from recycler and participation
data
Quantities compared to availability of other
collections
Staples calculates by matching questionnaire results
and quantities brought in for each store and SBA
business
Table 22.
Cost Data and Collection Method
Cost Data
Data Collection Method
Marketing and promotion
Staples calculates costs related to promotions
Processing and recycling computers
Recycler provides costs, including waived costs
Cost/value of electronics handling by Staples
Staples calculates time related to the collection,
including supplies and equipment
Value of transportation services
Staples calculates transportation costs on a perpallet costs
Associate training costs and materials
Staff planning, implementation, and monitoring
Staples calculates actual training expenses
Staples calculates staff time related to planning,
implementation, and monitoring
Product Stewardship Institute, Inc.
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FINAL June 2005
Staples Pilot Project –Final Report to U.S. EPA
Recommendations
EDUCATION AND OUTREACH

Phase Program Promotion. Continue the practice of phasing in the collection program
concurrent with ramped up advertising and promotion to ensure that staff do not become
overwhelmed by equipment and continue to support the program. Outreach should start
small, but progress gradually to full promotion. Regarding retail collections, consider starting
with in-store signage, then include an outside banner, flyers, and finally contact the news
media and conduct local outreach through recycling coordinators after six months. To cap off
an expansion effort, conduct media outreach to daily newspapers and trade press, for
maximum press visibility. The concept driving this recommendation is that, if staff becomes
overwhelmed, they will not be able to acclimate to the new service. A phased approach will
ensure that they continue to feel good about offering this added service.

Provide Recycling Education to Staples Customers. When equipment is being collected,
Staples has a unique opportunity to educate retail and commercial customers about why
recycling computers makes sense, what happens to the equipment once it is picked up, what
would happen if the equipment was not collected, and what other products Staples recycles.
Consider developing two types of messages – one for the general public, and one for business
owners. As discovered through the pilot, a percentage of small business customers shop in
the store now, along with municipal fire/police/schools, and others whose equipment may be
required by state law to be managed in a different manner. There is an opportunity to reach
these customers with a different message than households.

Enhance Communication with Partners. Regular communication updates with partners
will enhance project communication and reinforce the common goal toward which all
partners are working – the recycling of computer equipment. Update bulletins provide steady
information and answer questions that inevitably arise during the project.

Engage Pilot Partners in Outreach and Education. Pilot partners are interested in
receiving press attention as a result of their participation. To increase project visibility,
contact pilot partners early in the implementation planning to assess the promotional and
outreach resources available through these organizations (e.g., newsletters, presentations,
websites, hotlines, signage at recycling or household hazardous waste facilities). Consider
jointly funded print and radio advertisements and joint press events and outreach.

Obtain Local Approval to Exhibit Store Banners. Seek a waiver from the prohibition in
some municipalities to putting a banner on the exterior of the store.

Coordinate with America Recycles Day. Nearly every state has an America Recycles Day
coordinator who would be receptive to a partnership on computer recycling. A list of state
contacts can be found on the organization website at www.americarecyclesday.org.
According to one coordinator, most of these activities are dormant in between the annual
event (in November), but coordinators would likely welcome an opportunity to partner with
Staples. These state contacts also have established communication channels that can be used
for promoting the program when the program is ready to be ramped up.
Product Stewardship Institute, Inc.
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FINAL June 2005
Staples Pilot Project –Final Report to U.S. EPA
Recommendations
PROGRAM EVALUATION

Evaluate Customer Satisfaction. Staples should train its customer service staff to survey
retail and contractor customers to learn valuable lessons about the program. Periodic surveys
can be administered to randomly selected customers when they bring in their computers
(retail), or when their equipment is picked up or when an order for pick up is placed on-line
(contract). Alternatively, Staples staff can follow up within a week after the equipment has
been brought to the store or picked up. Discount coupons can be provided to those who agree
to assist with the survey.

Provide for Internal Feedback. Staples associates familiar with the recycling program
should provide important feedback on needed improvements. PSI views this evaluation as an
informal discussion with the Core Team based on feedback they receive from their
employees. Consider developing a simple list of questions for Core Team staff to ask of their
employees.

Communicate Project Results. Staples spent a great deal of time and effort to make this
project successful. Project partners contributed time and resources. Holding a briefing at
critical junctures in the project timetable will ensure that project results and implications are
understood, and that the feeling of participating in a joint project is enhanced. Consider
ending pilot projects, such as this one, with a press release announcing results and the
availability of the final report.
Product Stewardship Institute, Inc.
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FINAL June 2005
Staples Pilot Project –Final Report to U.S. EPA
Appendix A
Appendix A. Letter to Computer Manufacturers
Date
OEM Contact Name
OEM Contact Title
OEM Name
OEM Address
Dear XXXXXXXX,
As a valued vendor partner, major manufacturer and supplier of electronic equipment to Staples, Inc., we
are contacting you to participate in a project of national significance. Because we are a top retailer of
electronics in the U.S., Staples is concerned about the volume and toxicity of electronics waste. We are
developing, and will soon be testing, a business model to address this growing problem.
The business model will collect and recycle used electronic products from Staples’ retail, Internet and
commercial customers. It will utilize the reverse distribution capacity of the Staples fleet to transport
used electronics products from customers to regional distribution centers. Staples will design the system
to be financially sustainable.
A pilot project will test the business model using various scenarios. We are aware that EPA is providing
incentives for electronics manufacturers to be involved in collection and recycling. Therefore, one
scenario we would like to explore is cost sharing with our top OEM suppliers. Staples is willing to absorb
the costs of collection and transport of electronics to our regional distribution centers. We are seeking
OEM support to cover the costs of transporting the materials from the distribution centers to processors,
and the recycling.
The actual cost and the value of services will be measured in the pilot project to determine which
scenarios are replicable for a national system. Involvement in the pilot project does not necessitate your
continued involvement in the national system. Staples’ intent is to ultimately develop a business model
for electronics that not only provides an important service to our customers, but that may also be
replicated by other retailers.
Staples has contracted with the Product Stewardship Institute to assist with the design of the pilot project.
Scott Cassel, Executive Director of the Product Stewardship Institute, will contact you soon to discuss the
pilot project and your potential interest in participating. Please feel free to contact us directly if you have
any questions. We look forward to working with you on this important initiative.
Sincerely,
_______________________________
___________________________________
Mark F. Buckley
Vice President, Environmental Affairs
Staples, Inc.
Peter J. Scala
Sr. V.P., GMM Office Technology
Staples, Inc.
Product Stewardship Institute, Inc.
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FINAL June, 2005
Staples Pilot Project –Final Report to U.S. EPA
Appendix B
Appendix B. Contacts for Staples Pilot Project
Federal and State Government Contacts
Connecticut Department of Environmental
Protection
Tom Metzner, Environmental Analyst
79 Elm St, 4th Floor
Hartford, CT 06040
(860) 424-3242
Maine Department of Environmental
Protection
Carole Cifrino
17 State House Station
Augusta, ME 04333
(207) 287-7720
tom.metzner@po.state.ct.us
carole.a.cifrino@maine.gov
Maine Department of Environmental
Protection
Diana McKenzie
Bureau of Remediation and Waste
Management
17 State House Station
Augusta, ME 04333
(207) 287-7880
Maine State Planning Office
Sam Morris
38 State House Station
Augusta, ME 04333
207-287-8054
sam.morris@state.me.us
Diana.M.McKenzie@maine.gov
Massachusetts Department of Environmental
Protection
Brooke Nash, Recycling Grants Program
Manager
1 Winter St, 8th Floor
Boston, MA 02108
(617) 292-5984
Massachusetts Department of Environmental
Protection
Greg Cooper, Director of Consumer Programs
Office of Research & Standards
1 Winter St, 8th Floor
Boston, MA 02108
(617) 292-5988
brooke.nash@state.ma.us
greg.cooper@state.ma.us
Massachusetts Department of Environmental
Protection
James Paterson
1 Winter Street, 9th Floor
Boston, MA 02108
(617) 556-1096
New Hampshire Department of Environmental
Services
Phil O’Brien, Director
6 Hazen Drive
Concord, NH 03301
(603) 271-2905
James.Paterson@state.ma.us
probien@des.state.nh.us
Product Stewardship Institute, Inc.
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FINAL June, 2005
Staples Pilot Project –Final Report to U.S. EPA
New Hampshire Department of Environmental
Services
Chris Way, Supervisor of Planning and
Community Assistance
6 Hazen Drive
Concord, NH 03301
603-271-3571
Appendix B
New Hampshire Department of Environmental
Services
Pierce Rigrod
6 Hazen Drive
Concord, NH 03301
(693) 271-3713
prigrod@des.state.nh.us
cway@des.state.nh.us
Rhode Island Department of Environmental
Management
Mark Dennen
235 Promenade Street
Providence, RI 02908-5767
(401) 222-2797
New England Waste Management Officials
Association (NEWMOA)
Bill Cass, Executive Director
129 Portland St. Suite 602,
Boston, MA 02114
(617) 367-8558 x301
Mark.Dennen@dem.ri.gov
wcass@newmoa.org
Environmental Protection Agency (U.S. EPA)
Clare Lindsay
Office of Solid Waste (5306-W)
Ariel Rios building
1200 Pennsylvania Ave., NW
Washington, DC 20460
(703) 308-7266
U.S. EPA/New England
Christine Beling
One Congress Street
Suite 1100, SPP
Boston, MA
(617) 918-1792
Beling.Christine@epa.gov
Lindsay.Clare@epa.gov
Regional and State Recycling Organizations
Regional
Northeast Recycling Council (NERC)
Mary Ann Remolador, Assistant Director
139 Main Street, Suite 401
Brattleboro, VT 05301
(802) 254-3636
mary@nerc.org
Northeast Resource Recovery Association
(New England)
Elizabeth Bedard, Executive Director
NNRC
9 Bailey Rd.
Chichester, NH 03258
603-798-5777
nrra@tds.net
Product Stewardship Institute, Inc.
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FINAL June, 2005
Staples Pilot Project –Final Report to U.S. EPA
Appendix B
Gordon McCown, Recycling Specialist
NNRC
9 Bailey Rd.
Chichester, NH 03258
603-798-5777
nrra@tds.net
Connecticut
Connecticut Recyclers Coalition
Winston Averill
P.O. Box 4038
Old Lyme, Connecticut, 06371-4038
860-423-7683
Connecticut River Estuary Regional Planning
Agency
Amy Cabaniss
PO Box 778
Old Saybrook, CT 06745
(860) 388-3497
crerpa@snet.net
Maine
Maine Resource Recovery Association
Victor Horton, Executive Director
PO Box 1838
Bangor ME 04402-1838
207-942-6772
Kennebec Valley Council of Governments
Sarah Flaks
17 Main Street
Fairfield, MA 04937
207-453-4258
mrra.victor@verison.net
sflaks@kvcog.org
Massachusetts
MassRecycle
Jennifer Gitlitz, Executive Director
25 West Street
Boston, MA 02111
(617) 338-0244
jengitlitz@massrecycle.org
Municipal Recycling Assistance Coordinators,
Massachusetts DEP
Carolyn Dann
Kema Consulting Group
Three Burlington Woods
Burlington, MA 01803
(781)-273-5700 X298
cdann@kema-xenergy.com
Kate Gillooly
City of Boston, DPW
One City Hall Plaza
Boston, MA 02201
(617)-635-4959
Kathi Mirza
DPW
90 Ingell Street
Taunton, MA 02780
(508) 821-9469
Kate.gillooly@cityofboston.gov
kmirza@tmlp.com
Product Stewardship Institute, Inc.
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Staples Pilot Project –Final Report to U.S. EPA
Appendix B
Sharon Byrne Kishida
Beverly Community Development
191 Cabot Street
Beverly, MA 01915
(978) 921-8300
skishida@beverlyma.gov
Rhode Island
Rhode Island Resource Recovery Association
John Trevor
65 Shun Pike
Johnston, RI 02919
(401)-942-1430
johnt@rrirc.org
Local Recycling Contacts in Pilot Store Locations
South Portland, ME
Steve Johnson, Director of Public Works
42 O’Neil St.
South Portland, ME 04106
207-767-7635
Bangor, ME
Jerry Hughes, Safety Coordinator
530 Maine Ave
Bangor, ME 04401
207-942-0220
sjohnson@southportland.org
jerry.Hughes@bgrme.org
Brunswick, ME
Steve MacDonald
9 Industry Rd.
Brunswick ME 04011
207-725-6654
Lewiston, ME
Rob Stalford, Solid Waste Superintendent
PO Box 479
Lewiston, ME 04243
207-782-4200
smacdonald@brunswick.me.org
rstalford@ci.lewiston.me.us
Biddeford, ME
Guy Casavant
Public Works Dept
371 Hill St.
Biddeford ME 04005
207-282-1579
Falmouth, ME
Anthony Hayes, Director of Public Works
101 Woods Rd.
Falmouth ME 04105
207-781-3919
thayes@town.falmouth.me.us
gcasavant@biddefordmaine.org
Product Stewardship Institute, Inc.
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FINAL June, 2005
Staples Pilot Project –Final Report to U.S. EPA
Waterville, ME
Karl Morse
Water Public Works
6 Wentworth Court
Waterville ME 04901
207-877-7530
Appendix B
N. Windham, ME
Tony Plante
Town Manager
8 School Road
Windham, ME 04062
atplante@town.windham.me.us
kmorse@ci.waterville.me.us
Woburn, MA
Marlene Johnson, Board of Health
10 Common St.
Woburn, MA 01801
781-932-4409
Natick, MA
George Russell, Supervisor of Sanitation
Dept. of Public Works
75 West St. Natick MA 01760
508-647-6556
mjohnson@ci.woburn.ma.us
grussel@natick.ma.org
Saugus, MA
Lorna Cerbone, Recycling Coordinator
298 Central St.
Saugus, MA 01906
781-231-4145
Danvers, MA
Pamela Irwin
1 Sylvan St
Danvers, MA 01923
978-777-0005 X1633
lcerbone@townofsaugus.org
pirwin@mail.danvers-ma.org
Burlington, MA
Syamal Chavohri, Superintendent of Public
Works
25 Center St
Burlington MA 01803
781-270-1670
Needham, MA
Kristine Charbonneau
Solid Waste and Recycling
470 Dedham Ave
Needham, MA 02492
781-455-7548 X220
schaudhuri@burl.mass.org
kcardonneau@town.needham.ma.us
(Somersworth) Dover, NH
Jack Jackman
Department of Public Works
1 Government Way
Somersworth, NH 03878
603-692-4266
Rochester, NH
Melodie Esterberg, Public Works Director
or Lisa Clark
45 Old Dover Rd
Rochester NH 03867
603-332-4096
jjackman@somersworth.com
melodie.esterberg@rochesternh.net
Seabrook, NH
John Starkey, Manager of Recycling
PO Box 456
Seaport NH 03874
603-474-9771
Portsmouth, NH
Silke Psula, Manager of Recycling
Portsmouth Public Works
680 Beverly Hill Rd
Portsmouth, NH 03801
603-766-1454
jmstarkey@seabrooknh.org
spsula@pw.cityofportsmouth.com
Product Stewardship Institute, Inc.
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FINAL June, 2005
Staples Pilot Project –Final Report to U.S. EPA
Appendix B
N. Conway, NH
Eric Meador
Department of Public Works
PO Bo131
Center Conway NH 03818
603-356-2272
Westerly, Rhode Island
John Fusaro
Public Works
45 Broad Street
Westerly, Rhode Island 02891
(401)—348-2539
conway@conwaynh.org
jfusaro@westerly.org
Old Saybrook, CT
Larry Bonin
302 Main Street
Old Saybrook, CT 06475
(860) 395-3123
New London, CT
Ed Steward
Public Works
111 Union Street
New London, CT 06320
(860)-447-5250
gneri@town.old-saybrook.ct.us
esteward@ci.new-london.ct.us
Norwich, CT
Kenneth Marshall
100 Broadway
Norwich, CT 06360
(860) 823-3825
no e-mail
Product Stewardship Institute, Inc.
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FINAL June, 2005
Staples Pilot Project –Final Report to U.S. EPA
Appendix C
Appendix C. Standard MOU and Summary of Manufacturer MOUs
Plug-In To eCycling
Agreement between Staples and _________________
DRAFT – April 29, 2004
Through this agreement, ____________ joins with Staples, Inc. to participate in a pilot
project for the U.S. EPA Plug-In To eCycling Campaign. The Staples pilot and other
eCycling projects are designed to encourage the reuse and recycling of used consumer
electronics. ____________ agrees to assist Staples in covering the costs of processing
electronics collected in 2004 from customers at 26 participating retail stores, and from
selected Staples commercial and Internet customers. ____________ total expense for the
Staples pilot project will not exceed $10,000.
____________ Commitments
For the Staples pilot project, ____________ is committed to taking action in the areas
indicated below:
 Pay up to $10,000 for the processing and recycling costs for all ____________ products
brought into the Staples pilot collections in 2004. Actual costs will be billed to
____________ at the end of the project on a per pound basis by Envirocycle, the pilot
project recycling partner.
 Pay for a share of cost for processing “orphan” electronics (those for which the
manufacturers is no longer in business or is a non-participant in the Staples pilot
project). ____________ cost share will be determined by the share of equipment
brought to the pilot program that is ____________ products (i.e., if 10% of the
equipment coming to the pilot is ____________, ____________ will also pay for 10%
of the cost of processing orphan equipment).
Staples Commitments
For the pilot project, Staples is committed to the following actions:
 Assure that all collected electronics are handled and managed in a manner that protects
Staples and all partners from liability, and protects human health and the environment;
 Pay for any costs for processing ____________ products and ____________ share of
orphan electronics that exceed the $10,000 cap established by Staples;
 Promote pilot partners in promotional information associated with the pilot project;
Product Stewardship Institute, Inc.
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FINAL June, 2005
Staples Pilot Project –Final Report to U.S. EPA
Appendix C
 Provide ____________ with an opportunity to review promotional and press material
about the program and to participate in any related press or public acknowledgement
events;
 Adhere to terms of agreements with ____________ regarding the use of the
____________ logo and trademarks;
 Share pilot project results with partners in a report containing non-proprietary cost,
logistical, participant, and quantity information.
Dispute Resolution
___________ and Staples will assume good faith as a general principle for resolving
conflicts under the Plug-In To eCycling pilot project. Both parties will endeavor to resolve
all matters informally, so as to preserve maximum public confidence in both companies and
Plug-In To eCycling.
In the event informal channels do not produce a mutually agreeable resolution to a matter in
dispute, either party to this Agreement shall notify the other in writing as to the nature of the
dispute, the specific corrective action sought and their intent to terminate the Agreement,
either as a whole or in part, unless specific corrective actions sought are undertaken:
 Within 20 days of receiving formal notification from Staples indicating intent to
terminate the Agreement, either as a whole or in part, ____________ will reply,
agreeing to either (1) undertake in a timely and effective manner the corrective actions
sought by Staples, or (2) terminate the Agreement, either as a whole or in part;
 Within 20 days of receiving formal notification from ____________ indicating its
intent to terminate the Agreement, either as a whole or in part, Staples will reply, either
(1) agreeing to undertake in a timely and effective manner the corrective actions sought
by ____________, or (2) explaining why such corrective actions cannot be undertaken;
 If ____________ fails to respond within 20 days of receiving formal notification of
Staples intent to terminate the Agreement, either as a whole or in part, or if
____________ responds but does not agree to undertake corrective actions sought by
Staples, or if ____________ agrees but does not initiate the corrective actions in a
timely manner, then this agreement is terminated, either as a whole or in part.
Entry into Force and Duration of Agreement
Both parties concur that this agreement and the terms outlined in the supporting documents
will become effective when signed by both parties and will continue through December 31,
2004, but may be extended if the parties agree to do so in writing.
The undersigned hereby execute this Agreement with Staples, Inc., on behalf of their party.
The signatories of this agreement affirm that they have the authority to execute this
agreement on behalf of ____________ and Plug-In To eCycling.
Product Stewardship Institute, Inc.
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FINAL June, 2005
Staples Pilot Project –Final Report to U.S. EPA
Appendix C
Signatory for STAPLES, INC.:
Signature: __________________________________________________Date:
Name:
Title:
Address:
City:
State:
Phone:
Fax:
Zip:
E-mail:
Signatory for ____________:
Signature: __________________________________________________Date:
Name:
Title:
Address:
City:
State:
Phone:
Fax:
Zip:
E-mail:
Product Stewardship Institute, Inc.
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Staples Pilot Project –Final Report to U.S. EPA
Appendix C
STAPLES/PSI PILOT COMPUTER TAKE-BACK PROJECT
Summary of Manufacturer MOUs
March 21, 2005
Date MOU
Signed
Date Of Last
Agreement
(If Not
Signed)
Standard
Agreement
(Yes/No)
Special Aspects Of Agreement
Apple Computer, Inc.
Brian Miller
Corporate Manager, EH&S
Brian.m@apple.com
408-974-7629 (ph)
May 12,
2004
N/A
Yes
Brother International Corp.
Henry Sacco
Chief Legal Officer
Henry.Sacco@brother.com
(908) 252-3029 (ph)
N/A
May 26, 2004
Yes
Dell
Shari Carle
Sustainable Business Analyst
Shari_Carle@dell.com
512-728-4980 (ph)
512-907-5700 (pager)
N/A
May 26, 2004
No
Epson America, Inc.
Shelby Houston
Manager, Customer Programs
Shelby_Houston@ea.epson.com
562-290-5445 (ph)
June 1, 2004
N/A
Yes
HP
Renee St. Denis
renee.stdenis@hp.com
916-785-8034
N/A
Verbal only
No
Separate out HP products and
ship to HP.
Intel
Allen Wilson
Manager, EH&S
Allen.r.Wilson@intel.com
480-715-2390 (ph)
N/A
N/A
No
Intel gave $2,000 to the
Electronic Industries Alliance
for the pilot project costs.
Mike Watson
Program Manager,
Dell Asset Recovery Services
Mike_Watson@dell.com
Product Stewardship Institute, Inc.
- C4-
Pay up to $10,000 for recycling
of Dell computers from
commercial customers only
(NOT retail). Pay % of nonparticipants based on Dell’s
share coming to facility.
Products sorted and transported
to one of Dells’ approved
recycling partners.
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Staples Pilot Project –Final Report to U.S. EPA
Date MOU
Signed
Appendix C
Date Of Last
Agreement
(If Not
Signed)
Standard
Agreement
(Yes/No)
Special Aspects Of Agreement
Lexmark International, Inc.
Tonya Jackson
Manager, EH&S
tonyaj@lexmark.com
859-232-7925 (ph)
N/A
May 24, 2004
(date of
December 10,
2003, remains
on Draft)
Yes
Panasonic
David Thompson
General Manager
thompsond@us.panasonic.com
201-271-3486 (ph)
April 30,
2004
N/A
Yes
Originally did not want to pay
for products from nonparticipating companies, but
later allowed this based on the
low cost of the pilot
Sharp Electronics Corporation
Frank Marella
Manager, Corporate
Environmental Affairs
Francis.Marella@sharpusa.com
201-529-9408
May 5, 2004
N/A
No
Sony Electronics, Inc.
Doug Smith
Douglas.Smith@am.sony.com
858-942-2729
N/A
April 28,
2004 (dated
12/12/03 on
draft MOU)
Yes
Pay up to $5,000 for recycling
of Sharp computers from retail
and commercial customers.
MOU did not allow payment for
a % of non-participants share,
but later allowed this based on
the low cost of the pilot.
MOU stipulated monthly
reports on amount and quantity
of Sony product collected and
costs incurred, as well as the
percentage of Sony product
compared to the total product
recovered.
Product Stewardship Institute, Inc.
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Staples Pilot Project –Final Report to U.S. EPA
Appendix D
Appendix D. Staples/PSI Pilot Project Cost Detail
BRAND-SORTED DATA
Table D1. Brand-Sorted Data -- Monitors
Brand
Number Of
Units
Pounds*
% Of Total
465
196
167
94
91
33
10
4
4
2
576
1,642
17,670
7,448
6,346
3,572
3,458
1,254
380
152
152
76
21,888
62,396
28.32%
11.94%
10.17%
5.72%
5.54%
2.01%
0.61%
0.24%
0.24%
0.12%
35.08%
100%
Apple
HP/Compaq
Gateway (NP)
IBM (NP)
Dell
Sony
Panasonic
Brother
Epson
Sharp
Other
TOTAL
% Of Total
Participants
Cost Of Own
Brand**
57.76%
24.35%
$1,860
$784
$3,220
$1,934
$815
$378
$137
$42
$17
$17
$8
$3,348
% Of Total
-
-
11.30%
4.10%
1.24%
0.50%
0.50%
0.25%
$364
$132
$40
$16
$16
$8
-
100%
Cost Of NP
Share
Total Cost
$3,794
$1,599
$742
$269
$82
$33
$33
$16
$6,568
* Average weight for pilot project collection calculated at 38 pounds/unit.
** At project discounted rate of $4.00/monitor.
(NP) Non-Participant
Table D2. Brand-Sorted Data -- CPUs
Brand
Number Of Units
Pounds*
Cost Of Own
Brand**
217
207
145
84
67
7
7
3
0
0
339
1,076
4,991
4,761
3,335
1,932
1,541
161
161
69
0
0
7,797
24,748
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
HP/Compaq
Apple
Gateway (NP)
IBM (NP)
Dell
Sony
Epson
Panasonic
Brother
Sharp
Other
TOTAL
20.17%
19.24%
13.48%
7.81%
6.23%
0.65%
0.65%
0.28%
0.00%
0.00%
31.51%
100.00%
* Average weight for pilot project collection calculated at 23 pounds/unit.
** No charge for CPUs.
(NP) Non-Participant
Product Stewardship Institute, Inc.
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Appendix D
Table D3. Brand-Sorted Data -- Printers/Mfds/Fax/Desktop Copiers/Scanners
Brand
HP/Compaq
Apple
Epson
Panasonic
IBM (NP)
Brother
Sharp
Dell
Sony
Gateway (NP)
Other
TOTAL
Number Of
Units
Pounds*
340
139
130
57
10
9
2
0
0
0
402
1,089
2,761
1,129
1,056
463
81
73
16
0
0
0
3,264
8,843
% Of
Total
Cost Of
Own
Brand**
% Of Total
Participants
Cost Of
NP Share Total Cost
$193.27
$79.03
$73.92
$32.41
1.33%
$5.11
0.29%
$1.12
0.00%
$0
0.00%
$0
100.00%
$384.86
31.22%
12.77%
11.94%
5.24%
0.92%
0.83%
0.18%
0.00%
0.00%
0.00%
36.91%
100.00%
50.22%
20.53%
19.21%
8.42%
$117.59
$48.08
$44.97
$19.72
$3.11
$0.68
$0.00
$0.00
$234.15
$310.86
$127.11
$118.89
$52.13
$8.22
$1.80
$0.00
$0.00
$619.01
* Average weight for pilot project collection calculated at 8.12 pounds/unit.
** At project discounted rate of $0.07/pound.
(NP) Non-Participant
Table D4. Brand-Sorted Data -- Laptops, Small Peripherals & Non Computer Equipment*
Brand
HP/Compaq
Apple
Epson
Gateway (NP)
IBM (NP)
Panasonic
Dell
Sony
Brother
Sharp
Other
TOTAL
Monitors %
of Total
Participants
Large Peripherals % Other Equip Est.
Of Total
% Of Total
Est. Number
Participants
Participants
Of Units
24.35%
57.76%
0.50%
50.22%
20.53%
19.21%
-
1.24%
11.30%
4.10%
0.50%
0.25%
37.29%
39.15%
9.86%
-
8.42%
0.00%
0.00%
1.33%
0.29%
-
100.00%
4.83%
5.65%
2.05%
0.92%
0.27%
100.00%
541
568
143
70
82
30
13
4
-
100.00%
1450
Est.
Pounds
Est. Cost Of
Own Brand
7,099
7,454
1,876
920
1,076
390
174
51
19,041
$496.95
$521.74
$131.35
$64.38
$75.31
$27.32
$12.20
$3.60
$1,332.85
* Envirocycle conducted brand sorts only on monitors, CPUs, and large peripherals. For those equipment types, each brand’s cost
share for non-participants was calculated directly. However, for laptops, small peripherals, and non-computer equipment, PSI
averaged the brand shares for monitors and large peripherals and applied that average percentage to the three other categories in
which no brand sort occurred.
(NP) Non-Participant
Product Stewardship Institute, Inc.
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Appendix E
Appendix E. Project Summary
Pilot Project to Collect and Recycle Used Computers
Using Reverse Distribution Systems:
A Partnership Between Staples and the Product Stewardship Institute
Introduction
Staples, Inc., an $11.6 billion retail and commercial seller of a wide range of office products,
including supplies, technology, furniture, and business services, has partnered with the Product
Stewardship Institute (PSI) to launch a program to measure the success of retail-based
electronics recycling. PSI is a national organization that seeks to reduce the health and
environmental impacts from consumer products.
In this pilot project, Staples will collect and recycle used computers, peripherals and office
equipment from its customers. The project will provide a model for other retailers and will be a
shared responsibility partnership between Staples, its suppliers, manufacturers, and key
program partners. The goal of the pilot is to create a sustainable business model for long-term
electronics collection and recycling.
Pilot Area
PSI will collect data from Staples’ retail and delivery operations. The project will include 26
collections at retail stores in the Dayville, CT distribution network; 24 collections from corporate
customers surrounding the Putnam, CT warehouse; and 24 collections from Internet or catalog
customers serviced by its North Reading or Sharon, MA delivery hub.
Partners
Retail:

Staples, Inc.
Government:

Massachusetts Department of Environmental Protection

Connecticut Department of Environmental Protection

EPA Region 1

Established Staples’ computer suppliers

Other manufacturers (based on returns)

Product Stewardship Institute

WasteCap of Massachusetts

Local and national environmental organizations
Manufacturers:
Organizations:
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Appendix E
Program Description
Project partners will test and measure reverse distribution as a unique strategy for transporting
old computers and other business equipment from consumers to recyclers. Partners will
calculate the real costs of collecting and managing end-of-life electronics through the same
channels that provide new products to consumers. PSI will compile and evaluate data, assess
the potential to expand this program nationwide, and tie these findings into the developing
nationwide collection and recycling system. If reverse distribution proves to be an efficient
system, it could result in significant cost reductions for a national electronics program.
Contributions
Staples will use its labor, transportation equipment, and storage capacity for this pilot project.
Manufacturers that participate in the pilot will be asked to share the costs of transporting used
electronics from consolidation points to the recycler, as well as a share of the recycling costs.
Local and state government agencies in the pilot collection areas will be involved in designing
the project, promoting the collections, and providing technical assistance and regulatory
guidance regarding the handling of collected materials.
Contacts
Mark Buckley
Vice President, Environmental Affairs
Staples, Inc.
500 Staples Drive
Framingham, MA 01702
508-253-0510
mark.buckley@staples.com
Product Stewardship Institute, Inc.
Scott Cassel
Director, Product Stewardship Institute
Kitson Hall, Room 200
One University Avenue
Lowell, MA 01854
(978) 934-4855
scott@productstewardship.us
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Appendix F
Appendix F. Staples Retail Collection List
Staples Store
Address
Phone
MA
Brighton, MA
1660/1670 Soldiers Field Rd.
617-254-4822
Danvers, MA
301 Newbury Street, Danvers Plaza
978-777-9400
Danvers, MA
230 Independence Way, Liberty Tree Mall
978-762-0152
Natick, MA
881 Worcester Road
508-655-0811
Needham, MA
163 Highland Ave.
781-449-5766
Revere, MA
151 VFW Parkway
781-289-8950
Saugus, MA
444 Broadway (Rt 1), Martignetti Center
781-231-6860
Woburn, MA
335 Washington Street
781-932-4132
Bangor, ME
1131 Union St., Airport Mall
207-941-2182
Bangor, ME
180 Bangor Mall Blvd.
207-947-9225
Biddeford, ME
420 A Alfred Rd., 5 Point Shopping Center
207-284-7543
Brunswick, ME
Route 24 - Bath Road
207-725-2741
Falmouth, ME
244B US Route 1
207-781-2255
N. Windham, ME
770 Roosevelt Trail
207-892-1740
Lewiston, ME
855 Lisbon Street
207-753-0742
Rockland, ME
235 Camden St.
207-596-5696
South Portland, ME
443 Western Avenue
207-871-9148
Waterville, ME
40 Waterville Commons Drive
207-873-4092
North Conway, NH
1739 White Mountain Highway
603-356-2666
Portsmouth, NH
1981 Woodbury Ave and Gosling Rd
603-431-3527
Rochester, NH
106 Milton Rd.
603-332-4421
Seabrook, NH
536 Lafayette Road
603-474-8511
Somersworth (Dover), NH
249 Indian Brook Drive
603-750-0078
New London, CT
292 US Rte. 1
860-439-1872
Norwich, CT
45 Salem Turnpike
860-886-8870
Old Saybrook, CT
1000 Boston Post Road
860-395-2980
16 Post Road
401-348-4900
ME
NH
CT
RI
Westerly, RI
Product Stewardship Institute, Inc.
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Appendix G
Appendix G. Criteria for Selection of Retail Stores and Businesses for Pilot
Project
Criteria for Selection of Retail Stores for Pilot Project
Criteria
Application
Population density
Select stores in areas of population concentration (urban) and population
dispersion (suburban/rural) to simulate average population density.
Population in pilot areas will be compared to collection participation to
determine participation/capita.
Electronics retailer density
Select stores in areas where there are several other electronics retailers
and areas where Staples is the only, or predominant, electronics retailer.
This is intended to simulate areas of high and low computer usage.
Availability of existing
electronics collection
programs
Select stores in areas where other electronics collections may have
already addressed a large percentage of historic (outdated, unusable)
computers as well as areas where no collections have been offered.
State CRT management
regulations
Select stores in states where CRTs may be banned from disposal as solid
waste, and states where households and small businesses are allowed to
dispose of CRTs as solid waste.
Distance from store to
distribution center
Select stores at various distances from distribution centers to enable
average costs for transportation to be calculated in the pilot.
Criteria for Selection of Businesses for Pilot Project
Criteria
Application
Variety of business sizes
and sectors
Select business operations relying on multiple computers and those with
only a few computers.
Regulatory status
Select businesses considered “generators” of hazardous or universal
waste and those that are not be regulated as generators.
Availability of existing
electronics collection
programs
Select businesses in areas with electronics collection services and those
with no available collection.
State CRT management
regulations
Select stores in states where CRTs may be banned from disposal as solid
waste, and states where small businesses are allowed to dispose of CRTs
as solid waste.
Distance from store to
fulfillment center
Select businesses at various distances from the fulfillment center to
enable average costs for transportation to be calculated in the pilot.
Product Stewardship Institute, Inc.
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Appendix H
Appendix H. Staples Contract Collection List
Company
Address
City
State
Zip
Rogers Corp
One Technology Drive
Rogers
CT
06263
Barnes
80 Scott Swamp Road
Farmington
CT
06032
Verispan
460 Totten Pond Road
Waltham
MA
02451
Riso, Inc.
380 Boston Street
Topsfield
MA
01983
Mykrolis
Billerica
MA
01821
Boston
MA
02116
Safety Insurance
129 Concord Road
206 Newbury Street 3rd
Floor
20 Customhouse St
Boston
MA
02110
Todd Weld
28 State Street
Boston
MA
02109
Charles River Associates
200 Clarendon Street
Boston
MA
02116
DRS Power and Control
21 South Street
Danbury
MA
06810
Zoots
27 Needham Street
Newton
MA
02461
Texas Instruments
34 Forest Street
Attleboro
MA
02703
Delta Education
80 Northwest Blvd.
Nashua
NH
03063
Freudenerg NOK
450 Pleasant Street
Bristol
NH
03222
Stride Associates
Product Stewardship Institute, Inc.
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Appendix I
Appendix I. Retail and Commercial Electronics Drop-off Forms
Retail Store Electronics Drop-off Form
Date:
/
/ 2005
Staples store location:
Your information:
Zip (required): ______ ___
Name (optional): __________________________
Street(optional):
City (optional):
Telephone (optional): (_____) ____________ E-mail (optional):
Electronics being dropped off for recycling (please list all items):
Manufacturer
(Apple, Brother, Canon, Dell,
Epson, Hewlett Packard,
Intel, Lexmark, Panasonic,
Sharp, Sony, etc.)
Type of Electronics
(Laptop, CPU Desktop, flat panel monitor, CRT monitor,
printer, scanner, mouse, keyboard, speakers, etc.)
Approximate
Age
Quantity
Is this equipment from:  Your home  A business
Was this equipment:  Being used on your desktop  Being stored for recycling or disposal
Would you be willing to pay a nominal $10 fee to recycle your electronics in the future?  Yes  No
How did you hear about this program?  Store flyer  Store display  Other: _______________
For more information about this program, please contact Mark Buckley, VP for
Environmental Affairs, Staples, Inc., (508) 253-0510 or mark.buckley@staples.com
For internal use only: Mail these forms weekly to Betty Pratt, Staples, Inc., 500 Staples Drive, Framingham, MA 01702
Product Stewardship Institute, Inc.
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Staples Pilot Project –Final Report to U.S. EPA
Appendix I
Commercial Electronics Drop-off Form
Date:
/
/ 2005
Staples store location:
Your information:
Business Name: __________________________ Contact Person:
Street(optional):
City:
Telephone: (___)
_________ E-mail:
Zip:
Electronics being dropped off for recycling (please list all items):
Manufacturer
(Apple, Brother, Canon, Dell,
Epson, Hewlett Packard,
Intel, Lexmark, Panasonic,
Sharp, Sony, etc.)
Type of Electronics
(Laptop, CPU Desktop, flat panel monitor, CRT monitor,
printer, scanner, mouse, keyboard, speakers, etc.)
Approximate
Age
Quantity
Is this equipment from:  Your home  A business
Was this equipment:  Being used on your desktop  Being stored for recycling or disposal
Would you be willing to pay a nominal $10 fee to recycle your electronics in the future?  Yes  No
How did you hear about this program?  Store flyer  Store display  Other: _______________
For more information about this program, please contact Mark Buckley, VP for
Environmental Affairs, Staples, Inc., (508) 253-0510 or mark.buckley@staples.com
For internal use only: Mail these forms weekly to Betty Pratt, Staples, Inc., 500 Staples Drive, Framingham, MA 01702
Product Stewardship Institute, Inc.
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Appendix J
Appendix J. Staples Store Communications Package
Store Communications Package
Project Overview
A) Staples is sponsoring a (6) week recycling event in partnership with the US, EPA Plug into e-Cycling Program
and the Product Stewardship Institute to encourage local customers to recycle their computers, monitors and
business machines at their local Staples locations beginning Sunday, May 30 and ending Sunday, July 11th.
Retail, SBD and select SBA customers will also participate in the event. The objectives of this pilot are to:



Help create a solution for our customers to address the mounting global issues surrounding proper
disposal of electronic waste.
Highlight the Staples “makes it east to make a difference”.
Determine whether this model might become a viable part of our business in the future.
Customers will bring back their equipment to the store, fill out a recycling form (see attachment #1) at the
service deck and we will place the equipment into a cardboard Gaylord and collect the recycling form from the
customer. When the Gaylord is full the material will be backhauled to Killingly, CT, consolidated and then
shipped to the recycler (Envirocycle).
B) Product/Limitations:
Recyclable products for this event will be limited to the types of machines, which we sell i.e. CPUs, monitors,
keyboards, mice, printers, scanners, faxes etc.
No TVs, stereo systems etc. We will obviously encourage customers to utilize Staples every day recycling
services for items such as inkjet and toner cartridges, cellular phones, PDAs, chargers and rechargeable
batteries. We also will suggest that we limit recycling to (1) “system” per customer per store per day. Loosely
defined a system would include a CPU, monitor, keyboard, mouse and printer and scanner. Obviously we will
leave quantities up to your discretion. We are trying to avoid local recyclers and others from using the store as
a “dump site” for large quantities of materials and over burden the store. For example, a customer bringing in
(2) units is different than someone trying to bring a “truck load” of computers to the store.
C) Alternative Recycling Options and Contacts:
In the event that a recycler is interested in recycling more than the predetermined limit or more than your store
can handle, please provide the person(s) with the following contact information Mike Tallon, Environcycle
(570) 879-2862 xt 214 and he will assist them in recycling their items through a more appropriate channel.
Please explain that stores are not equipped to receive large numbers of machines due to space and logistical
constraints. Should your customer have any additional questions please do not hesitate to contact Mark
Buckley at (508) 253-0510 or page him at (888) 405-8977.
D) Recycle Process Retail:
Step 1: Recycler enters the store and approaches the recycling area to drop off items.
Step 2: Associate greets customer and provides them with Staples e-cycling form (attachment #1) to gather
basic information.
E) Store Layout and Material Handling:
To collect materials for this event each store participating in the pilot will receive (6) Gaylord’s, that will be
forced out of Killingly the week prior to May 30. These are the same 4x4x4 collapsible containers used to
collect and recycle mixed paper at the store. These can be reordered as a store supply on the AS400 Sku#
492935.
The gaylord’s will be positioned in the cart corral area in the store where carts are normally stored for the 6week event. Please note that the location will vary based on store layout. Please refer to the attached front-end
Product Stewardship Institute, Inc.
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Appendix J
drawings for Heartland Concept, Dover I and Dover II store locations. The collapsible Gaylord should be set up
on a pallet in the designated area and a sign clipped onto the exterior per the sign kit instructions, which you
will receive with the sign packages. For your particular store layout type please refer to attachments 2,3,4 and
5.
When customer return equipment, place the equipment in the Gaylord carefully and place monitors with screens
facing away from each other to avoid glass shattering during transit. Equipment can be co-mingled in the
Gaylord. Please place a layer of old corrugated cardboard between each layer of equipment. Equipment can be
stocked to the top of the Gaylord, but no higher for transit to Killingly and on to the recycler.
Each store will also receive a vinyl banner for the exterior of the store (see attachment #6) and a sign for the
gaylord container (see attachment #7). Stores’ will receive the copy of the bagstuffer (see attachment #8).
F) Logistics:
Stores can send less than two pallet quantities of materials back on their normal backhaul. More than two pallet
quantities must be scheduled through the transportation department.
All recycling forms must be mailed weekly to Betty Pratt, Staples, Inc., 500 Staples Dr., Framingham, MA
01702.
G) Frequently asked questions:
1.
What happens to this equipment?
Staples is working with Envirocycle a certified recycler in Hallstead, PA. Envirocycle initially
assesses equipment to determine if there is any value in refurbishing it or utilizing parts. The
remaining components and equipment is then broken down into their base materials metals, glass and
plastics. This material is then reused in the manufacturing of other products.
2.
Why is recycling electronics so important?
Due to the increased purchase and use of technology items there is a growing global problem
associated with the safe disposal of these materials.
3.
What are the environmental problems associated with improper electronic disposal?
Electronic equipment and their components contain many heavy metals and toxins, which if disposed
of improperly in landfills or incinerated contribute to contamination of water supplies and air. The
effects of these materials can be cumulative in ecosystems. One computer monitor alone contains
between 6-8 lbs of lead.
4.
Where do the recycled materials go? Does any equipment get shipped overseas?
No, Envirocycle maintains a strong chain or custody for these materials and all stay domestically.
5.
Can we donate some equipment to local school or other organizations?
No, for this project Staples needs to maintain very strict control of these materials and we cannot
donate these at this time.
6.
I’d like to recycle more items, how can I do that?
The attractiveness and ease of the event make this a fantastic opportunity to recycle computers,
monitors and other equipment. In order to meet the high demand of recycling products, Staples is
asking that customers limit their recycling activity to one “system” per store per day. Customers are
encouraged to visit multiple stores or return to the same store on different days. The event lasts for (6)
weeks.
7.
Where can I learn more about Staples and its commitment to the environment?
Staples is committed to protecting our natural resources, through focus on environmental stewardship.
Visit www.staples.com/recycle for more information about Staples recycled products, environmental
commitment and mission, plus fun and interesting facts about recycling.
8.
Who should I call if I have more questions?
Mark Buckley (508) 253-0580
Mark.buckley@staples.com
Product Stewardship Institute, Inc.
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Figure 1.
Banner
Figure 2.
Flyer
Product Stewardship Institute, Inc.
Appendix J
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Staples Pilot Project –Final Report to U.S. EPA
Appendix K
Appendix K. Calendar Listing – Promotional Announcement
ATTN: Calendar Editors
Calendar Listing
June 8, 2004
Staples Launches Electronics Recycling Program at 27 New England Store Locations
What:
Staples Electronics Recycling Program
When:
June – July 11 during regular store hours
Where:
27 Staples store locations (see list attached)
Details:
Staples is kicking off an Electronics Recycling Program at 27 New England-area store
locations to provide an easy way to recycle used desktop computers, monitors and business
machines. The [town name] Staples store is participating. Staples is collaborating on the
program with U.S. EPA’s Plug-In To eCycling program and the Product Stewardship Institute
at UMass Lowell.
The recycling program encourages local Staples customers to bring in used equipment to
participating Staples locations today through Sunday, July 11. Recyclable items are computer
hardware and business machines--printers, copiers, scanners, faxes--sold by Staples (no
TVs or radios). Companies supporting the program are: Apple, Brother International
Corporation, Dell, Epson America, HP, Lexmark, Panasonic, Sharp and Sony.
Unused electronics, or e-waste, is among the fastest growing waste streams due to growing
sales and rapid obsolescence of these products. Personal computers can pose significant
environmental and human health threats if improperly disposed. These products often contain
lead and mercury, among other potential health hazards.
Staples will send the collected items to Envirocycle, an electronics recycling company. With
15 years in electronics recycling, Envirocycle is one of the largest recyclers of electronic
equipment and CRT glass. (www.enviroinc.com)
About EPA’s Plug-In To eCycling program:
www.epa.gov/epaoswer/osw/conserve/plugin/
About the Product Stewardship Institute:
http://www.productstewardship.us/
(more)
Product Stewardship Institute, Inc.
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Appendix K
Staples – Electronics Recycling Program
Staples Store
Address
Phone
MA
Brighton, MA
1660/1670 Soldiers Field Rd.
617-254-4822
Burlington, MA
111 Middlesex Turnpike
781-221-4610
Danvers, MA
301 Newbury Street, Danvers Plaza
978-777-9400
Danvers, MA
230 Independence Way, Liberty Tree Mall
978-762-0152
Natick, MA
881 Worcester Road
508-655-0811
Needham, MA
163 Highland Ave.
781-449-5766
Saugus, MA
444 Broadway (Rt 1), Martignetti Center
781-231-6860
Woburn, MA
335 Washington Street
781-932-4132
Bangor, ME
1131 Union St., Airport Mall
207-941-2182
Bangor, ME
180 Bangor Mall Blvd.
207-947-9225
Biddeford, ME
420 A Alfred Rd., 5 Point Shopping Center
207-284-7543
Brunswick, ME
Route 24 - Bath Road
207-725-2741
Falmouth, ME
244B US Route 1
207-781-2255
N. Windham, ME
770 Roosevelt Trail
207-892-1740
Lewiston, ME
855 Lisbon Street
207-753-0742
Rockland, ME
235 Camden St.
207-596-5696
South Portland, ME
443 Western Avenue
207-871-9148
Waterville, ME
40 Waterville Commons Drive
207-873-4092
North Conway, NH
1739 White Mountain Highway
603-356-2666
Portsmouth, NH
1981 Woodbury Ave and Gosling Rd
603-431-3527
Rochester, NH
106 Milton Rd.
603-332-4421
Seabrook, NH
536 Lafayette Road
603-474-8511
Somersworth (Dover), NH
249 Indian Brook Drive
603-750-0078
New London, CT
292 US Rte. 1
860-439-1872
Norwich, CT
45 Salem Turnpike
860-886-8870
Old Saybrook, CT
1000 Boston Post Road
860-395-2980
16 Post Road
401-348-4900
ME
NH
CT
RI
Westerly, RI
Staples Contact: Owen Davis 508-253-8468 owen.davis@staples.com
Product Stewardship Institute, Inc.
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Appendix L
Appendix L. Natick Bulletin & Tab Article on Pilot Project
July 2, 2004
NATICK BULLETIN & TAB
Businesses need to play a recycling role.
By Philip Maddocks
Since June, 27 Staples stores in the Northeast, including the store located on Rte. 9 in Natick, have
allowed customers to discard used computers, computer “peripherals” (such as keyboards, mice, and
speakers), printers, scanners, fax machines, and desktop copiers at the locations during store hours at no
cost.
The used electronics are then transported by Staples to store distribution centers where they are shipped
off to Envirocycle in Hallstead, Pa. The products are dismantled and the materials are sold for reuse in
making new products.
The U.S. Environmental Protection Agency is hoping the Staples program, which runs through July 11,
will help lead to a consolidated electronics disposal program involving the private sector and public
agencies.
The Product Stewardship Institute, located at the University of Massachusetts, Lowell - which is
collaborating on the Staples pilot program along with the EPA’s Plug-In to eCycling program and a
number of electronics manufacturers - argues it is essential to involve manufacturers in the disposal
process because state and local governments have neither the existing collection and recycling
infrastructure, nor the necessary funds to properly manage electronics, which are generally manufactured
with components that contain toxic substances, including lead, mercury, cadmium, lithium, brominated
flame retardants, and phosphorous coatings.
“I think the area of [business] responsibility is emerging as the issue in solid waste management, at least
in the coming decade,” said Scott Cassel, the director of the Product Stewardship Institute or PSI, which
was formed in 1990 as a partnership between the state’s Executive Office of Environmental Affairs and
the University of Massachusetts. “Right now the entire burden is on the state and local agencies to collect,
recycle and dispose all the waste products. There needs to be a shared responsibility for these products. It
only makes sense.”
“Ideally what the state and Product Institute are looking for from the manufacturers is some sort of
financial assistance,” said Greg Cooper, the director for consumer programs at the Massachusetts
Department of Environmental Protection. “I would at least hope in Massachusetts that assistance to
municipalities would be a component of any system.”
Cassel said there are a number of companies within each product sector that have jumped out in front and
recognized that because they are making the products, or because they have a roll in selling the products,
they are playing a role in ultimately introducing the product into the waste stream.
Thus, they should also play a role in taking care that the product is properly disposed of.
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Appendix L
Disposal of electronics is among the top waste concerns for communities and states, said Cassel.
“The toxicity, the proliferation of the products, their built-in obsolescence - there are a number of reasons
why electronics is one of the top issues,” he said, adding that a particular concern is the mercury that is a
component in computers.
While there is agreement that a comprehensive and safe program for collecting old electronics is needed,
Cassel said the issue of who pays for it has been the topic of over two years of discussion through the
National Electronics Product Stewardship Initiative.
At an “electronics dialogue meeting held in Portland, Ore. in February, and that included representatives
from Dell, Epson, Hewlett-Packard, Panasonic, and Sharp, the participants drafted a resolution that
commits electronics manufacturers to develop a sustainable financing system that would relieve the
financial burden from state and local government agencies, though the group was still divided about
which means to follow.
Some companies favor a system that is financed with a visible fee at the point of sale, much like the
current bottle bill.
Other companies want a system that will allow them to incorporate the cost into the price they charge.
According to a PSI newsletter, the current system under consideration features a little of both ideas. The
plan, which would be enacted through federal legislation, would start with an advanced recycling fee for
the first seven years that would be paid into an industry-managed fund. At the end of the seven-year
period, the manufacturers would internalize a significant share of collection, transportation, and recycling
costs.
Some manufacturers, however, want to internalize costs at the start of the program and sell their products
without a fee.
“Right now we’re waiting for the manufacturers to come back with an agreement they can all live with,”
Cassel said. “They have been divided as an industry. The government, I believe, has been flexible.”
The government has also provided some of the motivation for businesses to police themselves. As the
Electronic Industries Alliance, a partnership of electronic and high-tech associations and companies,
states on its Web site, “a growing number of nations and states are considering legislation and regulations,
which would severely impact the ability of the electronics industry to ship and sell its products globally.
The industry’s overall goal is simple: to proactively develop programs to reduce the environmental
impacts of the industry’s manufacturing processes and products throughout their entire life cycle - from
design through use to end of life.”
Staples spokesman Owen Davis said the company’s pilot electronic recycling program is part of Staples’
environmental commitment and its ongoing effort to make product recycling easier for its customers.
Davis pointed out the company already accepts drop-offs of used printer ink cartridges, cell phones,
pagers, and personal digital assistants (frequently referred to as PDAs).
Customers drop the items in a vertical tube located in the stores and Staples sends the devices to
CollectiveGood in Tucker, Ga., where the phones are either refurbished for reuse throughout the
Caribbean, Latin America, Eastern Europe and India or broken down to its parts for recycling.
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Appendix L
Davis said the collection of larger consumer electronics such as computers, printers, and fax machines,
because of the bulk of the equipment, poses more of a challenge for the stores.
“We’re looking for some lessons,” he said of the pilot program. “We’re trying to learn how to best offer
this.”
“We certainly recognize there are a large number of these items that aren’t being used by people,” he
added. “The question is, what do I do with this?
From our experience, people have this type of equipment lying around and are waiting for the day when it
will be easy to recycle.”
Davis said it was still too early to sort out the number of computers and large business machines that had
been turned into Staples stores in the Northeast since the pilot project began in June, he did add, “We are
please so far with the participation.”
Dell Computer, one of the company’s participating in the pilot program run at Staples, also offers
computer recycling through its own business.
Through Dell, consumers can donate their computers to the National Cristina Foundation to help disabled
and economically disadvantaged children and adults in your own community. The foundation will pick up
your computer at the customer’s residence.
The company will also pick up any brand of computer or computer peripheral.
The cost is $15 per 50 pounds. Since a personal computer generally weighs about 30 pounds, according to
Dell, and a computer monitor weighs 42lb, the total cost of having a computer and monitor picked up by
Dell for recycling would cost $30.
The town of Natick considers computers and computer monitors bulky waste.
The town will pickup bulky waste items two Saturdays a month for a minimum of $25 each. Payment in
either cash or check for the appropriate quoted amount must be mailed or delivered to the Department of
Public Works on or prior to the Thursday before the Saturday pickup. Pickup dates for each month are
available by calling the Department of Public Works or the Sanitation Division.
Dell has also taken measures in the manufacture of its computers that it claims are environmentally
beneficial.
In its Dell Sustainability Report 2004, the company states that the energy-saving component in its
OptiPlex GX270 and SX270 systems alone “is estimated to reduce carbon dioxide emissions by over
700,000 tons per year.
The company also states in the report that the more expensive, space-saving flat-screen monitors that
employ a cold cathode fluorescent lamp to illuminate the display panel, and which many customers are
trading up to, are considerably more environmentally-friendly that the cathode ray tube monitors.
According to the report, the flat-screen monitors contain “only a few grams of lead in the solder” and use
about 54 percent less energy than CRT monitors.
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Dell’s plans for the future include shrinking the size of its desktop computers. Last year the company
launched what it calls its “Ultra Small Form Factor” chassis, which, at approximately 10 x 10 x 31/2
inches, has about 20 percent of the volume of the typical mini-tower design.
It’s goal for the end of the year is to make desktop computer, portable computer, and server chassis plastic
parts that are “free of halogenated flame retardants.”
Cassel said while the concept of product makers taking a role in the ultimate disposal or recycling of the
goods they make is not that new, the term product stewardship has only taken hold in the last four years
or so.
He thinks it signifies a change in attitude among business leaders.
“We need to do things differently, in a much clearer fashion,” he said.
“There is an understanding that manufacturers, state, and local agencies need to share the responsibility.
Many are stepping up to the plate, like Staples.”
Cassel said it was Staples that initiated the idea for the current pilot program it is running at their
Northeast stores and it should offer valuable lessons about what Cassel refers to as a reverse distribution
system.
As for product stewardship, he says, “Many companies are catching on that this a new trend that will
last.”
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Appendix M
Appendix M. Reviewing Electronics Recyclers
--- DOCUMENT FOR STAPLES, INC. --Company:
Company representative(s):
Who interviewed:
Date: ________________________________
A. GENERAL COMPANY INFORMATION
1. What kind of company are they?
 Broker - Brokers are companies that arrange for the electronics recycling
services. If you use a broker, you must document all the downstream
facilities that handle the equipment. Remember that a “Certificate of
Recycling”provides no assurance that materials are being safely handled.
 Reseller - Resellers triage to sort out saleable units from scrap, to erase hard
drives, and to prepare equipment for resale. Many resellers are not
interested in processing scrap for recycling and ship all non-saleable scrap
to processors or brokers. The environmental audit process must continue
downstream to determine how the scrap is being managed.
 Demanufacturers – These facilities usually sort commodities and
hazardous components using disassembly. Shredding systems might only
reduce volume for transportation efficiencies or may include systems to
separate different types of metallic and nonmetallic materials. Unless the
recycler also processes batteries, mercury, leaded glass and all other
hazardous materials, the audit process must still be continued downstream.
2. Can they give a general description of their business?
This type of information may include:
 Point of contact
 Number of employees
 Years in business and ownership history
 Facility site information and history
 Summary of operations and services offered
A qualifications statement would be an adequate alternative to requesting
individual types of information.
3. Do they process non-saleable equipment and components by breaking
down or shredding? If not:
Yes 
No 
Yes 
No 
Yes 
No 
Yes 
No 
Yes 
No 
 Are whole components outsourced or exported? If so, where are the
markets for the electronic equipment?
 What process does the downstream vendor employ?
 Has the company done due diligence and can provide
documentation on downstream facilities?
 Are permits required?
 How are residuals managed? _______________________________
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4.
Appendix M
What type of products do they accept?
(Later we need them to provide pricing for each type of equipment. We should specify if we want
fees quoted on a per pound or per product basis.)
Computers and peripherals
Telephones, communications
 Monitors
 Conference phones
 Desktop CPUs
 Corded phones
 LCD displays – laptops
 Cordless phones
 Notebook computers
 Answering machines
 CD drives
 Pagers
 Hard drives
Miscellaneous
 Zip drives
 Pocket PCs
 Cables (computers, etc.)
 Data cartridges
 DVD drives
 Battery back-ups/UPS
 Floppy drives
 PC and digital cameras
 Printers
 Digital pens
 Speakers
 Joysticks
Other office equipment
 Game pads
 Faxes
 Remotes
 Multifunction machines
 PC cameras
 Scanners
 Copiers
 Projectors/AV equipment
5. What services do they provide?
 Brand sorting
 Sort equipment for reuse to non-profit
 Hard drive erasure/data destruction
 Product tracking through final fate of materials
 Other? __________________________________
B. COMPLIANCE WITH FEDERAL, STATE, AND LOCAL ENVIRONMENTAL LAWS TO
SAFEGUARD OCCUPATIONAL AND ENVIRONMENTAL HEALTH AND SAFETY.
1. Does the company have an EPA ID number?
Yes 
No 
An EPA ID number only indicates that the company has registered with
EPA as a waste generator. It is not a permit or a certification and EPA does
not certify or approve electronics recyclers.
2. Can they provide information on the company’s compliance history?
Yes 
No 
This type of information is available from the state regulatory agency or the
federal EPA regional contact for RCRA compliance. Examples may
include:
 Summary of federal, state EPA, or other governmental agency
inquiries and enforcement actions during the past three years.
 Material reports to government agencies from the past three years
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Yes 
No 
Yes 
No 
An EMS system or certification is not a guarantee of high environmental
standards, but should be in place in all larger companies.
 ISO 14000
 EMAS (European Eco-Management and Audit Scheme)
 IAER (International Association of Electronic Recyclers)
 Recyclers Pledge of True Stewardship
 Other?________________________________
5. Do they have a hazardous materials management plan?
Yes 
No 
A service provider should have an operating plan in place that will ensure
that all hazardous constituents are managed and ultimately recycled in a
manner that prevents releases of hazardous constituents into the
environment.
6. Do they meet OSHA requirements?
Yes 
No 
OSHA requirements will vary between facilities. Check all for they
provided evidence:
 List of applicable OSHA mandates
 Summary of OSHA inquiries for past 3 years including health
hazard evaluations
 Full OSHA citation history
 Training records and written programs required by OSHA standards
7. Is there a trained Environment Heath and Safety supervisor on site?
Yes 
No 
3. Can they offer evidence of proper permits?
These permits may be environmental or business/operations oriented.
Permit requirements vary state to state. The size and scope of the service
provider will affect permit requirements as well. Permits might include:
 Air permit
 Storm water permit
 Solid Waste permit
 Business permit
 Zoning permit
 Transportation/licensure
4. Can they provide evidence of an environmental management system
(EMS), an environmental risk management plan or electronic recycling
certification?
A trained EHS supervisor will often perform informal and formal
inspections, procure needed safety equipment, and address EHS reporting
requirements. A smaller company may not have a supervisor on site, but
should have an employee assigned to this task.
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Appendix M
C. DOCUMENTATION REGARDING END-USE MARKETS.
Yes 
No 
Yes 
No 
Yes 
No 
5. If donated, can they supply you with documentation so that you can
apply it towards your federal tax return?
Yes 
No 
6. Can they provide a complete inventory of equipment sent to be recycled,
including property tags? Do they provide a certificate indicating when
material was received and how it was processed?
Yes 
No 
1. Can the company provide a detailed description of its processes?






Demanufacturing
Reuse/Resale/Donations
Storage
Secure destruction
Send materials to a metals reclamation plant or smelter
Process the plastic, metal and glass and ship these to other
companies for use in production of recycled products
 Products manufactured
2. Does the company have a complete list of end-markets for materials?
The company should be able to state where it sends commodity materials or
product streams including:
 CRTs
 Plastics
 Metals (steel, aluminum, copper)
 Circuit Boards
 Hazardous materials
 Solid waste materials
3. Do they audit their end-markets?
Smaller recyclers may not have the ability to perform an on-site audit of its
end markets. However, all recyclers should be able to evidence some level
of information regarding the capacity of its markets. In general, the facility
should be maintaining records or documentation showing that materials are
being properly managed.
4. How much of equipment received do they send for disposal in landfills
or for incineration?
Electronic products contain hazardous constituents. Television and computer
CRTs have significant amounts of lead, chromium, nickel and zinc. Printed
circuit boards contain small amounts of cadmium, nickel and other heavy
metals.
This information is important for tax records and for any potential liability
claims.
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Appendix M
Yes 
No 
Yes 
No 
1. Do they have environmental liability protection?
Yes 
No 
They should be able to provide a schedule or copy of its insurance policy
and indicate the amount of insurance coverage.
2. Do they have General Liability Insurance? How much coverage?
Yes 
No 
3. Do they have other types of insurance?
Yes 
No 
They should be able to provide a schedule or copy of the insurance policy
and indicate the amount of insurance coverage.
4. Do they have financial assurance e.g. bonding?
Yes 
No 
7. Do they export or broker for export used equipment? If so, can they
provide evidence that they are in compliance with notice and consent
procedures specified under international laws and bilateral agreements?
Countries that are part of the Organization for Economic Cooperation and
Development (OECD, www.oecd.org) have agreed to control exports and to
protect from the indiscriminate and uncontrolled traffic in hazardous wastes
that are exported to developing countries. These controls dictate high
standards for environmental management that involve costs that must be
passed along to customers. Some U.S. companies export scrap material to
less-developed countries, where lower labor costs contribute to lower
processing costs. However, the receiving country may also have less
protective environmental standards. Companies that export should at least
export only to OECD countries or comply with OECD laws and agreements
for the export of hazardous materials found in electronics.
D. OTHER STAPLES CONCERNS
1. Is the company willing to adapt its processes to accommodate Staples
concerns?
Examples of concerns include:
 Greater emphasis on reuse – equipment sent to World Computer
Exchange or other designated recipient (Staples should designate
whether low cost or no cost)
 No exporting – directly or indirectly through downstream markets - to less-developed countries
 No use of prison labor
E. RISK MANAGEMENT
They should be able to provide a schedule or copy of the insurance policy
and indicate the amount of insurance coverage.
Depending on the size and scope of the company, this question may not be
applicable to all recovery facilities
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Appendix M
F. DISCLOSURE VERIFICATION
1. Can they verify that their responses to your questions are
accurate through an independent verification process or through
documentation?
Yes 
No 
G. CONDUCTING THE SITE AUDIT
Ask to see the shipping docks and containers. This may require a walk around the outside of the
facility where shipping containers are stored. Check trash containers to see if any scrap
electronic components are being sent to landfill.
Look for shipping containers designed for export. These look quite different from a typical road
trailer in that they are entirely made of steel and sit on a flatbed trailer. Overseas shipping
containers have doors that seal tightly with a rubber gasket, and it is apparent that the container is
detachable from the trailer.
Within the facility look for indications of how outbound material is shipped. If you see only
baled or unprocessed scrap, it is likely that it is being exported to developing countries. Recovery
of material prepared this way would not be economical in most OECD countries.
Ask the recycler how many pounds of electronics are processed on a monthly basis. Then ask to
see documentation showing resale activities and scrap shipments for the previous month, which
should approximate that amount. If documentation falls short, you are not getting the whole
picture. Moreover, outbound documentation helps to determine if more downstream research is
required.
Watch out for recyclers that claim to be “EPA Permitted” or “EPA Certified.” The EPA has no
permitting or certification process for electronics recyclers. Many times when these recyclers are
asked for copies of their “EPA Permit” or “Certification” they offer a copy of an EPA ID
number. This typically begins with three letters, including the state initials (PAD, for example,
might be the beginning of an EPA ID number for a Pennsylvania company), followed by nine
numbers. This is merely an EPA-issued number that is required for manifesting hazardous waste
for shipment. Anyone who generates hazardous waste must have one to transport material for
disposal. It is not a permit to recycle electronics.
Be wary of state permits. Some states do provide electronics recyclers with state operating
permits but this does not necessarily mean the company is complying with any standards. In
some states the regulatory agency provides permits to electronics recyclers, but the qualification
process is limited.
Understand that a Certificate of Recycling is only the recycler’s own certification of, typically,
the total weight of material received on a particular date and confirmation that it was processed
“in accordance with all state and federal regulations.” For record-keeping purposes, it is good to
have a Certificate of Recycling for each shipment that a generator sends to be recycled; but,
remember, this is a highly unregulated industry, and you should conduct your own due diligence.
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Appendix M
While the auditing process may appear to be complicated, doing some investigative work upfront
when selecting your recycler can help to streamline the process and provide you with the
assurance that you’ve selected the proper company.
The following are some guidelines to consider:
1. Do the background. Develop a short list of pre-qualified recyclers. State environmental
agencies may be able to provide a list of e-recyclers serving your state but that does not
mean they are endorsed by the state.
2. Ask questions and expect adequate answers.
3. Audit the facilities: It is impossible to conduct due diligence without physical and
detailed facility audits.
4. Follow the materials trail and get all of the required downstream information.
5. Ask for references and follow up with contacting references to ensure that others have
been satisfied with the company services.
RESOURCES:
Computer TakeBack Campaign. “Recyclers Pledge of True Stewardship.” 2003
National Electronics Product Stewardship Initiative (NEPSI). “Due Diligence Guidance
For Selection of Electronics Reuse and Recycling Services,” draft document. 2003
Roman, Lauren, S. “Environmental Challenge 2003: How to Audit an Electronics Recycler.”
Roman is Vice President of Marketing for United Recycling Industries, Inc.
Lroman@unitedrecycling.com or 973-584-8859
Roman, Lauren, S. “Electronic Recycling Vendor Selection Process,” PowerPoint presentation.
State of Wisconsin. “Wisconsin Electronic Recycling Disclosure Checklist”
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Appendix N
Appendix N. Checklist For Electronics Recyclers
--- FOR STAPLES, INC. --Company:
Address, Phone, Email, www:
Contact Person and Position:
Date: ________________________________
A. GENERAL COMPANY INFORMATION
1. What kind of company is yours?
 Broker
 Reseller
 Demanufacturer
2. Please provide a general description of the business, including:
 Point of contact
 Number of employees
 Years in business and ownership history
 Facility site information and history
 Qualifications statement
3. Does your company process non-saleable equipment and components by
breaking down or shredding? If not:
Yes 
No 
Are whole components outsourced or exported? If so, where are the
markets for the electronic equipment?
Yes 
No 
What processes are employed by downstream vendors?
Yes 
No 
Have you done due diligence and can you provide documentation on
downstream facilities?
Yes 
No 
Are downstream facilities permitted?
Yes 
No 
How are residuals managed in downstream facilities?
Yes 
No 
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Appendix N
4.What type of products do you accept?
(Later we need pricing information. Do you provide quotes based on a per pound, per product, or other
basis?)
Computers and peripherals
Telephones, communications
 Monitors
 Conference phones
 Desktop CPUs
 Corded phones
 LCD displays – laptops
 Cordless phones
 Notebook computers
 Answering machines
 CD drives
 Pagers
 Hard drives
Miscellaneous
 Zip drives
 Pocket PCs
 Cables (computers, etc.)
 Data cartridges
 DVD drives
 Battery back-ups/UPS
 Floppy drives
 PC and digital cameras
 Printers
 Digital pens
 Speakers
 Joysticks
Other office equipment
 Game pads
 Faxes
 Remotes
 Multifunction machines
 PC cameras
 Scanners
 Copiers
 Projectors/AV equipment
5. What services does your company provide?





Brand sorting
Sort equipment for reuse to non-profit
Hard drive erasure/data destruction
Product tracking through final fate of materials
Other? __________________________________
6. Please provide references, including the most recent and related clients that you have
provided services for.
(List below or attach references.)
B. COMPLIANCE WITH FEDERAL, STATE, AND LOCAL ENVIRONMENTAL LAWS TO
SAFEGUARD OCCUPATIONAL AND ENVIRONMENTAL HEALTH AND SAFETY.
1. Does your company have an EPA ID number?
Yes 
No 
Yes 
No 
#_____________________________________________
2. Please provide information on the company’s compliance history:
Examples may include:
 Summary of federal, state EPA, or other governmental agency
inquiries and enforcement actions during the past three years.
 Material reports to government agencies from the past three years
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Appendix N
3. Please provide evidence of necessary permits:
 Air permit
 Storm water permit
 Solid Waste permit
 Business permit
 Zoning permit
 Transportation/licensure
4. Please provide evidence of an environmental management system (EMS) or an environmental
risk management plan.
5. Is your company a certified recycler? If so, check all that apply:
Yes 
No 
 ISO 14000
 EMAS (European Eco-Management and Audit Scheme)
 IAER (International Association of Electronic Recyclers)
 Recyclers Pledge of True Stewardship
 Other?________________________________
6. Does your company have a hazardous materials management plan?
Yes 
No 
7. Please provide evidence that your company meets OSHA requirements, including:
 List of applicable OSHA mandates
 Summary of OSHA inquiries for past 3 years including health hazard evaluations
 Full OSHA citation history
 Training records and written programs required by OSHA standards
Is there a trained Environment Heath and Safety supervisor on site?
Yes 
No 
C. DOCUMENTATION REGARDING END-USE MARKETS.
1. Please provide a detailed description of your company’s
processes:






Demanufacturing
Reuse/Resale/Donations
Storage
Secure destruction
Send materials to a metals reclamation plant or smelter
Process the plastic, metal and glass and ship these to other
companies for use in production of recycled 
 Products manufactured
2. Please provide a complete list of end-markets for materials.
Yes 
3. Does your company audit the end-markets?
No 
If not, how do you ensure environmental and worker protection?
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Appendix N
4. How much (and what type) of equipment or components received does your company
send for disposal in landfills or for incineration?
________________________
Yes 
No 
5. For equipment that is reused, is your company able to supply
Staples with documentation to apply towards the federal tax
return?
Yes 
No 
6. Can your company provide a complete inventory of equipment
that is sent to be recycled, including property tags? Do you
provide a certificate indicating when material was received and
how it was processed?
Yes 
No 
7. Does your company export or (broker for export) used
electronics equipment? If so, please provide evidence that your
export policies are in compliance with notice and consent
procedures specified under international laws and bilateral
agreements.
D. OTHER STAPLES CONCERNS
1. Is your company willing to adapt your processes to accommodate
Staples concerns?
Examples of concerns include:
 Equipment sent to World Computer Exchange or other designated
recipient
 No exporting of non-usable equipment or hazardous components -either directly or indirectly through downstream markets -- to lessdeveloped countries
 No use of prison labor
Yes 
No 
Yes 
No 
Yes 
No 
Yes 
No 
Yes 
No 
Yes 
No 
E. RISK MANAGEMENT
1. Does your company have environmental liability protection?
Please provide a schedule or copy of the insurance policy and indicate the
amount of insurance coverage.
2. Do you have General Liability Insurance?
Please provide a schedule or copy of the insurance policy and indicate the
amount of insurance coverage.
3. Do you have other types of insurance?
Please provide a schedule or copy of the insurance policy and indicate the
amount of insurance coverage.
4. Does your company have financial assurance (e.g., bonding)?
F. DISCLOSURE VERIFICATION
1. Please verify that your responses are accurate through an independent
verification process or through documentation?
Product Stewardship Institute, Inc.
- N4 -
FINAL June, 2005
Staples Pilot Project –Final Report to U.S. EPA
Appendix O
Appendix O. Reuse Organizations In The Northeast
Several organizations in the U.S. direct working computers to schools and needy non-profit
organizations. The following are a few of the reuse organizations in the northeast.
Share the Technology
PO Box 548
Rancocas, NJ 08073
recycle@sharetechnology.org
http://www.sharetechnology.org/
Cambridge (MA) Computer Donation Program
Kate Russell Walsh
Cambridge Chamber of Commerce
(617) 8764134
Email: Kate Russell Walsh
Mindshare Collaborative
Charles Thompson
P.O. BOX 35389
Brighton, MA 02135
(617) 787-7870
cmt@world.std.com
TecsChange-Technology For Social Change
1151 Massachusetts Avenue
Cambridge, MA 02138
617-783-1668
tecschange@tecschange.org
Virtually Wired Educational Foundation
Coralee Whitcomb
55 Temple Place
Boston, MA 02111
(617)542.5555
info@vw.org
National Cristina Foundation
(203) 863-9100
http://www.cristina.org/
Product Stewardship Institute, Inc.
- O1 -
FINAL June, 2005
Staples Pilot Project –Final Report to U.S. EPA
Appendix P
Appendix P. Retail Equipment Collection Survey Data
Retail Customer Equipment Collection
Survey Data
Table P1. Equipment Type Collected By Store And By Brand
Store
CPU
Monitor
#1-Brighton, MA
APPLE
ATARI
COMPAQ
MAC
1
1
1
5
Totals Store #1
8
#2-Woburn, MA
ACER
ADVANCE
APPLE
AST
AT&T
CLONE
COMP USA
COMPAQ
DEC
DELL
Digital
DYNAMICS
ELITE
EMACHINE
GATEWAY
HP
IBM
INTEL
MAC
MAC II
Micron
MISC
NEC
NPC
PACKARD BELL
POWERSPEC
PROTEVA
SONY
1
1
9
1
1
1
1
11
2
4
3
1
1
1
2
5
6
1
1
2
3
5
2
2
2
3
1
3
Totals Store #2
76
Product Stewardship Institute, Inc.
APPLE
COMPAQ
EMC
GATEWAY
MAC
MICS
MISC
SAMSUNG
Laptop
3
1
2
1
2
1
1
1
APPLE
12
ACER
ADC
AOC
Apple
AST
COMP USA
COMPAQ
COMPUADD
COMPUTINE
CORDATA
CTX
DEC
DELL
DIGIVIEW
EVEREX
GATEWAY
GOLDSTAR
HP
IBM
IMPRESSION
INTEL
LINK
MAC
MAG INOVISION
MAGNAVOX
MISC
NAP
NCR
NEC
NPC
Packard Bell
PCPC
PENTENIUM
PHILLIPS
PRINCETON
PROTEVA
PROVIEW
RIC
SAMPO
SAMSUNG
SONY
SUNSHINE
SUPER MAC
VIEW SONIC
WANG
WIT
ZENITH
2
1
1
12
1
1
5
1
1
1
1
2
5
1
1
3
1
9
4
1
1
3
1
1
2
3
1
1
4
1
2
1
1
1
2
1
1
1
1
1
5
1
1
4
1
1
1
98
- P1 -
Peripherals
1
1
HP
NEC
MISC
5
1
1
1
3
44
FINAL June, 2005
Staples Pilot Project –Final Report to U.S. EPA
Appendix P
Equipment Type Collected By Store And By Brand (continued)
Store
CPU
Monitor
#8 - Natick, MA
ACER
AMIGA
APPLE
AST
COMLINK
COMMODORE
COMPAQ
CREATIVE
DELL
DIGITAL
DTK
ELITE
EMACHINES
ESCAPE SYS
EXIDY
GATEWAY
HP
IBM
IDENTITY
IGENERIC
KLM
LEADING EDGE
MAC
MIB
MICRON
MISC
NPC
NSTAR
PACKARD BELL
PC BY MR. Z
PC WAREHOUSE
POWER SPEC
SMITH CORONA
STAR
SYQUEST
TANDY
TAVACIN
TC COMPUTER
TRI GEM
UNIRON
WANG
3
1
23
2
1
2
15
1
15
4
2
1
1
1
1
14
15
12
1
2
1
1
3
1
1
16
1
1
7
2
1
1
1
2
1
3
1
2
1
1
1
Totals Store #8
166
#51- Saugus
ACER
APPLE
COMPAQ
DELL
DIGITAL
HP
IBM
KIER
MB CORP
MICRO EXPRES
MISC
PACKARD BELL
PENTIUM
SRB
VIP CORP
2
3
9
4
2
5
6
2
1
1
9
2
1
2
1
Totals Store #51
50
Product Stewardship Institute, Inc.
ACER
AMIGA
APPLE
AST
AT & T
COMMODORE
COMPAQ
CRYSTAL SCAN
CTX
CYBERVISION
DELL
DIGITAL
DTK
EAGLE
EMERSON
GATEWAY
GOLDSTAR
HP
IBM
KFC
KLM
MAC
MICRON
MISC
MULTISCAN
NCR
NEC
NPC
OKIDATA
ORCHISTRA
Packard Bell
PGS
PHILIPS
PRINCETON
SAMPO
SAMSUNG
SCEPTRE
SONY
STAR
TANDY
TRI GEM
US LOGIC
VGA
VICTOR
VIEW SONIC
VISUAL SENSATION
ACER
APPLE
COMP U DYNE
COMPAQ
CTX
DELL
GATEWAY
HITACHI
HP
IBM
KDS
MISC
PANASONIC
PRINCETON
SONY
Laptop
7
1
24
1
1
2
11
1
5
1
13
1
1
1
1
8
1
18
9
2
1
4
1
17
1
1
3
1
1
1
7
1
1
1
2
4
2
1
3
3
1
1
1
1
4
1
174
APPLE
ARCHE
COMPAQ
DELL
IBM
LAPNOTE
MISC
NEC
SHARP
SONY
TOSHIBA
ZENITH
1
14
2
10
1
13
13
2
8
7
1
1
1
1
2
APPLE
77
- P2 -
Peripherals
4
1
2
1
4
1
1
1
1
1
2
1
20
354
2
2
57
FINAL June, 2005
Staples Pilot Project –Final Report to U.S. EPA
Appendix P
Equipment Type Collected By Store And By Brand (continued)
Store
CPU
Monitor
#108-South Portland, ME
APPLE
AST
ASTI
AT&T
CHERRYTOWN
COMPAQ
COMPUADD
CSM
DELL
DIGITAL
EMACHINES
EPSON
FAST DANA
GATEWAY
GORHAM MICRO
HP
IBM
INTEL
MICRON
MISC
NEC
PACKARD BELL
TANDY
UNISYS
US TECH
14
1
1
2
1
18
1
1
2
1
2
1
1
16
1
13
11
1
3
15
3
6
1
1
1
Totals Store #108
118
#167-Danvers, MA
APPLE
AST
COMPAQ
DELL
EPSON
GATEWAY
HP
MISC
IBM
Micron
NCP
NCR
NPC
PACKARD BELL
ROYAL
ZEOS
MAC
ADM
PERFECT SYSTEM
SONY
NORTGAR
16
1
11
11
1
2
6
9
11
1
1
1
2
5
1
1
1
3
1
1
1
Product Stewardship Institute, Inc.
ACTRONICS
ADDONICS
APPLE
AST
AT&T
BROTHER
BSR
COMPAQ
CTX
CTX
CYBERVISION
DEC
DELL
EMC
ENVISION
EPSON
GATEWAY
HPS
HYUNDAI
IBM
KENSIKO
MAG INOVISION
MAGNAVOX
MEGA IMAGE
MICRON
MISC
NEC
OPQUES
Packard Bell
PRINCETON
PROMOTHERS
PROVIEW
SONY
SUPERCOM
SVE
TANDY
UNISYS
VISION
YAMA
ACER
AOG
APEX
APPLE
AST
AST
COMPAQ
Compudine
CPX
CTX
DELL
EVEREX
GATEWAY
HEADSTART
HP
IBM
LEADING
MAG 21
MICRON
MISC
NCP
NCR
NEC
PACKARD BELL
PRINCETON
ROYAL
SANYO
- P3 -
Laptop
1
1
11
1
1
1
1
16
1
1
1
1
2
1
1
1
13
8
1
4
1
1
1
2
1
15
4
1
5
1
1
1
1
1
1
1
1
1
1
109
APPLE
TOSHIBA
NEC
COMPAQ
QUANTEX
GATEWAY
1
1
2
17
1
1
10
1
1
1
8
1
4
1
3
10
1
1
1
8
1
1
2
3
1
1
1
COMPAQ
ZENITH
Peripherals
5
1
3
1
1
1
12
270
2
1
FINAL June, 2005
Staples Pilot Project –Final Report to U.S. EPA
Appendix P
Equipment Type Collected By Store And By Brand (continued)
Store
CPU
Monitor
#167-Danvers, MA
APPLE
AST
COMPAQ
DELL
EPSON
GATEWAY
HP
MISC
IBM
Micron
NCP
NCR
NPC
PACKARD BELL
ROYAL
ZEOS
MAC
ADM
PERFECT SYSTEM
SONY
NORTGAR
16
1
11
11
1
2
6
9
11
1
1
1
2
5
1
1
1
3
1
1
1
Totals Store #167
87
#176-Portsmouth, NH
ACER
AMIGA
APPLE
ASSEMBLED
CUSTOM
DELL
DIGITAL
HONEYWELL
HP
MAC
MICRON
NA
PACKARD BELL
XEROX
Totals Store #176
Product Stewardship Institute, Inc.
ACER
AOG
APEX
APPLE
AST
AST
COMPAQ
Compudine
CPX
CTX
DELL
EVEREX
GATEWAY
HEADSTART
HP
IBM
LEADING
MAG 21
MICRON
MISC
NCP
NCR
NEC
PACKARD BELL
PRINCETON
ROYAL
SANYO
SONY
SUPER VEGA
TANDY
TECHMEDIA
US LOGIC
VIEWSONIC
Laptop
1
1
2
17
1
1
10
1
1
1
8
1
4
1
3
10
1
1
1
8
1
1
2
3
1
1
1
5
1
2
1
1
3
COMPAQ
ZENITH
97
1
1
7
1
2
5
1
2
2
1
1
1
1
1
ACER
AMIGA
APPLE
CTX
HONEYWELL
HP
IBM
KDS
MAC
Mag Inovision
MGC
MISC
Occidental
Packard Bell
PSI
Quantex
Signature
Sony
27
- P4 -
2
1
3
2
1
7
1
1
4
1
1
1
1
1
2
1
4
1
1
1
1
32
Peripherals
APPLE
COMPAQ
DELL
HP
TOSHIBA
ZENITH
101
3
2
1
1
1
1
9
58
FINAL June, 2005
Staples Pilot Project –Final Report to U.S. EPA
Appendix P
Equipment Type Collected By Store And By Brand (continued)
Store
CPU
Monitor
#194-Bangor, ME
ACER
AMPTEC
APPLE
ATA
BTO
COMPAQ
COMPUADD
COMTRADE
DATASHIELD
DELL
DOS
EVEREX
GATEWAY
HP
IBM
IBM
KDS
KLH
KOMODO
LASER
LEADING EDGE
MCINTOSH
MICRON
MIDWEST MICRO
MISC
NAMCO
NEC
PACKARD BELL
PANASONIC
PREMIO
PROFESSIONAL PC
QUANTEX
RADIO SHACK
SWAN
TANDY
TELEVIDEO
TIGER
TOSHIBA
ULTRA
WANG
ZEOS
1
1
23
1
2
6
1
1
2
5
1
15
9
4
1
6
1
1
1
1
2
2
1
2
9
1
1
7
4
1
1
1
1
1
1
1
1
1
1
1
2
Totals Store #194
125
Product Stewardship Institute, Inc.
ACER
ADI
AOL SPECTRUM
APPLE
ARCUS
AS
AT & T
BTC
COMPAQ
COMPUADD
CTX
DAYTEK
DELL
DELL
DESKTOP DISPLAY
DIGITAL
EVEREX
GATEWAYS
GOLDSTAR
GRID 800
HANSON
HITACHI
HP
IBM
ICM
KDS
KFC
KLH
LEADING EDGE
MACINTOSH
MAG VISION
MICRON
MIDWEST MICRO
MIRROR
MISC
MITAC
NEC
ORCHESTRA
PACKARD BELL
PANASONIC
PIXIE
PRINCETON
QUANTEX
RADIO SHACK
RELYSIS
ROYAL
SAMSUNG
SMITH CORONA
SONY
STANDARD TECH
SWAN
TANDY
TELEX
TRADEMARK
ULTRA SONIC
VIEWSONIC
YAMA
Laptop
2
1
2
24
1
1
1
1
7
2
1
1
1
7
1
2
1
14
1
1
1
1
3
11
1
1
1
2
1
3
1
1
1
1
4
1
3
1
8
2
1
2
1
1
1
1
2
1
3
1
1
2
1
1
1
2
1
143
- P5 -
ZENITH
Peripherals
1
1
185
FINAL June, 2005
Staples Pilot Project –Final Report to U.S. EPA
Appendix P
Equipment Type Collected By Store And By Brand (continued)
Store
CPU
Monitor
#200-Needham, MA
APPLE
COMPAQ
DELL
GATEWAY
HP
MISC
MOTOROLA
NA
NPC
PCCLONE
ZENITH
8
3
4
2
4
13
1
1
2
1
1
Totals Store #200
40
#297-Brunswick, ME
ACER
ACROS
APPLE
CLONE
COMMODOR
COMPAQ
CRYSDALIEN
DELL
DIGITAL
ELITE
GATEWAY
HP
IBM
KEYPRO
LASER
LEADING EDGE
MAC
MAGITRONIC
MARKET TEK
MICRON
MIDWEST MICRO
MISC
NORTHGATE
PACKARD BELL
PC CLONE
PERFORMA
PIOPNEX
PREMIO
SEAGATE
SYSTEM RESOURCES
TANDY
TIGER
ULTRA
VALUE LINE
1
1
32
1
1
4
1
6
1
1
15
19
3
1
1
3
5
1
1
1
1
26
2
1
1
1
1
1
1
4
4
4
2
7
Totals Store #297
155
Product Stewardship Institute, Inc.
AOC
APPLE
AT&T
COMPAQ
COMTERM
DELL
GATEWAY
HP
IBM
MISC
NEC
PACKARD BELL
PRINCETON
PRO COMPUTING
SAMSUNG
TATUNG
VISION GRAPHICS
ZENITH
ACER
ACROS
AMDEK
APPLE
BROTHER
CHAMPION
COMPAQ
CSX
CTX
DATA GENERAL
DELL
DIGITAL
ELITE
GATEWAY
HITACHI
HP
IBM
IMTEC
KEYPRO
KOREA DATA SYS
LASER
LEADING EDGE
LIKOM
LINK
MAC
MAGNITRONIC
MAGNOVOX
MEMOREX
MIAC
MICRON
MISC
MITSUBISHI
NEC
OPTIQUEST
ORCHESTRA
PACKARD BELL
PACOM
PANASONIC
PHILLIPS
PIONEX
PRINCETON
QUANTEX
SAMSUNG
SCAN PRO
SONY
TANDY
TARDON
TAXAN
TEXAS INSTR
VIEW SONIC
ZENITH
Laptop
1
10
1
2
1
3
3
3
2
11
3
1
1
1
1
1
1
1
47
COMPAQ
DELL
APPLE
EVEREX
WINBOOK
17
1
1
25
1
1
4
1
1
1
13
2
1
8
1
7
2
1
1
1
2
2
2
1
3
2
4
1
1
1
11
3
4
1
1
2
1
2
1
1
1
1
1
1
1
6
1
1
3
2
1
APPLE
CANON
DELL
ZENITH
ZEOS
155
- P6 -
Peripherals
1
1
2
1
1
6
73
3
1
1
1
1
7
267
FINAL June, 2005
Staples Pilot Project –Final Report to U.S. EPA
Appendix P
Equipment Type Collected By Store And By Brand (continued)
Store
CPU
Monitor
#307-Lewiston, ME
APPLE
CREATIVE
DATAWORLD
DELL
DIGITAL
GATEWAY
HP
IBM
KAYPRO
MISC
PACKARD BELL
PROTEVA
TANDY
TIGER
TOSHIBA
1
2
1
3
1
5
1
1
1
2
1
1
1
1
1
Totals Store #307
23
#373-Rochester, NH
ABS
ACER
APPLE
BEC
COMPAQ
GATEWAY
PACKARD BELL
SAMSUNG
Totals Store #373
1
3
1
1
1
1
2
1
11
Product Stewardship Institute, Inc.
ADP
APPLE
AST
COMODORE
CTX
DELL
DIGITAL
GATEWAY
HP
IBM
IBM
KDS
LINK
MISC
PACKARD BELL
PRINCETON
PRO VIEW
SONY
TELEVIDEO
TOUCH
Laptop
1
1
1
1
1
3
1
4
1
1
1
1
4
1
3
1
1
3
1
1
GATEWAY
TOSHIBA
32
APPLE
COMPAQ
GATEWAY
IBM
PACKARD BELL
1
1
1
2
2
7
- P7 -
Peripherals
1
1
2
APPLE
51
1
1
21
FINAL June, 2005
Staples Pilot Project –Final Report to U.S. EPA
Appendix P
Equipment Type Collected By Store And By Brand (continued)
Store
CPU
Monitor
#495-Danvers, MA
APPLE
ARALZE
ASPEN
COMPAQ
COMSTAR
DELL
EPSON
GATEWAY
HP
MAC
MICRON
MISC
PACKARD BELL
WHITE BOX
ZEOS
47
1
1
16
1
4
1
5
5
4
1
9
1
1
1
Totals Store #495
98
Product Stewardship Institute, Inc.
ACER
APPLE
COMPAQ
CTX
DELL
DIGIVIEW
ELZO
EMC
EPSON
GATEWAY
GOLDSTAR
GVC
HP
IBM
KDS
MAC
MAG
MAXTEC
MICRON
MISC
MITSUBISHI
MTX
NEC
PACKARD BELL
PANASONIC
PHILIPS
PRESIDENT TECH
PRINCETON
SAMSUNG
SANPO ALPHA
SCEPTINE
SMITH CORONA
SONIC VIEW
SONY
VGA
VIEW SONIC
VIVITRON
WANG
Laptop
2
48
12
1
12
1
1
1
3
3
2
1
3
2
2
5
1
1
1
11
1
1
1
3
2
1
1
2
1
1
1
1
1
1
1
1
1
1
135
- P8 -
COMPAQ
HUNDAI
IBM
TOSHIBA
WINBROOK
ZENITH
Peripherals
1
1
1
1
1
2
7
89
FINAL June, 2005
Staples Pilot Project –Final Report to U.S. EPA
Appendix P
Equipment Type Collected By Store And By Brand (continued)
Store
CPU
Monitor
#495-Danvers, MA
APPLE
ARALZE
ASPEN
COMPAQ
COMSTAR
DELL
EPSON
GATEWAY
HP
MAC
MICRON
MISC
PACKARD BELL
WHITE BOX
ZEOS
47
1
1
16
1
4
1
5
5
4
1
9
1
1
1
Totals Store #495
98
Product Stewardship Institute, Inc.
ACER
APPLE
COMPAQ
CTX
DELL
DIGIVIEW
ELZO
EMC
EPSON
GATEWAY
GOLDSTAR
GVC
HP
IBM
KDS
MAC
MAG
MAXTEC
MICRON
MISC
MITSUBISHI
MTX
NEC
PACKARD BELL
PANASONIC
PHILIPS
PRESIDENT TECH
PRINCETON
SAMSUNG
SANPO ALPHA
SCEPTINE
SMITH CORONA
SONIC VIEW
SONY
VGA
VIEW SONIC
VIVITRON
WANG
Laptop
2
48
12
1
12
1
1
1
3
3
2
1
3
2
2
5
1
1
1
11
1
1
1
3
2
1
1
2
1
1
1
1
1
1
1
1
1
1
135
- P9 -
COMPAQ
HUNDAI
IBM
TOSHIBA
WINBROOK
ZENITH
Peripherals
1
1
1
1
1
2
7
89
FINAL June, 2005
Staples Pilot Project –Final Report to U.S. EPA
Appendix P
Equipment Type Collected By Store And By Brand (continued)
Store
CPU
Monitor
#648-Bangor, ME
ACER
ACS
AMI
AMTELCO
APPLE
AST
COMPAQ
COMPU ADD
DELL
DIGIVIEW
DSR
EMACHINES
EVEREX
GATEWAY
GENISYS
HP
IBM
MAC
MICRON
MISC
NEC
PACKARD BELL
TANDY
ULTRA
ZENITH
2
1
1
2
12
1
4
1
4
1
2
1
2
10
1
5
1
2
1
7
2
3
2
1
2
Totals Store #648
71
#806 Old Saybrook, CT
APPLE
COMPAQ
DBI
DELL
IBM
PACKARD BELL
SAMSUNG
6
3
1
5
3
9
1
Totals Store #806
28
Product Stewardship Institute, Inc.
ACER
ACERVIEW
ADC
APPLE
ATT
COMMODORE
COMPAQ
CTX
DAEWOO
DELL
DIGITAL
DIGIVIEW
DTK
EMACHINE
EMC
EVEREX
EVERVISION
GATEWAY
GOLDSTAR
HP
IBM
MAC
MAGNAVOX
MAGNAVOX
MICRO
MISC
NEC
NUMBUE
PACKARD BELL
RIC
SAMSUNG
SMITH CORONA
SONY
TANDY
TANTUNG
ULTRA
ACER
APPLE
COMPAQ
DELL
EMACHINE
GATEWAY
IBM
KOS
MAC
MISC
NEC
NORTHGATE
PACKARD BELL
PHILLIPS
SAMSUNG
SONY
Laptop
9
1
1
11
1
1
7
1
1
3
2
1
1
2
1
1
1
13
1
4
2
1
1
1
1
3
4
1
3
1
1
1
1
1
2
1
88
1
1
114
1
6
2
1
2
2
2
2
1
1
1
1
9
1
1
2
35
- P10 -
LUBREX
Peripherals
41
FINAL June, 2005
Staples Pilot Project –Final Report to U.S. EPA
Appendix P
Equipment Type Collected By Store And By Brand (continued)
Store
CPU
Monitor
#836-Westerly, RI
ACER
APPLE
AUSTIN
BSR
CANON
COMPAQ
GATEWAY
IBM
MISC
OSC
PACKARD BELL
PREMIA
1
1
1
1
2
1
2
1
5
1
2
20
Totals Store #836
38
#871-Biddeford, ME
AOC
APPLE
COCCI COMP
COMPAQ
EMACHINE
HP
IBM
LEADING EDGE
MICRON
MISC
NEC POWERMATE
PACKARD BELL
TEXAS INSTRUMENT
1
3
1
1
1
2
4
1
5
2
1
5
1
Totals Store #871
28
#947-Norwich, CT
APPLE
COMPAQ
GATEWAY
HP
IBM
MACINTOSH
MISC
NEC
PACKARD BELL
ZEROX
Totals Store #947
3
6
1
1
1
1
2
1
1
1
18
Product Stewardship Institute, Inc.
ACER
CANON
CYBERVISION
DELL
DTK
EPSON
GATEWAY
GOLDSTAR
IBM
KDS
MISC
MITSUBISHI
PACKARD BELL
SAMSUNG
AMDEK
AOC
APPLE
COCCI COMP
COMPAQ
CTI
CTX
DELL
EMACHINE
ENVISION
HP
IBM
LEADING EDGE
MAGNAVOX
MICRON
MISC
NEC
NEC
NEC POWERMATE
PACKARD BELL
PRINCETON
VOX
APPLE
COMPAQ
DELL
GATEWAY
HP
NEC
PACKARD BELL
PRINCETON
PSI
TRINITRON
- P11 -
Laptop
1
1
1
42
1
3
2
1
1
1
4
1
2
4
65
APPLE
MAC
2
1
1
1
2
1
2
1
1
1
2
3
1
2
1
10
1
1
1
7
1
1
44
IBM
3
1
1
1
2
1
1
1
1
1
13
Peripherals
1
1
2
77
1
1
61
0
45
FINAL June, 2005
Staples Pilot Project –Final Report to U.S. EPA
Appendix P
Equipment Type Collected By Store And By Brand (continued)
Store
CPU
Monitor
#1095-Falmouth, ME
APPLE
COMP USA
COMPAQ
CREATIVE
DELL
DIGITAL
DOWNTIME
DTX
EVEREX
GATEWAY
IBM
INTEL
LEXMARK
MAC
MISC
NCR
PACKARD BELL
PATRIOT
ZENITH
ZEOS PANTERA
13
1
5
1
5
1
2
1
1
4
8
2
1
1
3
2
1
1
1
1
Totals Store #1095
55
#1100-Somersworth, NH
APPLE
DELL
IBM
MAC
MICRO EXPRESS
SAMSUNG
SPECTRA
ULTRA
ZENITH
3
1
1
1
1
1
1
1
1
Totals Store #1100
11
Product Stewardship Institute, Inc.
ACER VIEW
APPLE
COMP USA
COMPAQ
DELL
DTX
EVEREX
GATEWAY
HP
IBM
ICD
INTEL
KDS
LEXMARK
MAC
MEMOREX
MISC
MITSUBISHI
NCR
NEC
OPTIQUEST
PACKARD BELL
PHILLIPS
PROVIEW
SEPTER
ULTRA
V TECH
VIEWSONIC
APPLE
DELL
GATEWAY
IBM
MAC
MAGNAVOX
MITSUBUSHI
NAP ELECTORNICS
NEC
PRINCETON
SAMSUNG
TATUNG
ULTRA
Laptop
2
16
1
5
6
1
1
6
2
5
1
1
2
1
1
1
5
1
3
2
1
2
1
1
1
1
1
2
73
AST
DIGITAL
GATEWAY
1
1
2
1
1
2
1
1
1
1
1
1
1
DELL
TOSHIBA
15
- P12 -
Peripherals
1
1
1
3
120
1
1
2
17
FINAL June, 2005
Staples Pilot Project –Final Report to U.S. EPA
Appendix P
Equipment Type Collected By Store And By Brand (continued)
Store
CPU
Monitor
#1124-Seabrook, NH
APPLE
COMMODORE
COMPAQ
COMPUDYNE
CPS
GATEWAY
GENERIC
HP
IBM
MISC
NA
PACKARD BELL
SHARP
SONY
TANDY
6
1
2
1
1
3
1
4
7
8
2
5
2
1
3
Totals Store #1124
47
#1132-Waterville, ME
APPLE
FIRST VIEW
GATEWAY
HP
MICRON
QUANTEX
RADIO SHACK
Totals Store #1132
1
1
1
2
1
1
1
8
HP
PHILLIPS
RADIO SHACK
SAMSUNG
SUPERVIEW
#1228-North Conway, NH
APEX
APPLE
AST
COMPAQ
DELL
DFI
EMERSON
EPIC
E-TOWER
GATEWAY
IBM
MAGITRONIC
METRA
MICRON
MICROX
MISC
NCR
NEC
OKIDATA
PACKARD BELL
PAI
TANDY
1
6
1
4
4
1
1
1
1
2
2
1
1
2
1
7
1
1
1
7
1
1
APPLE
AST
COMPAQ
CYBERVISION
DELL
DIGITAL
EMACHINE
EMC
EMERSON
E-TOWER
GATEWAY
IBM
MIC
MICRON
MISC
NEC
PACKARD BELL
PRINCETON
RADIUS
SMITH CORONA
SONY
TANDY
TECH MEDIA
Totals Store #1228
48
Product Stewardship Institute, Inc.
ACER
APPLE
AT&T
COMPAQ
COMPUDYNE
CYBERVISION
DELL
DIGITAL
EMACHINE
EMC
EMERSON
Gateway
HP
INTEL
KDS
MAGVIEW
MISC
NA
NA
NEC
PACKARD BELL
PHILIPS
SAMSUNG
SANYO
Laptop
1
9
2
2
1
1
1
3
1
1
1
2
6
1
1
1
15
4
4
2
3
1
1
1
65
SHARP
TOSHIBA
2
1
1
1
1
NEC
SHARP
- P13 -
3
1
4
6
6
1
2
1
2
17
1
1
1
1
1
3
1
2
3
2
5
1
1
1
1
2
1
57
Peripherals
1
1
2
APPLE
COMPAQ
NEC
74
7
3
1
1
5
137
FINAL June, 2005
Staples Pilot Project –Final Report to U.S. EPA
Appendix P
Equipment Type Collected By Store And By Brand (continued)
Store
CPU
Monitor
#1259-North Windham, ME
APPLE
ARCHE LEGACY
AT&T
DMI
GENERIC
HP
HYUNDAI
MISC
NEC
QUANTUM
TANDY
THINKPAD
1
1
1
1
1
2
1
4
1
2
1
1
Totals Store #1259
17
#1291-Rockland, ME
COMPAQ
DEC
GATEWAY
HP
MAC
Totals Store #1291
1
1
3
2
3
10
COMBINED TOTALS
1363
Product Stewardship Institute, Inc.
AST VISION
AT&T
COMPAQ
DIGITAL
IBM
LEADING EDGE
MAG
MITSUBISHI
NEC
PACKARD BELL
RGB
SEPTRE
VIEWSONIC
GATEWAY
HP
MISC
PANASONIC
RADIUS
Laptop
1
1
1
1
1
1
1
1
1
1
1
3
1
15
IBM
1
1
1
1
1
5
IBM
TBM
1599
- P14 -
Peripherals
1
1
25
2
1
3
14
98
2307
FINAL June, 2005
Staples Pilot Project –Final Report to U.S. EPA
Appendix P
Table P2. Total Equipment Type Collected By Store
STATE
CPU
0806
CT
0947
CT
TOTAL CT
0001
MA
0002
MA
0008
MA
0051
MA
0167
MA
0200
MA
0495
MA
TOTAL MA
0108
ME
0194
ME
0297
ME
0307
ME
0648
ME
0871
ME
1095
ME
1132
ME
1259
ME
1291
ME
TOTAL ME
0176
NH
0373
NH
1100
NH
1124
NH
1228
NH
TOTAL NH
0836
RI
TOTALS
MONITOR
LAPTOP PERIPHERALS
TOTAL
28
18
46
8
74
166
50
87
40
98
523
118
125
155
23
71
28
55
8
17
11
611
27
11
12
47
48
145
38
35
13
48
12
98
174
77
97
47
135
640
109
143
155
32
88
44
73
6
15
5
670
32
7
15
65
57
176
65
0
0
0
1
3
20
2
3
7
6
42
12
1
7
2
1
1
3
2
1
3
33
9
1
2
4
5
21
2
41
45
86
5
44
354
57
101
73
89
723
270
185
267
51
114
61
120
7
25
14
1114
58
21
17
74
137
307
77
1363
1599
98
2307
180
1928
2428
649
182
5367
Table P3. Equipment Type Collected By Major Brand
MONITOR
APPLE
COMPAQ/HP
DELL
GATEWAY/EMACHINES
IBM
PACKARD BELL
LAPTOP
251
187
137
112
74
73
APPLE
COMPAQ/HP
IBM
NEC
TOSHIBA
ZENITH
834
52.1%
24
14
9
7
8
6
COMPAQ/HP
EPSON
APPLE
CANON
LEXMARK
PANASONIC
68
68.7%
Product Stewardship Institute, Inc.
SCANNER
PRINTER
262
81
75
45
27
27
COMPAQ/HP
MICROTECH
UMAX
MUSTEK
CANON
APPLE
517
- P15 -
25
12
8
4
3
3
BROTHER
PANASONIC
HP
SHARP
CANON
PANAFAX
55
64.7%
71.1%
FAX
COPIER
6
5
4
4
3
2
CANON
XEROX
HP
SHARP
24
75.0%
5
4
2
2
13
72.2%
FINAL June, 2005
Staples Pilot Project –Final Report to U.S. EPA
Appendix P
Equipment Type Collected By Major Brand (continued)
MONITOR
ACER
ACROS
ACTRONICS
ADC
ADDONICS
ADI
ADP
AMDEK
AMIGA
AOC
AOL SPECTRUM
APEX
ARCUS
AST
AT&T
BROTHER
BSR
BTC
CANON
CHAMPION
COCCI COMP
COMMODORE
COMP U DYNE
COMP USA
COMPUADD
COMPUTINE
COMTERM
CORDATA
CPX
CRYSTAL SCAN
CSX
CTI
CTX
CYBERVISION
DAEWOO
DATA GEN
DAYTEK
DEC
Desktop Displays
DIGITAL
DTK
EAGLE
ELITE
ELZO
EMC
EMERSON
ENVISION
LAPTOP
49
1
1
2
2
1
1
2
2
4
2
2
2
9
8
2
1
1
1
1
1
4
2
5
3
4
1
1
1
1
1
1
18
5
1
1
1
3
1
32
4
1
1
1
7
3
2
ARCHE
AST
CANON
DELL
DIGITAL
EVEREX
GATEWAY
HUNDAI
LAPNOTE
LUBREX
MAC
MISC
QUANTEX
SHARP
SONY
TBM
WINBOOK
ZEOS
Product Stewardship Institute, Inc.
SCANNER
PRINTER
1
1
1
5
1
1
3
1
1
1
1
2
1
5
1
1
2
1
ACER
1
ADOBE
1
ALPS
2
AMEGA
1
AMT
1
APEX
1
APPOLLO
1
ATARI
1
BROTHER
10
CITIZEN
2
COMMODORE 3
DEC
1
DELL
2
DESKJET
2
DIGITAL
22
DOT MATRIX
1
FARGO
2
FUJITSU
3
GATEWAY
8
GEMINI 15
1
IBM
13
IMAGE MAKER 7
INTEL
1
LASER PRINTER1
MAC
5
MANNESMEN 1
MINOLTA
1
MISC
47
MPI
1
NCR
1
NEC
6
OKIDATA
16
OLYMPIA
2
PACKARD BELL 5
PRINTER WORKS
1
RADIO SHACK 3
REYNOLDS
1
SILVER REED 1
SMITH CORONA 4
STAR
4
STORM
1
STYLE WRITER 2
STYLUS
2
TANDY
8
TEXAS INST
5
TIGER
1
XEROX
4
ACER
AGFA
ASTA
DIGITAL
EASY PHOTO
EPSON
FUJITSU
GATEWAY
LEXMARK
LUMINA
MEMOREX
MICROSOFT
MISC
NIKON
PRIMA SCAN
RELISYS
SCAN MAKER
SCANTAK
SCAPORT
VANTAS
VISIONEER
XEROX
- P16 -
FAX
3
1
1
1
1
1
1
1
1
2
2
1
3
1
1
1
1
1
1
1
3
1
AUTLOGIC
BELL
LUMAK
MICROTEC
MINOLTA
MISC
MURATA
XEROX
COPIER
1
1
1
1
1
1
1
1
IBM
LANIER
MISC
STAR
1
1
2
1
FINAL June, 2005
Staples Pilot Project –Final Report to U.S. EPA
Appendix P
Equipment Type Collected By Major Brand (continued)
MONITOR
EPSON
E-TOWER
EVEREX
EVERVISION
GOLDSTAR
GRID 800
GVC
HANSON
HEADSTART
HITACHI
HYANDAI
HONEYWELL
ICD
ICM
IMPRESSION
IMTEC
INTEL
KDS
KENSIKO
KEYPRO
KFC
KLM
KOREA DATA SYS
KOS
LASER
LEADING EDGE
LEXMARK
LIKOM
LINK
MAC
MAG
MAGNOVOX
MAXTEC
MEGA IMAGE
MEMOREX
MGC
MIAC
MICRO
MICRON
MICS
MIDWEST MICRO
MIRROR
MISC
MITAC
MITSUBUSHI
MTX
MULTISCAN
NAP
NCR
NEC
NEC POWERMATE
NORTHGATE
NPC
NUMBUE
Occidental
OKIDATA
OPTIQUEST
ORCHESTRA
PACOM
PANASONIC
PCPC
PENTENIUM
PGS
PHILLIPS
PIONEX
PIXIE
President Tech
PRINCETON
PRO COMPUTING
PRO VIEW
LAPTOP
7
1
5
1
7
1
1
1
1
4
1
1
1
1
2
1
3
10
1
1
3
3
1
2
2
6
1
2
8
23
7
13
1
1
2
1
1
1
10
1
1
1
128
1
8
1
1
6
4
40
1
1
3
1
1
1
3
3
1
8
1
1
1
8
1
1
1
17
1
4
Product Stewardship Institute, Inc.
PRINTER
SCANNER
- P17 -
FAX
COPIER
FINAL June, 2005
Staples Pilot Project –Final Report to U.S. EPA
Appendix P
Equipment Type Collected By Major Brand (continued)
MONITOR
PENTENIUM
PGS
PHILLIPS
PIONEX
PIXIE
President Tech
PRINCETON
PRO COMPUTING
PRO VIEW
PROMOTHERS
PROTEVA
PSI
QUANTEX
RADIO SHACK
RADUIS
RELYSIS
RGB
RIC
ROYAL
SAMPO
SAMSUNG
SANPO ALPHA
Sanyo
SCANPRO
SCEPTINE
SCEPTRE
SIGNATURE
SMITH CORONA
SONY
SPECTRA
STANDARD TECH
STAR
SUNSHINE
SUPER MAC
SUPERCOM
SUPERVGA
SUPERVIEW
SVE
SWAN
TANDY
TARDON
TATUNG
TAXAN
TECHMEDIA
TELEVIDEO
TELEX
TEXAS INSTR
TOUCH
TRADEMARK
TRI GEM
TRINITRON
ULTRA
UNISYS
US LOGIC
V TECH
VGA
VICTOR
VIEWSONIC
VISION
VISUAL SENTATION
VIVITRON
VOX
WANG
WIT
YAMA
ZENITH
LAPTOP
SCANNER
PRINTER
FAX
COPIER
1
1
8
1
1
1
17
1
4
1
1
2
3
2
2
1
1
2
2
3
20
1
2
1
1
4
2
4
30
1
1
3
1
1
1
1
1
1
1
17
1
4
1
2
1
1
3
1
1
1
1
4
1
2
1
2
1
20
3
1
1
1
2
1
2
3
766
30
Product Stewardship
Institute, Inc.
210
- P18 -
30
8
5
FINAL June, 2005
Staples Pilot Project –Final Report to U.S. EPA
Appendix P
Equipment Type Collected By Major Brand (continued)
MONITOR
WIT
YAMA
ZENITH
LAPTOP
SCANNER
PRINTER
FAX
COPIER
1
2
3
766
47.9%
30
30.6%
1600
210
28.9%
98
Product Stewardship Institute, Inc.
30
35.3%
727
25.0%
85
- P19 -
8
5
27.8%
32
18
FINAL June, 2005
Staples Pilot Project –Final Report to U.S. EPA
Appendix Q
Appendix Q. Contract Equipment Collection Survey Data
Table Q1. Staples Contract Customer Collection Data Total Number, Weight, And Cost By Brand
Brand
3COM
ACER
ACW
ADI
AMPTRON
APC
APPLE
ARBOR
AST
AXIS
BAYNETWORKS
BROTHER
CABLESCAN
CANON
CARON
COMPUTCITY
CTS
CTX
CYBEX
DATA MAX
DECISION DATA
DELL
ELO
ELTRON
EPSOM
GATEWAY
HP/COMPAQ
IBM
ICON
IMPRESSION
K25 SYSTEM
KDS
LEXMARK
LYNX
MACINTOSH
MAG
MANITOO
MGC
MICRON
MICROTEK
MISC/GENERIC
NEC
OKIDATA
OPXIQUEST
PANASONIC
PHILIPS
SAFE
SAMSUNG
SMILE
SONY
STARR
SUN
SUN SPARK
TATUNG
TI
TOSHIBA
TRINITRON
TRISTAR
TRONIX
VIEWSONIC
WELLFLEET
WYSE
TOTALS
Monitors (1)
Wgt
Cost
#
1
2
2
1
38
76
76
38
$4.00
$8.00
$8.00
$4.00
4
7
152
266
$16.00
$28.00
CPU's (2)
Wgt
Cost
#
Laptops (3)
Wgt
Cost
#
1
18
414
3
69
1
1
38
15
15
#
Large
Peripherals (4) (A)
Wgt
Cost
$1.05
10
3
1
81.2
24.36
8.12
$5.68
$1.71
$0.57
1
4
8.12
32.48
$0.57
$2.27
2
16.24
$1.14
5
3
40.6
24.36
$2.84
$1.71
58
1
470.96
8.12
$32.97
$0.57
14
113.68
$7.96
1
1
380
38
$40.00
$4.00
1
9
7
38
342
266
$4.00
$36.00
$28.00
6
7
2
5
1
228
266
76
190
38
$24.00
$28.00
$8.00
$20.00
$4.00
1
38
$4.00
1
38
$4.00
1
38
$4.00
1
1
38
38
$4.00
$4.00
39
1482
$156.00
21
38
38
38
$4.00
$4.00
$4.00
6
1
1
228
38
38
$24.00
$4.00
$4.00
483
7
49
2
1
161
1127
46
23
1
23
19
437
19
437
68
4
1564
92
1
38
$4.00
5
190
$20.00
1
3
3
38
12
45
45
570
180
$3.15
$3.15
$39.90
$12.60
38
2
20.8 $
1.46
1
10.4 $
0.73
15
1
10.4 $
0.73
$1.05
8.12
5
75
$5.25
1
10.4 $
0.73
1
1
15
15
$1.05
$1.05
9
1
93.6 $
10.4 $
6.55
0.73
1
15
$1.05
2
20.8 $
1.46
1
10.4 $
0.73
4
41.6 $
2.91
1
10.4 $
0.73
1
1
10.4 $
10.4 $
0.73
0.73
10
104 $
7.28
35
364
$0.57
22
4
60
$4.20
18
270
$18.90
5
40.6
$2.84
3
24.36
$1.71
1
8.12
$0.57
1
8.12
$0.57
330
$23.10
23
2
1
1
Non-Computer
Equipment (6)
Wgt.
Cost
23
1
1
1
1
#
$1.05
$4.00
10
1
Small
Peripherals (5) (B)
#
Wgt.
Cost
30
15
$2.10
$1.05
$4.00
1
1
23
23
1
23
$524.00 217
4,991
1
38
$4.00
1
38
$4.00
131
4,978
83
1,245
2
16.24
$1.14
$87.15 115
933.8
$65.37
31
465
$32.55
$25.48
#
Wgt.
Totals
Cost
2
20.8
2
53
2
76
2
76
1
38
1
10.4
22
566
7
266
3
69
10
81.2
3
24.36
2
23.12
2
53
1
8.12
4
32.48
1
23
10
380
1
38
1
10.4
2
16.24
1
38
39
955.4
7
266
5
40.6
3
24.36
16
434
162 2,542.56
19
335.52
6
213
1
38
1
23
2
53
16
134.48
1
38
19
437
1
38
1
10.4
1
38
20
475
1
8.12
133
3417.6
8
152
6
51
1
38
22
332.36
2
61
1
8.12
6
228
1
38
1
38
1
8.12
2
48.4
1
10.4
5
190
2
30
1
15
1
38
1
23
1
23
1
38
12
120.24
2
61
$1.46
$5.05
$8.00
$8.00
$4.00
$0.73
$16.00
$28.00
$0.00
$5.68
$1.71
$1.62
$5.05
$0.57
$2.27
$0.00
$40.00
$4.00
$0.73
$1.14
$4.00
$45.13
$28.00
$2.84
$1.71
$27.15
$108.47
$22.95
$20.00
$4.00
$0.00
$5.05
$9.41
$4.00
$0.00
$4.00
$0.73
$4.00
$4.00
$0.57
$182.01
$4.20
$3.57
$4.00
$24.61
$4.00
$0.57
$24.00
$4.00
$4.00
$0.57
$4.73
$0.73
$20.00
$2.10
$1.05
$4.00
$0.00
$0.00
$4.00
$8.42
$4.00
612
$734.55
12976.8
(1)
(2)
(3)
(4)
(5)
(6)
Average weight for pilot project collection calculation at 38 pounds/unit. At project discounted rate of $4.00/monitor.
Average weight for pilot project collection calculated at 23 pounds/unit. No charge for CPU recycling.
Average weight for pilot project collection calculated at 15 pounds/unit. At project discounted rate of $0.07/pound.
Average weight for pilot project collection calculated at 8.12 pounds/unit. At project discounted rate of $0.07/pound.
Average weight for pilot project collection calculated at 15 pounds/unit. At project discounted rate of $0.07/pound.
Average weight for pilot project collection calculated at 10.4 pounds/unit (based on an estimated percentage using full collection figures for non-computer equipment in this pilot). At
project discounted rate of $0.07/pound.
(A) Large Peripherals Include: Printers/Dot Matrix/Laser/Fax/Other
(B) Small Peripherals Include: Keyboard/Mice/Speakers/etc.
Product Stewardship Institute, Inc.
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FINAL June, 2005
Staples Pilot Project –Final Report to U.S. EPA
Appendix R
Appendix R. Retail and Contract Customer Satisfaction Surveys
STAPLES/PSI RETAIL CUSTOMER SURVEY
(1)
What motivated you to bring in your equipment?
(2)
Did you buy anything at the store when you returned your item? Yes ____ No _____
If yes, was the purchase:
under $50 _____
$51-$100 _____
$101-$250 _____
over $250 _____
(3)
What about the program worked well?
(4)
What problems, if any, did you have with the program?
(5)
What suggestions would you have for future improvement?
(6)
In the future, would you be willing to pay to recycle your computer equipment?
If yes, how much per computer system?
under $5 _____
$6-10 _____
$11-15 _____
$16-20 _____
(7)
Are there other items that you would like Staples to collect? Would you be willing to pay
to recycle those?
***************************
STAPLES/PSI COMMERCIAL CUSTOMER SURVEY
(1)
What about the program worked well?
(2)
What problems, if any, did you have with the program?
(3)
What suggestions would you have for future improvement?
(4)
In the future, would you be willing to pay to recycle your computer equipment?
If yes, how much per computer system?
under $5 _____
$6-10 _____
$11-15 _____
$16-20 _____
(5)
Are there other items that you would like Staples to collect? Would you be willing to pay
to recycle those?
Product Stewardship Institute, Inc.
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FINAL June, 2005
Staples Pilot Project –Final Report to U.S. EPA
Appendix S
Appendix S. Staples Data Needs for Pilot Project
1)
To identify the sample of stores and contract customers
Commercial customers

Businesses of different size (number of employees within the facility)

Businesses from various sectors (healthcare, manufacturing, etc.)

Businesses with hazardous materials management already in place vs. those without

Businesses served by Staples’ trucks vs. those served by commercial carrier

Businesses at various distances from the fulfillment center

Businesses at various distances from the transportation hubs

Businesses that do large volume Staples’ purchasing vs. lower volume

Businesses in MA (with CRT ban enforced) vs. those in other states

Businesses that participate in (or plan to participate in) other Staples collection/recycling
programs vs. those that do not participate

Businesses that purchase equipment from several OEMs versus purchasing equipment from a
single OEM
Retail customers

Stores serving concentrated (urban) vs. dispersed (suburban, rural) populations

Stores in a cluster of large retail electronics stores vs. one large retail electronics store for
several miles

Communities with active electronics recycling programs vs. those without

Communities in MA (with CRT ban) vs. those in other states

Stores in one region so that advertising or publicity doesn’t result in customers coming with
equipment to a non-participating store

Stores in locations that would be suitable for a collection “event” such as big, open lot, good
access and egress from highway, ability to hold a line of traffic without obstructing through
traffic

Stores at various distances from the distribution center

Stores with adequate retail space to accommodate an ongoing collections area
Internet customers

Customers within certain geographic regions (rural, urban, and/or suburban)

Customers that purchase high and/or low volumes of Staples products
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FINAL June, 2005
Staples Pilot Project –Final Report to U.S. EPA
Appendix S

Customers at various distances from the recycler (if they need to ship directly to the recycler)

Customers at various distances to Staples stores (if they have the option of returning
electronics to stores)
2)
To Determine Operational Costs/Values
Advertising and promotion (initial and ongoing) will there be separate promotion of the
collection services or will it be included in broader collection? Will it be possible to determine a
value for the promotion if it is part of a larger advertising effort?
Staples staff training – Will there be training of Staples staff about the electronics recycling
program, safe lifting and handling of heavy materials, handling of bare CRTs that are removed
from their housing, etc? If so, can a cost or value be determined for the training?
Cost of electronics handling (value of time, etc.) – Is there a way for Staples to estimate the
amount of time employees are spending on moving equipment, dealing with customer returns of
equipment, stacking and loading, etc.? This should include retail store employees for managing
the drop-offs from customers, delivery employees for pick-up of materials, delivery employees
for material drop-off at the FCs, DCs, and transportation hubs, and logistics employees to
coordinate pickups by recyclers.
Value of storage space – Does Staples have a formula for determining value of storage space at
retail store and at DCs, FCs, and transportation hubs (assuming that space would not be used
otherwise. If space was used before and now contains electronics for any period of time, we
should calculate this as a real cost)
Value of transporting the equipment to DCs or FCs – Has Staples already determined the cost
per mile (or cost per trip) for empty trucks returning to warehouses? Will it be possible to
measure any additional costs for those trucks running full or partially full on the backhaul (e.g.,
added fuel costs, less stores/businesses on a delivery run because of additional time required to
pick-up the waste electronics, etc.).
Cost of serving Internet customers – How does Staples collect information on the Internet
customers (e.g. shipping charges)?
Costs of additional shipping supplies/equipment – Will Staples be able to determine costs for
equipment specific to electronics collection (Gaylord containers, pallets, pallet jacks, etc.)?
Cost of processing and recycling – We will need to determine costs broken down for contractor
set up at collection events, contractor transport from consolidation points to recycling facility,
sorting costs (if we decide to sort by brand for vendor recycling), and recycling costs. If vendors
pay for part of recycling, we will calculate the value of that service based on the cost to recycle
the rest).
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FINAL June, 2005
Staples Pilot Project –Final Report to U.S. EPA
Appendix S
Note: For business collections, we need to determine if:
1) The transportation hub is the electronics consolidation point for the recycler or
2) The fulfillment center is the electronics consolidation point for the recycler. If
this is the case then it appears there is a two-step process where Staples must
collect the electronics from the business and deliver/store the electronics at the
transportation hub. Staples must then pick-up the electronics at the
transportation hub and transport the electronics to the fulfillment center.
3)
To Evaluate Results of Pilot Project

Quantities of electronics collected by pound (perhaps also by unit, product type, OEM, etc.)

Number of participants in the program

Satisfaction of participants, willingness to pay attitudes based on surveys

Satisfaction of employees with the pilot – suggestions for improvements

Total program costs to Staples

Total value of Staples’ (and OEMs and other key stakeholders’) services
Product Stewardship Institute, Inc.
- S3 -
FINAL June, 2005
Staples Pilot Project –Final Report to U.S. EPA
Product Stewardship Institute, Inc.
Appendix T. Staples Internal Retail Collection Costs
Table T1. Staples Retail Pallet Costs
- U1 -
City/State
New London, CT
Old Saybrook, CT
Westerly, RI
Norwich, CT
South Portland, ME
Bangor, ME
Brunswick, ME
Lewiston, ME
Bangor, ME
Biddeford, ME
Falmouth, ME
Waterville, ME
North Conway, NH
N. Windham, ME
Rockland, ME
Woburn, MA
Natick, MA
Saugus, MA
Danvers, MA
Portsmouth, NH
Brighton,MA
Needham, MA
Rochester, NH
Revere, MA
Danvers, MA
Somersworth (Dover), NH
Seabrook, NH
Address
State
Zip
292 US Rte. 1
CT
06320
1000 Boston Post Road CT
06475
16 Post Road
RI
02891
45 Salem Turnpike
CT
06360
443 Western Avenue
ME
04106
1131 Union St.
ME
04401
Route 24 - Bath Road
ME
04011
855 Lisbon Street
ME
04240
180 Bangor Mall Blvd.
ME
04401
420 A Alfred Rd.
ME
04005
244B US Route 1
ME
04105
40 Waterville Commons Drive
ME
04901
1739 White Mountain Highway
NH
03860
770 Roosevelt Trail
ME
04062
235 Camden St.
ME
04841
335 Washington Street MA
01801
881 Worcester Road
MA
01760
444 Broadway (Route 1) MA
01906
301 Newbury Street
MA
01923
1981 Woodbury Ave and Gosling
NH
Rd 03801
1660 Soldiers Field Rd. MA
2135
163 Highland Ave.
MA
02494
106 Milton Rd.
NH
03868
151 VFW Parkway
MA
02151
230 Independence way MA
01923
249 Indian Brook Drive NH
03878
536 Lafayette Road
NH
3874
Phone
860-439-1872
860-395-2980
401-348-4900
860-886-8870
207-871-9148
207-941-2182
207-725-2741
207-753-0742
207-947-9225
207-284-7543
207-781-2255
207-873-4092
603-356-2666
207-892-1740
207-596-5696
781-932-4132
508-655-0811
781-231-6860
978-777-9400
603-431-3527
617-254-3351
781-449-5766
603-332-4421
781-289-8950
978-762-0152
603-750-0078
7
17
6
6
32
20
23
14
17
10
12
10
11
8
10
17
26
6
29
11
6
16
7
12
22
8
14
377
$1,869.92
# Pallets
Shipping/
National
$28.53/
Pallet
$3,645.59 $10,755.81
Total Pilot
S&H Cost
$102.41
$248.71
$87.78
$87.78
$336.49
$292.60
$336.49
$204.82
$248.71
$146.30
$175.56
$146.30
$160.93
$117.04
$146.30
$248.71
$380.38
$87.78
$424.27
$160.93
$87.78
$234.80
$102.41
$175.56
$321.86
$117.04
$204.82
Total
National
S&H Cost
$5,515.51 $12,625.73
Appendix T
FINAL June, 2005
Store
0187
0806
0836
0947
0108
0194
0297
0307
0648
0871
1095
1132
1228
1259
1291
0002
0008
0051
0167
0176
1
0200
0373
0394
0495
1100
1124
Handling/
$4.96 Pallet
$34.72
$84.32
$29.76
$29.76
$158.72
$99.20
$114.08
$69.44
$84.32
$49.60
$59.52
$49.60
$54.56
$39.68
$49.60
$84.32
$128.96
$29.76
$143.84
$54.56
$29.76
$79.36
$34.72
$59.52
$109.12
$39.68
$69.44
Shipping/
Killingly
$9.67 Pallet
$67.69
$164.39
$58.02
$58.02
$309.44
$193.40
$222.41
$135.38
$164.39
$96.70
$116.04
$96.70
$106.37
$77.36
$96.70
$164.39
$251.42
$58.02
$280.43
$106.37
$58.02
$154.72
$67.69
$116.04
$212.74
$77.36
$135.38
Staples Pilot Project –Final Report to U.S. EPA
Appendix U
Appendix U. U.S. EPA Regulatory Guidelines for Plug In Partners
Plug-In to eCycling
Guidelines for Materials Management
Purpose
As part of an effort by EPA to develop national guidance for the management of “end-of-life”
electronics, the Agency has drafted the following guidelines for use in the Plug-In To eCycling
Campaign. The Campaign and its pilots will be used by the Agency to “test” these guidelines
and allow the Agency to have real world information about what practices will most effectively
protect human health and the environment, while at the same time enabling practicable programs
for management of end-of-life electronics.
These guidelines are intended to be used as a framework for considering the acceptance of
partners to the Plug-In Campaign. The Agency developed these guidelines based on what we
believe, on a general basis, to be the most important elements for protection of human health and
the environment in managing end-of-life electronics. However, the Agency is open to the
possibility that not all aspects of these guidelines are critical in all cases of end-of-life
management. That is, the Agency recognizes that, on a facility-specific basis, there may be
practices that do not conform with every element of these guidelines, yet these practices may
also ensure the protection of human health and the environment.
Vital to the success of the Campaign, as well as any program for improved management of endof-life electronics, is the availability of adequate markets for reuse and recycling. Thus, these
guidelines are not intended to be a barrier to delivering reusable equipment or industrial
feedstock materials to legitimate markets and environmentally sound facilities, wherever they
exist.
Applicability of Guidelines
These guidelines are applicable to all Plug-In partners who, through contracts or other
arrangements, utilize reuse, refurbishment, recycling or disposal services. Plug-In partners take
appropriate due diligence measures to ensure that downstream facilities and operations use
practices that are consistent with these guidelines. The guidelines are applicable to all activities
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FINAL June, 2005
Staples Pilot Project –Final Report to U.S. EPA
Appendix U
undertaken by a Plug-In partner, not just those that are undertaken as part of a Plug-In To
eCycling pilot.
The guidelines are not written to directly address collection activities. Rather, the guidelines
address activities that ensue following collection: reuse, refurbishment, recycling and disposal,
as well as the responsibilities of the Plug-In partner to ensure that such activities are conducted
consistent with these guidelines.
Companies or other entities that perform recycling or related processing activities (other than
collection) are not eligible to become Plug-In partners at this time. In order for the Agency to
form Plug-In partnerships directly with processors and recyclers, the Agency would specifically
request certain data and other information from these entities and/or request that such
information be kept at the facility that would document the consistency of their operations with
these guidelines. In order to minimize the burden on the public for information gathering
pursuant to federal activities, the Paperwork Reduction Act of 1995 requires that the Agency
obtain approval from the Office of Management and Budget (OMB) for such information
gathering activities. Unfortunately, development of such an information gathering request by
EPA, as well as the OMB approval process, would require 6 months to a year to complete. Thus,
the Agency is not now in a position to request, receive and review information from processors
and recyclers regarding the consistency of their operations with these guidelines. As an
alternative, it is the intent of the Agency to work towards the establishment of a third-party
organization to function as an entity for review and recognition of processors and recyclers of
end-of-life electronics. The Agency also will not accept as Plug-In partners entities who are
primarily engaged in the landfill or incineration of end-of-life electronics, as these disposal
operations are not the primary focus of the Plug-In To eCycling program.
Due Diligence
The guidelines call for due diligence efforts on the part of Plug-In partners regarding the
handling and disposition of end-of-life electronics. However, the guidelines do not incorporate
the same level of due diligence under all circumstances. Rather, the level of due diligence
recommended is commensurate with the risk of the activities involved, as well as being aimed
at fulfillment of certain waste and material management goals under Plug-In. For example, the
guidelines call for due diligence to provide assurance that incineration and landfill of any form
of e-waste is minimized and, if utilized, is safe; whereas, the due diligence steps for reuse,
refurbishment and recycling focus on only those used electronics that contain or consist of
materials that, if mismanaged, are most likely to present hazards to human health or the
environment. Thus, reuse is the most favored management option, followed by recycling and,
least desirable, landfilling or incineration.
Guidelines 1-4 below pertain to all end-of-life electronics for which Plug-In partners have
responsibility. Among other things, guidelines 1-4 call for due diligence regarding any
electronic products or components that are sent to incineration or land disposal. However,
guideline 5, regarding reuse and refurbishment, and guideline 6, regarding recycling, only
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FINAL June, 2005
Staples Pilot Project –Final Report to U.S. EPA
Appendix U
pertain to certain “designated materials,” as defined in the relevant footnote. Designated
materials are those that are of concern because they contain or consist of materials that, when
mismanaged, may present hazards to human health or the environment.
Thus, no guidelines beyond those of 1-4 apply to the reuse, refurbishment or recycling of end-oflife electronics that, either in processed or unprocessed form, do not contain or consist of
designated materials. The Agency encourages the processing (including sorting) of used
electronics to enhance the value of output streams, often resulting in the generation of multiple
commodity streams that do not contain or consist of designated materials.
Because equipment for reuse often contains designated materials, guideline 5 will be applicable
to many reuse markets. However, to maximize reuse, the elements of guideline 5 are relatively
simple--the Plug-In partner ensures that equipment meets legitimate reuse specifications, is
packaged to protect its value, and that proper business records are kept of the transaction. The
only other guideline having relevance to reuse is guideline 4(a)—the Plug-in partner ensures that
export of reusable equipment is in conformance with the laws of importing and transit countries.
Guidelines 1-5 are applicable to equipment for refurbishment.
GUIDELINES for MATERIALS MANAGEMENT
All electronics
1
1. The Plug-In partner ensures that reuse, refurbishment and recycling techniques are used
to the full extent practicable, i.e., recognizing technical and economic feasibility, in
an effort to minimize incineration and land disposal of electronic equipment and
components. The Plug-In partner ensures that proper business records are kept
demonstrating that incineration and land disposal are minimized.
2.
Where incineration or land disposal is unavoidable, the Plug-In partner ensures that:
(a) Consideration is first given to whether the waste has value for energy recovery. For
certain wastes, such as plastics, incineration with energy recovery is preferable over
incineration without energy recovery or landfill. For wastes that have value for
energy recovery, but for which energy recovery is technically or economically
infeasible, the Plug-In partner ensures that a reasonable case of infeasibility has been
made.
(b) The wastes (including those generated at refurbishment and recycling operations,
smelters, etc.) are managed safely at facilities that are fully licensed for treatment and
disposal purposes by all appropriate governing authorities. The Plug-In partner
ensures that there is written evidence substantiating this.
(c) Landfills and incinerators have an environmental management system in place, as is
described in guideline 6(b) below for certain recycling facilities.
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FINAL June, 2005
Staples Pilot Project –Final Report to U.S. EPA
Appendix U
3. The Plug-In partner ensures that all applicable federal and state requirements pertaining
to the transport, processing and management of electronic products and components are
complied with.
4. In the case of export of any electronic products and components, the Plug-In partner
ensures that:
(a) Any applicable requirements of the U.S., as well as applicable requirements of
importing and transit countries, are complied with, and proper business records are
kept documenting such compliance.
(b) Prior to export, the materials listed below are removed and handled separately, unless:
(i) The export is for purposes of reuse or refurbishment, or
(ii) The Plug-In partner has documented and regularly monitored controls in
place to assure that the materials will be removed in member countries of
the OECD:
(1) Batteries.
(2) Mercury- and PCB-containing lamps and devices.
(3) Circuit boards, unless they are contained in hand-held electronic equipment,
such as cellular phones, PDAs, etc. (Note: Under U.S. rules, minimal
quantities of mercury and batteries that are protectively packaged to
minimize dispersion of metal constituents do not need to be removed from
whole circuit boards).
(4) CRTs and CRT glass, both of which are adequately processed for use as an
industrial feedstock material prior to export.
Note: The U.S. is not currently a party to the Basel Convention, although the U.S. is a member of
the OECD. International trade in hazardous wastes is governed by existing agreements under
both OECD and Basel, as well as by the laws of exporting, importing and transit countries.
Trade in end-of-life electronics that are considered hazardous wastes intended for recovery
between the U.S. and any OECD country are governed by the OECD control system, as
implemented through the laws and regulations of the member countries. Because the U.S. is not
a party to the Basel Convention, federal law does not yet include obligations for U.S. exporters
of end-of-life electronics that are considered hazardous wastes under the Basel Convention.
However, U.S. exporters should be cognizant that Basel Convention requirements could affect
them, as implemented by the laws of importing and transit countries. In addition, the importing
and transit countries may have other laws and regulations that could affect U.S. exporters and
their transactions. Until such time as the U.S. becomes a party to the Basel Convention, no
country that is a party to Basel but not a member of OECD can legally accept hazardous waste
exported from the U.S. absent a bilateral agreement between the governments under Article 11
of the Basel Convention. At this time, the U.S. has no bilateral agreements with any countries
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Staples Pilot Project –Final Report to U.S. EPA
Appendix U
outside of the OECD that provide for the export of hazardous waste. Current U.S. rules
regarding the export of hazardous wastes can be found at 40 CFR Part 262, Subparts E and H.
“Designated materials” for reuse or refurbishment
2
5.
This guideline applies to designated materials that are directed to reuse or
3
refurbishment. However, it is only intended to apply to those shipments of designated
materials (such as the following intact equipment: monitors, televisions, CRT bulbs,
CPUs, laptops, printers and cell phones) that have been prescreened to meet legitimate
reuse or refurbishment specifications. Unscreened shipments for evaluation of
reuse/refurbishment potential and shipments containing some reusable (or refurbishable)
and some non-reusable (or non-refurbishable) equipment are considered shipments for
recycling and are addressed in guideline 6. In the case of refurbishment, guidelines 1-4
and 6 apply to any components that are subsequently determined to be unusable.
For designated materials that are directed to reuse or refurbishment, the Plug-In partner
ensures that:
(a) All items in the shipment meet legitimate reuse or refurbishment specifications.
(b) All items in the shipment meet the specifications of the consignee.
(c) All items in the shipment are packaged in a manner that is consistent with
preservation of the used equipment for reuse or refurbishment. That is, the packaging
protects the used equipment in storage and transport, such that the value of the used
equipment for reuse or refurbishment is not diminished.
(d) Proper business records are kept that document the transfer of the used equipment to
the consignee for reuse or refurbishment purposes, including:
(i) Name and address of consignee.
(ii) Description of shipment content and conformance with consignee product
specifications.
(iii) Product specifications of consignee.
(iv) If for-profit transaction, amount paid for the consigned material.
“Designated materials” for recycling
6.
4
The Plug-In partner ensures that all designated materials that are directed to recycling are
processed by facilities that meet the guidelines herein. The Plug-In partner ensures that
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proper business records are kept that demonstrate that all downstream processing and
recycling operations, including smelters, that receive designated materials, use practices
that are consistent with these guidelines. For any processing and recycling facilities that
receive designated materials, the Plug-In partner ensures that:
(a) Facilities are fully licensed by all appropriate governing authorities. The degree of
licensing necessary will vary depending upon the particular jurisdiction, as well as the
size and nature of the facility. In some cases, extensive environmental permitting
may be required by the governmental authorities, whereas in other cases perhaps only
a business license is needed.
(b) Facilities have an environmental management system (EMS) in place. EPA
recognizes that flexibility for small businesses is necessary and that, in some cases, a
fully developed and certified EMS may be unnecessary. In lieu of a fully developed
and certified EMS (e.g., using ISO, EMAS or industry standards, such as those of the
IAER), a facility has a written plan describing the facility’s risk management
objectives for environmental performance and compliance and its plans for attaining
these objectives based on a “plan-do-check-act” continual improvement model.
Regular re-evaluation of environment, health and safety (EH&S) objectives and
monitoring of progress toward achievement of these objectives is conducted and
documented at all facilities. EPA also recognizes that a fully developed EMS may
not yet be in place for many facilities. In any case, a written plan describing risk
management objectives and plans for attainment based on a “plan-do-check-act”
model is in place.
(c) Facilities take sufficient measures to safeguard occupational and environmental
health and safety. Such measures may be indicated by local, state, national and
international regulations, agreements, principles and standards, as well as by industry
standards and guidelines. Except as noted below, such measures for all facilities
include:
i. EH&S training of personnel.
ii. An up-to-date, written hazardous materials identification and management
plan that specifically addresses at least the following: lead, mercury,
beryllium, cadmium, batteries, toner, phosphor compounds, PCBs, and
brominated flame retardants and other halogenated materials, with
particular focus on possible generation of by-product dioxins and furans.
iii. Where materials are shredded or heated, appropriate measures to protect
workers, the general public and the environment from hazardous dusts and
emissions. Such measures include adaptations in equipment design or
operational practices, air flow controls, personal protective devices for
workers, pollution control equipment or a combination of these measures.
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iv. An up-to-date, written plan for reporting and responding to exceptional
pollutant releases, including emergencies such as accidents, spills, fires, and
explosions.
v. Liability insurance for pollutant releases, accidents and other emergencies.
vi. Completion of an EH&S audit, preferably by a recognized independent
auditor, on an annual basis. However, for small businesses, greater
flexibility may be needed, and an audit every three years may be
appropriate.
(d) Facilities have a regularly-implemented and documented monitoring and
recordkeeping program that tracks key process parameters, compliance with relevant
safety procedures, effluents and emissions, and incoming, stored and outgoing
materials and wastes.
(e) Facilities have an adequate plan for closure. The need for closure plans and financial
guarantees is determined by applicable laws and regulations, taking into consideration
the level of risk. Closure plans should be updated periodically, and financial
guarantees should ensure that the necessary measures are undertaken upon definite
cessation of activities to prevent any environmental damage and return the site of
operation to a satisfactory state, as required by the applicable laws and regulations.
“Plug-In partner” means a manufacturer, retailer, government agency, non-profit, or other entity
who (1) is not a recycler nor performs recycling activities (other than collection), (2) through
contracts or other arrangements, utilizes reuse, refurbishment, recycling or disposal services, and
(3) has a Plug-In To eCycling partnership agreement with EPA.
1
“Designated materials” means any electronic products and components containing or consisting
of circuit boards, shredded circuit boards, CRTs, batteries, and mercury- and PCB-containing
lamps and devices. However, this definition does not include circuit boards that have been
processed to the point where they no longer are readily identifiable as circuit boards or shredded
circuit boards (such as after burning/melting), as well as CRT glass that has been adequately
processed for use as an industrial feedstock material. In these cases, the economic value of the
material has been enhanced significantly through processing; thus, commodities of value have
been created and concern for the subsequent environmental mismanagement of this material is
greatly decreased.
2
“Refurbishment” means the repair, reconditioning or upgrading of an end-of-life product or
component for the purpose of equipment reuse. Refurbishment of end-of-life electronics
includes replacement of components or parts that are part of a larger piece of electronic
equipment, aesthetic improvements, such as polishing and removal of scratches, and upgrading
of the equipment by installation of new operating systems, memory, or software.
3
4
“Recycling” facilities include any non-disposal facilities that receive designated materials under
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conditions that do not conform with guideline 5 above for legitimate reuse or refurbishment.
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Appendix V.
Connecticut Department of Environmental Protection
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Appendix V
Universal Waste Rule
Connecticut Department of Environmental Protection Fact Sheet
(Excerpts)
Purpose
This fact sheet is designed to answer general questions and provide basic information on management of
universal wastes in Connecticut, and is not intended to supersede the applicable regulations. The
information provided below addresses the requirements applicable only to large quantity handlers (LQH)
and small quantity handlers (SQH) of universal wastes. The universal waste rule requirements are found
in Section 22a-449(c)-113 of the Regulations of Connecticut State Agencies (RCSA), effective as of June
27, 2002. It incorporates 40 CFR (Code of Federal Regulations) 273 in its entirety except for following
provision that is not incorporated: 40 CFR 273.32(a)(3) (regarding an exemption from notification
requirements for large quantity handlers of recalled universal waste pesticides). It is your responsibility to
comply with all applicable laws and regulations. The state has modified certain federal requirements
making the program more stringent in certain sections. For the specific modifications, refer to the above
noted web site.
What is the Universal Waste Rule?
The Universal Waste Rule provides a set of streamlined regulations to reduce the regulatory burden by
allowing longer time for the storage of the wastes, reduced record-keeping requirements and
consolidation off-site without a permit. Universal wastes are:
1. Generated in a wide variety of settings other than the industrial settings usually associated with
hazardous wastes;
2. Generated by a vast community (typically greater than 1,000 sources);
3. May be present in significant volumes in non-hazardous waste management systems.
Why did EPA develop the Universal Waste Rule and DEP adopt the rule?
1.
There are three general goals that EPA had when it developed the streamlined universal waste
regulations:
2.
To encourage resource conservation while ensuring adequate protection of human health and
the environment;
3.
To improve implementation of the current Subtitle C hazardous waste regulatory program;
4.
To provide incentives for individuals and organizations to collect the unregulated portions of
these universal waste streams and manage them using the same systems developed for the
regulated portion, thus removing them from the municipal waste stream.
Although EPA’s primary goal for the universal waste program is to encourage recycling, batteries,
thermostats, pesticides, lamps and used electronics being sent for disposal may also be managed under the
universal waste regulations.
What wastes are subject to the Universal Waste Rule? 40 CFR 273.1 and Sections 22a-449(c)113(a)(2)(B) of the RCSA
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There are five waste streams that can be managed as a universal waste in Connecticut. These universal
wastes are:

Batteries,

Mercury-containing thermostats,

Certain pesticides,

Lamps (including but not limited to fluorescent, neon and mercury vapor lamps), and

Used electronics.
How long can I store Universal Wastes on-site? 40 CFR 273.15 and 40 CFR 273.35
In general, a handler can store a universal waste on-site for no longer than one year from the date the
universal waste is generated, or received from another handler.
How much can I store on-site? 40 CFR 273.6
A small quantity handler can accumulate not more than 5000 kilograms total of universal waste (batteries,
pesticides, thermostats, lamps and used electronics collectively) at any time.
A large quantity handler can accumulate 5000 kilograms or more of universal waste (batteries, pesticides,
thermostats, lamps and used electronics collectively) at any time.
When does the time limit begin? 40 CFR 262.34(a)(2)
In general, the time limit begins when the generator first determines that the universal waste is a waste. It
must be marked, labeled and dated at that time.
What are the universal waste labeling and marking requirements? 40 CFR 273.14 and 273.34 with
modifications under Section 22a-449(c)-113(a)(2)(I) &(T) of the RCSA and Sections 22a-449(c)-113(c)
and (d) of the RCSA. A generator must follow the labeling and marking requirements as outlined below:
Universal waste batteries (each battery) or a container in which the batteries are contained must be labeled
or marked clearly with any of the following: “Universal Waste - Battery(ies)” or “Waste Battery(ies), or
“Used Battery(ies)”.
Universal waste lamps (each lamp) or a container or package in which such lamps are contained must be
labeled or marked clearly with any of the following: “Universal Waste - Lamp(s)” or “Waste Lamp(s), or
“Used Lamp(s)”.
Universal waste used electronics (each piece of equipment) or a container, package or pallet in which the
used electronics are contained must be labeled or marked clearly with any of the following: “Universal
Waste - used electronics” or “Waste Used Electronics, or “Used Electronics”.
What are the requirements for areas where universal wastes are stored? 40 CFR 273.13 and 273.33
with modifications in Section 22a-449(c)-113(F), (G), (H), (Q), (R) and (S) of the RCSA and Section
22a-449(c)-113(c) and (d) of the RCSA.
A handler must manage universal wastes in a way that prevents releases of any universal waste or
component, or constituent of a universal waste to the environment. Universal waste pesticides, lamps and
thermostats must be stored in a container. A handler must contain any universal waste battery that shows
evidence of leakage, spillage or damage that could cause leakage in a container. A handler must place and
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keep any universal waste thermostats in a container. All containers for universal waste must be closed,
structurally sound, compatible with the contents of the universal waste, and must be capable of preventing
leakage, spillage or damage that could cause leakage.
Used electronics must be stored in a building with a roof and four walls or in a cargo carrying portion of a
truck, in a manner to prevent used electronics from being exposed to the environment. The used
electronics must be handled, stored and transported in a manner that maintains the reuse or recyclability
of the used electronic. A handler must immediately clean up and contain any broken cathode ray tube and
place in a container that is closed, structurally sound and compatible with the CRT. It should prevent
leakage, spillage or releases of broken CRTs, glass particles or other hazardous constituents from such
broken tubes to the environment. A handler must not shred, crush, heat or otherwise treat used electronics.
A small quantity handler may disassemble used electronics for the sole purpose of marketing, reselling,
reusing or recycling components. A large quantity handler must first obtain a permit issued by the
commissioner before disassembling used electronics.
Adequate aisle space must be maintained around the containers to allow unobstructed movement of
personnel and emergency response equipment. A minimum of 30-inch aisle space is recommended.
Handlers of universal waste must immediately contain all releases of universal wastes and other residues
from universal wastes. A handler must determine whether any material resulting from the release (e.g.,
spilled material, residue, absorbent) is hazardous wastes, and if so, must manage that material as a
hazardous waste. The handler is considered the generator of the material resulting from the release and is
treated as a hazardous waste generator.
What are the requirements when shipping universal waste off-site? RCSA Section 22a-449(c)113(a)(1) incorporating 40 CFR 273.18 and 40 CFR 273.38 with modifications under 22a-449(c)113(a)(2)(L),(M),(W) and (X).
You are prohibited from sending or taking universal waste to a place other than another universal waste
handler, a destination facility (including a RCRA treatment, storage, disposal facility), or a foreign
destination.
If you self-transport universal waste off-site, you become a universal waste transporter and must comply
with all universal waste transporter regulations under Subpart D and F of 40 CFR 273.
If your universal waste meets the definition of hazardous materials under 49 CFR 171 through 180, you
must package, label, mark and placard the shipment, and prepare the proper shipping papers in
accordance with DOT regulations under 49 CFR parts 172 through 180.
Before sending universal waste to another universal waste handler, you must ensure that the receiving
handler will receive the shipment.
If you send a shipment of universal waste to another handler or to a destination facility and the shipment
is rejected, you must either receive the waste back or agree on a destination facility to which the shipment
will be sent.
You may reject a shipment of universal waste to your site. If you do so, you must inform the original
handler. You must send the shipment back to the original handler or send the shipment to a destination
facility agreed to by both the originating and receiving handler.
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If you receive a shipment of hazardous waste that cannot be managed as a universal waste, you must
notify EPA of the illegal shipment and provide the necessary information to EPA. If you receive a
shipment of non-hazardous, non-universal waste, the handler may manage the waste in compliance with
federal, state or local solid waste regulations.
How do I track my universal waste shipments? RCSA Section 22a-449(c)-113(a)(2)(Y) and (Z)
incorporating 40 CFR 273.19; 273.39.
Universal waste does not count toward generator status. Universal wastes do not need to be shipped on a
manifest.
A small quantity handler of universal waste is not required to keep records of shipments of universal
wastes unless the waste is being exported to a foreign destination.
A large quantity handler of universal waste must keep a record of each universal waste shipment received
at the facility. In addition, a large quantity handler of universal waste must keep a record of each universal
waste shipment sent from the handler to other facilities. Each record may be in the form of a log, invoice,
manifest, bill of lading or other shipping document. The records must include the following information:
name and address of the original handler, quantity of each type of universal waste shipped or received,
date of shipment or receipt. You must retain all of these records for at least three years from the date of
receipt of shipment or the date a shipment of universal waste left the facility.
What are the employee training requirements?
A small quantity handler of universal waste must inform all employees who handle or have responsibility
for managing universal waste. The information must describe proper handling and emergency procedures
appropriate to the type(s) of universal waste handled at the facility.
A large quantity handler of universal waste must ensure that all employees are thoroughly familiar with
the proper waste handling and emergency procedures, relative to their responsibilities during normal
facility operations and emergencies.
Where can I obtain additional information?
For further information on this program, visit our web site www.dep.state.ct.us/wst/hw/hwregs.htm or by
contacting DEP’s Waste Engineering and Enforcement Division through COMPASS (Compliance
Assistance) at (888) 424-4193 or mail to:
Connecticut Department of Environmental Protection
Bureau of Waste Management
Engineering and Enforcement Division
79 Elm Street
Hartford, CT 06106-5127
September 2002
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Appendix W
Appendix W. Maine Department Of Environmental Protection
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Appendix X
Appendix X. Massachusetts Department of Environmental Protection
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COMMONWEALTH OF MASSACHUSETTS
EXECUTIVE OFFICE OF ENVIRONMENTAL AFFAIRS
DEPARTMENT OF ENVIRONMENTAL PROTECTION
ONE WINTER STREET, BOSTON, MA 02108, 617-292-5500
Questions and Answers Regarding
Massachusetts DEP’s Cathode Tube Regulations
The following is regulatory guidance for the handling of discarded CRT in accordance with
Department’s regulations for this waste stream, which appear at 310 CMR 16.02, 16.05,
19.043(5)(k), 30.010 and 30.104.
What is a CRT?
A CRT is the picture tube made of glass, lead and other materials found inside televisions,
computer monitors and some video game units.
What should a resident do with a used or obsolete TV or computer monitor?
First, consider giving your TV or computer monitor to some person or organization, either a
local school system or non-profit organization that can use it. If the unit is very old, broken, or
simply obsolete it needs to be properly recycled or disposed of.
Second, residents should call their municipal Department of Public Works or Board of Health to
determine how TV sets and computer monitors are being handled in their community. In many
cases, communities with curbside trash and recycling collection will schedule specific collection
dates during the year for TVs and computer monitors just as they do for refrigerators, stoves, and
other household appliances. Communities with drop-off collection of trash and recyclables will
often designate a collection site for TVs and monitors at the drop-off facility. The DEP provides
grant funding to many municipalities for the proper handling of CRTs. However, municipal
programs set their own collection schedules, hours of operation, and collection procedures.
Residents are advised to call their municipal program first to obtain updated information.
Residents who live in a city or town without municipal trash or recycling collection need to make
their own arrangements for the proper recycling or disposal of TVs and computer monitors. The
DEP provides information to assist residents in locating a recycling company or non-profit
organization.
Consult the DEP’s “Recycling Services Directory and Markets Guide for Massachusetts” for a
list of companies that handle TVs, computer monitors and other kinds of used electronic
equipment. (www.state.ma.us/dep/recycle/rsd/rsd.htm) Locate the listing for “Computers and
Electronic Equipment”.
When a company upgrades its computer system, are the old CRTs regulated by DEP?
As long as the company sends the CRTs to someone who will determine whether to reuse, resell
or repair them for return to service as operable CRTs, or pass them on to someone else who will
make this determination, the old CRTs are a “commodity” and are not regulated by DEP.
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When are CRTs regulated by DEP as a solid or hazardous waste?
A CRT is regulated as a hazardous waste once it has been crushed or when it is disposed intact.
Note: hazardous waste rules do not apply to households. Additional rules apply to companies
that accumulate “non-commodity CRTs,” which are CRTs that have been determined will not be
returned to service as operable CRTs. Companies that accumulate non-commodity CRTs are
regulated under the solid waste regulations as “CRT Operations,” the requirements for which are
described below.
How are monochrome CRTs regulated under DEP’s new CRT regulations?
DEP’s position that monochrome CRTs are non-hazardous has not changed. Monochrome CRTs
are, however, subject to the solid waste disposal ban that took effect April 1, 2000.
What’s the difference between a “commodity CRT” and a “non-commodity CRT”?
A commodity CRT is a CRT that is in use or a CRT for which a determination regarding its
future use has not yet been made by another party, such as a CRT repair expert. A commodity
CRT may include working CRTs as well as non-working CRTs which are repairable by a CRT
professional. Non-commodity CRTs are CRTs that have been determined will definitely not be
returned to service.
Some of the CRTs my company wants to get rid of are not working and may not be returned to
service. Is my company a “CRT Operation” because it may be accumulating “non-commodity
CRTs”? No, your company would not be subject to the rules for CRT Operations unless it makes
a decision that a CRT will definitely not be returned to service.
How can a company or municipal collection program avoid becoming a CRT Operation
inadvertently by accumulating a non-commodity CRT(s)?
DEP does not expect most CRT users to be experts in determining whether an inoperable CRT
can be repaired and returned to service. This determination should be deferred to a CRT repair
expert. As long as this determination is deferred to a CRT operation or CRT repair expert, a
company or municipal collection program is not subject to regulation as a CRT Operation.
What if a company, municipal collection program or charity elects to make the
determination that its CRTs are “non-commodity CRTs”?
In the event that a determination is made that a CRT will not be returned to service, it must be
managed in accordance with the solid waste requirements for “CRT Operations” which appear at
310 CMR 16.05(3)(f): Conditionally Exempt Recycling Operations.
A CRT Operation that accumulates up to 40 tons of non-commodity CRTs must:
 Minimize breakage,

Segregate its non-commodity CRTs from solid waste,

Comply with RCRA export rules for shipments to foreign countries,

Transfer its CRTs only to another CRT operation, recycler or hazardous waste facility
(TSDF),

Hold CRTs no longer than 1 year, and
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
Appendix X
Label its CRTs.
A CRT Operation that holds 40 tons of non-commodity CRTs for more than 21 days must
also:
 Notify DEP

Maintain shipping records and accumulation duration records for 3 years
I own/operate a CRT Operation and may occasionally need to store my non-commodity
CRTs for more than a year. Is this allowable, and if so, how would I demonstrate to DEP
the need to exceed the 1-year limit?
A CRT Operation may store CRTs for more than one year when it is necessary to facilitate
proper shipment (e.g. economically viable loads), recovery, treatment or disposal. Since you are
required to demonstrate the need for more than one year of storage, DEP recommends that
companies maintain records for non-commodity CRT accumulation in accordance with good
business practices. These could include records ordinarily kept by businesses such as a log,
written communications (including signed contracts) or copies of shipping documents such as
bills of lading or receipts.
My company handles commodity CRTs exclusively (e.g. CRTs that are no longer needed by
their original users) but is concerned that a DEP inspector might ask us to prove they are
not “non-commodity CRTs.” What should we do?
DEP recommends, but does not require, that companies maintain records for commodity CRTs
in accordance with good business practices. These could include records ordinarily kept by
businesses such as a log, inventory, written communications (including signed contracts) or
copies of shipping documents such as bills of lading or receipts.
DEP’s CRT regulations state that a CRT Operation that accumulates more than 40 tons of noncommodity CRTs (for more than 21 days) must notify DEP of its activity and comply with other
additional requirements. What volume of CRTs does 40 tons translate to? 40 tons translates to
approximately two full tractor trailer loads of CRTs. For the purposes of determining whether the
40- ton limit has been exceeded, the DEP does not make a distinction between CRT monitors
that are intact and those CRTs whose glass is intact but have been stripped of the plastic housing.
If I choose not to send my company’s CRTs to a facility for reuse, repair or to a CRT
Operation for potential recycling, and instead decide to dispose of the CRTs, what shipping
and other requirements apply?
Since there is a disposal ban on sending CRTs to a solid waste facility, you would have to send
the CRTs to a hazardous waste treatment, storage or disposal facility (TSDF). CRT shipments to
a TSDF must be made in accordance with applicable hazardous waste regulations found at 310
CMR 30.000. CRTs shipped into other States become subject to those other States’ requirements.
What do I do with a CRT that has broken accidentally?
Incidental numbers of CRTs that are visibly broken and substantially intact (i.e. cracked and
slightly damaged) may be managed as commodity CRTs. Greater than incidental numbers of
such CRTs must be managed as either non-commodity CRTs or as a hazardous waste. Incidental
numbers of broken CRTs that are significantly damaged (i.e. broken into pieces) resulting from
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unintentional breakage during routine handling and transportation may be shipped off-site as
non-commodity CRTs provided that the broken CRTs are handled in a manner that is protective
of worker health and safety. Greater than incidental numbers of such CRTs must be managed as
hazardous waste.
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Appendix Y. New Hampshire Department of Environmental Services
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Appendix Z
WMD-HW-25
2002
Proper Management of Cathode Ray Tubes from Computer Monitors and Televisions
What is a Cathode Ray Tube?
A cathode ray tube (CRT) is the video display unit found in televisions and computer monitors. A picture
is created when a stream of electrons travels through a tube and lights up a phosphor coating on the
glass face. There are two waste management issues associated with CRTs: the impact on the
environment/health issues attributed to high amounts of lead and glass under pressure, and society’s
ability to deal with a growing number of discarded items. For these reasons, it is important to properly
manage CRTs and then send them to appropriate locations for recycling, reuse, or disposal.
How are CRTs regulated?
A household CRT is considered solid waste and is subject to the New Hampshire Solid Waste Rules, up
to the point it is separated from other household wastes. A CRT generated by a business, or separated
from the disposal waste stream falls within the State’s Universal Waste Rule, which became effective on
October 13, 2001 (Env-Wm 1101-1114 of the New Hampshire Hazardous Waste Rules). The Universal
Waste Rule sets management standards for commonly generated items based upon their relative risk
and includes common consumer items such as fluorescent lamps, thermometers, thermostats and
antifreeze. The Universal Waste Rule streamlines the more stringent hazardous waste regulations that
would otherwise apply to a waste CRT.
The Growing Waste Stream
According to the U.S. Environmental Protection Agency (EPA), monitors make up 11percent of the
electronics waste stream. In a 1995 study, it is also estimated that CRTs contribute 28 percent of the
lead found in the entire municipal waste stream, a figure that is expected to jump to 30 percent when
numbers for 2000 become available. In the next ten years, it is estimated that 315 million computers will
inundate the national waste infrastructure, with about 1.5 million units impacting New Hampshire.
Approximately 95 percent of discarded computers end up in the solid waste stream, headed for disposal
or treatment in landfills and incinerators. Additionally, the television industry is bracing for a change to
digital broadcasts, scheduled to happen after 2006, which means existing televisions will need to be
replaced or upgraded.
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Appendix Z
Health and Environmental Concerns
Computer monitors and televisions are heavy and
extremely bulky, and a typical monitor can weigh as
much as 35-70 pounds, occupying significant storage
space. In fact, the very bulk of these items has
created problems for handlers in terms of back strain
and injuries due to dropping. Also, the CRTs in
monitors and televisions contain lead in the tube,
neck and the enclosed glass seal (“frit”). According to
a recent study, the funnel alone can contain as much
as 75 ppm of leachable lead as determined through a
toxicity characteristic leaching procedure. A typical 27” television can have up to 8 pounds of lead.
Requirements for Households
Households are not required to recycle their CRTs, although it is certainly recommended. The local
transfer station/recycling center is often the recipient of these household computers and televisions,
which usually end up in the disposal container or the metal recycling bin. If the municipality separates
the materials from the disposable trash, they must treat the computers as universal waste, store the
computers, and arrange for their transportation to alternate locations. If the community has a “swap
shop,” there is the greater likelihood of reuse of the entire unit or parts by local repair shops and other
consumers. Consumers should check with their local facility for specific acceptance requirements.
Finally, there are several “takeback” programs, where manufacturers or retail establishments will accept
monitors and televisions, either free of charge or for a fee ranging from $7-$30.00 (e.g., IBM and
Hewlett Packard). Contact the New Hampshire Department of Environmental Services (DES) at 2716847 for specific vendors and programs, or visit the DES website at www.des.state.nh.us/pcas.
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Appendix Z
Requirements for Businesses (Universal Waste
Handlers)
CRTs from a business are considered a universal waste once they
are no longer usable or repairable. Thus, the CRT will either need to
be recycled or donated (working), or sent to a hazardous waste
disposal facility. For vendor information and specific rules for
universal waste (Env-Wm 1101-1114), contact the DES at 271-6847
or visit the website at www.des.state.nh.us/pcas.
The Informed Consumer
When upgrading your
computer, consider keeping
your old monitor. Since most
monitors made within the last
five years are compatible with
today’s computers, you can
CRTs should be stored in a manner that does not pose a hazard to
health or the environment. Unless the universal waste handler meets
the requirements of Env-Wm 1113.03 of the Hazardous Waste Rules,
save a significant amount of
money by using your current
unit.
CRTs must not be broken. Those CRTs that are broken should be
stored in non-leaking containers. Each CRT must be labeled with the
words “Waste Cathode Ray Tube,” “Used Cathode Ray Tube(s),” or
“Universal Waste - Cathode Ray Tube(s).”
Requirements for Facilities that Process Electronic Wastes
If electronic equipment wastes (including CRTs) are collected from households or businesses, a solid
waste permit may be needed. If the activity is simply repairing and reselling or donating electronic
equipment, then no permit is necessary. If there is actual dismantling of the electronic equipment for
recycling or disposal, a solid waste facility permit is required. Contact the DES Solid Waste Bureau at
271-2925 for permit information.
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Appendix Z
Appendix Z. Rhode Island Department Of Environmental Management
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Product Stewardship Institute, Inc.
Appendix Z
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Product Stewardship Institute, Inc.
Appendix Z
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Appendix AA
Appendix AA. Computer Manufacturers
Apple Computer Inc.
Brian Miller, Corporate Manager
Environmental Health & Safety
Apple
1 Infinite Loop, MS: 35-EHS
Cupertino, CA 95104
p: 408 974-7629
c: 408 640-9014
brian.m@apple.com
Brother International Corp.
Bill Epperson
Director of Sales
p: 603 964-1530
bill.epperson@brother.com
Canon
Mario J. Rufino, Senior Chemical Safety Engineer
Environmental Management and Product Safety
Department (EMPS)
Canon U.S.A., Inc.
One Canon Plaza
Lake Success, NY 11042
p: 516 328-5610
f: 516 328-5169
mrufino@cusa.canon.com
Dell
Pat Nathan
Vice President, Corporate Social Responsibility
Dell
One Dell Way
Round Rock, TX 78682
p: 512 728-1479
pat_nathan@dell.com
Henry Sacco
Chief Legal Officer
(908) 252-3029 (ph)
Henry.sacco@brother.com
Shari Carle
Sustainable Business Analyst
Shari_Carle@dell.com
512-728-4980 (ph)
512-907-5700 (pager)
Mike Watson
Program Manager,
Dell Asset Recovery Services
Mike_Watson@dell.com
Epson America, Inc.
Shelby Houston
Manager, Customer Programs
Shelby_Houston@ea.epson.com
562-290-5445 (ph)
George Lundberg
Environmental and Safety Engineer
Epson Portland Inc.
3950 NW Aloclek Place
Hillsboro, OR 97124
p: 503 617-5607
f: 503 617-6746
george.lundberg@epi.epson.com
Product Stewardship Institute, Inc.
Gateway
Donald McClellan
Vice President
Gateway, Inc.
707 D Street NW
Washington, DC 20004
donald.mcclellan@gateway.com
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Hewlett-Packard
Renee St. Denis
renee.stdenis@hp.com
916-785-8034
David Isaacs
Manager, Environmental Policy
Hewlett-Packard Company
900 17th Street, NW -- Suite 1100
Washington, DC 20006
p: 202 884-7033
david_isaacs@hp.com
Appendix AA
IBM
Tim Mann
Program Manager, Product Environmental Policy
IBM Corporation
8660 Maidstone Court
Largo, FL 33777
p: 877 247-8964
timmann@us.ibm.com
Kevin Farnam
f: 281-514-8254
Intel
Allen Wilson
Manager, EH&S
Allen.r.Wilson@intel.com
480-715-2390 (ph)
Lexmark International, Inc.
Patrick Brewer
Manager Government Affairs
740 West New Circle Road
Lexington, KY 40550
pbrewer@lexmark.com
Tonya Jackson
Manager, Environmental, Health & Safety
Lexmark
740 West New Circle Road
Lexington, KY 40550
p: 859 232-7925
tonyaj@lexmark.com
NEC
Toshio Nakajima
President and CEO Corporate Headquarters
NEC Electronics America Inc.
2880 Scott Boulevard
Santa Clara, CA 95050-2554
Panasonic
David A. Thompson
General Manager
Corporate Environmental Department, 3G-4
Matsushita Electric Corporation of America
One Panasonic Way
Secaucus, NJ 07094
p: 201 271-3486
f: 201 348-7686
thompsond@panasonic.com
Sharp Electronics Corporation
Frank Marella
Manager, Corporate Environmental Affairs
Sharp Electronics Corporation
One Sharp Plaza
Mahwah, NJ 07430
p: 201 529-9408
f: 201 529-8425
Francis.Marella@sharpusa.com
Sony
Mark Small
Sony Corporation
16450 W. Berardo Drive/MZ7160
San Diego, CA 92127
858-942-2729
Douglas.Smith@am.sony.com
Product Stewardship Institute, Inc.
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